20230912IPC to IIPA 1-14.pdf

LISA D. NORDSTROM
Lead Counsel
[e-mail]

September 12, 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
Idaho Irrigation Pumpers Association, Inc.’s First Set of Data Requests 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
Tuesday, September 12, 2023 3:49:12 PM
IDAHO PUBLIC
UTILITIES COMMISSION

CERTIFICATE OF ATTORNEY

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

The undersigned attorney, in accordance with Commission Rules of Procedure 67,
believes that the Attachments in Response to Request Nos. 1-2 and 1-10 to Idaho Power
Company’s Response to Idaho Irrigation Pumpers Association, Inc.’s First Set of Data
Requests dated September 12, 2023, contain information that Idaho Power Company
and a third party claim are trade secrets, business records of a private enterprise required
by law to be submitted to or inspected by a public agency, and/or public records exempt
from disclosure by state or federal law (material nonpublic information under U.S.
Securities and Exchange Commission Regulation FD) 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 12th day of September, 2023.

LISA D. NORDSTROM
Counsel for Idaho Power Company

IDAHO POWER COMPANY’S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S
FIRST SET OF DATA REQUESTS - 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 IDAHO
IRRIGATION PUMPERS
ASSOCIATION, INC.’S FIRST SET
OF DATA REQUESTS

COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), and in
response to Idaho Irrigation Pumpers Association, Inc. (“IIPA”) First Set of Data Requests
dated August 22, 2023, herewith submits the following information:

IDAHO POWER COMPANY’S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S
FIRST SET OF DATA REQUESTS - 2
REQUEST FOR PRODUCTION NO. 1-1: Please provide hourly loads by schedule
from January 1, 2018 to present. Please indicate if these data represent load at the
generator or at the customer’s meter. Please provide such data separately for each
jurisdiction.
RESPONSE TO REQUEST FOR PRODUCTION NO. 1-1: Please see
Attachments 1 and 2 provided with this response for hourly load by rate schedule from
1/1/2018 to 7/31/2023 for Idaho and Oregon jurisdictions, respectively. Please see
Attachment 3 for a description of rate schedules.
All data is at the customer meter. Unmetered and monthly-read meter data is not
included. The values have not been adjusted for demand response. Note, the data for
customer generation rate schedules represents ‘net hourly’ data, where negative values
are net exports and positive values are net consumption.
The response to this Request is sponsored by Jordan Prassinos, Manager Load
Forecast and Principal Economist, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S
FIRST SET OF DATA REQUESTS - 3
REQUEST FOR PRODUCTION NO. 1-2: Please provide all billing determinants
used to calculate customer bills, by schedule and month, from January, 2018 to present.
Please provide such data separately for each jurisdiction.
RESPONSE TO REQUEST FOR PRODUCTION NO. 1-2: Please see the
confidential attachment provided with this response.
The response to this Request is sponsored by Jessi Brady, Regulatory Analyst,
Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S
FIRST SET OF DATA REQUESTS - 4
REQUEST FOR PRODUCTION NO. 1-3: Please provide forecasted hourly loads
by schedule for the test year and 2024. Please include all workpapers, models, and
source data used to forecast these loads. Please provide such data separately for each
jurisdiction.
RESPONSE TO REQUEST FOR PRODUCTION NO. 1-3: The Company’s hourly
load forecast is not produced by rate schedule but rather by rate class. Therefore, the
Company has provided the hourly load forecast by rate class for 2023 and 2024 in
Attachment 1 included with this response.
The table below details several attachments provided in response to Staff
Production Request Nos. 75, 77, and 79. These attachments include the monthly sales
forecast models that are used as the basis of the hourly forecast process. In addition, a
mnemonics key for the explanatory variables is provided in Attachment 7 of Staff
Production Request No. 75.
Sales Forecast Models Request Attachment
Residential Staff 77 ttachment 1
Irri ation Staff 75 ttachment 3
Commercial Services Staff 79 ttachment 1
Commercial Manufacturin Staff 79 ttachment 2
Industrial Manufacturin Staff 79 ttachment 3
Industrial Services Staff 79 ttachment 4
Lar e Commercial Manufacturin Staff 79 ttachment 5
Lar e Commercial Services Staff 79 ttachment 6

The models used to develop the hourly forecast are kept in specific regression
software and, therefore, are not provided with this response. However, a written narrative
is supplied below on how the hourly models are structured. It is important to note the
hourly load forecast methodology described below allocates the monthly model
regressions, referenced in the table above, to each hour of the year.

