20230919IPC to IIPA 2nd Set - 1-24.pdf

LISA D. NORDSTROM
Lead Counsel
[e-mail]

September 19, 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 Second Set of Data Requests.

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 to 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
2023 SEPTEMBER 19, 2023 4:46PM
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 provided in response to Request No. 2-10 filed in Idaho
Power Company’s Response to the Idaho Irrigation Pumpers Association’s Second Set
of Data Requests dated September 19, 2023, contain information that Idaho Power
Company and a third party claim are trade secrets 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 19th day of September, 2023.

LISA D. NORDSTROM
Counsel for Idaho Power Company

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

COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), and in
response to Idaho Irrigation Pumpers Association, Inc. (“IIPA”) Second Set of Data
Requests dated September 12, 2023, herewith submits the following information:
IDAHO POWER COMPANY’S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S
SECOND SET OF DATA REQUESTS - 2
REQUEST FOR PRODUCTION NO. 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 2-1: Please see the
attached Excel file “Attachment – Response to IIPA Request No. 2-1 - McKenzie Idaho
Power Exhibit File.xlsx.” The requested workpapers were provided via the Company’s
File Transfer (“FTP”) Site on June 7, 2023.
The response to this Request is sponsored by Stacy Gust, Regulatory
Administrative Assistant, Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S
SECOND SET OF DATA REQUESTS - 3
REQUEST FOR PRODUCTION NO. 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 2-2: Please refer to the tab
labeled “Proxy Group Criteria” in the Excel file “Attachment – Response to IIPA Request
No. 2-1.”
The response to this Request is sponsored by Adrien McKenzie, CFA, President,
FinCap, Inc.
IDAHO POWER COMPANY’S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S
SECOND SET OF DATA REQUESTS - 4
REQUEST FOR PRODUCTION NO. 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 2-3: As indicated in footnote
(d) of Exhibit 13, Mr. McKenzie did not calculate the beta values presented on Exhibit 13.
Rather, he obtained them from The Value Line Investment Survey (“Value Line”). To the
best of Mr. McKenzie’s knowledge and belief, Value Line calculates beta by reference to
weekly returns over the last five years for the stock in question and the NYSE Composite.
Value Line adjusts raw betas towards the mean (“Blume” adjustment) using the following
formula:
βAdjusted = 0.67(βRaw) + 0.35
The response to this Request is sponsored by Adrien McKenzie, CFA, President,
FinCap, Inc.
IDAHO POWER COMPANY’S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S
SECOND SET OF DATA REQUESTS - 5
REQUEST FOR PRODUCTION NO. 2-4: Please refer to McKenzie Direct page
64.
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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 2-4:
a. Please refer to the tab labeled “2023 03 Market DCF” in the Excel file “Attachment
– Response to IIPA Request No. 2-1.xlsx” provided in response to Request for
Production No. 2-1.
b. Mr. McKenzie adopted the CAPM methodology approved by the Federal Energy
Regulatory Commission (“FERC”). FERC has argued that, “S&P 500 companies
with growth rates that are negative or in excess of 20 percent should be excluded
from the CAPM analysis because their growth rates are not representative of
sustainable growth rates.” Assoc. of Bus. Advocating Tariff Equity, Opinion No.
569, 169 FERC ¶ 61,129 at P 268 (2019).
c. As FERC has determined, “Using a DCF analysis of the dividend-paying members
of the S&P 500 is a well-recognized method of estimating the expected market
return for purposes of the CAPM model.” Assoc. of Bus. Advocating Tariff Equity,
Opinion No. 569, 169 FERC ¶ 61,129 at P 260 (2019). Financial research also
IDAHO POWER COMPANY’S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S
SECOND SET OF DATA REQUESTS - 6
supports using a DCF analysis of the dividend paying members of the S&P 500
when determining a forward-looking expected market return as part of the CAPM
model. For example, in Estimating Shareholder Risk Premia, Harris and Marston
present estimates of shareholder required rates of return and risk premiums using
forward-looking analysts’ growth forecasts. They state that “a ‘market’ required
rate of return is calculated using each dividend paying stock in the S&P 500 for
which data is available.” In describing this process, the authors state, “This
expectational approach employs the [DCF model] in which a consensus measure
of financial analysts’ forecasts . . . of earnings is used as a proxy for investor
expectations.” A copy of the Harris and Marston article cited above is attached.
The response to this Request is sponsored by Adrien McKenzie, CFA, President,
