20230906IPC to Staff 253-264.pdf

LISA D. NORDSTROM
Lead Counsel
[e-mail]

September 5, 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
Twelfth 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
Enclosure

RECEIVED
2023 SEPTEMBER 6, 2023 8:46AM
IDAHO PUBLIC
UTILITIES COMMISSION

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

COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), and in
response to the Twelfth Production Request of the Commission Staff (“Commission” or
“Staff”) dated August 22, 2023, herewith submits the following information:

IDAHO POWER COMPANY’S RESPONSE TO THE TWELFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 2
REQUEST FOR PRODUCTION NO. 253: Please update Company Witness
Noe's workpapers for Account 101 - Electric Plant in Service to actuals with the most
current information available.
RESPONSE TO REQUEST FOR PRODUCTION NO. 253: As discussed with
Staff, Idaho Power will respond to this request on September 8, 2023.

IDAHO POWER COMPANY’S RESPONSE TO THE TWELFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 3
REQUEST FOR PRODUCTION NO. 254: Please update Company Witness Noe's
workpapers for Depreciation and Amortization to actuals with the most current information
available.
RESPONSE TO REQUEST FOR PRODUCTION NO. 254: As discussed with
Staff, Idaho Power will respond to this request on September 8, 2023.

IDAHO POWER COMPANY’S RESPONSE TO THE TWELFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 4
REQUEST FOR PRODUCTION NO. 255: Please provide explanation/analysis of
the increased LOLP on the heat maps provided in file "Attachment - Response to Staff
Request No. 96" inside tab labeled "Summer" on 06/12/2019 and 06/13/2019.
RESPONSE TO REQUEST FOR PRODUCTION NO. 255: Please see the Excel
file labeled “Attachment – Response to Staff Request No. 255” for the Reliability and
Capacity Assessment Tool (“RCAT”) hourly output for June 12 and 13 for all test years.
The “Summary” tab highlights that the high Loss of Load Probability (“LOLP”) values
identified in the referenced heat map for test year 3 are primarily due to high loads
combined with minimal solar, wind, and run-of-river hydro generation output.
The response to this Request is sponsored by Jared L. Ellsworth, Transmission,
Distribution & Resource Planning Director, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE TWELFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 5
REQUEST FOR PRODUCTION NO. 256: Referencing the table in the Company's
response to Staff Production Request No. 44, please explain why the Company was
unable to answer 80% of customer calls within 20 seconds for most of the months for
each of the past three years (2020, 2021, and 2023). Please explain what the Company
is doing to improve the percentage rate.
RESPONSE TO REQUEST FOR PRODUCTION NO. 256: Please note that the
Company’s Response to Request No. 44 reflects the percentage of calls answered within
60 seconds in 2020, 2021 and 2022, which differs from the timeframes stated within this
Request for Production.
During early to mid-2020, the Company paused much of its recruitment for open
positions, including for roles such as Customer Service Representatives (“CSRs”), due to
the many then-unknown factors surrounding the COVID-19 pandemic. When the
Company resumed less-restricted recruiting for open positions in the third quarter of 2020,
only a limited number of CSRs were hired given the continued uncertainties regarding the
COVID-19 pandemic. As a result of the Company’s limited recruitment of CSRs in the
initial three quarters of 2020, a number of positions remained open which resulted in fewer
CSRs being available to achieve a service level of answering 80 percent of customer calls
within 60 seconds. Adding to this situation was the fact that, in the latter half of 2020, the
Company resumed recruiting for various other positions as well, leading to the higher-
than-usual internal hiring of CSRs for different roles compared to historical norms.
In an effort to improve the Company’s level of service and achieve 80 percent of
customer calls being answered by CSRs within 60 seconds, the Company has increased
the frequency that it recruits CSRs. Additionally, the Company has also recently adopted