IDAHO POWER COMPANY’S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S
FIRST SET OF DATA REQUESTS - 5
An industry approach to weather responsiveness is to utilize a linear model based
on a heating degree day (“HDD”) or cooling degree day (“CDD”) level of 65 degrees
Fahrenheit (°F) (actual point may differ by local utility weather characteristics). Utilities
will also often use splines in regression equations to define the weather function to reflect
the change of slope as the average daily temperature moves away from the 65°F mark
and there is less weather responsiveness. This methodology works well by minimizing
the potential of overfitting. Building on this framework, Idaho Power uses a non-linear
approach, wherein the derivative or local slope of a curve is calculated at each instance
along the weather responsiveness curve.
The model design adopted by Idaho Power outputs a single series of hourly energy
with only one hidden layer that contains two nodes (H1 and H2) representing the heating
and cooling effects along the sales curve. Each of the H1 and H2 nodes uses a logistic
activation function with a linear function applied, where impacts of the calendar (weekend,
weekday, holidays, etc.) can be captured.
A distinct model is developed for each hour of the year to capture the full spectrum
of temperature responsiveness. For each non-linear hourly model, an instantaneous
derivative value is calculated along the curve to obtain the relationship of energy sales to
temperature.
A typical meteorological year is developed using a rolling 30 years of weather
history within Idaho Power’s service area. The Company does a rank and average of the
daily temperature within a month from hottest to coldest, averaging the daily temperature
for each rank across years. The result is an appropriate representation of severe,
moderate, and mild daily temperatures for each month. The Company uses the ranked

IDAHO POWER COMPANY’S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S
FIRST SET OF DATA REQUESTS - 6
and averaged typical weather by month and reorders days based on a typical weather
pattern.
The response to this Request is sponsored by Jordan Prassinos, Manager Load
Forecast and Principal Economist, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S
FIRST SET OF DATA REQUESTS - 7
REQUEST FOR PRODUCTION NO. 1-4: Please provide all forecasted billing
determinants used to calculate customer bills, by schedule and month, for the test year
and for 2024. Please provide all workpapers, models, and source data used to forecast
these loads. Please provide such data separately for each jurisdiction.
RESPONSE TO REQUEST FOR PRODUCTION NO. 1-4: For the 2023 test year,
please see Brady Workpapers 1 and 2 for current and proposed billing determinants by
schedule and month. Because Idaho Power developed a 2023 test year in this filing, it
did not calculate billing determinants for 2024.
The response to this Request is sponsored by Jessi Brady, Regulatory Analyst,
Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S
FIRST SET OF DATA REQUESTS - 8
REQUEST FOR PRODUCTION NO. 1-5: Please refer to Exhibit No. 35 - JSS -
2023 Test Year.xlsx.
a. Please provide the source for hard coded numbers in column F and provide all
supporting workpapers.
b. Please provide the source for hard coded numbers in cells G1048 to H1096. Please
provide all supporting workpapers.
RESPONSE TO REQUEST FOR PRODUCTION NO. 1-5:
a. The hard coded values in column “F” are copy and pasted from Exhibit 34,
column “J” and the source of the values that make up column “J” is provided in
response to IIPA 1-7.
b. The source for the hard coded numbers in cells G1048 to H1096 can be found in
the workpapers provided by Company witness Ms. Kelley Noe and references to
the source of each allocation factor is provided below.
 Rows 1048 to 1051 can be found in the workpaper titled “2023 TY
Demand Allocator.”
 Rows 1054-1055 can be found in the workpaper titled “2023 TY Demand
Allocator.”
 Row 1058 can be found in the workpaper titled “ACCT902_2022.”
 Row 1059 can be found in the workpaper titled “ACCT903_2022.”
 Row 1060 can be found in the workpaper titled “2022 Account 904
Jurisdictionalized.”
 Row 1061 can be found in the workpaper titled “2022 Form 1 – Pg.
304_Brady.”
 Row 1065 can be found in the workpaper titled “CUSTADV_2022.”
 Row 1066 through 1087 can be found in the workpaper titled “2022 Plant
Book Allocation Factors.”
 1088 and 1089 can be found in the workpaper titled “2022 Other
Revenues ID and OR Combo.”
 1090 can be found in the workpaper titled “DA908_2022.”
 1091 can be found in the workpaper titled “Brady Exhibit 27 – Summary of
Retail Revenues.”