FinCap, Inc.
IDAHO POWER COMPANY’S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S
SECOND SET OF DATA REQUESTS - 7
REQUEST FOR PRODUCTION NO. 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 2-5: An alternate version of
WP-6 is attached. The size adjustments relied on by Mr. McKenzie were computed by
Kroll using data as of December 31, 2022. The methodology used to calculate the size
premiums is described on page 68 of Mr. McKenzie’s direct testimony.
The response to this Request is sponsored by Adrien McKenzie, CFA, President,
FinCap, Inc.
IDAHO POWER COMPANY’S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S
SECOND SET OF DATA REQUESTS - 8
REQUEST FOR PRODUCTION NO. 2-6: Please refer to McKenzie Direct page
67 line 1. Does the Company consider Kroll a reliable source for current CAPM model
parameters?
RESPONSE TO REQUEST FOR PRODUCTION NO. 2-6: While Mr. McKenzie
considers Kroll to be a reliable source, he does not agree that historical rates of return
provide an appropriate basis for the current expected market rate of return required by
the assumptions underlying CAPM.
The response to this Request is sponsored by Adrien McKenzie, CFA, President,
FinCap, Inc.
IDAHO POWER COMPANY’S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S
SECOND SET OF DATA REQUESTS - 9
REQUEST FOR PRODUCTION NO. 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?
RESPONSE TO REQUEST FOR PRODUCTION NO. 2-7:
a. Figure 2 is a hypothetical portrayal designed to illustrate the concepts underlying
the ECAPM and was not based on actual data.
b. Please refer to the response to subpart (a).
c. Please refer to the response to subpart (a).
The response to this Request is sponsored by Adrien McKenzie, CFA, President,
FinCap, Inc.
IDAHO POWER COMPANY’S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S
SECOND SET OF DATA REQUESTS - 10
REQUEST FOR PRODUCTION NO. 2-8: Please refer to McKenzie Direct page
4.
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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 2-8:
a. The Company has generally been able to attract capital on reasonable terms,
albeit at increasing interest rates in recent periods. However, the current period of
higher capital expenditures needed to serve customers, among other factors such
as utility-specific risks, puts strain on the Company’s balance sheet and prospects
and its ability to access both debt and equity capital markets, particularly given the
Company’s comparatively small size, and thus its risk profile is elevated. In
December 2022, Idaho Power was unable to raise the amount of debt capital it
had originally intended to issue, with limited interest from fixed-income investors in
Idaho Power given its risk profile.
b. In addition to Idaho Power’s experience in December 2022, Idaho Power is aware,
based on confidential discussions, of two other utilities unable to attract capital at
reasonable terms, including one failed debt offering, within the past year.
Mr. McKenzie’s direct testimony notes the importance that the investment
community places on the regulatory environment in determining their willingness
IDAHO POWER COMPANY’S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S
SECOND SET OF DATA REQUESTS - 11
to provide capital and at what cost. This testimony was not based on a
comprehensive research study to identify all instances in which a regulated utility
was unable to attract capital; rather, it was based on his experience and on the
publications cited in footnotes 4, 5, and 6 to his direct testimony. Nevertheless,
Mr. McKenzie is aware of a number of instances in which regulated utilities were
unable to attract capital and were forced to enter into bankruptcy proceedings,
including Pacific Gas and Electric Company (2019 and 2001), El Paso Electric
Company (1992), and Public Service of New Hampshire (1988). In addition,
Brazos Electric Power Cooperative, the largest and oldest electric power
cooperative in Texas, filed for bankruptcy in 2021 due to insufficient financial
resources to fund the cost of replacement power incurred during winter storm Uri.
While these are extreme examples, the impact that an insufficient ROE can have
on a utility’s credit standing is also illustrated by the investment community’s
reaction to the 8.7% ROE awarded to Arizona Public Service Company in 2021.
As The Value Line Investment Survey (“Value Line”) reported:
Pinnacle West stock is still reeling from the regulatory thrashing
the company suffered last year. The issue has lost over 30% of
its value from mid-2021, when it started to become apparent that
things would not go the company’s way in its general rate case.
When the decision arrived in November, Pinnacle West saw its
allowed return reduced from 10.7% to 8.7% (the lowest level in the
U.S.), and its annual earnings power cut by $0.90 per share. The
Value Line Investment Survey, Pinnacle West (Oct. 21, 2022).

