20231122IPC to Staff 1-31.pdf

LISA D. NORDSTROM
Lead Counsel
[e-mail]

November 22, 2023

VIA ELECTRONIC EMAIL

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-23-23
Idaho Power Company’s 2023 Integrated Resource Plan

Dear Ms. Noriyuki:

Enclosed for electronic filing, please find Idaho Power Company’s Response to the
First Production Request of Commission Staff.

The confidential attachments will be uploaded to the FTP Site and provided to the
parties who sign the Protective Agreement.

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

Very truly yours,

Lisa D. Nordstrom
LDN:cd
Attachments
RECEIVED
2023 NOVEMBER 22, 2023 1:36PM
IDAHO PUBLIC
UTILITIES COMMISSION

CERTIFICATE OF ATTORNEY

ASSERTION THAT INFORMATION CONTAINED IN AN IDAHO PUBLIC UTILITIES
COMMISSION FILING IS PROTECTED FROM PUBLIC INSPECTION

Idaho Power Company’s 2023 Integrated Resource Plan

Case No. IPC-E-23-23

The undersigned attorney, in accordance with Commission Rules of Procedure 67,
believes that the Attachment No(s). 1, 2, and 10 to Idaho Power Company’s Response to
the First Production Request of the Commission Staff, dated November 22, 2023, may
contain information that Idaho Power Company claims is a confidential trade secret and
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 Wednesday, November 22, 2023.

Lisa Nordstrom
Counsel for Idaho Power Company

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF- 1
LISA D. NORDSTROM (ISB No. 5733)
MEGAN GOICOECHEA ALLEN (ISB No. 7623)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
[e-mail]
[e-mail]

Attorneys for Idaho Power Company

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF IDAHO POWER
COMPANY’S 2023 INTEGRATED
RESOURCE PLAN.
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CASE NO. IPC-E-23-23

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

COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), and in
response to the First Production Request of the Commission Staff (“Commission” or
“Staff”) dated November 3, 2023, herewith submits the following information:

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF- 2
STAFF REQUEST FOR PRODUCTION NO. 1: Please provide all data input files
used in the Reliability and Capacity Assessment Tool ("RCAT"). Where appropriate,
please separate the input files by scenario and provide a brief description of any
adjustments made to the data for that scenario.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 1:
For the 2023 Integrated Resource Plan (“IRP”), the Company used the Reliability
and Capacity Assessment Tool (“RCAT”) to assess annual capacity positions for the
following 10 main cases1:
1. Preferred Portfolio (Valmy 1 & 2)
2. Valmy 2
3. Without Valmy
4. Nov2026 B2H Valmy 1 & 2
5. Nov2026 B2H Valmy 2
6. Nov2026 B2H Without Valmy
7. Without B2H
8. Without GWW Phases
9. GWW Phase 1 Only
10. GWW Phases 1 & 2 Only
For each of the 10 main cases, the Company used the same historical data. For
the historical data input files, please see Confidential Attachments 1-4 as named and
described below:
 2017-2022 American Falls Hydro (for known maintenance adjustments)