IDAHO POWER COMPANY’S RESPONSE TO THE TWELFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 6
forward hiring practices to address CSRs’ increased attrition rates more effectively. These
strategies, combined with the Company’s effort to ensure customers are placed in the
appropriate call queue, have resulted in the Company achieving more than 80 percent of
customer calls being answered by CSRs within 60 seconds for nearly all months between
June 2022 through December 2022, and a similar trend has continued into 2023, year-
to-date.
The response to this Request is sponsored by Bo Hanchey, Vice President of
Customer Operations and Chief Safety Officer, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE TWELFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 7
REQUEST FOR PRODUCTION NO. 257: Referencing Staff Production Request
No. 49, regarding first call resolution rate, please explain what types of calls are not
resolved upon initial contact with the Company?
RESPONSE TO REQUEST FOR PRODUCTION NO. 257: The “First Call
Resolution Rates” provided within the Company’s Response to Request No. 49 are
calculated based on the total number of instances that a phone number calls back into
the Company’s Interactive Voice Response unit within a 72-hour timeframe from the
initial call. These calls can encompass various types of customer inquiries, and, at this
time, the Company does not have the ability to determine the specific types of customer
calls that remain unresolved following initial contact with the Company. The Company is
currently evaluating whether data at this level of granularity can be made available in
the future.
The response to this Request is sponsored by Bo Hanchey, Vice President of
Customer Operations and Chief Safety Officer, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE TWELFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 8
REQUEST FOR PRODUCTION NO. 258: Referencing the table in the Company's
response to Staff Production No. 45, do the numbers reflect the number of calls that
reached a customer service representative("CSR") or the number of incoming calls
regardless of whether the call was answered by a CSR?
RESPONSE TO REQUEST FOR PRODUCTION NO. 258: The number of
monthly incoming calls stated within the Company’s Response to Request No. 45 reflect
the number of calls that were answered by a CSR.
The response to this Request is sponsored by Bo Hanchey, Vice President of
Customer Operations and Chief Safety Officer, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE TWELFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 9
REQUEST FOR PRODUCTION NO. 259: Referencing the table in the Company's
response to Staff Production Request No. 50, please explain why the average response
time for email transactions the Customer Service Center received increased, by month,
for each of the past three years (2020, 2021, and 2022), increased?
RESPONSE TO REQUEST FOR PRODUCTION NO. 259: CSRs that respond to
email transactions are also responsible for handling incoming calls. Because the
Company strives to answer as many incoming calls within 60 seconds as possible, call
volumes take precedence over email transactions which are afforded up to a 3-business
day turnaround.
Of note, customers are initially informed that it may take the Company up to 3
business days to provide a response to their inquiry and that urgent requests should be
made via the phone, as shown in the below image. Additionally, the average email
response times stated within the Company’s Response to Request No. 50 encompass
the entire duration from the moment an email is received, including all times outside of
the CSC’s operating hours. As such, emails received outside of the CSC’s operating
hours have the potential to skew the Company’s average response times. This is
because these emails naturally take longer to receive a response because they must
wait until CSRs return to work before having the opportunity to be addressed.

IDAHO POWER COMPANY’S RESPONSE TO THE TWELFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 10
The response to this Request is sponsored by Bo Hanchey, Vice President of
Customer Operations and Chief Safety Officer, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE TWELFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 11
REQUEST FOR PRODUCTION NO. 260: Referencing Staff Production Requests
Nos. 58 and 59, please explain what upgrade(s) would have to be made to have an
automated or systematic way for the Company to issue a confirmation number to
customers when they:
a. Request to add or remove a name from an existing account; and
b. Request both new service and the disconnection of service.
RESPONSE TO REQUEST FOR PRODUCTION NO. 260:
a. The Company currently estimates that a custom program would need to be
developed to systematically issue a confirmation number to customers requesting
to add or remove a name from an existing account. The work associated with
implementing this type of a custom program is projected to take between 10 to 12
weeks, and the estimated cost of such implementation effort is included within
“Attachment – Response to Staff Request No. 260”.
b. The Company currently anticipates that the same custom program described
above, including its associated implementation timeframe and cost, could be
leveraged to systematically issue a confirmation number to customers requesting
new service or the disconnection of service.
The response to this Request is sponsored by Bo Hanchey, Vice President of
Customer Operations and Chief Safety Officer, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE TWELFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 12
REQUEST FOR PRODUCTION NO. 261: To supplement the Company's
response to Staff Production Request No. 67, please provide the Federal Energy
Regulatory Commission ("FERC") account numbers for both the fire-protective mesh on
transmission poles project and the pilot satellite imagery and vegetation artificial
intelligence modeling project that were booked to in 2022.
RESPONSE TO REQUEST FOR PRODUCTION NO. 261: Mesh Wrap costs in
2022 were allocated 20 percent to FERC account 571 and 80 percent to FERC account
593. Satellite Imagery costs in 2022 were allocated 20 percent to FERC account 571 and
80 percent to FERC account 593.
The response to this Request is sponsored by Paula Jeppsen, Forecasting and
Planning Director, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE TWELFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 13
REQUEST FOR PRODUCTION NO. 262: Please provide the proportion of usage
of the Company's bulk transmission system by Open Access Transmission Tariff
("OATT") customers and native load customers in 2022. Please explain how the
proportion was calculated and provide supporting workpapers.
RESPONSE TO REQUEST FOR PRODUCTION NO. 262: The portion of Idaho
Power’s transmission system utilized by the Company’s point-to-point and network
customers, as well as the portion used to serve native load customers (Idaho Power’s
retail customers), can be found on page 400 of Idaho Power’s Federal Energy Regulatory
Commission (“FERC”) Form 1, which is presented below.