IDAHO POWER COMPANY’S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S
FIRST SET OF DATA REQUESTS - 9
 1092-1096 utilize a 1 or a 0 to indicate a 100 percent or 0 percent
assignment to either Idaho or Oregon.
The response to this Request is sponsored by Kelley Noe, Regulatory Consultant,
Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S
FIRST SET OF DATA REQUESTS - 10
REQUEST FOR PRODUCTION NO. 1-6: Please refer to Exhibit No. 31 - Major
Plant Additions Annualized for 2023.xlsx. Please provide the source for hard coded
numbers in columns F, N, and R and provide all supporting workpapers.
RESPONSE TO REQUEST FOR PRODUCTION NO. 1-6: Please refer to
Attachment 1-IIPA Request 1-6 Major Projects for the source of the numbers in column F
of Exhibit No. 31. Please refer to Attachment 2-IIPA Request 1-6 Composite Property Tax
Rates for the source of the annual property tax rates in column N. Please refer to
Attachment 3-IIPA Request 1-6 Property Insurance Rate for the source of the annual
insurance rates in column R.
The response to this Request is sponsored by Paula Jeppsen, Forecasting and
Planning Director, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S
FIRST SET OF DATA REQUESTS - 11
REQUEST FOR PRODUCTION NO. 1-7: Please refer to Exhibit No. 34 -
Development of System Revenue Requirement 2023 Test Year.xlsx. Please provide the
source for hard coded numbers in columns D, E, F, G, H, and I and provide all supporting
workpapers.
RESPONSE TO REQUEST FOR PRODUCTION NO. 1-7: The majority of the data
presented within Exhibit 34 was provided by Ms. Jeppsen and can be found in Jeppsen
Exhibits 22-24 and within the filed workpapers provided by Ms. Noe. Written details of the
2022 actual adjustments (column E) are described in Ms. Jeppsen’s testimony, the written
details of the test year forecast methodology (column G) can be found in Mr. Larkin’s
testimony and Exhibit 26, and annualizing adjustments (column I) are described in Ms.
Noe’s testimony. The full breadth of workpapers used by Ms. Noe to prepare Exhibit 34
are provided as a PDF attachment to this request and the notes below provide guidance
on Ms. Jeppsen’s exhibits and Ms. Noe’s filed Excel workpapers and how they were used
to develop Exhibit 34.
 Exhibit 22 is formatted similarly to Exhibit 34 with the same data column titles as
follows:

D: 2022 Actual
E: 2022 Actual Adjustments
F: 2022 Base
G: Forecast Adjustment
H: 2023 Unadjusted Test Year
I: Annualizing Adjustment

 Exhibit 22 provides the data for all columns listed above for Tables 1, 2, 3, 4, 5,
6, 7, 8 and the Summary table inputs of Exhibit 34. This information was also
provided in a workpaper by Ms. Noe titled “Exhibits 2023 Idaho.”

 Please note that the detailed tax workpapers for column G of Tables 9, 10, 11
and 12 were inadvertently missing in the initial filed workpapers for Ms. Noe but
are included within the PDF attachment to this request (PDF pages 63-70).

IDAHO POWER COMPANY’S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S
FIRST SET OF DATA REQUESTS - 12
 The detailed workpaper for column G of Table 1 (Electric Plant in Service) is
titled “EPIS 2023 Forecast.”

 The detailed workpapers for columns E, H and I of Table 2 (Accumulated
Provision for Depreciation) are titled “2022 Accum Reserve for Dept Adjusted for
Steam_Remove Bridger Valmy” and the tabs labeled Accumulated Reserve and
Annualizing Adjustment within the file titled “Depreciation and Amortization
Annualizing Adj.”

 The detailed workpaper for Columns D, H and I of Table 6 (Depreciation and
Amortization Expense) is included on tabs labeled Expense and Annualizing
Adjustment within the file titled “Depreciation and Amortization Annualizing Adj.”

 The 2022 Base (column F) net power supply expense (“NPSE”) accounts reflect
the 2013 base NPSE and that workpaper is titled “2013 Base NPSE” and the
Forecast Adjustment/2023 Unadjusted Test Year (columns G and H) NPSE
amounts are provided in workpaper titled “Base NPSE 2023 Test Year” and
“Demand Response 2023 TY Amount.”

 Annualizing adjustments (column I) for both major plant additions and payroll
were included as Exhibits 31 and 33 to Ms. Noe’s testimony. Major plant
additions impacted Table 1, 2, 5 and 6 of Exhibit 34. Payroll annualizing
adjustments were spread over 2022 labor related operations and maintenance
expense accounts and impacted Table 5 of Exhibit 34.

 The detailed interest sync workpaper is titled “Interest Synchronization.”

 The Valmy and Bridger levelized Revenue Requirement workpaper is titled
“Valmy and Bridger Levelized Revenue Requirement.”

 The detailed workpaper for the normalized incentive for the adjustment in
account 920, column E and G is titled “Incentive Normalized 2023 TY.”