Higher regulatory risk stemming from the unfavorable regulatory decision led
Moody’s Investors Service, S&P Global Ratings, and Fitch Ratings Inc. to
downgrade the credit ratings of Pinnacle West Capital Corporation and its
regulated electric utility subsidiary. A copy of the Value Line publication cited
IDAHO POWER COMPANY’S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S
SECOND SET OF DATA REQUESTS - 12
above is attached.
The response to this Request is sponsored by Brian Buckham, Senior Vice
President and Chief Financial Officer, Idaho Power Company and by Adrien McKenzie,
CFA, President, FinCap, Inc.
IDAHO POWER COMPANY’S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S
SECOND SET OF DATA REQUESTS - 13
REQUEST FOR PRODUCTION NO. 2-9: Please provide the capital structure or
balance sheet for Idaho Power by quarter from 2013 to present.
RESPONSE TO REQUEST FOR PRODUCTION NO. 2-9: Please see the
attached Excel spreadsheet “Attachment – Response to IIPA’s Request No. 2-9 – Cap
Structure.xlsx” for Idaho Power’s capital structure by quarter from 2013 to present, as
disclosed in Idaho Power’s quarterly Forms 10-Q filed with the Securities and Exchange
Commission.
The response to this Request is sponsored by Brian Buckham, Senior Vice
President & Chief Financial Officer, Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S
SECOND SET OF DATA REQUESTS - 14
REQUEST FOR PRODUCTION NO. 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 2-10: Please see
Confidential Attachments 1 through 12 to this response for each credit opinion issued by
Moody’s or S&P Global Ratings (previously known as Standard and Poor’s) from 2019 to
present.
The response to this Request is sponsored by Brian Buckham, Senior Vice
President & Chief Financial Officer, Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S
SECOND SET OF DATA REQUESTS - 15
REQUEST FOR PRODUCTION NO. 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 2-11: Please see the
Company’s Response to Industrial Customers of Idaho Power (“ICIP”) Requests Nos. 13
and 14 for communications between Idaho Power and Moody’s Investor Services and
Standard and Poor’s (“S&P”) from January 1, 2022, through today.
Similar to that response, communications between Idaho Power and Moody’s and
S&P from 2019 to 2021 that were not conducted telephonically consisted of the
publication of credit opinions by Moody’s and S&P (provided in the Company’s response
to Request No. 2-10), and additional highly confidential presentations and reports
provided by Idaho Power to Moody’s and S&P. The highly confidential information will be
made available to IIPA at Idaho Power's corporate headquarters. Please contact Tami
White at [phone] or David Fewkes at [phone] to arrange a time to review
the requested material.
The response to this Request is sponsored by Brian Buckham, Senior Vice
President & Chief Financial Officer, Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S
SECOND SET OF DATA REQUESTS - 16
REQUEST FOR PRODUCTION NO. 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 2-12: The requested
information is highly confidential and contains attorney-client privileged information. It will
be made available, as applicable, to IIPA at Idaho Power's corporate headquarters.
Please contact Tami White at [phone] or David Fewkes at [phone] to
arrange a time to review the requested material.
The response to this Request is sponsored by Cheryl Thompson, Lead Counsel
and Deputy Corporate Secretary, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S
SECOND SET OF DATA REQUESTS - 17
REQUEST FOR PRODUCTION NO. 2-13: Please provide Idaho Power’s total
dividend payout by year and stock type from 2010 to present.
RESPONSE TO REQUEST FOR PRODUCTION NO. 2-13: All of Idaho Power’s
common stock is owned by IDACORP, Inc. Idaho Power has not paid dividends on any
other type of stock from 2010 to present. Below are Idaho Power’s total cash dividend
payouts by year from 2010 to present, in thousands of dollars.
2010 2011 2012 2013 2014 2015 2016
$58,070 $59,705 $68,740 $78,926 $88,584 $96,907 $105,121

