20230830IPC to Staff 232-252.pdf

LISA D. NORDSTROM
Lead Counsel
[e-mail]

August 30, 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
Eleventh 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 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 30, 2023 4:59PM
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 some of the attachments in Response to Response to Requests Nos. 243
and 244 to Idaho Power Company’s Response to the Eleventh Production Request of the
Commission Staff dated August 30, 2023, contain information that Idaho Power Company
and a third party claim 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 30th day of August, 2023.

LISA D. NORDSTROM
Counsel for Idaho Power Company

IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH 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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)
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CASE NO. IPC-E-23-11

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

COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), and in
response to the Eleventh Production Request of the Commission Staff (“Commission” or
“Staff”) dated August 16, 2023, herewith submits the following information:

IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 2
STAFF REQUEST FOR PRODUCTION NO. 232: According to the Direct
Testimony of Company Witness Hackett at 12, the Company identified a near-term deficit
in summer 2023.
a. Please provide the load and resource balance analysis prepared in May 2021, in
which the 2023 capacity deficit was anticipated; and
b. Please provide all load and resource balance analyses produced after May 2021.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 232:
a. The load and resource balance prepared in May 2021 and referenced in Mr.
Hackett’s testimony is the load and resource balance prepared for the 2021
Integrated Resource Plan (“IRP”), which can be found on page 20 of the 2021 IRP
- Appendix C: 2021 IRP Technical Appendix_WEB (idahopower.com). This is the
load and resource balance for which procurement of 2023 resources was based.
b. Idaho Power currently utilizes the Loss of Load Expectation (“LOLE”) methodology
to assess system reliability via the internally developed Reliability & Capacity
Assessment Tool (“RCAT”), which is capable of producing outputs such as the
capacity position for a given year. While the Company is able to represent the
RCAT’s input and output data in the form of a Load & Resource (“L&R”) balance,
it is the capacity position determined through the LOLE analysis that drives
resource selection decisions. Because the monthly L&R balance is a
representation of the RCAT inputs and annual results, a LOLE-derived L&R
balance is no longer created due to the inaccuracies when translating annual data
to a monthly spread. While system reliability assessments have been performed
since the L&R balance was prepared for the 2021 IRP, no additional L&R balances

IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 3
were prepared that impacted the resource procurement process for the 120
megawatts (“MW”) of batteries discussed by Mr. Hackett in his testimony. To better
align with and represent the probabilistic reliability analyses currently utilized, the
Company now provides results in the form of annual capacity positions as they are
a better indication of resource reliability. This method and the corresponding
preliminary annual capacity position results for the 2023 IRP were shared in the
August 15, 2023 IRP Advisory Council meeting Portfolio Reliability Analysis
presentation.
The response to this Request is sponsored by Jared Ellsworth, Transmission,
Distribution, and Resource Planning Director, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 4
STAFF REQUEST FOR PRODUCTION NO. 233: Please provide a copy of: IHS
Markit: "Multiple factors halt downward trajectory of Li-ion battery costs, with higher prices
for energy storage systems set to continue throughout 2022 and 2023" January 6th, 2022,
as referenced in Company Witness Hackett's Direct Testimony at 21.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 233: Please see
Attachment – Response to Staff Request No. 233 which can also be found at the following
link: https://www.spglobal.com/commodityinsights/en/ci/research-analysis/multiple-
factors-increase-lithium-ion-battery-prices.html
The response to this Request is sponsored by Eric Hackett, Projects and Design
Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 5

STAFF REQUEST FOR PRODUCTION NO. 234: Company Witness Barretto's
Direct Testimony at 10 stated, "In addition, all new or unbudgeted Unit 2 or common
facility capital projects larger than $1 million, at the plant level, require a review and
authorization in writing by each Valmy Co-Owner prior to starting the project." Please
answer the following:
a. What are the new capital projects less than $1 million and what are their costs?
b. What are the unbudgeted Unit 2 projects less than $1 million and what are their
costs?
c. What are the common capital projects less than $1 million and what are their
costs?
d. Please explain the budget review and authorization process for the above-
mentioned capital projects.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 234:
a. Please see the Attachment – Response to Staff Request No. 234 for an updated
Exhibit No. 2, which includes the Valmy investments made during the January 1,
2019, through December 31, 2022, time period. In Attachment 49 – Response to
Staff’s Request No. 169, Idaho Power added a column to Exhibit No. 2 that
identified the original work order approval amount at the Idaho Power level for
Project Nos. 1 through 16. In Attachment – Response to Staff Request No. 234 the
Company has populated the column with the original work order approval amount
for all projects over $50,000 at the Idaho Power level or associated with Unit 1. As
can be seen in the Original WO Approval Amount column, all new capital projects
except for Project Nos. 1 and 2 were expected to be below $500,000 at the Idaho

IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 6

Power level, or $1 million at the plant level.
b. Please see Attachment – Response to Staff Request No. 234. Projects associated
with Unit 2 have actual costs in the V2 column and the corresponding budget
amount is presented in the Original WO Approval Amount column. Of the projects
over $50,000 at the Idaho Power level for which the Original WO Approval Amount
is provided, there were no unbudgeted Unit 2 projects less than $1 million.
c. Please see Attachment – Response to Staff Request No. 234. Projects associated
with common facilities have actual costs in the VC column and the corresponding
budget amount is presented in the Original WO Approval Amount column.
d. Please see the Company’s Response to Staff’s Request for Production No. 166
for the budget review and authorization process that occurs between NV Energy
and Idaho Power associated with the capital projects at Valmy.
The response to this Request is sponsored by Lindsay Barretto, 500-kV and Joint
Projects Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 7