The portion of the usage utilized by native load customers is presented in column (e) titled
Firm Network Service for Self, the portion utilized by network customers is presented in
column (f) titled Firm Network Service for Others, and the portion utilized by point-to-point
customers is presented in columns (g) and (i), titled Long-Term Firm Point-to-Point

IDAHO POWER COMPANY’S RESPONSE TO THE TWELFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 14
Reservations and Short-Term Firm Point-to-Point Reservations, respectively.
The response to this Request is sponsored by Matt Larkin, Revenue Requirement
Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE TWELFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 15
REQUEST FOR PRODUCTION NO. 263: Please explain the Company's method
for allocating system transmission expenses in its OATT rates.
RESPONSE TO REQUEST FOR PRODUCTION NO. 263: Idaho Power allocates
transmission expenses to its transmission customers in accordance with the FERC-
approved methodology prescribed under Attachment H to the Company’s OATT which
can be found here: IPC_OATT_Issued_2023-08-29.pdf (oati.com). In general,
development of the transmission revenue requirement is based on the previous calendar
year’s FERC Form 1 data and includes transmission-related plant and expenses, and an
allocated portion of other plant and expenses, and is offset by short-term and non-firm
transmission revenues and transmission-related rent revenues received from others.
The response to this Request is sponsored by Matt Larkin, Revenue Requirement
Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE TWELFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 16
REQUEST FOR PRODUCTION NO. 264: Please provide when the Company filed
to update the Company's OATT rate with FERC. Please explain if the Company included
any wildfire mitigation costs into its revenue requirement for the OATT rate.
RESPONSE TO REQUEST FOR PRODUCTION NO. 264: As described in
Attachment H of Idaho Power’s OATT, the transmission revenue requirement is updated
annually, effective October 1 of each year, using the previous calendar year’s FERC Form
1 data. Generally speaking, wildfire mitigation costs would be included in the Company’s
OATT rate to the extent that these costs are reflected in the Company’s FERC Form 1
data and as prescribed under Attachment H. For the formula rate effective October 1,
2023, because the jurisdictional allocation factors approved by the Idaho Public Utilities
Commission and the Public Utility Commission of Oregon in the last rate case do not total
100 percent, a portion of wildfire mitigation costs recorded to transmission-related
expense accounts are not deferred and therefore would be a component of the
transmission revenue requirement computation for which the transmission formula rate
computed under Attachment H of the OATT is based.
The response to this Request is sponsored by Matt Larkin, Revenue Requirement
Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE TWELFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 17
DATED at Boise, Idaho, this 5th day of September 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 TWELFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 18
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the 5th day of September 2023, I served a true and
correct copy of Idaho Power Company’s Response to the Twelfth 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 TWELFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 19
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 TWELFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 20
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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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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IDAHO POWER COMPANY’S RESPONSE TO THE TWELFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 21
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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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