The response to this Request is sponsored by Kelley Noe, Regulatory Consultant,
Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S
FIRST SET OF DATA REQUESTS - 13
REQUEST FOR PRODUCTION NO. 1-8: Please refer to Exhibit No. 33 -
Summary of Payroll-Related Annualizing Adjustments.xlsx.
a. Please refer to sheet 2022 Actual Payroll-SourcePg1. Please provide this data for
2019, 2020, and 2021.
b. Please provide the basis for the salary adjustment in sheet Payroll-Source Page A
cell k22 and identify all such similar adjustments made in 2019 through 2023.
c. Please refer to sheet Payroll Tax-Source Pg2. Please provide this data by month
from January, 2019 to present.
RESPONSE TO REQUEST FOR PRODUCTION NO. 1-8:
a. Please refer to Attachment 1-Response to IIPA Request 1-8, tab labeled 1-8a.
b. The basis for the salary adjustment in sheet Payroll-Source Page A cell k22 is an
estimate for the 2024 general wage adjustment (“GWA”) that will be effective
December 23, 2023. Please refer to Idaho Power’s response to Idaho Public
Utilities Commission Staff Request for Production No. 250 for historical GWA
amounts.
c. Please refer to Attachment 1-Response to IIPA Request 1-8, tab labeled 1-8c.
The response to this Request is sponsored by Paula Jeppsen, Forecasting and
Planning Director, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S
FIRST SET OF DATA REQUESTS - 14
REQUEST FOR PRODUCTION NO. 1-9: Please provide the following information
for all generation resources:
a. Name of resource
b. Type of resource
c. Nameplate Capacity
d. Generation by hour from January 2019 to present
e. Net plant in service
f. For other production resources, whether the resource is considered a baseload
resource or peaker resource for purpose of cost functionalization and
classification.
RESPONSE TO REQUEST FOR PRODUCTION NO. 1-9:
a - e. Please see Attachment – Response to IIPA’s Request No. 1-9 which includes
the name, type, nameplate capacity, hourly generation from January 1, 2019 –
June 30, 2023, and net plant-in-service as of December 31, 2022, for each of the
Company’s generation resources.
f. Other Production, FERC Accounts 340-346, includes the Company’s three natural
gas-fueled generation plants, Bennett Mountain, Danskin, and Langley Gulch,
and the Salmon diesel generation plant. In the Company’s 2023 general rate case
class cost-of-service (“CCOS”) study, all non-PURPA and non-PPA generation
resources are considered base and intermediate load serving, except for the
Bennett Mountain and Danskin simple cycle combustion turbines, and the Salmon
diesel five-megawatt (“MW”) reciprocating engine, which are peak-load serving
resources. Costs for Other Production are split into separate rows in both the

IDAHO POWER COMPANY’S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S
FIRST SET OF DATA REQUESTS - 15
Jurisdictional Separation Study and the CCOS, such that Bennett Mountain,
Danskin, and Salmon diesel are grouped together and follow cost allocation for
peak-load serving generation plant, with Langley Gulch costs listed independently
to allow for cost allocation for base and intermediate load serving generation
plant.
See Goralski Exhibit No. 36, pages 5-7, for description of production plant cost
allocation.
Idaho Power notes, while this production request specifically requests information
for generating plant, the cost of the 120 MW of battery storage recorded under
FERC account 363 in the 2023 test year is also functionalized and classified as
other production-baseload-100 percent capacity, like Langley Gulch. However,
the revenue requirement associated with the storage resources is ultimately offset
from the Company’s request in this case by the inclusion of the storage
accumulated deferred investment tax credits (“ADITC”) mitigation measure
described in Mr. Tatum’s testimony.
The response to this Request is sponsored by Paul Goralski, Regulatory
Consultant, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S
FIRST SET OF DATA REQUESTS - 16
REQUEST FOR PRODUCTION NO. 1-10: Please provide the company’s market
energy transactions from January 1, 2019 to present. Please provide the data at the most
granular level available and include an information that is normally maintained regarding
these transactions, including but not limited to delivery hour, direction, quantity, and price.
RESPONSE TO REQUEST FOR PRODUCTION NO. 1-10: Please see the
confidential attachment provided with this response, which includes all bilateral market
physical energy transactions from January 1, 2019 – June 30, 2023.
The response to this Request is sponsored by Camille Christen, Resource
Acquisition, Planning and Coordination Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S
FIRST SET OF DATA REQUESTS - 17
REQUEST FOR PRODUCTION NO. 1-11: Please refer to Exhibit No. 38-43 -
Series of Goralski Testimony Exhibits.xlsx. Please provide the source and all supporting
worksheets for the data in sheets “Tax Alloc” and “Alloc Factor Input”.
RESPONSE TO REQUEST FOR PRODUCTION NO. 1-11: Please see the
attachment for this response, which lists the Goralski exhibits and workpapers previously
provided and are the source documents for the data in the “Tax Alloc” and “Alloc Factor
Input” worksheets that do not contain cell references to source workpapers.
The response to this Request is sponsored by Paul Goralski, Regulatory
Consultant, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S
FIRST SET OF DATA REQUESTS - 18
REQUEST FOR PRODUCTION NO. 1-12: Please refer to Exhibit No. 37 -
Functionalization and Classification of Costs.xlsx.
a. Please explain why the company functionalizes 100 percent of production plant in
service to demand and none to energy.
b. Please provide the source for hard coded numbers in rows 913 to 936 and provide
all supporting workpapers.
RESPONSE TO REQUEST FOR PRODUCTION NO. 1-12:
a. As described in Goralski DI,1 the Company is proposing to use a more “accounting-
like” fixed cost versus variable cost approach to classifying generation plant costs
between energy and capacity. Costs that are fixed in nature, those that do not vary
on a year-to-year based on customer energy consumption, are considered fixed,
and those that vary from customer energy consumption in a duration of a year or
less, such as fuel expense, are considered variable. Classifying production plant
as 100 percent demand recognizes the portions of the Company’s costs that do
not generally vary through those changes in customer system utilization on a year-
to-year basis and aligns rate design price signals to encourage wise and efficient
use of energy.
b. Supporting workpapers were previously provided by Idaho Power and may be
accessed through the FTP site. The source of values is as follows:
Exhibit No. 37 Rows Source Source Rows
914-925 Goralski Workpaper 14 – DA360-2 PLANT 20-21; 40-41
926-933 Goralski Workpaper 2 – ACCT364_7 15-16; 27-28
934-935 Goralski Workpaper 2 – ACCT368 23-24; 34

