20230823IPC to Staff 197-209.pdf

LISA D. NORDSTROM
Lead Counsel
[e-mail]

August 23, 2023

VIA ELECTRONIC FILING

Jan Noriyuki, Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg 8,
Suite 201-A (83714)
PO Box 83720
Boise, Idaho 83720-0074

Re: Case No. IPC-E-23-11
Idaho Power Company’s General Rate Case

Dear Ms. Noriyuki:

Enclosed for electronic filing, please find Idaho Power Company’s Response to the
Eighth Production Request of the Commission Staff to Idaho Power Company.

Due to the collectively voluminous confidential and non-confidential information
provided in response to data requests in this case, the Company is posting the
attachments to these requests to the secure FTP site to allow parties to view the
requested information remotely unless otherwise noted in the response. Because certain
attachments contain confidential information, the FTP site is divided between confidential
and non-confidential information.

The login information for the non-confidential portion of the FTP site has been
provided to all parties that have intervened to date. The login information for the
confidential portion of the FTP site has been provided to the parties that have executed
the Protective Agreement in this matter.

If you have any questions about the attached filing, please do not hesitate to
contact me.

Very truly yours,
Lisa D. Nordstrom
LDN:sg
Enclosures
RECEIVED
2023 August 23, PM 4:18
IDAHO PUBLIC
UTILITIES COMMISSION

CERTIFICATE OF ATTORNEY

ASSERTION THAT INFORMATION CONTAINED IN AN IDAHO PUBLIC UTILITIES
COMMISSION FILING IS PROTECTED FROM PUBLIC INSPECTION
Case No. IPC-E-23-11
In the Matter of the Application of Idaho Power Company for Authority to Increase
Its Rates and Charges for Electric Service to Its Customers In the State of Idaho
and For Associated Regulatory Accounting Treatment

The undersigned attorney, in accordance with Commission Rules of Procedure 67,
believes that the attachment in response to Request No. 207 to Idaho Power Company’s
Response to the Eighth Production Request of the Commission Staff dated August 23,
2023, contain information that Idaho Power Company claims are trade secrets and/or
business records of a private enterprise required by law to be submitted to or inspected
by a public agency as described in Idaho Code § 74-101, et seq., and/or § 48-801, et seq.
As such, it is protected from public disclosure and exempt from public inspection,
examination, or copying.

DATED this 23rd day of August, 2023.

LISA D. NORDSTROM
Counsel for Idaho Power Company

IDAHO POWER COMPANY’S RESPONSE TO THE EIGHTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 1
LISA D. NORDSTROM (ISB No. 5733)
DONOVAN E. WALKER (ISB No. 5921)
MEGAN GOICOECHEA ALLEN (ISB No. 7623)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
[e-mail]

Attorneys for Idaho Power Company

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF THE
APPLICATION OF IDAHO POWER
COMPANY FOR AUTHORITY TO
INCREASE ITS RATES AND CHARGES
FOR ELECTRIC SERVICE IN THE
STATE OF IDAHO AND FOR
ASSOCIATED REGULATORY
ACCOUNTING TREATMENT.
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CASE NO. IPC-E-23-11

IDAHO POWER COMPANY’S
RESPONSE TO THE
CONFIDENTIAL EIGHTH
PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO
POWER COMPANY

COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), and in
response to the Confidential Eighth Production Request of the Commission Staff
(“Commission” or “Staff”) dated August 2, 2023, herewith submits the following
information:
IDAHO POWER COMPANY’S RESPONSE TO THE EIGHTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 2
REQUEST FOR PRODUCTION NO. 197: Please provide a schedule showing the
rate case processing timeframes from filing until rates go into effect for the companies
shown in Witness McKenzie's Exhibit No. 9. (i.e., Idaho Power rate case time frame from
filing until rates effective is seven months).
RESPONSE TO REQUEST FOR PRODUCTION NO. 197: Mr. McKenzie did not
conduct a research study to ascertain the “rate case processing timeframes” associated
with historical rate filings in the various jurisdictions served by each of the operating
utilities included within the scope of his proxy group; nor was such a study necessary to
support the findings and conclusions presented in his direct testimony. This data is
publicly available from the respective regulatory commissions.
The previous paragraph notwithstanding, the Company was able to gather much
of the requested publicly available information, and the information is included in the
attachment to this request. The Company has not validated the data or ascertained its
completeness.
The response to this Request is sponsored by Brian Buckham, Senior Vice
President and Chief Financial Officer, Idaho Power Company and Adrien McKenzie, CFA,
President, FINCAP, Inc.
IDAHO POWER COMPANY’S RESPONSE TO THE EIGHTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 3
REQUEST FOR PRODUCTION NO. 198: For the companies included in
McKenzie's Exhibit No. 9, please provide the date of each company's last rate case and
the Return on Equity ("ROE") included in that rate case. Please identify if that case was
settled or not.
RESPONSE TO REQUEST FOR PRODUCTION NO. 198: Mr. McKenzie did not
conduct a research study to ascertain the date of the last rate case and ROE authorized
for each of the operating utilities included within the scope of his proxy group; nor was
such a study necessary to support the findings and conclusions presented in his direct
testimony. This data is publicly available from the respective regulatory commissions.
The previous paragraph notwithstanding, the Company was able to gather much
of the requested publicly available information, and the information is included in the
attachment to Staff Request No. 197. The Company has not validated the data or
ascertained its completeness.
The response to this Request is sponsored by Brian Buckham, Senior Vice
President and Chief Financial Officer, Idaho Power Company and Adrien McKenzie, CFA,
President, FINCAP, Inc.
IDAHO POWER COMPANY’S RESPONSE TO THE EIGHTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 4
REQUEST FOR PRODUCTION NO. 199: Please provide the details of how Value
Line calculates the beta provided in McKenzie's Exhibit No 13.
RESPONSE TO REQUEST FOR PRODUCTION NO. 199: Beta values reported
by Value Line are calculated by conducting a linear regression analysis of the weekly
percentage changes in the price of a stock and the weekly percentage changes in the
NYSE Index over a period of five years. In addition, Value Line adjusts the resulting “raw”
beta values to account for the observed tendency of beta values to regress towards the
market mean over time, which is sometimes referred to as a “Blume adjustment.” Value
Line uses the following formula to arrive at the adjusted betas published in its reports:
Adjusted Beta = 0.67(historical beta) + 0.35.
The response to this Request is sponsored by Adrien McKenzie, CFA, President,
FINCAP, Inc.
IDAHO POWER COMPANY’S RESPONSE TO THE EIGHTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 5
REQUEST FOR PRODUCTION NO. 200: Please provide a schedule showing the
number of employees at each step of the Company's pay scale. Please include the years
of service for each employee at each step.
RESPONSE TO REQUEST FOR PRODUCTION NO. 200: The Company has
included two attachments in response to this request containing data as of August 2023.
Attachment 1 – Response to Staff Request No. 200 lists a count of employees by grade
and step and includes the average years of service for the employees at each grade and
step. Attachment 2 – Response to Staff Request No. 200 is a list of all employees with
their current grade and step and years of service.
The response to this Request is sponsored by Sarah Griffin, VP, Human
Resources, Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO THE EIGHTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 6
REQUEST FOR PRODUCTION NO. 201: Please provide a schedule showing the
number of bad debts written off and the total amount of bad debt written off by month for
the past five years.
RESPONSE TO REQUEST FOR PRODUCTION NO. 201: Please see Excel file
Attachment – Response to Staff Request No. 201. For monthly bad debt amounts, please
refer to the Company’s Response to Staff Request No. 194.
The response to this Request is sponsored by Paula Jeppsen, Forecast and
Planning Director, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE EIGHTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 7
REQUEST FOR PRODUCTION NO. 202: Please provide a schedule showing the
number of employees that received a step increase by month for the past five years.
Please also include the number of employees that received a 2-step increase each
month.
RESPONSE TO REQUEST FOR PRODUCTION NO. 202: Please see
“Attachment – Response to Staff Request No. 202.pdf.”
The response to this Request is sponsored by Sarah Griffin, VP, Human
Resources, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE EIGHTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 8
REQUEST FOR PRODUCTION NO. 203: Please provide a list of services Idaho
Power provides for IdaCorp Financial. Please provide a schedule of expenses for those
services and their location in this rate case filing.
RESPONSE TO REQUEST FOR PRODUCTION NO. 203: Idaho Power provides