STAFF REQUEST FOR PRODUCTION NO. 235: As referenced in Company
Witness Barretto's Direct Testimony at 11, please provide the following information:
a. Authorization of Expenditures ("AFE") requests produced by NV Energy for all
capital projects from 2012 to 2023; and
b. Considering the statement: "If the project is expected to exceed the AFE amount
by either 10 percent, for variances greater than $10,000, or $100,000, a
supplemental AFE is required." Please provide all supplemental AFEs that satisfy
these criteria.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 235:
a. Please see the Company’s Response to Staff’s Request for Production No. 169.
As clarified with Commission Staff on August 18, 2023, the Company is providing
all AFE associated with projects over $50,000 at the Idaho Power level or
associated with Unit 1 between January 1, 2019, through December 31, 2022, the
time period for which the Company is seeking prudence in this case.
b. Of the projects over $50,000 at the Idaho Power level or associated with Unit 1
between January 1, 2019, through December 31, 2022, the time period for which
a Supplemental AFE was issued, were provided in the Company’s Response to
Staff’s Request for Production No. 169. The Supplemental AFE was either
provided as a separate attachment or was combined with the original AFE.
The response to this Request is sponsored by Lindsay Barretto, 500-kV and Joint
Projects Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 8

STAFF REQUEST FOR PRODUCTION NO. 236: Please provide the following
documentation for the Valmy Pin Mixer/Unloader Rebuild (Project No. 27528897)
referenced in Company Witness Barretto's Direct Testimony at 15. If any of the
information requested below cannot be provided or is not available, please explain why,
and explain how the Company can ensure the construction of the project was completed
in a least-cost manner.
a. Analysis of Need - a justification of need for the project and a cost/benefit analysis
comparing alternatives.
b. Project Plan
i. Initial project scope;
ii. Proposed budget;
iii. Proposed schedule; and
c. Requests for proposals ("RFP")
i. Project requirements;
ii. Specifications;
iii. Short list bidder scorecard; and
iv. RFP from winning bid.
d. Project construction documentation including:
i. Construction contract;
ii. Organizational chart;
iii. Scope document;
iv. Work breakdown structure;
v. Baseline Schedule;

IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 9

vi. Monthly project status report(s);
vii. Action items list(s); and
viii. Contractors change order request(s).
e. Company project completion analysis:
i. Lessons learned;
ii. Budget-to-actual comparisons for overall project and by year;
iii. Baseline schedule-to-actual schedule comparison; and
iv. For any actual costs differing from the budget amount by plus or minus five
percent during a particular year, please list and explain the reason(s) for the
budget amount difference.
f. Documentation specific to Idaho Power approving the project prior to start of
construction.
g. Documentation specific to Idaho Power acknowledging the project was completed at
a reasonable least-cost to its customers.
h. Documentation and a detailed explanation of the incident where the ash hauling
dump truck damaged Unit 2 wet fly ash unloader and the total damage caused by
the incident.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 236:
a – g. Please see the Company’s Response to Staff’s Request for Production No.
169 and 170. This project was identified as Project No. 9.
h. In 2018, the ash hauling contractor at Valmy, Eagle View, backed into the fly ash
unloading equipment. A safety Stand Down meeting of plant personnel and
contractors was conducted. The fly ash unloading equipment that was in-service at

IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 10

the time was obsolete and was impending failure prior to the incident. Because the
pin mixer/unloader rebuild project was already planned, it was executed and
completed.
The response to this Request is sponsored by Lindsay Barretto, 500-kV and Joint
Projects Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 11

STAFF REQUEST FOR PRODUCTION NO. 237: Please provide the following
documentation for the Valmy Ground Water Monitoring Well Installation (Project No.
27555279) referenced in Barretto Direct Testimony at 31. If any of the information
requested below cannot be provided or is not available, please explain why, and also
explain how the Company can ensure the construction of the project was completed in a
least-cost manner.
a. A copy of the Nevada Division of Environmental Protection ("NDEP")'s well
monitoring guidelines.
b. Copies of reports or documentation demonstrating 9 wells that were reading critical
ground water levels (five wells that were reading above top screen level and four
wells that were close to be invalid).
c. Analysis of Need - a justification of need for the project and a cost/benefit analysis
comparing alternatives.
d. Project Plan
i. Initial project scope;
ii. Proposed budget; and
iii. Proposed schedule.
e. RFP
i. Project requirements;
ii. Specifications;
iii. Short list bidder scorecard; and
iv. RFP from winning bid.

IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 12

f. Project construction documentation including:
i. Construction contract;
ii. Organizational chart;
iii. Scope document;
iv. Work breakdown structure;
v. Baseline Schedule;
vi. Monthly project status report(s);
vii. Action items list(s); and
viii. Contractors change order request(s).
g. Company project completion analysis
i. Lessons learned;
ii. Budget-to-actual comparisons for overall project and by year;
iii. Baseline schedule-to-actual schedule comparison; and
iv. For any actual costs differing from the budget amount by plus or minus five
percent during a particular year, please list and explain the reason(s) for the
budget amount difference.
h. Documentation specific to Idaho Power approving the project prior to start of
construction.
i. Documentation specific to Idaho Power acknowledging the project was completed at
a reasonable least-cost manner to its customers.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 237:
a-b. Idaho Power is still gathering the documentation for this request and will provide a
response by Tuesday, September 5, 2023.

IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 13

c – i. Please see the Company’s Response to Staff’s Request for Production No. 169
and 170. This project was identified as Project No. 10.
The response to this Request is sponsored by Lindsay Barretto, 500-kV and Joint
Projects Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 14

STAFF REQUEST FOR PRODUCTION NO. 238: According to Company Witness
Barretto's Direct Testimony at 20, the Company found it is more cost-effective to purchase
Freeze Protection Heaters than renting Portable Electric Space Heaters for the Valmy
Plant with an approximate cost of $541,000. Please provide the following information as
requested. If any of the information requested below cannot be provided or is not
available, please explain why, and also explain how the Company can ensure the
construction of the project was completed at least cost.
a. A justification of need for the project and a cost-benefit analysis.
b. Details on previous rental contract or orders of Portable Electric Space Heaters since
2012 until the purchase and installation of the Freeze Protection Heaters.
c. Project Plan
i. Initial project scope;
ii. Proposed budget; and
iii. Proposed schedule.
d. RFP
i. Project requirements;
ii. Specifications;
iii. Short list bidder scorecard; and
iv. RFP from winning bid.
e. Documentation specific to Idaho Power approving the project prior to start of
construction.
f. Documentation specific to Idaho Power acknowledging the project was completed at
a reasonable least-cost manner to its customers.

IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 15

RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 238:
a. Please see the AFE for VA2140 provided in Response to Staff’s Request for
Production No. 169.
b. Idaho Power is still gathering the documentation for this request and will provide a
response by Tuesday, September 5, 2023.
c – f. Please see the Company’s Response to Staff’s Request for Production No. 169
and 170. This project was identified as Project No. 4.
The response to this Request is sponsored by Lindsay Barretto, 500-kV and Joint
Projects Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 16

STAFF REQUEST FOR PRODUCTION NO. 239: Please provide the following
information as requested on the Project No. 27493693 (Bridger 2017C110 U4 Boiler
Optimization System 17). If any of the information requested below cannot be provided
or is not available, please explain why, and also explain how the Company can ensure
the construction of the project was completed at least cost.
a. The following details on the neural network combustion controls and soot blowing
optimizer (including but not limited to):
i. Make, model, capacity, specifications, etc.; and
ii. Brochure, datasheets, etc.
b. Analysis of Need - a justification of need for the project and a cost/benefit analysis
comparing alternatives.
c. Project Plan
i. Initial project scope;
ii. Proposed budget; and
iii. Proposed schedule.
d. RFP
i. Project requirements;
ii. Specifications;
iii. Short list bidder scorecard; and
iv. RFP from winning bid.
e. Project construction documentation including:
i. Construction contract;
ii. Organizational chart;

IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 17

iii. Scope document;
iv. Work breakdown structure;
v. Baseline Schedule;
vi. Monthly project status report(s);
vii. Action items list(s); and
viii. Contractors change order request(s).
f. Company project completion analysis:
i. Lessons learned;
ii. Budget-to-actual comparisons for overall project and by year;
iii. Baseline schedule-to-actual schedule comparison; and
iv. For any actual costs differing from the budget amount by plus or minus five
percent during a particular year, please list and explain the reason(s) for the
budget amount difference.
g. Documentation specific to Idaho Power approving the project prior to start of
construction.
h. Documentation specific to Idaho Power acknowledging the project was completed at
a reasonable least-cost manner to its customers.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 239: Idaho Power
is still gathering the documentation for this request and will provide a response by
Tuesday, September 5, 2023.

IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 18

STAFF REQUEST FOR PRODUCTION NO. 240: Please provide the following
information as requested on the Project No. 27475574 (Bridger CITC2017C207
Backup Bandwidth Upgrades 2017). If any of the information requested below cannot
be provided or is not available, please explain why, and also explain how the Company
can ensure the construction of the project was completed at least cost.
A. The following details on previous/deprecated radio communications at the plant
(including but not limited to):
i. Make, model, capacity, specifications, etc.; and
ii. Brochure, datasheets, etc.
b. The following details on the upgraded radio communications at the plant (including
but not limited to):
i. Make, model, capacity, specifications, etc.; and
ii. Brochure, datasheets, etc.
c. Analysis of Need – a justification of need for the project and a cost/benefit analysis
comparing alternatives.
d. Project Plan
i. Initial project scope;
ii. Proposed budget; and
iii. Proposed schedule.
e. RFP
i. Project requirements;
ii. Specifications;
iii. Short list bidder scorecard; and

IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 19

iv. RFP from winning bid.
f. Project construction documentation including:
i. Construction contract;
ii. Organizational chart;
iii. Scope document;
iv. Work breakdown structure;
v. Baseline Schedule;
vi. Monthly project status report(s);
vii. Action items list(s); and
viii. Contractors change order request(s).
g. Company project completion analysis:
i. Lessons learned;
ii. Budget-to-actual comparisons for overall project and by year;
iii. Baseline schedule-to-actual schedule comparison; and
iv. For any actual costs differing from the budget amount by plus or minus five
percent during a particular year, please list and explain the reason(s) for the
budget amount difference.
h. Documentation specific to Idaho Power approving the project prior to start of
construction.
i. Documentation specific to Idaho Power acknowledging the project was completed at
a reasonable least-cost manner to its customers.

IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 20

RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 240: Idaho Power
is still gathering the documentation for this request and will provide a response by
Tuesday, September 5, 2023.

IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 21

STAFF REQUEST FOR PRODUCTION NO. 241: Please provide the following
information as requested on the Project No. 27574748 (Valmy 98483985 V2 Ovation HMI
and Server Update). If any of the information requested below cannot be provided or is
not available, please explain why, and also explain how the Company can ensure the
construction of the project was completed at least cost.
a. The following details on previous/deprecated Emerson Ovation Distributed Control
System ("DCS") equipment at the plant (including but not limited to):
i. Make, model, capacity, specifications, etc.; and
ii. Brochure, datasheets, etc.
b. All communications with Emerson confirming the end of previous DCS's original
equipment manufacturer ("OEM") support.
c. The following details on upgraded DCS at the plant (including but not limited to):
i. Make, model, capacity, specifications, etc.; and
ii. Brochure, datasheets, etc.
d. A copy of the latest Top 20 Critical Security Controls ("CSC") SANS guidelines for
cyber defense and detection tools, as mentioned in Exhibit No. 2 Barretto Direct at
1.
e. Analysis of Need - a justification of need for the project and a cost/benefit analysis
comparing alternatives.
f. Project Plan
i. Initial project scope;
ii. Proposed budget; and
iii. Proposed schedule.

IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 22

g. RFP
i. Project requirements;
ii. Specifications;
iii. Short list bidder scorecard; and
iv. RFP from winning bid.
h. Project construction documentation including:
i. Construction contract;
ii. Organizational chart;
iii. Scope document;
iv. Work breakdown structure;
v. Baseline Schedule.
vi. Monthly project status report(s);
vii. Action items list(s); and
viii. Contractors change order request(s).
i. Company project completion analysis:
i. Lessons learned;
ii. Budget-to-actual comparisons for overall project and by year;
iii. Baseline schedule-to-actual schedule comparison; and
iv. For any actual costs differing from the budget amount by plus or minus five
percent during a particular year, please list and explain the reason(s) for the
budget amount difference.
j. Documentation specific to Idaho Power approving the project prior to start of
construction.

IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 23

k. Documentation specific to Idaho Power acknowledging the project was completed
at a reasonable least-cost manner to its customers.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 241:
a. – d. Idaho Power is still gathering the documentation for this request and will
provide a response by Tuesday, September 5, 2023.
e – k. Please see the Company’s Response to Staff’s Request for Production No. 169
and 170. This project was identified as Project No. 2.
The response to this Request is sponsored by Lindsay Barretto, 500-kV and Joint
Projects Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 24

STAFF REQUEST FOR PRODUCTION NO. 242: Please provide the following
information regarding the Midpoint-to-Borah 345-kV transmission modifications as
mentioned in Colburn Direct at 11.
a. Clear and detailed maps identifying the locations where the enhancements were
performed since 2012 to date. Please use color highlighting (or suitable
alternatives) to distinguish between the completed portion of the project, the
ongoing portion of the project, and the future work.
NOTE: Please provide this map in an electronic format (.pdf) which can be scale
enlarged to identify all aspects of the system.
b. Justification and documentation supporting on the issues that began to arise as the
transmission line aged (according to Colburn Testimony).
i. The details should include but not be limited to power outages and disruption
reports, customer complaints, etc.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 242:
a. See Attachment 1 – Response to Staff Request No. 242 for a map identifying the
location of the enhancements to the Midpoint to Borah 345-kV transmission line.
All work has been completed and no outstanding future work remains. Also please
see the attachments to the Company’s Response to Request for Production No.
187 which include detailed work maps as part of the construction documentation.
b. Please see the Company’s Response to Request for Production No. 187 for a
description of the project need. Additional information related to the project
justification can be found in Attachment 2 – Response to Staff Request No. 242 in
which additional information is contained describing the assessment and

IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 25

justification of the project. Outage information is included in Attachment 3 –
Response to Staff Request No. 242 showing the decline in outages since the
project has been completed. Patrol reports identifying maintenance needs are
included in Attachment 4 – Response to Staff Request No. 242. Idaho Power is
unable to provide customer complaints that may have led to the Midpoint-to-Borah
345-kV transmission modifications as customer complaints are not tracked to that
level of detail.
The response to this Request is sponsored by Mitch Colburn, Vice President
Planning, Engineering, and Construction, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 26

STAFF REQUEST FOR PRODUCTION NO. 243: Please provide the following
information regarding the underground cable replacement program that began in 2012 as
mentioned in Colburn Direct at 16. If any of the information requested below cannot be
provided or is not available, please explain why. Please also explain how the Company
can ensure the construction of the project was completed at least cost.
a. Clear and detailed maps identifying the locations/zones of the 4 million feet of
direct-buried cable that was replaced with cable within the conduit.
b. Clear and detailed maps identifying the locations/zones of the remaining 3 million
feet of direct-buried cable that is planned to be replaced with cable within the
conduit. Please use color highlighting (or suitable alternatives) to distinguish
between the completed portion of the project, the ongoing portion of the project,
and the future work.
NOTE: Please provide this map in an electronic format (.pdf) which can be scale
enlarged to identify all aspects of the system.
i. Justification and documentation supporting the reliability issues the Company
was facing that compelled the Company to replace 7 million feet of existing
direct-buried distribution cables; and
ii. The details should include but not limited to power outages and disruption
reports, customer complaints, etc.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 243: Completion
at Least-Cost: See part (c) to the Company’s Response to Staff's Request for Production
No. 188 along with adherence to the Idaho Power Procurement Policy and Procurement
Standard, provided as Attachment 2 – Response to Staff’s Request No. 34 that support

IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 27

the Company’s efforts to ensure the project was completed in a least-cost manner.
a. See Confidential Attachment 1 - Response to Staff Request No. 243 for the detailed
maps by county and feeder identifying the locations/zones of the replaced cable
as well as the current and future cable replacements. Please note that Confidential
Attachment 1 contains thousands of maps, totaling over 2 gigabytes of electronic
data, some of which are confidential. Given the significant time and resources
required to individually label each confidential document contained in this
attachment, Idaho Power has instead marked the entirety of the contents
contained within the Response to Staff’s Request No. 243 Attachment 1 as
confidential by designating the Attachment folder as “ALL CONTENTS
CONFIDENTIAL.” Prior to printing or introducing any of these documents into the
evidentiary record, please contact Idaho Power Lead Counsel Lisa Nordstrom to
review the documents’ confidentiality designation and add the appropriate label if
they are indeed confidential.
b. See part (a) above.
i. A description of the justification and project need was provided in the Company’s
Response to Staff's Request for Production No. 188 parts (a) and (b). See also
Confidential Attachment 2 - Response to Staff Request No. 243 for a description
of the transition from a cable rejuvenation program into the cable replacement
program due to the increasing number of faults and backlog of cables identified
to be replaced.
ii. See Confidential Attachment 3 - Response to Staff Request No. 243 that
contains information pertaining to outages that occurred on primary

IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 28

underground lines dating back to 2010. Idaho Power is unable to provide
customer complaints specific to the underground cable replacement project as
customer complaints are not tracked to that level of detail.
The response to this Request is sponsored by Mitch Colburn, Vice President
Planning, Engineering, and Construction, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 29