1 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, Goralski DI p. 10.

IDAHO POWER COMPANY’S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S
FIRST SET OF DATA REQUESTS - 19
The response to this Request is sponsored by Paul Goralski, Regulatory
Consultant, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S
FIRST SET OF DATA REQUESTS - 20
REQUEST FOR PRODUCTION NO. 1-13: Please refer to the Direct Testimony of
Pawel P. Goralski page 10 lines 15 to 21.
a. Please provide the definition of fixed and variable costs used in this testimony.
b. Please also refer to page 6 lines 6 to 10. Does the Electric Utility Cost Allocation
Manual recommend classifying demand and energy costs based on fixed and
variable costs? If yes, please provide page citations to such recommendations.
RESPONSE TO REQUEST FOR PRODUCTION NO. 1-13:
a. Variable production costs are those that generally vary directly with customer
energy consumption over a period of less than a year; and fixed costs are those
that do not vary based on short-term, less than a year, customer energy
consumption.
b. Classifying production plant costs as either fixed or variable is one of the two ways
listed in the NARUC Electric Utility Cost Allocation Manual on page 35 as the Cost
Accounting Approach:

IDAHO POWER COMPANY’S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S
FIRST SET OF DATA REQUESTS - 21

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

IDAHO POWER COMPANY’S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S
FIRST SET OF DATA REQUESTS - 22
REQUEST FOR PRODUCTION NO. 1-14: Please provide the company’s CCOS
filed in its last general rate case.
RESPONSE TO REQUEST FOR PRODUCTION NO. 1-14: Please see the eight
attachments provided for this request. The Company clarified with IIPA on August 23,
2023, that it completed a supplemental CCOS study using the 2023 test year data, but
under a similar methodology basis as the 2011 general rate case CCOS, described in
Goralski testimony, page 22, with summary results included in Goralski Exhibit No. 47.
IIPA requested to receive both the 2011 CCOS study filed in IPC-E-11-08, and the 2023
CCOS study completed using methodology consistent with the 2011 GRC methodology.
The response to this Request is sponsored by Paul Goralski, Regulatory
Consultant, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S
FIRST SET OF DATA REQUESTS - 23
DATED at Boise, Idaho, this 12th 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 IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S
FIRST SET OF DATA REQUESTS - 24
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the 12th day of September 2023, I served a true and
correct copy of Idaho Power Company’s Response to Idaho Irrigation Pumpers
Association, Inc.’s First Set of Data Requests 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 IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S
FIRST SET OF DATA REQUESTS - 25
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

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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 IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S
FIRST SET OF DATA REQUESTS - 26
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.
Washin ton, DC 20585
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IDAHO POWER COMPANY’S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S
FIRST SET OF DATA REQUESTS - 27
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