2017 2018 2019 2020 2021 2022 June 2023 YTD
$113,284 $121,791 $129,877 $137,885 $146,076 $114,447 $80,538

The response to this Request is sponsored by Brian Buckham, Senior Vice
President & Chief Financial Officer, Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S
SECOND SET OF DATA REQUESTS - 18
REQUEST FOR PRODUCTION NO. 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 balance sheet) actual basis
for the past three calendar years. Please provide such data separately for Idaho Power
and each subsidiary or operating entity.
RESPONSE TO REQUEST FOR PRODUCTION NO. 2-14: Please see the Excel
file “Attachment – Response to IIPA’s Request No. 2-14 Financial Statements.xlsx” for
Idaho Power’s complete annual financial statements in electronic spreadsheet format, as
disclosed in Idaho Power’s Annual Reports on Forms 10-K filed with the Securities and
Exchange Commission, excluding the notes to the consolidated financial statements. The
notes are an integral part of the financial statements and are available on the website of
the Securities and Exchange Commission or IDACORP, Inc.’s website at
https://www.idacorpinc.com/investor-relations/sec-filings/default.aspx.
The response to this Request is sponsored by Brian Buckham, Senior Vice
President & Chief Financial Officer, Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S
SECOND SET OF DATA REQUESTS - 19
REQUEST FOR PRODUCTION NO. 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.).
RESPONSE TO REQUEST FOR PRODUCTION NO. 2-15: As described in the
IDACORP’s and Idaho Power’s Annual Report on Form 10-K for the year ended
December 31, 2022:
The amount and timing of dividends paid on IDACORP’s common stock are
within the discretion of IDACORP’s board of directors. IDACORP's board of
directors reviews the dividend rate periodically to determine its
appropriateness in light of IDACORP’s current and long-term financial
position and results of operations, capital requirements, rating agency
considerations, contractual and regulatory restrictions, legislative and
regulatory developments affecting the electric utility industry in general and
Idaho Power in particular, competitive conditions, and any other factors the
board of directors deems relevant. The ability of IDACORP to pay dividends
on its common stock is generally dependent upon dividends paid to it by its
subsidiaries, primarily Idaho Power.

IDACORP has a dividend policy that provides for a target long-term
dividend payout ratio of between 60 percent and 70 percent of sustainable
IDACORP earnings, with the flexibility to achieve that payout ratio over time
and to adjust the payout ratio or to deviate from the target payout ratio from
time to time based on the various factors that drive IDACORP's board of
directors' dividend decisions. Notwithstanding the dividend policy adopted
by IDACORP's board of directors, the dividends IDACORP pays remain in
the discretion of the board of directors who, when evaluating the dividend
amount, will continue to take into account the factors above, among others.
In September of 2022 and 2021, IDACORP's board of directors voted to
increase the quarterly dividend to $0.79 per share and $0.75 per share of
IDACORP common stock, respectively. IDACORP's dividends during 2022
were 59.5 percent of actual 2022 earnings.

