20230912IIPA 1-24 to IPC.pdf

IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S SECOND SET OF DATA REQUESTS – Page 1
CASE NO. IPC-E-23-11

Eric L. Olsen (ISB# 4811)
ECHO HAWK & OLSEN, PLLC
505 Pershing Ave., Ste. 100
P.O. Box 6119
Pocatello, Idaho 83205
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]

Attorney for Intervenor Idaho Irrigation Pumpers Association, Inc.

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 IRRIGATION PUMPERS
ASSOCIATION, INC.’S SECOND
SET OF DATA REQUESTS

Idaho Irrigation Pumpers, Inc., by and through counsel, hereby submits its Second Data
Requests to Idaho Power Company (“Company”), pursuant to Commission Rule 225, and requests
that the Company provide the following documents and information as soon as possible and no
later than September 19, 2023, as follows:
IIPA 2 -1: Please provide the following Exhibits 8 through 18 and all supporting work
papers, source documents, and source data in their native format with all original formulae intact.
IIPA 2 -2: Please refer to exhibit 9. Please identify all companies considered for inclusion in
the proxy group and for each potential member provide the criteria used to determine
membership in the proxy group.
IIPA 2 -3: Please refer to Exhibit 13. Please provide the methodology used to calculate beta.
Please include sufficient detail to allow independent verification of the beta calculations for each
company.
IIPA 2 -4: Please refer to McKenzie Direct page 64.
RECEIVED
Tuesday, September 12, 2023 2:21:48 PM
IDAHO PUBLIC
UTILITIES COMMISSION

IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S SECOND SET OF DATA REQUESTS – Page 2
CASE NO. IPC-E-23-11

a. Please provide all workpapers in native format used to calculate the
market return of 11.6 percent. Please include data on all companies considered,
regardless of growth rate and indicate which companies were excluded due to
growth rate.
b. Please explain the basis for excluding firms with negative projected
earnings growth and firms with growth rates exceeding 20 percent.
c. Please explain why the referenced discounted cash flow analysis results in
a measure of the expected market return.
IIPA 2 -5: Please provide a legible version of McKenzie-WP-6.pdf and provide the
publication date of this work paper. If the publication date of this work paper is not 2023, please
explain why Kroll’s current estimates are not used. Please also include documentation of the
methodology used to calculate the size premium.
IIPA 2 -6: Please refer to McKenzie Direct page 67 line 1. Does the Company consider Kroll
a reliable source for current CAPM model parameters?
IIPA 2 -7: Please refer to McKenzie Direct page 68.
a. Were the betas used in Figure 2 raw betas or adjusted betas?
b. Were the betas used in Figure 2 levered or unlevered betas?
c. What was the time period used to predict returns and calculate actual
returns?
IIPA 2 -8: Please refer to McKenzie Direct page 4.

IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S SECOND SET OF DATA REQUESTS – Page 3
CASE NO. IPC-E-23-11

a. Has the Company been unable to attract capital on reasonable terms? If
yes, please identify each instance, provide the amount of capital sought, the
amount of capital attracted, and the terms of the capital.
b. Is the company aware of any other regulated electric utility that has been
unable to attract capital on reasonable terms? If yes please identify the companies,
dates, and basis for believing that the companies were unable to attract capital.
IIPA 2 -9: Please provide the capital structure or balance sheet for Idaho Power by quarter
from 2013 to present.
IIPA 2 -10: Please provide all credit opinions or ratings available to Idaho Power and issued
by Moody’s, Standard and Poor’s, and any other rating agency regarding Idaho Power and from
2019 to present.
IIPA 2 -11: Please provide all communications between Idaho Power and Moody’s or
Standard and Poor’s pertaining specifically to Idaho Power’s credit rating or credit metrics, from
2019 to present.
IIPA 2 -12: Please provide all meeting agendas, minutes, and presentations for Idaho Power’s
board of directors, board of director committees, or board of director subcommittee meetings,
from 2019 to present.
IIPA 2 -13: Please provide Idaho Power’s total dividend payout by year and stock type from
2010 to present.
IIPA 2 -14: Please provide, in electronic spreadsheet format, Idaho Power's complete financial
statements (e.g., balance sheet, income statement, cash flow statement, statement of
shareholders’ equity, and statement of comprehensive income) on an annual (or year-end for the

IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S SECOND SET OF DATA REQUESTS – Page 4
CASE NO. IPC-E-23-11

balance sheet) actual basis for the past three calendar years. Please provide such data separately
for Idaho Power and each subsidiary or operating entity.
IIPA 2 -15: Please describe Idaho Power’s current dividend policy and any planned changes
to the current policy. Please also provide any existing documentation of the current policy (e.g.,
statements, e-mails, etc.).
IIPA 2 -16: Please provide an electronic copy of each financial presentation made by Idaho
Power or Idaho Power’s parent to representatives of any investment bank, broker-dealer, equity
analyst, investment services firm, current or potential investor, or other party since January 1 of
the third year preceding the test year through present. Please indicate the purpose of each
presentation and provide the date, the names of Idaho Power representatives attending each such
presentation, and a summary description of the audience.
IIPA 2 -17: Please provide Idaho Power’s current 5-year business plan, 10-year business plan,
and any other long-term business plan or document memorializing Idaho Power’s forecasted
investments and earnings.
IIPA 2 -18: Please provide, in electronic spreadsheet format, Idaho Power’s actual debt terms
with maturity of one year or more (“LT Debt”) for each LT Debt security as of December 31,
2022, and for each actual or pro-forma debt issuance in 2023. Please include assumptions used
for pro-forma issuances. For each individual LT Debt security listed, please provide the
following information:
a. Coupon rate;
b. Description of the security;
c. Issuance date;
d. Maturity date;

IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S SECOND SET OF DATA REQUESTS – Page 5
CASE NO. IPC-E-23-11

e. Original issue principal amount;
f. Currently outstanding principal amount;
g. Amount of any premium or discount at issuance;
h. Redemption expenses;
i. Issuance expenses;
j. Net proceeds to Idaho Power in dollars; and
k. Annual debt service cost.
IIPA 2 -19: Please describe Idaho Power’s accounting treatment of costs associated with the
issuance of LT Debt. If the treatment of these costs varies over time, please indicate the
timeframe for which each treatment applies. Include a description of whether any amortization or
expensing of these costs are included in the revenue requirement.
IIPA 2 -20: Please describe Idaho Power’s accounting treatment of costs associated with the
issuance of stock since January 1, 2018. If the treatment of these costs has varied over this
timeframe, please indicate the timeframe for which each treatment applies.
IIPA 2 -21: For stock issuance since January 1, 2018, please provide the following data:
a. Date of issuance;
b. Type of stock;
c. Describe the circumstances that led Idaho Power to issue securities
through a private placement instead of a public offering or vice versa;
d. Number of shares issued;
e. Original issue principal amount;
f. Premium or discount at issuance;
g. Issuance expenses; and

IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S SECOND SET OF DATA REQUESTS – Page 6
CASE NO. IPC-E-23-11

h. Net proceeds to Idaho Power in dollars.

IIPA 2 -22: Please provide the following data by year from Idaho Power’s last general rate
case to present:
a. Retail load by schedule or customer class
b. Retail revenue by schedule or customer class
c. Total utility revenue
d. Total utility expense
IIPA 2 -23: Please refer to Griffin Direct pages 3 and 4. Please provide the following
information by year from Idaho Power’s last general rate case to present. Please provide such
data separately for executive and non-executive labor.
a. Base wages,
b. Incentive compensation,
c. Share of incentive compensation associated with electric reliability goals,
d. Share of incentive compensation associated with customer satisfaction
goals,
e. Share of incentive compensation associated with profit sharing goals,
f. Share of incentive compensation associated with other metrics, and a
description of other metrics,
g. Health benefit expense,
h. Retirement benefit expense,
i. Other benefit expense,
j. Total capitalized labor expense including loadings, and

IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S SECOND SET OF DATA REQUESTS – Page 7
CASE NO. IPC-E-23-11

k. Total non-capitalized labor expense including loadings.
IIPA 2 -24: Please refer to Griffin Direct page 27 lines 13 and 14. Please provide the
following information by year from Idaho Power’s last general rate case to present.
a. Description of executive incentive pay model,
b. Amount of executive incentive pay,
c. Amount of executive incentive pay included in capitalized labor costs.

