20230901IPC to Staff 268-276.pdf

MEGAN GOICOECHEA ALLEN
Corporate Counsel
[e-mail]

September 1, 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
Fourteenth 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,

Megan Goicoechea Allen
MGA:sg
Enclosure

RECEIVED
Friday, September 1, 2023 2:59:01 PM
IDAHO PUBLIC
UTILITIES COMMISSION

IDAHO POWER COMPANY’S RESPONSE TO THE FOURTEENTH 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.
)
)
)
)
)
)
)
)
)

CASE NO. IPC-E-23-11

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

COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), and in
response to the Fourteenth Production Request of the Commission Staff (“Commission”
or “Staff”) dated August 25, 2023, herewith submits the following information:

IDAHO POWER COMPANY’S RESPONSE TO THE FOURTEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 2
REQUEST FOR PRODUCTION NO. 268: Please respond to the following
regarding the Company's response to Staff Production Request No. 138.
a. If embedded transmission revenues are approved for true up in the PCA, please
confirm that the Company's proposed amount of $46,361,643 for "Transmission
Point-to-Point" revenues as shown in Cell G389 of Exhibit 35 is the amount to be
used as the base for true up. If different, please explain the difference with a
breakdown of each component, and where each component can be found in the
Company's workpapers or exhibits in this case;
b. Please explain how the value of $46,361,643 was determined and provide
workpapers that calculate the amount with formula intact;
c. Please explain how the value of $48,333,338 in Cell F389 of Exhibit 35 was
determined and provide workpapers that calculate the amount with formula intact;
and
d. Please provide the costs of transmission that the Company stated would also need
to be included for true-up in the PCA. Please explain why each cost should be
included and provide where each component can be found in the Company's
workpapers or exhibits in this case. Please provide workpapers that calculate the
amount with formula intact.
RESPONSE TO REQUEST FOR PRODUCTION NO. 268:
a. As noted in the Company’s Response to Staff’s Request No. 138, Idaho Power
does not believe transmission wheeling revenue should be included in base net
power supply expenses (“NPSE”), as transmission revenue from third parties is
not tied to the variable cost of delivered energy serving Idaho Power loads and

IDAHO POWER COMPANY’S RESPONSE TO THE FOURTEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 3
does not vary based on Idaho Power’s load service or related costs. If the
Commission does ultimately order that third-party transmission revenues should
be tracked through the Power Cost Adjustment (“PCA”), the Company would need
to review the order to determine the appropriate course of implementation. Further,
as also discussed in the Company’s Response to Staff’s Request No. 138, the
introduction of these revenues into the PCA mechanism would require
consideration of the corresponding transmission-related costs, including how and
when these costs should be updated. These complexities and others may warrant
consideration in a separate dedicated docket.
b. Point-to-point transmission revenues are forecast at a system level. The
$46,361,643 represents the Idaho allocated amount of point-to-point transmission
revenue and is the result of applying the Idaho “D11” demand factor of 95.92
percent to the total system level point-to-point transmission revenues of
$48,333,338.
c. Point-to-point transmission revenues of $48,333,338 were calculated based on
nine months of the 2023 equivalent kilowatt-hours (“kWhs”) times the formula-
based FERC transmission rate (effective 10/1/2022-9/30/2023), and three months
of the 2023 equivalent kWhs times the forecasted transmission rate (effective
10/1/2023-9/30/2024). The 2023 equivalent kWhs used to calculate the OATT non-
firm and short-term firm transmission wheeling revenues was based on the
average of 2021 and 2022 equivalent kWhs. The long-term firm point-to-point
transmission revenues were based on 2022 actual MW demand. Please see the
attachment included with this response for the workpaper containing the