Other statements IDACORP has made pertaining to dividends are included in the
materials provided in response to request 2-16 below.
The response to this Request is sponsored by Brian Buckham, Senior Vice
President and Chief Financial Officer, Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S
SECOND SET OF DATA REQUESTS - 20
REQUEST FOR PRODUCTION NO. 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 2-16: Presentations made
in 2022 and 2023 are available on the IDACORP website at
https://www.idacorpinc.com/investor-relations/events-and-presentations/default.aspx.
Presentations from 2020 and 2021 are included as Attachments 1 and 2 to this response.
The purpose of each of these presentations is debt and equity investor outreach and
engagement.
IDACORP tracks many of its investor meetings to provide a reminder of who the
Company met with as part of its outreach efforts. It is important to note, however, that
these internal notes may not be a complete list of every outreach interaction because the
notes are meant to provide a reminder of outreach efforts and not an exhaustive list.
IDACORP engages in regular inbound and outbound telephonic and virtual outreach
efforts with the investment community. The information IDACORP has retained for its
meetings from 2020 through 2023 is included as Attachment 3 to this response.
The response to this Request is sponsored by Brian Buckham, Senior Vice
President and Chief Financial Officer, Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S
SECOND SET OF DATA REQUESTS - 21
REQUEST FOR PRODUCTION NO. 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 2-17: The requested
information is highly confidential. It will be made available at Idaho Power's corporate
headquarters. Please contact Tami White at [phone] or David Fewkes at (208)
388-2628 to arrange a time to review the requested material.
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
SECOND SET OF DATA REQUESTS - 22
REQUEST FOR PRODUCTION NO. 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;
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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 2-18: Please see the Excel
file “Attachment 1 – Response to IIPA Request No. 2-18.xlsx” for actual debt details as of
December 31, 2022.
Please see the Excel file “Attachment 2 – Response to IIPA Request No. 2-18.xlsx”
for Pro Forma debt details estimated for December 31, 2023, which is the spreadsheet
version of Exhibit 21 page 2 of Brian Buckham’s testimony. Assumptions used on the cost
IDAHO POWER COMPANY’S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S
SECOND SET OF DATA REQUESTS - 23
of debt as of December 31, 2023, are noted on the spreadsheet.
The response to this Request is sponsored by Brian Buckham, Senior Vice
President and Chief Financial Officer, Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S
SECOND SET OF DATA REQUESTS - 24
REQUEST FOR PRODUCTION NO. 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 2-19: Idaho Power accounts
for long-term debt according to Federal Energy Regulatory Commission prescribed
procedures, recording expense of issue as an asset, loss on reacquired debt as an asset,
discounts as reduction to a liability, premiums as an increase to a liability, and the principal
amount as a liability. Expense of issue, discounts and premiums, and loss on reacquired
debt are amortized on a straight line basis to interest expense over the life of each bond.
These amortization expenses (or credits) are included in the overall cost of debt
calculation, which is explained in detail on page 59 of the direct testimony of Brian
Buckham.
The response to this Request is sponsored by Brian Buckham, Senior Vice
President and Chief Financial Officer, Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S
SECOND SET OF DATA REQUESTS - 25
REQUEST FOR PRODUCTION NO. 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 2-20: Idaho Power and
IDACORP have not issued common stock to the public during the period requested.
The response to this Request is sponsored by Brian Buckham, Senior Vice
President and Chief Financial Officer, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S
SECOND SET OF DATA REQUESTS - 26
REQUEST FOR PRODUCTION NO. 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
h. Net proceeds to Idaho Power in dollars.
RESPONSE TO REQUEST FOR PRODUCTION NO. 2-21: Idaho Power and
IDACORP have not issued common stock to the public during the period requested.
The response to this Request is sponsored by Brian Buckham, Senior Vice
President and Chief Financial Officer, Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S
SECOND SET OF DATA REQUESTS - 27
REQUEST FOR PRODUCTION NO. 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
RESPONSE TO REQUEST FOR PRODUCTION NO. 2-22: Please see the Excel
file named “Attachment – Response to IIPA’s Request No. 2-22.xlsx” for the requested
information.
The response to this Request is sponsored by Brian Buckham, Senior Vice
President & Chief Financial Officer, Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S
SECOND SET OF DATA REQUESTS - 28
REQUEST FOR PRODUCTION NO. 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
k. Total non-capitalized labor expense including loadings.
RESPONSE TO REQUEST FOR PRODUCTION NO. 2-23: As discussed with
IIPA, Idaho Power will respond to this request on, or before September 26, 2023.
IDAHO POWER COMPANY’S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S
SECOND SET OF DATA REQUESTS - 29
REQUEST FOR PRODUCTION NO. 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 2-24:
a. Short-term incentive compensation under Idaho Power’s Executive Incentive Plan
is determined by performance relative to annual performance goals and is intended
to encourage and reward annual financial, operational, and customer-focused
results. The Company provides participants in the Executive Incentive Plan the
opportunity to earn cash-based short-term incentives in order to be competitive
from a total compensation standpoint and to ensure focus on annual financial,
operational, and customer service goals. The incentive goal structure from 2011-
2022 was as follows:
 Customer Satisfaction (15% weighting) - The customer satisfaction goal
focuses on the Company’s relationship with and service to customers. The
Company measures customer satisfaction through quarterly surveys
conducted by an independent survey firm. The survey data covers five
specific performance qualities: overall satisfaction, quality, value, advocacy,
and loyalty;
 Service Reliability (15% weighting) - The service reliability goal is intended
to focus executive officers on Idaho Power’s system reliability and its impact
IDAHO POWER COMPANY’S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S
SECOND SET OF DATA REQUESTS - 30
on the Company’s relationship with its customers. The Company measures
this goal by the number of interruptions greater than five minutes in duration
experienced by Idaho Power’s metered general customers over the course
of the year; and,
 Adjusted Consolidated Net Income (70% weighting) - The IDACORP
adjusted consolidated net income goal reflects a measure of the Company’s
year-end financial performance.
b. The table below presents annual executive incentive pay.
Incentive Plan Year Incentive Paid Year Executive Incentive Paid
2011 2012 $ 3,493,439.00
2012 2013 $ 3,943,906.00
2013 2014 $ 3,868,084.00
2014 2015 $ 3,884,498.46
2015 2016 $ 2,903,370.18
2016 2017 $ 4,065,256.88
2017 2018 $ 4,057,327.78
2018 2019 $ 4,968,347.12
2019 2020 $ 5,258,353.47
2020 2021 $ 4,702,098.48
2021 2022 $ 4,757,406.31
2022 2023 $ 4,954,098.62