STAFF REQUEST FOR PRODUCTION NO. 244: Please provide the following
information regarding the Field Area Network ("FAN") and replacement of an Automated
Capacitor Control ("ACC") system with the development of a new integrated volt-var
control ("IVVC") system, mentioned in Colburn Direct at 17. If any of the information
requested below cannot be provided or is not available, please explain why. Please also
explain how the Company can ensure the construction of the project was completed at
least cost.
a. Analysis of Need - a justification of need for the project and a cost/benefit analysis
comparing alternatives.
b. Project Plan
i. Initial project scope;
ii. Proposed budget; and
iii. Proposed schedule.
c. RFP
i. Project requirements;
ii. Specifications;
iii. Short list bidder scorecard; and
iv. RFP from winning bid.
d. Project construction documentation including:
i. Construction contract;
ii. Organizational chart;
iii. Scope document;
iv. Work breakdown structure;

IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 30

v. Baseline Schedule;
vi. Monthly project status report(s);
vii. Action items list(s); and
viii. Contractors change order request(s).
e. Company project completion analysis:
i. Lessons learned;
ii. Budget-to-actual comparisons for overall project and by year;
iii. Baseline schedule-to-actual schedule comparison; and
iv. For any actual costs differing from the budget amount by plus or minus
five percent during a particular year please list and explain the reason(s)
for the budget amount difference.
f. Documentation specific to Idaho Power approving the project prior to start of
construction.
g. Documentation specific to Idaho Power acknowledging the project was completed
at a reasonable least-cost manner to its customers.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 244:
a. Up through 2017, voltage and reactive power on Idaho Power’s distribution system
was controlled through a legacy, custom developed system of autonomous load
tap changers, line voltage regulators, and line capacitor banks. There was no
coordination between the individual devices. The automated capacitors were
controlled by the legacy, custom built Automated Capacitor Control (“ACC”)
system. Each capacitor operated according to pre-set rules based on substation
sensor data. Control signals were sent via a one-way radio frequency system.

IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 31

Voltage regulating devices had stand-alone controls that made decisions based
on local device conditions. In the past, this approach was effective in managing
reactive power due to the relatively static nature of Idaho Power’s loads and low
levels of distributed generation located on the distribution feeders.
The end-of-life of the existing ACC system, cyber security risks associated with
the legacy, DOS-based ACC program, and increasing penetration of distributed
energy resources required the replacement of the existing system. Replacing the
existing system with a similar automated, autonomous volt/volt-ampere reactive
(“VAR”) management system would leave the Company unprepared to effectively
manage voltage and reactive power given the dynamic voltage swings and reverse
power flows that occur with distributed generation growth. In fact, in 2016, Idaho
Power was already experiencing the effects of distributed generation growth –
several of the Company’s distribution feeders now had large, utility-scale solar
photovoltaic installations with a capacity greater than the peak load on the individual
feeder, and even greater than the substation. These feeders were experiencing
reverse power flow nearly every day of the year. This project replaced the current
capacitor management system with an Integrated Volt-VAR Control (“IVVC”) system
that is capable of managing feeders with high levels of distributed energy resources,
provides enhanced cyber security controls, and establishes a sustainable foundation
for current and future operations.
Idaho Power considered the following alternatives prior to the IVVC replacement
of the ACC:
 Modernizing the ACC system, which would require the custom

IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 32

development of a new capacitor control system. However, due to the
complexity a custom development of the system, the Company did not
have the technical expertise to complete all aspects of the project.
 (Selected option) Replace the ACC over a 3-year buildout with off-the-
shelf software. This solution would replace the legacy, in-house built,
DOS-based ACC system with a modern, vendor supported and
sustainable system. It would eliminate the cyber security risks associated
with the existing system while providing full optimization of the voltage and
reactive power control on the distribution system which is foundational to
operating the system.
 Do nothing. This option would expose the Company to cyber security
threats and situations in which the current systems begin to fail due to
hardware and software platform issues.
Through the RFP process, Idaho Power focused on a solution that best met the
requirements of the system and effectively reduced risk at the least cost.
b. Project Plan
i. Initial project scope - See Attachment 1 - Response to Staff Request No. 244 for
the Request for Proposal (“RFP”) IVVC System. Section I. D details the scope of
work/specifications and requirements.
ii. Proposed budget - the original (pre-design) proposed capital budgets were:
 IVVC program: $30.2 million
 Communications system (FAN): $8.7 million
 Stations: $5.0 million

IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 33

 Distribution Lines: $9.0 million
 Information Technology: $7.5 million
iii. Proposed schedule – Section II. A of the RFP included as Attachment 1 - Response
to Staff Request No. 244 details the proposed project schedule.
c. RFP
i. Project requirements - See Attachment 2 - Response to Staff Request No. 244
for the technical requirements provided as Appendix C to the RFP and
Attachment 3 - Response to Staff Request No. 244 for the functional
requirements provided as Appendix D to the RFP.
ii. Specifications - see Section I. D of Attachment 1 - Response to Staff Request
No. 244.
iii. Short list bidder scorecard – see Attachment 4 - Response to Staff Request
No. 244 for the bidder scorecard.
iv. RFP from winning bid – see Confidential Attachment 5 - Response to Staff
Request No. 244 for the winning bid.
d. Project construction documentation including:
i. Construction contract – see Confidential Attachment 6 - Response to Staff
Request No. 244 for the statement of work with Open Systems International.
ii. Organizational chart – see the Contractor and IPC Personnel section of the
statement of work provided as Confidential Attachment 6 - Response to Staff
Request No. 244.
iii. Scope document - the full scope of work consists of two bodies of work (1)
purchasing, installing, configuring, testing and commissioning the software,

IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 34

and (2) substation and distribution system upgrades and additions as outlined
in the attached. Scope for the software work is included in the statement of
work provided in Confidential Attachment 6 - Response to Staff Request No.
244 under the Scope of Services section. In addition, Attachment 7 – Response
to Staff Request No. 244 - Scope Document includes Idaho Power’s Scope
Document / Project Plan. Similar scoping information was gathered for the
subsequent buildout across the service territory that occurred from 2019
through 2021.
iv. Work breakdown structure – please see Attachment 7 – Response to Staff
Request No. 244 - Scope Document for a work breakdown structure.
v. Baseline Schedule - The IVVC system was envisioned as a 5-year project
which began with the proof of concept, pilot, scoping and design in 2017 –2018,
followed by the system build out scheduled for 2019-2021. See Attachment 8 -
Response to Staff Request No. 244 - IVVC Schedule for a high-level schedule.
vi. Monthly project status report(s) – See the project status reports provided in
Attachment 9 - Response to Staff Request No. 244 - Project Status - 2018-
2020 and Attachment 10 - Response to Staff Request No. 244 - Grid Mod
Project status 2021.
vii. Action items list(s) - Action items and activities are included in the project status
updates provided in Attachments 9 and 10 – Response to Staff Request No.
244.
viii. Contractors change order request(s) – there were no contractor change order
requests.

IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 35

e. Company project completion analysis:
i. Lessons learned – Key actions that were taken that had large impacts on the
success of the project and were considered lessons learned include (1) internal
planning and communication, (2) getting the designs completed well ahead of
the planned construction, (3) ordering materials early, (4) having spare
materials in stores, and (5) breaking the annual line work into six groups that
could be bid and managed separately.
ii. Budget-to-actual comparisons for overall project and by year - Overall, the
actual spend for the 5-year project was about 93 percent of the original
proposed budget. Please see Attachment 11 - Response to Staff Request No.
244 – IVVC Budget vs Actuals for more details.
iii. Baseline schedule-to-actual schedule comparison – The original baseline
schedule called for a project finish on December 31, 2021. The actual finish
date of the project was in March 2022 to allow time for some final
commissioning that was not able to be completed in December. Also, some
field monitoring devices had to be moved to early 2022 because they could not
be commissioned until after the IVVC system was installed on feeders and
substations.
iv. For any actual costs differing from the budget amount by plus or minus five
percent during a particular year please list and explain the reason(s) for the
budget amount difference – Please see Attachment 11 - Response to Staff
Request No. 244 – IVVC Budget vs Actuals.
f. Documentation specific to Idaho Power approving the project prior to start of

IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 36

construction – Idaho Power’s capital budget must be presented to the Board of
Directors for review and approval each November for the following calendar year.
Board of Directors approval of Idaho Power’s capital budget is documented in the
November board meeting minutes. Board of Directors meeting minutes are highly
confidential and will be made available to Staff at Idaho Power's corporate
headquarters. Please contact Tami White at [phone] or David Fewkes at
[phone] to arrange a time to review the requested material.
g. Documentation specific to Idaho Power acknowledging the project was completed
at a reasonable least-cost manner to its customers – Through the RFP process,
Idaho Power selected the solution to build the new IVVC system that best met
system requirements and managed cyber security risk at the lowest cost. Then,
Idaho Power managed the entire 5-year project to finish under budget by
optimizing the design and implementing construction efficiencies to minimize the
costs to our customers.
The response to this Request is sponsored by Mitch Colburn, Vice President
Planning, Engineering, and Construction, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 37

STAFF REQUEST FOR PRODUCTION NO. 245: "SBAR = Energy Related
Generation Function Revenue Requirement ÷ Idaho Retail Sales" Please explain why
Line 114 in the "Miscellaneous" section of Exhibit No. 38 is part of "Energy Related
Generation Function Revenue Requirement".
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 245: Idaho Power
calculated the Sales Based Adjustment Rate (“SBAR”), Goralski Exhibit No. 49, in
compliance with Order Nos. 32206 (GNR-E-10-03), 33307 (IPC-E-15-15), and 35482
(IPC-E-22-06), under the methodology directed by the Idaho Public Utilities Commission
in those respective cases.
The response to this Request is sponsored by Paul Goralski, Regulatory
Consultant, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 38

STAFF REQUEST FOR PRODUCTION NO. 246: Tab "Table I" of Exhibit No. 49
shows "A&G Expense Exclusion" is subtracted from "Energy Related Generation
Function Revenue Requirement". Please respond to the following:
a. Please define A&G Expense Exclusion;
b. Please explain why A&G Expense Exclusion should be subtracted from "Energy
Related Generation Function Revenue Requirement" when the SBAR is
calculated;
c. Please explain why Line 499 through Line 558 in Exhibit No. 37 represent the
portion of the overall A&G exclusion that should be subtracted from "Energy
Related Generation Function Revenue Requirement";
d. Please define Line 536 "energy related FERC admin assess & securities" and
explain why this should be excluded;
e. Please define Line 538 "FERC Order 472" and explain why this should be
excluded; and
f. Please define Line 558 "Merchandising Expense" and explain why this should be
excluded.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 246:
a. As listed in Note 1 of Goralski Exhibit No. 49, the “A&G Expense Exclusion”
references amounts listed in Exhibit No. 37, Lines 499-558, specifically Table 5,
FERC accounts 900-935; 416. In Exhibit No. 37, the three amounts which
comprise the total $1,855,842 of A&G Expense Exclusion are from FERC Account
928; Energy Related FERC Admin Assess & Securities, and FERC Order 472,
Exhibit No. 37 rows 536 and 528, and FERC account 416, merchandising expense,

IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 39

Exhibit No. 37 row 558.
b. Please see the Company’s response to Staff’s Request for Production No. 245.
c. Please see the Company’s response to Staff’s Request for Production No. 245.
d. 928.101 FERC administrative assessment and securities is the annual FERC fees
assessed to Idaho Power under the Federal Power Act to reimburse the United
States for the costs of administration of the Commission’s hydropower regulatory
program. The energy-classified portion is determined by the ratio of actual billed
capacity (kW) vs generation (kWh) billings received from FERC in 2021-2022.
Please see the Company’s response to Staff’s Request for Production No. 245.
e. FERC Order 472 – these are FERC admin fees assessed on Idaho Power’s
wholesale energy sales. Please see the Company’s response to Staff’s Request
for Production No. 245.
f. Account 416 – Costs and expenses for merchandising, jobbing and contract work.
This account primarily consists of payments to PacifiCorp for joint operating
agreements, joint use contract work and to a lesser extent other Idaho Power
services. The specific value functionalized and classified and production-energy,
$10,097 is for water management services. Please see the Company’s response
to Staff’s Request for Production No. 245.
The response to this Request is sponsored by Paul Goralski, Regulatory
Consultant, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 40