1 Idaho Power’s 2023 Integrated Resource Plan, p. 125-126

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF- 3
 2017-2022 Arrowrock Hydro-Clatskanie Agreement (for Clatskanie
Agreement assumptions)
 2017-2022 Total Renewables (for expected and future resource shaping)
 2024-2043 70th Percentile Load Based on Historical (historical load shaped
to the 70th percentile peak load)
Because the resource selections differ across each portfolio, two unique Excel
spreadsheets were created for each main case and for an additional ‘No IRP Resource
Additions’ case. The ‘No IRP Resource Additions’ case is utilized to generate pre-
Preferred Portfolio annual capacity positions for comparison in Table 11.15 of the 2023
IRP. For the case-specific data input files, please see Confidential Attachments 5-26 as
named and described below:
1) 2024-2043 Flexible & EFORd (lists the flexible resource selections with their
associated Equivalent Forced Outage Rate during Demand (“EFORd”) and monthly
capacity)
2) 2024-2043 VERs & ELRs (lists the variable energy resource (“VER”) and energy
limited resource (“ELR”) selections)
The response to this Request is sponsored by Jared Ellsworth, Transmission,
Distribution & Resource Planning Director, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF- 4
STAFF REQUEST FOR PRODUCTION NO. 2: Please provide all RCAT scripts
used to conduct supporting analysis for the IRP in PDF format. For each script, please
include a definition for each variable used.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 2:
Please see the attached PDF files, which include all Reliability and Capacity
Assessment Tool (“RCAT”) scripts utilized to perform annual capacity position
calculations for the 2023 Integrated Resource Plan (“IRP”). The Company has included
detailed comments in each PDF file that summarizes the RCAT script’s primary purpose
and describes each variable and function within the script. Please note that the lines with
descriptive comments are demarcated by a ‘%’ and are displayed in green text.
Additionally, the Company offers the following definitions for a few key terms and
phrases used to describe various parts of the provided RCAT scripts:
 Initialize variable: memory initialization of a variable that is later called on (and
described) in the script that allows for the most efficient simulation times.
 Temporary variable: a variable that is only used temporarily within the code as
an intermediate step.
 Internal variable: a variable that is only used within the specified script and not
used globally.
The response to this Request is sponsored by Jared Ellsworth, Transmission,
Distribution & Resource Planning Director, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF- 5
STAFF REQUEST FOR PRODUCTION NO. 3: Please provide workpapers like
those provided in response to Staff's Production Request No. 96 in Case No. IPC-E-23-
11, showing the hourly Loss of Load Probability ("LOLP") and monthly Loss of Load
Expectation ("LOLE") for preferred portfolio forecast years 2025 through 2030 with and
without the inclusion of Battery Energy Storage System resources.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 3:
Please see the attached Excel spreadsheet for the requested information.
The response to this Request is sponsored by Jared Ellsworth, Transmission,
Distribution & Resource Planning Director, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF- 6
STAFF REQUEST FOR PRODUCTION NO. 4: Please provide the rational for
using 90% of total hourly risk to determine seasons of highest risk.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 4:
The goal in establishing a threshold to determine seasons of highest risk is to
identify the critical timeframes that incentivize either additional resource output or reduced
demand. Utilizing 100 percent of total hourly risk would include all hours of the year and
provide no meaningful information. Meanwhile, utilizing a 90 percent threshold eliminates
the non-critical hours, while still accounting for different weather patterns from the six test
years of historical data when establishing seasons.
The response to this Request is sponsored by Jared Ellsworth, Transmission,
Distribution & Resource Planning Director, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF- 7
STAFF REQUEST FOR PRODUCTION NO. 5: Please define the "time of
occurrence" used to group the top 90% of LOLP values when determining seasons of
highest risk.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 5:
When determining seasons of highest risk, a Loss of Load Probability (“LOLP”) is
calculated for each hour in the calendar year. Then, the top 90 percent of those calculated
hourly LOLP values are selected to inform the seasons of highest risk. Each LOLP value
that is within the top 90 percent maintains its individually associated time stamp, which
includes the hour, day, and month. The associated time stamps of the top 90 percent
LOLP values are the referenced “time of occurrence.” For example, if the highest LOLP
value occurred on July 14th at 7:00 pm, that would be its “time of occurrence.” For
determining the seasons of highest risk, the Company focuses on the day and month of
the top 90 percent of LOLP values and their time of occurrence.
The response to this Request is sponsored by Jared Ellsworth, Transmission,
Distribution & Resource Planning Director, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF- 8
STAFF REQUEST FOR PRODUCTION NO. 6: Please define the criteria that the
Company uses to identify the seasons of highest risk as November 1 through February
28 and June 1 through September 15.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 6:
As discussed in the Company’s responses to Request Nos. 4 and 5, the Company
first calculated the top 90 percent of Loss of Load Probabilities (“LOLP”) and their
associated times of occurrence. Then, utilizing the identified times of occurrences, the
time stamps were grouped by month. Within each month, the time stamps were then
grouped by the nearest half month. For example, if the latest identified time stamp in