accounting, financial analysis, legal, and investor relations services to IDACORP
Financial. These costs for direct payroll, incentive pay, benefits, travel costs, and
overheads are charged to FERC account 417.1, Expenses of nonutility operations, and
reimbursed to Idaho Power on a monthly basis. Account 417.1 is excluded from the rate
case filing.
The response to this Request is sponsored by Paula Jeppsen, Forecasting and
Planning Director, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE EIGHTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 9
REQUEST FOR PRODUCTION NO. 204: Please provide the costs for the
Environmental, Social, Governance ("ESG") steering committee and where they are in
the rate case filing.
RESPONSE TO REQUEST FOR PRODUCTION NO. 204: Idaho Power has not
incurred any incremental costs for the Environmental, Social, Governance (“ESG”)
steering committee. The ESG steering committee is composed of employees throughout
the organization, including the Company’s Chief Financial Officer, Director of Investor
Relations, Corporate Secretary, Lead Counsel and Deputy Corporate Secretary,
Customer Operations Support Senior Manager, Talent and Employment Director,
Environmental Affairs Director, Chief Accounting Officer & Treasurer, Senior Counsel,
Senior Program Specialist, Information & SOX Compliance Manager, Legal
Administrative Assistant, Communication Specialist, Accounting and Reporting Director
and General Counsel. The ESG steering committee meets quarterly.
The response to this Request is sponsored by Brian Buckham, Senior Vice President
and Chief Financial Officer, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE EIGHTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 10
REQUEST FOR PRODUCTION NO. 205: Please provide the Company's ESG
scores and supporting documentation from 2020 to present.
RESPONSE TO REQUEST FOR PRODUCTION NO. 205: There are several
different methods to evaluate ESG. Idaho Power is providing information from ISS
Corporate Services because the Company understands that many shareholders rely on
this information to inform annual voting positions. Please see the Company’s ESG scoring
from ISS Corporate Services from 2020 to 2023 within the “QualityScore” at the top of
each page within Attachment – Response to Staff Request No. 205.
The response to this Request is sponsored by Brian Buckham, Senior Vice
President and Chief Financial Officer, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE EIGHTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 11
REQUEST FOR PRODUCTION NO. 206: Please provide the Company's click rate
on the internal phishing tests from 2020 to present.
RESPONSE TO REQUEST FOR PRODUCTION NO. 206: At the time of request
No. 206, the average monthly click rate for all Idaho Power exercise phishing campaigns
from January 1, 2020, to August 16, 2023, was 1.84 percent.
The response to this Request is sponsored by Brian Buckham, Senior Vice
President and Chief Financial Officer, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE EIGHTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 12
REQUEST FOR PRODUCTION NO. 207: Regarding the Company's response to
Production Request No. 35, Confidential Attachment 1, please provide all transactions, in
Excel format, associated with each project listed in the attached Confidential spreadsheet
"Idaho Power Capital Project Sample".
RESPONSE TO REQUEST FOR PRODUCTION NO. 207: Please see
Confidential Attachment – Response to Staff Request No. 207 for all transactions
associated with the selected projects. For ease of reference, the Excel file includes a
worksheet labeled “TSource Description” with definitions of the types of transactions
associated with each “TSOURCE” as this field is included within the transaction data
provided.
The response to this Request is sponsored by Paula Jeppsen, Forecasting and
Planning Director, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE EIGHTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 13
REQUEST FOR PRODUCTION NO. 208: Please provide a list of all vehicles
purchased between 2015 and 2023, including the make, model, price, and what it is used
for. Please explain how many vehicles were retired and replaced, and how many are new
purchases due to the growing customer base.
RESPONSE TO REQUEST FOR PRODUCTION NO. 208: Attachment 1 –
Response to Staff Request 208 identifies the vehicles (including on road vehicles, trailers,
utility task vehicles (“UTV”), and construction equipment) placed in-service between 2015
and July of 2023.
From 2015 to 2023 there have been 1,130 pieces of equipment (includes on road
vehicles, trailers, UTVs, and construction equipment) purchased by Idaho Power. Of that,
909 were replacement purchases for existing/retired equipment and 221 were new
purchases. The large majority of new purchases were made to meet the demand of the
growing customer base and to a less degree to reduce customer and environmental
impacts.
The response to this Request is sponsored by Melissa Boyd, Operations Support
Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE EIGHTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 14
REQUEST FOR PRODUCTION NO. 209: Please provide all transactions and
journal entries for the wildfire mitigation deferral account in Excel format. Please include
item name, brief description, cost broken down by month and year since 2021 to date.
RESPONSE TO REQUEST FOR PRODUCTION NO. 209: Please see the
Company’s Confidential Response to Staff Request No. 64, which shows all transactions
of the originating expenses that were deferred since 2021 through May 2023. Attachment
1 – Response to Staff Request No. 209 provides June 2023 transactions. Attachment 2
– Response to Staff Request No. 209 provides journal entries for the wildfire mitigation
deferral account from 2021 through June 2023.
The response to this Request is sponsored by Paula Jeppsen, Forecasting and
Planning Director, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE EIGHTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 15
DATED at Boise, Idaho, this 23rd day of August 2023.

