20230914IPC to Staff 283-297.pdf

LISA D. NORDSTROM
Lead Counsel
[e-mail]

September 14, 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 Eighteenth 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
Thursday, September 14, 2023 2:26:43 PM
IDAHO PUBLIC
UTILITIES COMMISSION

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

COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), and in
response to the Eighteenth Production Request of the Commission Staff (“Commission”
or “Staff”) dated September 7, 2023, herewith submits the following information:

IDAHO POWER COMPANY’S RESPONSE TO THE EIGHTEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 2
REQUEST FOR PRODUCTION NO. 283: According to the Company's response
to Staff's Production Request No. 35 (Confidential Attachment 1-Response to Staff
Request No. 35), the total actual (Jan 2012 thru May 2023) amount for Budget ID -
RELC220001 - Line Relocations for ITD Extension of SH-16 from Chinden (SH-20/26) to
I-84, is significantly over the total budget amount. Please provide the following
information:
a. Overall and year-by-year budget-to-actual comparisons;
b. A baseline schedule-to-actual schedule comparison; and
c. A list and a detailed explanation of all the specific reasons that the actual cost
exceeded the budgeted amount and the cost impact of each reason.
RESPONSE TO REQUEST FOR PRODUCTION NO. 283:
a. Please see Attachment – Response to Staff Request No. 283. The first tab, titled
All Projects, presents a year-by-year budget to actuals comparison for each of the
projects identified in Staff’s Request for Production Nos. 283 through 297. Each
subsequent tab presents the individual projects for which the budget-to-actuals
comparison was requested and includes a detailed explanation of the reason for
the variances.
b. Baseline schedule comparisons to actual schedule delivery is not compared due
to the ever-changing landscape of the entire portfolio of capital projects. Rather,
projects are managed in real-time, and schedules are constantly monitored in
comparison to the entire portfolio of projects to manage timeline and execution
strategy, in conjunction with all other capital project needs. Project schedules are
updated at least monthly for resource leaders to evaluate planned work across the