IDAHO POWER COMPANY’S RESPONSE TO THE FOURTEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 4
calculations.
d. Please see Part A above. The process of modifying the PCA to include an
additional category of costs and revenues is of a complex nature that may warrant
the opening of a separate dedicated docket. Therefore, with information known
today and the amount of time provided to respond to this request, Idaho Power
has not prepared the requested analysis.
The response to this Request is sponsored by Matt Larkin, Revenue Requirement
Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FOURTEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 5
REQUEST FOR PRODUCTION NO. 269: Page 13 of Exhibit No. 26 states
"Account 537 was increased by $471,796 above 2022 Base due to a 9.9 percent increase
from the Idaho Department of Fish and Game for the cost of hatchery operations." Please
provide supporting documentation including invoices, contracts, and other necessary
information to verify and calculate the 9.9 percent increase.
RESPONSE TO REQUEST FOR PRODUCTION NO. 269: Attached is an Excel
spreadsheet (Attachment 1-Response to Staff No. 269) that shows how Idaho Power
calculated a 9.9 percent increase to the 2022 base year.
Please see Attachment 2-Response to Staff No. 269 which is the Idaho
Department of Fish and Game’s Annual Operating Plan for fiscal year 2023 showing the
9.9% increase from the prior year budget on page 43 and 57.
The response to this Request is sponsored by Paula Jeppsen, Forecasting and
Planning Director, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FOURTEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 6
REQUEST FOR PRODUCTION NO. 270: Please provide an Excel spreadsheet
listing all expenses booked into FERC Account 561-Load Dispatching in 2022.
RESPONSE TO REQUEST FOR PRODUCTION NO. 270: Attached is an Excel
spreadsheet (Attachment 1-Response to Staff No. 270) which includes all expenses
recorded in FERC account 561-Load Dispatching in 2022. This account consists of labor,
materials, purchased services and other expenses. Of note, in this account there are 3
non-refundable site control deposits (rows 1,485-1,487) from generator interconnection
projects offset with a write-off (row 1,488) due to non-collection of one project.
The response to this Request is sponsored by Paula Jeppsen, Forecasting and
Planning Director, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FOURTEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 7
REQUEST FOR PRODUCTION NO. 271: The Company's response to Staff
Production Request No. 139 (a) states that "[t]he Company reduced the AURORA-stated
zonal price by the weighted average wheeling rate in the model and the Company's loss
rate of 3.6 percent." Please respond to the following:
a. Please explain how the weighted average wheeling rate in the model is
determined; and
b. Please explain why the Company's loss rate, instead of inter-zonal loss
rate, is used.
RESPONSE TO REQUEST FOR PRODUCTION NO. 271: As discussed with
Staff, Idaho Power Company will provide a response to this request on September 6,
2023.
IDAHO POWER COMPANY’S RESPONSE TO THE FOURTEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 8
REQUEST FOR PRODUCTION NO. 272: Brady's Workpaper No. 4 shows that
Transmission Expenses are calculated as the product of the Company's three-year
Average Wheeling Rate ($/MWh) and the AURORA generated Market Purchase Volume
(MWh). Please respond to the following:
a. Please explain why the wheeling rate in the AURORA model, which
determined the AURORA generated Market Purchase Volume (MWh), is not
used; and
b. Please provide the Transmission Expenses that are calculated using the
wheeling rate in the AURORA model, instead of the Company's three-year
Average Wheeling Rate ($/MWh).
RESPONSE TO REQUEST FOR PRODUCTION NO. 272: As discussed with
Staff, Idaho Power Company will provide a response to this request on September 6,
2023.

IDAHO POWER COMPANY’S RESPONSE TO THE FOURTEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 9
REQUEST FOR PRODUCTION NO. 273: The Company's response to Staff
Production Request No. 146(b) states that for DR programs, only estimated fixed
incentives were included in the net power expenses, and estimated variable incentives
were not included in the net power expenses. Please explain why.
RESPONSE TO REQUEST FOR PRODUCTION NO. 273: In the Company’s last
General Rate Case, IPC-E-11-08, the Commission approved in Order No. 32426 the
Settlement Stipulation between Idaho Power and Parties where the base level of Net
Power Supply Expense included $11,252,256 of base level demand response incentive
payments which are tracked through the Power Cost Adjustment mechanism.1 The fixed
incentive payments for the demand response programs are the base level incentives and
do not include the variable incentive payments. Variable demand response incentives are
not always paid and are only earned after the Company runs four events. Idaho Power is
required to run a minimum of three events for each of the three programs per season,
and it is not uncommon for the Company to only run the minimum number of events. The
incentives are structured this way so that customers are incentivized to continue their
participation by providing meaningful load reduction throughout the entire demand
response season and are compensated beyond the fixed incentive amount when Idaho
Power runs more than four events. Therefore, the Company’s proposal to only include
the estimated fixed demand response incentive payments in Net Power Supply Expense
was to maintain consistency with the methodology approved in Order No. 32426.

1 In the Matter of the Application of Idaho Power Company for Authority to Increase its Rates and Charges
for Electric Service in Idaho, Case No. IPC-E-11-08, Motion for Approval of Stipulation and Motion to
Open Fixed Cost Adjustment Case, Attachment 1, Paragraph 6 Part (a) (Sept. 23, 2011).

IDAHO POWER COMPANY’S RESPONSE TO THE FOURTEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 10
The response to this Request is sponsored by Zack Thompson, Regulatory
Analyst, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FOURTEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 11
REQUEST FOR PRODUCTION NO. 274: Please explain whether the AURORA-
calculated market purchase expense (recorded in FERC Account 555) and surplus sales
revenue (recorded in FERC Account 447) net the expenses and revenues associated
with wheeling, and whether these expenses and revenues associated with wheeling are
recorded in other accounts.
RESPONSE TO REQUEST FOR PRODUCTION NO. 274: As discussed with
Staff, Idaho Power Company will provide a response to this request on September 6,
2023.