DATED this 12th day of September, 2023.

ECHO HAWK & OLSEN
_____________________________________
ERIC L. OLSEN

IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S SECOND SET OF DATA REQUESTS – Page 8
CASE NO. IPC-E-23-11

CERTIFICATE OF SERVICE

I HEREBY CERTIFIY that on this 12th day of September, 2023, I served a true, correct
and complete copy of the Petition of Idaho Irrigation Pumpers Association, Inc. for Leave to
Intervene to each of the following, via U.S. Mail or private courier, email or hand delivery, as
indicated below:

Jan Noriyuki, Commission Secretary
Idaho Public Utilities Commission
P.O. Box 83720
Boise, ID 83720-0074
[e-mail]
U.S. Mail
Hand Delivered
Overnight Mail
Telecopy (Fax)
Electronic Mail (Email)

Lisa D. Nordstrom
Donovan E. Walker
Megan Goicoechea
IPC Dockets
Timothy Tatum
Connie Aschenbrenner
Matt Larkin
Idaho Power Company
1221 W. Idaho Street (83702)
P.O. Box 70
Boise, ID 83707
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]

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Dayn Hardie
Chris Burdin
Deputy Attorneys General
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg. No. 8,
Suite 201-A (83714)
PO Box 83720
Boise, ID 83720-0074
[e-mail]
[e-mail]
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IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S SECOND SET OF DATA REQUESTS – Page 9
CASE NO. IPC-E-23-11

Michael Heckler
Courtney White
Clean Energy Opportunities for Idaho Inc.
3778 Plantation River Dr., Suite 102
Boise, ID 83703
[e-mail]
[e-mail]

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Kelsey Jae
Law for Conscious Leadership
920 N. Clover Dr.
Boise, ID 83703
[e-mail]

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Lance Kaufman, Ph.D.
2623 NW Bluebell Place
Corvallis, OR 97330
[e-mail]

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Peter J. Richardson
Richardson, Adams, PLLC
515 N. 27th Street
Boise, ID 83702
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Dr. Don Reading
280 S. Silverwood Way
Eagle, ID 83616
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Jim Swier
Micron Technology, Inc.
8000 South Federal Way
Boise, ID 83707
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Austin Rueschhoff
Thorvald A. Nelson
Austin W. Jensen
Holland & Hart, LLP
555 17th Street Suite 3200
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IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S SECOND SET OF DATA REQUESTS – Page 10
CASE NO. IPC-E-23-11

Denver, CO 80202
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]

Tom Arkoosh
Arkoosh Law Offices
913 W. River St., Suite 450
P.O. Box 2900
Boise, ID 83701
[e-mail]
[e-mail]

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Ed Jewell
Darrell Early
Deputy City Attorney
Boise City Attorney’s Office
150 N. Capitol Blvd.
PO Box 500
Boise, ID 83701-0500
[e-mail]
[e-mail]
[e-mail]

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Wil Gehl
Energy Program Manager
Boise City Dept. of Public Works
150 N. Capitol Blvd.
P.O. Box 500
Boise, Idaho 83701-0500
[e-mail]

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Marie Callaway Kellner
Brad Heusinkveld
Idaho Conservation League
710 N. 6th Street
Boise, ID 83702
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[e-mail]

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IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S SECOND SET OF DATA REQUESTS – Page 11
CASE NO. IPC-E-23-11

Peter Meier
U.S. Department of Energy
1000 Independence Ave., SW
Washington, D.C. 20585
[e-mail]

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Dwight Etheridge
Exeter Associates
5565 Sterrett Place, Suite 310
Columbia, MD 21044
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F. Diego Rivas
NW Energy Coalition
1101 8th Ave. Helena, MT 59601
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_____________________________________
ERIC L. OLSEN