IDAHO POWER COMPANY’S RESPONSE TO THE EIGHTEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 3
matrixed organization. Variances in budget forecasts are also constantly evaluated
and monitored within the overall portfolio of projects.
c. See the tab titled RELC220001 of the Attachment – Response to Staff Request
No. 283 for the detailed explanation of the variances between budget and actuals.
The response to this Request is sponsored by Mitch Colburn, Vice President of
Planning, Engineering and Construction, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE EIGHTEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 4
REQUEST FOR PRODUCTION NO. 284: According to the Company's response
to Staff's Production Request No. 35 (Confidential Attachment 1-Response to Staff
Request No. 35), the total actual (Jan 2012 thru May 2023) amount for Budget ID -
ELDRl90001 - ELDR Construct two new 12.5-kV feeder ELDR-012 and ELDR-013, is
significantly over the total budget amount. Please provide the following information:
a. Overall and year-by-year budget-to-actual comparisons;
b. A baseline schedule-to-actual schedule comparison; and
c. A list and a detailed explanation of all the specific reasons that the actual cost
exceeded the budgeted amount and the cost impact of each reason.
RESPONSE TO REQUEST FOR PRODUCTION NO. 284:
a. See part (a) to the Company’s Response to Request for Production No. 283.
b. See part (b) to the Company’s Response to Request for Production No. 283.
c. See the tab titled ELDRl90001 of the Attachment – Response to Staff Request No.
283 for the detailed explanation of the variances between budget and actuals.
The response to this Request is sponsored by Mitch Colburn, Vice President of
Planning, Engineering and Construction, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE EIGHTEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 5
REQUEST FOR PRODUCTION NO. 285: According to the Company's response
to Staff's Production Request No. 35 (Confidential Attachment 1-Response to Staff
Request No. 35), the total actual (Jan 2012 thru May 2023) amount for Budget ID -
T423120001 - T423 Ontario-Quartz 138kV Line - FAC008 Compliance, is significantly
over the total budget amount. Please provide the following information:
a. Overall and year-by-year budget-to-actual comparisons;
b. A baseline schedule-to-actual schedule comparison; and
c. A list and a detailed explanation of all the specific reasons that the actual cost
exceeded the budgeted amount and the cost impact of each reason.
RESPONSE TO REQUEST FOR PRODUCTION NO. 285:
a. See part (a) to the Company’s Response to Request for Production No. 283.
b. See part (b) to the Company’s Response to Request for Production No. 283.
c. See the tab titled T423120001 of the Attachment – Response to Staff Request No.
283 for the detailed explanation of the variances between budget and actuals.
The response to this Request is sponsored by Mitch Colburn, Vice President of
Planning, Engineering and Construction, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE EIGHTEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 6
REQUEST FOR PRODUCTION NO. 286: According to the Company's response
to Staff's Production Request No. 35 (Confidential Attachment 1-Response to Staff
Request No. 35), the total actual (Jan 2012 thru May 2023) amount for Budget ID -
T216150001 - T216 Rebuild 69-kV Line T216 from Brownlee to Halfway- approx. ten
miles, is significantly over the total budget amount. Please provide the following
information:
a. Overall and year-by-year budget-to-actual comparisons;
b. A baseline schedule-to-actual schedule comparison; and
c. A list and a detailed explanation of all the specific reasons that the actual cost
exceeded the budgeted amount and the cost impact of each reason.
RESPONSE TO REQUEST FOR PRODUCTION NO. 286:
a. See part (a) to the Company’s Response to Request for Production No. 283.
b. See part (b) to the Company’s Response to Request for Production No. 283.
c. See the tab titled T216150001 of the Attachment – Response to Staff Request No.
283 for the detailed explanation of the variances between budget and actuals.
The response to this Request is sponsored by Mitch Colburn, Vice President of
Planning, Engineering and Construction, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE EIGHTEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 7
REQUEST FOR PRODUCTION NO. 287: According to the Company's response
to Staff's Production Request No. 35 (Confidential Attachment 1-Response to Staff
Request No. 35), the total actual (Jan 2012 thru May 2023) amount for Budget ID -
T4040401 - T404 ZLOG-CADA Build/rebuild to 138-kV from ZLOG to new CADA
substation, is significantly over the total budget amount. Please provide the following
information:
a. Overall and year-by-year budget-to-actual comparisons;
b. A baseline schedule-to-actual schedule comparison; and
c. A list and a detailed explanation of all the specific reasons that the actual cost
exceeded the budgeted amount and the cost impact of each reason.
RESPONSE TO REQUEST FOR PRODUCTION NO. 287:
a. See part (a) to the Company’s Response to Request for Production No. 283.
b. See part (b) to the Company’s Response to Request for Production No. 283.
c. See the tab titled T4040401 of the Attachment – Response to Staff Request No.
283 for the detailed explanation of the variances between budget and actuals.
The response to this Request is sponsored by Mitch Colburn, Vice President of
Planning, Engineering and Construction, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE EIGHTEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 8
REQUEST FOR PRODUCTION NO. 288: According to the Company's response
to Staff's Production Request No. 35 (Confidential Attachment 1-Response to Staff
Request No. 35), the total actual (Jan 2012 thru May 2023) amount for Budget ID -
T4791101 - T479 BOMT-HPVY Build 138 kV line, is significantly over the total budget
amount. Please provide the following information:
a. Overall and year-by-year budget-to-actual comparisons;
b. A baseline schedule-to-actual schedule comparison; and
c. A list and a detailed explanation of all the specific reasons that the actual cost
exceeded the budgeted amount and the cost impact of each reason.
RESPONSE TO REQUEST FOR PRODUCTION NO. 288:
a. See part (a) to the Company’s Response to Request for Production No. 283.
b. See part (b) to the Company’s Response to Request for Production No. 283.
c. See the tab titled T4791101 of the Attachment – Response to Staff Request No.
283 for the detailed explanation of the variances between budget and actuals.
The response to this Request is sponsored by Mitch Colburn, Vice President of
Planning, Engineering and Construction, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE EIGHTEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 9
REQUEST FOR PRODUCTION NO. 289: According to the Company's response
to Staff's Production Request No. 35 (Confidential Attachment 1-Response to Staff
Request No. 35), the total actual (Jan 2012 thru May 2023) amount for Budget ID -
NEWX170001 - NEWX - Reconstruct 138-kV CDAL-HBRD T438 line to add a 230-kV
circuit and double circuit distribution underbuild, is significantly over the total budget
amount. Please provide the following information:
a. Overall and year-by-year budget-to-actual comparisons;
b. A baseline schedule-to-actual schedule comparison; and