STAFF REQUEST FOR PRODUCTION NO. 247: Tab "Table I" of Exhibit No. 49
shows "Subsidiary Income" is subtracted from "Energy Related Generation Function
Revenue Requirement". Please respond to the following:
a. Please define "Subsidiary Income";
b. Please explain how "Subsidiary Income" is calculated and provide the workpaper
with formula intact;
c. Please explain why "Subsidiary Income" should be subtracted from "Energy Related
Generation Function Revenue Requirement"; and
d. Subsidiary Income is based on Line 35 of Exhibit No. 42 "IERCO Operating Income."
Please explain what IERCO stands for and what IERCO Operating Income means.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 247:
a. Subsidiary Income is IERCO Operating Income. IERCO stands for Idaho Energy
Resources Co., a wholly owned subsidiary of Idaho Power which owns one-third
interest in Bridger Coal Company (“BCC”), which mines and supplies coal to the
Jim Bridger power plant, owned in part by Idaho Power. PacifiCorp owns the other
two-thirds interest in BCC.
b. Subsidiary Income is sourced from the Idaho Jurisdictional Separation Study, Noe
Exhibit No. 35, row 25. Please see Larkin Exhibit No. 26, pages 19-20 for IERCO
forecast methodology, and the previously submitted Noe Workpaper “Exhibits
2023 Idaho,” worksheet “IERCO IncStmt” for the workpaper.
c. Please see the Company’s response to Staff’s Request for Production No. 245.
d. Please see the responses to (a) and (b).

IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 41

The response to this Request is sponsored by Paul Goralski, Regulatory
Consultant, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 42

STAFF REQUEST FOR PRODUCTION NO. 248: Please re-run the AURORA
model and provide an updated Table 5 "2023 Base Level NPSE," contained in Brady's
Direct Testimony, with Bridger Units 1 and 2 not converted to natural gas units.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 248: Please see
below for updated 2023 Base Level NPSE, calculated by modeling Bridger Units 1 and 2
in AURORA as coal units.
2023 Base Level NPSE
95% Accounts (with 95% recovery in PCA)
501, Coal $ 93,248,910.00
536, Water for Power $ 0.00
547, Other Fuel $ 130,882,565.49
555, Non-PURPA Purchased Power $ 79,069,369.25
565, Third Party Transmission $ 6,016,920.75
447, Surplus Sales $ (36,562,197.39)
Net 95% Accounts $ 272,655,568.10

100% Accounts (with 100% recovery in PCA)
555, PURPA $ 214,448,754.57
555, Demand Response $ 10,240,003.00
Total $ 497,344,325.67

The response to this Request is sponsored by Jessi Brady, Regulatory Analyst,
Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 43

STAFF REQUEST FOR PRODUCTION NO. 249: Regarding the attachment in the
Company's response to Production Request No. 81, please indicate how the amount of
"2023 Forecasted Billed Revenue," of $1,641,862,697, correlates to the revenue
requirement model.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 249: The amount
of $1,641,862,697 reflects the forecast of 2023 billed revenues on a system basis. “Billed”
revenues refer to all charges that comprise a customer’s total bill, including the Energy
Efficiency Rider (“Rider”), the Power Cost Adjustment (“PCA”), and the Fixed Cost
Adjustment (“FCA”). The 2023 system billed revenue forecast was utilized in the
calculation of uncollectible expenses because the historical revenues used to determine
the 10-year expense-to-revenue ratio also reflected system billed amounts. To determine
the $1,641,832,697 figure, when Idaho Power was preparing its rate case in spring 2023
it estimated billed revenue for Idaho for the 2023 test year utilizing current base rates, the
current Rider amount, and filed FCA and PCA rates to go into effect June 1, 2023.
Ultimately the FCA was approved as filed, while the Company was ordered to collect the
deferral balance of the PCA over a two-year period. The $1,641,832,697 figure also
includes retail revenues from Idaho Power’s Oregon jurisdiction, as the historical ratios
and final uncollectible amount were determined at an Idaho Power system level.
The revenue requirement model presented in Exhibit No. 34 to Company Witness
Ms. Kelley Noe’s testimony reflects base retail revenues, i.e., charges to customers from
base charges contained within each class’s respective rate schedule.
The response to this Request is sponsored by Matthew Larkin, Revenue
Requirement Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 44

STAFF REQUEST FOR PRODUCTION NO. 250: Please indicate the percentage
and effective dates of all General Wage Increases ("GWI") that occurred since the
Company's last general rate case.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 250: General
Wage Adjustments (“GWA”) must be approved by the Board of Directors each November
and are generally made effective the first pay period of the new year. The chart below
shows the effective dates and the approved GWA percentage increases since the last
general rate case.
GWA Year Effective Date GWA Percentage
2023 12/24/2022 6%
2022 Mid-Year 07/09/2022 2%
2022 12/25/2021 6%
2021 12/26/2020 2.75%
2020 12/28/2019 2.75%
2019 12/29/2018 3%
2018 12/30/2017 3%
2017 12/31/2016 2.75%
2016 01/06/2016 3%
2015 01/03/2015 3%
2014 01/04/2014 3%
2013 01/05/2013 3%
2012 01/07/2012 2.75%

The response to this Request is sponsored by Sarah Griffin, Vice President Human
Resources, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 45

