20230915IPC to Staff 300-304.pdf

MEGAN GOICOECHEA ALLEN
Corporate Counsel
[e-mail]

September 15, 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 Twentieth Production Request of the Commission Staff to Idaho Power Company.

Due to the collectively voluminous confidential and non-confidential information
provided in response to data requests in this case, the Company is posting the
attachments to these requests to the secure FTP site to allow parties to view the
requested information remotely unless otherwise noted in the response. Because certain
attachments contain confidential information, the FTP site is divided between confidential
and non-confidential information.

The login information for the non-confidential portion of the FTP site has been
provided to all parties that have intervened to date. The login information for the
confidential portion of the FTP site has been provided the parties that have executed the
Protective Agreement in this matter.

If you have any questions about the attached filing, please do not hesitate to
contact me.

Very truly yours,

Megan Goicoechea Allen
MGA:sg
Enclosures

RECEIVED
Friday, September 15, 2023 2:03:14 PM
IDAHO PUBLIC
UTILITIES COMMISSION

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

COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), and in
response to the Twentieth Production Request of the Commission Staff (“Commission” or
“Staff”) dated September 8, 2023, herewith submits the following information:

IDAHO POWER COMPANY’S RESPONSE TO THE TWENTIETH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 2
REQUEST FOR PRODUCTION NO. 300: Regarding the Company's response to
Staff Production Request No. 214, please answer the following regarding employee
housing:
a. What happens to the property purchased by the Company when employee(s)
located in McCall, Bellevue, Hailey, and New Plymouth find other housing?
b. How many Company-owned units for employee housing are currently vacant. How
long does the employee housing stay vacant?
c. Does the Company intend to expand its real estate portfolio?
d. When was the decision made to provide Company-owned housing rent free?
e. Please provide the year that each Line Operations housing was purchased.
f. Please provide the full fair-market rental value in or around McCall, Bellevue,
Hailey, and New Plymouth for the units owned by the Company?
g. What is the average fair-market rental value in or around hydro facilities?
h. Please provide the actual maintenance expenses associated with employee
housing for years 2018 through 2021.
i. Of the $525,950.76 actual maintenance expenses in 2022, how much is included
for recovery in the general rate case?
J. Are the 86 employees in Company-owned housing provided any other benefits,
such as higher wages (locational adjustment), stipends, daily per diem, Company
vehicle, etc.? If so, please specify each benefit, and quantify the benefits on an
annual basis.
k. Does the Company expect the $13,049 rent revenue to continue to occur in the
future? If not, was it removed from the Company's Application?

IDAHO POWER COMPANY’S RESPONSE TO THE TWENTIETH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 3

RESPONSE TO REQUEST FOR PRODUCTION NO. 300:
a. When a Company-owned house is vacated, it is made available for other
employees in need of temporary or transitional housing. If there is not a need for
temporary or transitional housing, the house may be rented at the fair-market rental
value by an employee.
b. There are currently 12 Company-owned housing units vacant. The majority of the
vacant units are in the Western Plant Region (Hells Canyon Complex.) The length
of time that a Company-owned house remains vacant varies based on many
factors: the region in which the house is located, turnover rates in the area, housing
demand in the area, etc. Idaho Power does not currently track vacancy length.
c. The Company is continuing to monitor the housing situation in areas of the service
area with ongoing recruiting and retention challenges. Currently there are no
pending real estate transactions for company-owned housing, and it is not known
at this time if circumstances will warrant expanding the Company-owned housing
portfolio.
d. The Company has provided company-owned housing to employees in the power
plant regions since the early 1900’s. Payroll records indicate that Company-owned
housing has been treated as a taxable benefit to employees for over 25 years and
it is not known if there was a time in the past when employees paid rent.
e. The purchase years for the Lines Operations houses were as follows:
 380 Parkside Dr, Bellevue ID – 2009
 13855 Williams Rd, McCall ID – 2010

IDAHO POWER COMPANY’S RESPONSE TO THE TWENTIETH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 4
 117 SW Blvd, New Plymouth ID – 2021
 940 Cherry Creek Dr, Hailey ID - 2022
f. The fair-market rental value for all Company-owned housing is reassessed every
five years and adjusted accordingly per IRS guidelines. The last review was
completed in 2021. The rental values are set based on property type and location.
Due to a lack of comparable rental inventory in many of the rural areas, the
Department of Housing and Urban Development (“HUD”) fair market rents (“FMR”)
are used in this assessment. HUD’s FMR rates vary by county and target the 40th
percentile of rental rate in the area. Once the FMR rates are identified, a travel
time discount is applied to determine the taxable benefit amount for employees.
The time travel discount is based on location of the property and travel time to the
nearest hub/city with public amenities. Below are the monthly fair-market rental
values and the monthly employee taxable benefit values for the properties in
McCall, Bellevue, Hailey, and New Plymouth as determined in 2021:
Property Location
2 Bed
FMR
3 Bed
FMR
2 Bed -
Employee
Taxable
Benefit
3 Bed -
Employee
Taxable
Benefit
Valley County $798 $1,142 $605 $949
Blaine County $1,042 $1,474 $938 $1,370
New Plymouth/Payette $899 $1,272 $794 $1,167

g. Below are the average monthly fair-market rental value and average monthly
employee taxable benefit values for the properties in the power plant areas:
Property Location
2 Bed
FMR
3 Bed
FMR
2 Bed -
Employee
Taxable
Benefit
3 Bed -
Employee
Taxable
Benefit
Eastern Plant Region $827 $1,143 $628 $944
Western Plant Region $763 $1,054 $294 $585