c. A list and a detailed explanation of all the specific reasons that the actual cost
exceeded the budgeted amount and the cost impact of each reason.
RESPONSE TO REQUEST FOR PRODUCTION NO. 289:
a. See part (a) to the Company’s Response to Request for Production No. 283.
b. See part (b) to the Company’s Response to Request for Production No. 283.
c. See the tab titled NEWX170001 of the Attachment – Response to Staff Request
No. 283 for the detailed explanation of the variances between budget and actuals.
The response to this Request is sponsored by Mitch Colburn, Vice President of
Planning, Engineering and Construction, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE EIGHTEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 10
REQUEST FOR PRODUCTION NO. 290: According to the Company's response
to Staff's Production Request No. 35 (Confidential Attachment 1-Response to Staff
Request No. 35), the total actual (Jan 2012 thru May 2023) amount for Budget ID -
ELDRl80002 - ELDR New distribution station in central Pocatello, is significantly over the
total budget amount. Please provide the following information:
a. Overall and year-by-year budget-to-actual comparisons;
b. A baseline schedule-to-actual schedule comparison; and
c. A list and a detailed explanation of all the specific reasons that the actual cost
exceeded the budgeted amount and the cost impact of each reason.
RESPONSE TO REQUEST FOR PRODUCTION NO. 290:
a. See part (a) to the Company’s Response to Request for Production No. 283.
b. See part (b) to the Company’s Response to Request for Production No. 283.
c. See the tab titled ELDRl80002 of the Attachment – Response to Staff Request No.
283 for the detailed explanation of the variances between budget and actuals.
The response to this Request is sponsored by Mitch Colburn, Vice President of
Planning, Engineering and Construction, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE EIGHTEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 11
REQUEST FOR PRODUCTION NO. 291: According to the Company's response
to Staff's Production Request No. 35 (Confidential Attachment 1-Response to Staff
Request No. 35), the total actual (Jan 2012 thru May 2023) amount for Budget ID -
HBNDl101 - HBND Create alternate 35 kV route to Garden Valley, is significantly over
the total budget amount. Please provide the following information:
a. Overall and year-by-year budget-to-actual comparisons;
b. A baseline schedule-to-actual schedule comparison; and
c. A list and a detailed explanation of all the specific reasons that the actual cost
exceeded the budgeted amount and the cost impact of each reason.
RESPONSE TO REQUEST FOR PRODUCTION NO. 291:
a. See part (a) to the Company’s Response to Request for Production No. 283.
b. See part (b) to the Company’s Response to Request for Production No. 283.
c. See the tab titled HBNDl101 of the Attachment – Response to Staff Request No.
283 for the detailed explanation of the variances between budget and actuals.
The response to this Request is sponsored by Mitch Colburn, Vice President of
Planning, Engineering and Construction, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE EIGHTEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 12
REQUEST FOR PRODUCTION NO. 292: According to the Company's response
to Staff's Production Request No. 35 (Confidential Attachment 1-Response to Staff
Request No. 35), the total actual (Jan 2012 thru May 2023) amount for Budget ID -
SKWYl80001 - SKWY New Skyway distribution substation northwest of Caldwell
Industrial Airport, is significantly over the total budget amount. Please provide the
following information:
a. Overall and year-by-year budget-to-actual comparisons;
b. A baseline schedule-to-actual schedule comparison; and
c. A list and a detailed explanation of all the specific reasons that the actual cost
exceeded the budgeted amount and the cost impact of each reason.
RESPONSE TO REQUEST FOR PRODUCTION NO. 292:
a. See part (a) to the Company’s Response to Request for Production No. 283.
b. See part (b) to the Company’s Response to Request for Production No. 283.
c. See the tab titled SKWYl80001 of the Attachment – Response to Staff Request
No. 283 for the detailed explanation of the variances between budget and actuals.
The response to this Request is sponsored by Mitch Colburn, Vice President of
Planning, Engineering and Construction, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE EIGHTEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 13
REQUEST FOR PRODUCTION NO. 293: According to the Company's response
to Staff's Production Request No. 35 (Confidential Attachment 1-Response to Staff
Request No. 35), the total actual (Jan 2012 thru May 2023) amount for Budget ID -
VARIl30001 - VARI Replace communications multiplex equipment, is significantly over
the total budget amount. Please provide the following information:
a. Overall and year-by-year budget-to-actual comparisons;
b. A baseline schedule-to-actual schedule comparison; and
c. A list and a detailed explanation of all the specific reasons that the actual cost
exceeded the budgeted amount and the cost impact of each reason.
RESPONSE TO REQUEST FOR PRODUCTION NO. 293:
a. See part (a) to the Company’s Response to Request for Production No. 283.
b. See part (b) to the Company’s Response to Request for Production No. 283.
c. See the tab titled VARIl30001 of the Attachment – Response to Staff Request No.
283 for the detailed explanation of the variances between budget and actuals.
The response to this Request is sponsored by Mitch Colburn, Vice President of
Planning, Engineering and Construction, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE EIGHTEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 14
REQUEST FOR PRODUCTION NO. 294: According to the Company's response
to Staff's Production Request No. 35 (Confidential Attachment 1-Response to Staff
Request No. 35), the total actual (Jan 2012 thru May 2023) amount for Budget ID -
B09900124 - Western UG New Business, is significantly over the total budget amount.
Please provide the following information:
a. Overall and year-by-year budget-to-actual comparisons;
b. A baseline schedule-to-actual schedule comparison; and
c. A list and a detailed explanation of all the specific reasons that the actual cost
exceeded the budgeted amount and the cost impact of each reason.
RESPONSE TO REQUEST FOR PRODUCTION NO. 294:
a. – c. See part (a) to the Company’s Response to Request for Production No. 283.
Budget ID - B09900124 - Western UG New Business is a blanket budget ID that
is used when creating work orders associated with customer requests for
underground new business service in Idaho Power’s Western region area. A
budget ID of this nature can be comprised of hundreds or thousands of individual
work orders, each associated with a customer request for new underground
service. Because the Company is responding to new business customer requests
as they are received, there is no long-term or multi-year schedule for the work to
be completed, rather the Company administers these requests for service under
Rule H of its Commission-approved tariff. During each budget cycle, when the
budget amount for this budget ID is established, Idaho Power estimates the costs
associated with underground new business service requests by evaluating
historical activity (typically the prior one to three years), and then factoring in