STAFF REQUEST FOR PRODUCTION NO. 251: Please list the number of
customer service representatives ("CSRs") employed in each month from 2017-2023.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 251: Please see
the table below, which details the number of CSRs employed within the Company’s
Customer Service Center (“CSC”) in each month from 2017 through 2023, year-to-date.
Each month’s count reflects the total number of CSRs actively employed within the CSC
(i.e., CSRs not on long-term disability, etc.) as of the end of each month, and whose job
title is “Entry Customer Service Representative,” “Customer Service Representative I,” or
Customer Service Representative II.”
Yr./Mo. Jan. Feb. Mar. Apr. May Jun. Jul. Aug. Sep. Oct. Nov. Dec.
2017 70 71 69 76 67 66 65 65 63 61 58 57
2018 68 68 67 66 69 66 63 61 61 67 67 66
2019 65 62 62 60 61 59 59 57 58 63 62 61
2020 59 58 56 56 56 56 52 61 60 60 59 57
2021 55 54 63 62 60 58 52 50 64 63 59 61
2022 61 59 56 66 61 71 71 68 64 71 71 68
2023 69 68 67 64 59 59 66 65

The response to this Request is sponsored by Bo Hanchey, Vice President of
Customer Operations and Chief Safety Officer, Idaho Power Company.
STAFF REQUEST FOR PRODUCTION NO. 252: In regards to the Excel file
labeled "Attachment - Response to Staff Request No. 96" provided by the Company, the
analysis is performed without Battery Energy Storage System ("BESS"') Projects.
Please answer the following:
a. Please explain why the Company conducts this analysis without BESS Projects;
b. Please explain why BESS projects should not be considered when establishing
TOU rates;
c. Please explain why BESS projects should not be considered when expanding the
summer season
d. The Company's analysis includes Demand Response as a resource, please
explain why it is appropriate to include Demand Response while BESS resources
are removed; and
e. Please provide an updated worksheet that updates all analysis and accompanying
tabs by including all existing and contracted BESS Projects.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 252: The analysis
used to inform the Company’s initial recommendation in this docket was conducted in the
first half of 2023. As the Company continued development of its 2023 Integrated
Resource Plan (“IRP”) after the GRC was filed on June 1, 2023, methods have been
refined, which has resulted in some modifications to the IRP-informed highest-risk hours.
Ultimately, the Company believes it is appropriate to align definitions for Time-of-Use
(“TOU”) hours with the analysis that will be finalized as part of the 2023 IRP. As described
in the responses below, the IRP methods have been refined regarding how BESS and
Demand Response are treated in the development of identifying the Company’s highest-
IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 46
IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF
THE COMMISSION STAFF - 47
risk hours.
a. Depending on the timing of adding BESS, the highest-risk hours will vary. The
Company excluded BESS projects from its analysis of hours of highest risk
because of the operational characteristics of the resource. Specifically, while the
BESS is a dispatchable resource, it is limited to its nameplate capacity output for
a fixed number of hours (e.g., four-hour BESS). In comparison, other fully
dispatchable resources such as thermal and hydro units have more discretion in
the run times available to meet customer loads for extended periods and are not
limited in the duration of dispatch in the same ways as BESS resources. Please
see responses to Part B for the analysis specific to defining the TOU definitions
and Part C for the approach specific to defining the summer season.
b. If BESS projects are included in the analysis, this would shift or smooth out the
highest-risk hours because of the addition of BESS. However, if the analysis
excludes BESS, it can inform the highest-risk hours to define the TOU hours, which
will then be relied on to send a price signal to customers through TOU rates. The
Company then can dispatch its BESS resources after any behavioral response
from customers based on the newly established definitions for TOU. Please note
that the Company's method used in the IRP has been refined throughout the
development of the 2023 IRP, and as a result the current approach also excludes
Demand Response for the TOU highest-risk hour analysis. The Company believes
it is appropriate to rely on the highest-risk hours, as informed by the preliminary
2023 IRP analysis, for its rate design proposals in this case.
c. After filing the Company’s recommendation in this docket, the Company’s method
IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF
THE COMMISSION STAFF - 48
for defining the highest-risk hours to define the summer season evolved. The
Company’s updated method includes all resources (i.e., including BESS) for
determining the months to define the summer season. However, the Company
tested the impact on the length of the season with and without BESS and found no
change – both methods support adding September to the summer season. The
approach for defining the highest-risk hours for determining the TOU periods
versus the summer season can primarily be attributed to the limitations for run
times for both BESS and Demand Response.
d. The Company’s method has been revised, as described in more detail in Part B
and C of this response. The revised method excludes BESS and Demand
Response for determining the highest-risk hours for defining the TOU periods.
Please see the Excel file labeled “Attachment – Response to Staff Request No.
252” for this analysis on the three tabs with “NoBESS_NoDER” in the naming
convention.
e. Please see the Excel file labeled “Attachment – Response to Staff Request No.
252” for an updated worksheet that updates the analysis to include all existing and
contracted BESS projects on the three tabs with “All_Resources” in the naming
convention. The “All_Resources_Summer” tab includes the supporting analysis for
defining the summer season as June 1 to September 30. As a result of the all-
resource approach to defining TOU hours, all winter hours are defined as medium-
risk hours, and no hours qualify as high-risk or low-risk hours. As described in Part
B, the Company does not recommend including all resources to define the TOU
hours and instead proposes to exclude both BESS and Demand Response.
IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF
THE COMMISSION STAFF - 49
The response to this Request is sponsored by Jared L. Ellsworth, Transmission,
Distribution and Resource Planning Director, and Connie G. Aschenbrenner, Senior Rate
Design Manager, Idaho Power Company.
DATED at Boise, Idaho, this 30th 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 ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 50
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 30th day of August 2023, I served a true and
correct copy of Idaho Power Company’s Response to the Eleventh 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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IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 51
Dr. Don Reading
280 Silverwood Way
Eagle, Idaho 83616
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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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IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 52
City of Boise
Ed Jewell
Darrell Early
Boise City Attorney’s Office
150 N. Capitol Blvd.
Boise, ID 83701
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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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IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 53
Federal Executive Agencies
Peter Meier
Paige Anderson
Tanner Crowther
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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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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IDAHO POWER COMPANY’S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 54
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