IDAHO POWER COMPANY’S RESPONSE TO THE FOURTEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 12
REQUEST FOR PRODUCTION NO. 275: Please explain whether the base level
of market purchase expense contained in FERC Account 555 has already netted the
expenses associated with wheeling.
RESPONSE TO REQUEST FOR PRODUCTION NO. 275: As discussed with
Staff, Idaho Power Company will provide a response to this request on September 6,
2023.

IDAHO POWER COMPANY’S RESPONSE TO THE FOURTEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 13
REQUEST FOR PRODUCTION NO. 276: In the example described in the
Company's response to Staff Production Request No. 151, please explain why Zone A's
purchase expense is not equal to Zone B's surplus sales revenue.
RESPONSE TO REQUEST FOR PRODUCTION NO. 276: As discussed with
Staff, Idaho Power Company will provide a response to this request on September 6,
2023.

IDAHO POWER COMPANY’S RESPONSE TO THE FOURTEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 14
DATED at Boise, Idaho, this 1st day of September 2023.

MEGAN GOICOECHEA ALLEN
Attorney for Idaho Power Company

LISA D. NORDSTROM
Attorney for Idaho Power Company

DONOVAN E. WALKER
Attorney for Idaho Power Company

IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 15
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the 1st day of September 2023, I served a true and
correct copy of Idaho Power Company’s Response to the Fourteenth 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

Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email [e-mail]
[e-mail]

Clean Energy Opportunities for Idaho
Kelsey Jae
Law for Conscious Leadership
920 N. Clover Dr.
Boise, ID 83703
Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email [e-mail]

Courtney White
Mike Heckler
Clean Energy Opportunities for Idaho
3778 Plantation River Drive, Suite 102
Boise, ID 83703

Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email
[e-mail]
[e-mail]

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

Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email [e-mail]

IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 16
Dr. Don Reading
280 Silverwood Way
Eagle, Idaho 83616

Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email [e-mail]

Idaho Irrigation Pumpers Association,
Inc.
Eric L. Olsen
ECHO HAWK & OLSEN, PLLC
505 Pershing Avenue, Suite 100
P.O. Box 6119
Pocatello, Idaho 83205

Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email [e-mail]

Lance Kaufman, Ph.D.
2623 NW Bluebell Place
Corvallis, OR 97330
Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email [e-mail]

Micron Technology, Inc.
Austin Rueschhoff
Thorvald A. Nelson
Austin W. Jensen
Holland & Hart, LLP
555 Seventeenth Street, Suite 3200
Denver, Colorado 80202

Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email [e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]

Jim Swier
Micron Technology, Inc.
8000 South Federal Way
Boise, Idaho 83707
Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email [e-mail]

IDAHO POWER COMPANY’S RESPONSE TO THE FOURTEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 17
City of Boise
Ed Jewell
Darrell Early
Boise City Attorney’s Office
150 N. Capitol Blvd.
Boise, ID 83701
Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email [e-mail]
[e-mail]
[e-mail]

Wil Gehl
Boise City Dept. of Public Works
150 N. Capitol Blvd.
P.O. Box 500
Boise, Idaho 83701-0500

Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email [e-mail]

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

Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email [e-mail]

Brad Heusinkveld
Idaho Conservation League
710 N. 6th Street
Boise, Idaho 83702
Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email
[e-mail]

IdaHydro
C. Tom Arkoosh
Arkoosh Law Offices
913 W. River Street, Suite 450
P.O. Box 2900
Boise, Idaho 83701

Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email [e-mail]
[e-mail]

Federal Executive Agencies
Peter Meier
Paige Anderson
Tanner Crowther
U.S. Department of Energy
1000 Independence Ave., S.W.
Washin ton, DC 20585
Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email [e-mail]

IDAHO POWER COMPANY’S RESPONSE TO THE FOURTEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 18
Dwight Etheridge
Exeter Associates
5565 Sterrett Place, Suite 310
Columbia, MD 21044
Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email [e-mail]

NW Energy Coalition
F. Diego Rivas
1101 8th Ave
Helena, MT 59601
Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email [e-mail]

Walmart Inc.
Norman M. Semanko
Parsons Behle & Latimer
800 West Main Street, Suite 1300
Boise, Idaho 83702
Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email [e-mail]

Steve W. Chriss
Director, Energy Services
Walmart Inc.
2608 Southeast J Street
Bentonville, Arkansas 72716
Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email [e-mail]

Walmart Inc.
Justina A. Caviglia
Parsons Behle & Latimer
50 West Liberty Street, Suite 750
Reno, NV 89502
Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email [e-mail]

Stacy Gust Regulatory Administrative
Assistant