IDAHO POWER COMPANY’S RESPONSE TO THE EIGHTEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 15
growth and inflationary assumptions. Variances occur when the number of
customer requests deviates from prior year growth projections or the actual costs
associated with new business requests are different than the estimate arrived at
during the previous year when establishing budget amounts.
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 EIGHTEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 16
REQUEST FOR PRODUCTION NO. 295: According to the Company's response
to Staff's Production Request No. 35 (Confidential Attachment 1-Response to Staff
Request No. 35), the total actual (Jan 2012 thru May 2023) amount for Budget ID -
VARIDEQUIP - VARI - Region Distribution Line Equipment Planned Reconstruction, is
significantly over the total budget amount. Please provide the following information:
a. Overall and year-by-year budget-to-actual comparisons;
b. A baseline schedule-to-actual schedule comparison; and
c. A list and a detailed explanation of all the specific reasons that the actual cost
exceeded the budgeted amount and the cost impact of each reason.
RESPONSE TO REQUEST FOR PRODUCTION NO. 295:
a. See part (a) to the Company’s Response to Request for Production No. 283.
b. See part (b) to the Company’s Response to Request for Production No. 283.
c. See the tab titled VARIDEQUIP of the Attachment – Response to Staff Request
No. 283 for the detailed explanation of the variances between budget and actuals.
The response to this Request is sponsored by Mitch Colburn, Vice President of
Planning, Engineering and Construction, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE EIGHTEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 17
REQUEST FOR PRODUCTION NO. 296: According to the Company's response
to Staff's Production Request No. 35 (Confidential Attachment 1-Response to Staff
Request No. 35), the total actual (Jan 2012 thru May 2023) amount for Budget ID -
B00900276 - Lower Salmon #4 Turbine Refurbishment, is significantly over the total
budget amount. Please provide the following information:
a. Overall and year-by-year budget-to-actual comparisons;
b. A baseline schedule-to-actual schedule comparison; and
c. A list and a detailed explanation of all the specific reasons that the actual cost
exceeded the budgeted amount and the cost impact of each reason.
RESPONSE TO REQUEST FOR PRODUCTION NO. 296:
a. See part (a) to the Company’s Response to Request for Production No. 283.
b. See part (b) to the Company’s Response to Request for Production No. 283.
c. See the tab titled B00900276 of the Attachment – Response to Staff Request No.
283 for the detailed explanation of the variances between budget and actuals.
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 EIGHTEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 18
REQUEST FOR PRODUCTION NO. 297: According to the Company's response
to Staff's Production Request No. 35 (Confidential Attachment 1-Response to Staff
Request No. 35), the total actual (Jan 2012 thru May 2023) amount for Budget ID -
CHQBl60049- BSPO U3 Kaplan Turbine and Generator Refurbishment, is significantly
over the total budget amount. Please provide the following information:
a. Overall and year-by-year budget-to-actual comparisons;
b. A baseline schedule-to-actual schedule comparison; and
c. A list and a detailed explanation of all the specific reasons that the actual cost
exceeded the budgeted amount and the cost impact of each reason.
RESPONSE TO REQUEST FOR PRODUCTION NO. 297:
a. See part (a) to the Company’s Response to Request for Production No. 283.
b. See part (b) to the Company’s Response to Request for Production No. 283.
c. See the tab titled CHQBl60049 of the Attachment – Response to Staff Request
No. 283 for the detailed explanation of the variances between budget and actuals.
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 EIGHTEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 19
DATED at Boise, Idaho, this 14th 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 EIGHTEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 20
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the 14th day of September 2023, I served a true and
correct copy of Idaho Power Company’s Response to the Eighteenth 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 EIGHTEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 21
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 EIGHTEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 22
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 THE EIGHTEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 23
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
Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email [e-mail]

Stacy Gust Regulatory Administrative
Assistant