c. Executive incentive pay is not included in capitalized labor costs.
The response to this Request is sponsored by Sarah Griffin, Vice President,
Human Resources, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S
SECOND SET OF DATA REQUESTS - 31
DATED at Boise, Idaho, this 19th 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
SECOND SET OF DATA REQUESTS - 32
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the 19th day of September 2023, I served a true and
correct copy of Idaho Power Company’s Response to Idaho Irrigation Pumpers
Association, Inc.’s Second 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
SECOND SET OF DATA REQUESTS - 33
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

Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email [e-mail]

Lance Kaufman, Ph.D.
2623 NW Bluebell Place
Corvallis, OR 97330
Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email [e-mail]

Micron Technology, Inc.
Austin Rueschhoff
Thorvald A. Nelson
Austin W. Jensen
Holland & Hart, LLP
555 Seventeenth Street, Suite 3200
Denver, Colorado 80202

Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email [e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]

Jim Swier
Micron Technology, Inc.
8000 South Federal Way
Boise, Idaho 83707
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
SECOND SET OF DATA REQUESTS - 34
City of Boise
Ed Jewell
Darrell Early
Boise City Attorney’s Office
150 N. Capitol Blvd.
Boise, ID 83701
Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email [e-mail]
[e-mail]
[e-mail]

Wil Gehl
Boise City Dept. of Public Works
150 N. Capitol Blvd.
P.O. Box 500
Boise, Idaho 83701-0500

Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email [e-mail]

Idaho Conservation League
Marie Callaway Kellner
Idaho Conservation League
710 N. 6th Street
Boise, Idaho 83702

Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email [e-mail]

Brad Heusinkveld
Idaho Conservation League
710 N. 6th Street
Boise, Idaho 83702
Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email
[e-mail]

IdaHydro
C. Tom Arkoosh
Arkoosh Law Offices
913 W. River Street, Suite 450
P.O. Box 2900
Boise, Idaho 83701

Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email [e-mail]
[e-mail]

Federal Executive Agencies
Peter Meier
Paige Anderson
Tanner Crowther
U.S. Department of Energy
1000 Independence Ave., S.W.
Washington, DC 20585
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
SECOND SET OF DATA REQUESTS - 35
Dwight Etheridge
Exeter Associates
5565 Sterrett Place, Suite 310
Columbia, MD 21044
Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email [e-mail]

NW Energy Coalition
F. Diego Rivas
1101 8th Ave
Helena, MT 59601
Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email [e-mail]

Walmart Inc.
Norman M. Semanko
Parsons Behle & Latimer
800 West Main Street, Suite 1300
Boise, Idaho 83702
Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email [e-mail]

Steve W. Chriss
Director, Energy Services
Walmart Inc.
2608 Southeast J Street
Bentonville, Arkansas 72716
Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email [e-mail]

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