IDAHO POWER COMPANY’S RESPONSE TO THE TWENTIETH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 5

h. Actual maintenance expenses associated with employee housing for the years
2018 through 2021 are provided in ‘Attachment – Response to Staff Request No.
300-h.
i. The entire $525,950.76 of actual maintenance expenses in 2022 is included for
recovery in the general rate case.
j. Due to the complex and critical nature of Idaho Power’s operations in Hells Canyon
and the remote and isolated location of the Hells Canyon Complex (“HCC”), certain
employees involved in generation at this location qualify for premium pay, whether
they live in employee housing or not. Eligible employees must directly support plant
operations and be based full-time at the HCC. The HCC operations premium paid
to eligible employees is 3 percent of the employee’s base pay rate. Below is the
total amount of the HCC operations premium paid for the last five years:
Year HCC Premium
Annual Cost
2022 $122,463
2021 $122,277
2020 $122,323
2019 $114,616
2018 $112,507

k. The Company is unable to predict with any certainty how much rent revenue will
continue to occur in the future. The entire $13,049 in rent revenue is included as a
revenue credit in the general rate case.
The response to this Request is sponsored by Sarah Griffin, Vice President Human
Resources, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE TWENTIETH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 6
REQUEST FOR PRODUCTION NO. 301: Please provide a list of taxable fringe
benefits. When identifying each, please specify how many employees were taxed, the
process of identifying who qualifies for each fringe benefit, and the cost savings
associated with each fringe benefit provided.
RESPONSE TO REQUEST FOR PRODUCTION 301: The Company has two
taxable fringe benefit offerings: Company-owned housing and Group Term Life
Insurance.
Company-owned housing – Please refer to production request No’s. 214 and 300
for Company-owned housing program details. As previously reported, there are currently
86 employees living in Company-owned housing and paying tax on the fair market value
of the rent.
Group Term Life Insurance – All regular and temporary employees are eligible and
automatically enrolled in Group Term Life Insurance - Basic Life coverage. Basic Life is
a benefit of one and a half times an employee’s annual base pay up to a maximum benefit
amount of $750,000 and is provided by Idaho Power at no cost to the employee. The
Internal Revenue Code requires that company-provided life insurance be taxable to the
employee. The first $50,000 of Company-provided coverage is tax-free. For coverage in
excess of $50,000, the government sets the cost per $1,000 per month according to age.
The taxable amount is then included as imputed income in the participant’s W-2 at year
end. At the end of 2022, there were 2,044 employees being taxed for group term life
insurance. Group Term Life Insurance is a part of Idaho Power’s competitive Total
Rewards offerings and is a common offering throughout utility and general industry
companies.

IDAHO POWER COMPANY’S RESPONSE TO THE TWENTIETH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 7

The response to this Request is sponsored by Sarah Griffin, Vice President Human
Resources, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE TWENTIETH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 8
REQUEST FOR PRODUCTION NO. 302: In the Company' s proposed tariffs,
Schedule 8 does not include a change for the proposed summer season to include
September. Please explain.
RESPONSE TO REQUEST FOR PRODUCTION NO. 302: The Company’s
proposed changes to Schedule 8 should have included a change for the proposed
summer season to include September consistent with other residential service schedules.
Please see the file labeled “Attachment – Response to Request No. 303,” which
accurately reflects the proposed tariff revisions for Schedule 8 to update the summer
season to include September.
The response to this Request is sponsored by Stacy Gust, Regulatory
Administrative Assistant, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE TWENTIETH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 9
REQUEST FOR PRODUCTION NO. 303: Please provide a legislative copy of the
Company's proposed tariffs for Schedules 6, 8, and 84 that include the combined changes
from Case No. IPC-E-23-11 and Case No. IPC-E-23-14 filings.
RESPONSE TO REQUEST FOR PRODUCTION NO. 303: Please see the file
labeled “Attachment – Response to Staff Request No. 303.”
The response to this Request is sponsored by Stacy Gust, Regulatory
Administrative Assistant, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE TWENTIETH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 10
REQUEST FOR PRODUCTION NO. 304: Regarding the Company' s response to
Staffs Production Request Nos. 64 and No. 209, please provide the amount included in
the wildfire deferral that is related to transmission plant and projects on a quarterly basis.
Please include deprecation, operation and maintenance expenses, etc.
RESPONSE TO REQUEST FOR PRODUCTION NO. 304: Please see
Attachment 1 – Response to Staff Request No. 304 identifying the quarterly transmission
wildfire deferral. Note, the main wildfire deferral calculations are based on annual
incremental spend over the 2019 base. Therefore, it is most meaningful to review the
deferral in annual figures. However, as requested this has been broken out by quarter.
The response to this Request is sponsored by Paula Jeppsen, Forecasting and
Planning Director, Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO THE TWENTIETH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 11
DATED at Boise, Idaho, this 15th day of September 2023.
MEGAN GOICOECHEA ALLEN Attorney for Idaho Power Company
LISA D. NORDSTROM
Attorney for Idaho Power Company
DONOVAN E. WALKER
Attorney for Idaho Power Company

IDAHO POWER COMPANY’S RESPONSE TO THE TWENTIETH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 12
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the 15th day of September 2023, I served a true and
correct copy of Idaho Power Company’s Response to the Twentieth 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 TWENTIETH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 13
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 TWENTIETH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 14
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
U.S. Department of Energy
1000 Independence Ave., S.W.
Washington, DC 20585

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IDAHO POWER COMPANY’S RESPONSE TO THE TWENTIETH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 15
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