LISA D. NORDSTROM
Attorney for Idaho Power Company

DONOVAN E. WALKER
Attorney for Idaho Power Company

MEGAN GOICOECHEA ALLEN
Attorney for Idaho Power Company

IDAHO POWER COMPANY’S RESPONSE TO THE EIGHTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 16
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the 23rd day of August 2023, I served a true and
correct copy of Idaho Power Company’s Response to the Eighth Production Request of
the Commission Staff to Idaho Power Company upon the following named parties by the
method indicated below, and addressed to the following:

Commission Staff
Dayn Hardie
Chris Burdin
Deputy Attorney General
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg No. 8
Suite 201-A (83714)
PO Box 83720
Boise, ID 83720-0074

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Clean Energy Opportunities for Idaho
Kelsey Jae
Law for Conscious Leadership
920 N. Clover Dr.
Boise, ID 83703
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Courtney White
Mike Heckler
Clean Energy Opportunities for Idaho
3778 Plantation River Drive, Suite 102
Boise, ID 83703

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Industrial Customers of Idaho Power
Peter J. Richardson
Richardson Adams, PLLC
515 N. 27th Street
Boise, Idaho 83702

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Dr. Don Reading
280 Silverwood Way
Eagle, Idaho 83616

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X Email dreadin mindsprin .com

IDAHO POWER COMPANY’S RESPONSE TO THE EIGHTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 17
Idaho Irrigation Pumpers Association,
Inc.
Eric L. Olsen
ECHO HAWK & OLSEN, PLLC
505 Pershing Avenue, Suite 100
P.O. Box 6119
Pocatello, Idaho 83205

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Lance Kaufman, Ph.D.
2623 NW Bluebell Place
Corvallis, OR 97330
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Micron Technology, Inc.
Austin Rueschhoff
Thorvald A. Nelson
Austin W. Jensen
Holland & Hart, LLP
555 Seventeenth Street, Suite 3200
Denver, Colorado 80202

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Jim Swier
Micron Technology, Inc.
8000 South Federal Way
Boise, Idaho 83707
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City of Boise
Ed Jewell
Darrell Early
Boise City Attorney’s Office
150 N. Capitol Blvd.
Boise, ID 83701
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IDAHO POWER COMPANY’S RESPONSE TO THE EIGHTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 18
Wil Gehl
Boise City Dept. of Public Works
150 N. Capitol Blvd.
P.O. Box 500
Boise, Idaho 83701-0500

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Idaho Conservation League
Marie Callaway Kellner
Idaho Conservation League
710 N. 6th Street
Boise, Idaho 83702

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Brad Heusinkveld
Idaho Conservation League
710 N. 6th Street
Boise, Idaho 83702
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IdaHydro
C. Tom Arkoosh
Arkoosh Law Offices
913 W. River Street, Suite 450
P.O. Box 2900
Boise, Idaho 83701

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Federal Executive Agencies
Peter Meier
U.S. Department of Energy
1000 Independence Ave., S.W.
Washington, DC 20585

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Dwight Etheridge
Exeter Associates
5565 Sterrett Place, Suite 310
Columbia, MD 21044
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IDAHO POWER COMPANY’S RESPONSE TO THE EIGHTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 19
NW Energy Coalition
F. Diego Rivas
1101 8th Ave
Helena, MT 59601
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Walmart Inc.
Norman M. Semanko
Parsons Behle & Latimer
800 West Main Street, Suite 1300
Boise, Idaho 83702
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Steve W. Chriss
Director, Energy Services
Walmart Inc.
2608 Southeast J Street
Bentonville, Arkansas 72716
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Walmart Inc.
Justina A. Caviglia
Parsons Behle & Latimer
50 West Liberty Street, Suite 750
Reno, NV 89502
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Stacy Gust, Regulatory Administrative
Assistant