September occurred on the 9th, the season was extended to September 15th to account
for the year-to-year variation in weather and load.
The response to this Request is sponsored by Jared Ellsworth, Transmission,
Distribution & Resource Planning Director, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF- 9
STAFF REQUEST FOR PRODUCTION NO. 7: Please provide the rationale for
selecting the top 50% risk hours in each month for the purpose of determining the hours
of highest risk.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 7:
The top 50 percent of risk hours per month threshold was selected to create a
relevant and manageable sample size for determining the hours of highest risk. For
example, this threshold reduces the 720 hours in the month of June to a number in the
double digits. This sample includes enough data points to develop a meaningful
distribution of high-risk hours and captures the year-to-year and day-to-day variability of
the calculated Loss of Load Probabilities (“LOLP”), while also minimizing computational
burden.
The response to this Request is sponsored by Jared Ellsworth, Transmission,
Distribution & Resource Planning Director, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF- 10
STAFF REQUEST FOR PRODUCTION NO. 8: Please describe the "percent of
occurrence threshold" that the Company uses to differentiate between hours of medium
risk and hours of highest risk.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 8:
Using the top 50 percent of risk hours, as described in the Company’s response to
Request No. 7, the Company identified monthly risk hours by grouping data points by the
hour of day in which they occurred. Then, from the determined monthly risk hours, the
highest risk hours were identified from the percent of occurrences greater than
approximately 15 percent for the summer months and the percent of occurrences greater
than approximately 10 percent for the winter months. Hours that did not exceed these
thresholds were determined to be “medium risk” hours.
The response to this Request is sponsored by Jared Ellsworth, Transmission,
Distribution & Resource Planning Director, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF- 11
STAFF REQUEST FOR PRODUCTION NO. 9: Please explain how the method
for modeling Energy Limited Resources accounts for the need of these resources to
recharge in the event of consecutive high net load days.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 9:
Idaho Power assumes Staff’s request is specific to Battery Energy Storage
Systems (“BESS”), considering the question’s reference to “recharge.” When modeling 2-
hour, 4-hour, and 8-hour BESS in Idaho Power’s Reliability and Capacity Assessment
Tool (“RCAT”), the model first allows BESS to charge based on the day’s minimum net
load hours and then discharge based on the day’s maximum net load hours. In the
scenario where there are multiple days in which the net load is flat, the charging hours
and discharging hours could be the same. This results in an idle scenario, meaning there
is no opportunity to charge the battery and, therefore, the battery cannot be cycled.
For more information on how BESS is charged and discharged in the RCAT,
please see the Company’s response to Request No. 2, which includes the RCAT scripts
in PDF format. The energy storage files contain detailed comments on the various
variables and functions, which dictate the behavior of the BESS resources.
The response to this Request is sponsored by Jared Ellsworth, Transmission,
Distribution & Resource Planning Director, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF- 12
STAFF REQUEST FOR PRODUCTION NO. 10: Please provide supporting
worksheets for the updated Boardman to Hemingway ("B2H") September 2023 cost
estimates, with a breakdown of the total amount by cost component. Additionally, please
explain why the cost estimates have increased in the 2023 Integrated Resource Plan
("IRP") since the estimates provided in the Company's certificate of public convenience
and necessity filing (Case No. IPC-E-23-01).
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 10:
Please see the attached confidential Excel spreadsheet for updated Boardman to
Hemingway (“B2H”) costs broken out by cost component. The estimated cost has been
updated to reflect preliminary bids received for materials and construction.
The response to this Request is sponsored by Lindsay Barretto, 500kV and Joint
Projects Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF- 13
STAFF REQUEST FOR PRODUCTION NO. 11: Please provide further
explanation of the long duration pilot project for the five megawatts ("MW") of storage the
Company would like to explore in 2024 through 2028. Please provide examples of what
the Company is considering as a long duration project. Additionally, please explain how
the Company plans to seek to receive Commission approval.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 11:
As the quantity of short-duration storage increases on the power system, the
effectiveness of additional short-duration storage will decrease. Longer duration storage
will become necessary to shift energy not just between hours of the day but between
seasons and across multi-day events. A small, long-duration storage project will allow the
utility to learn where it can be used to the greatest effect and to better understand its
limitations prior to a larger investment in a similar technology.
An example of a long-duration storage technology that could be considered for this
project is the iron-air 100-hour battery. The Company is still considering where such a
project would be located to maximize value while also gaining the necessary experience.
If Idaho Power moves forward with such a project, the Company will seek regulatory
approval through a formal filing with the Idaho Public Utilities Commission.
The response to this Request is sponsored by Jared Hansen, Resource Planning
Leader, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF- 14
STAFF REQUEST FOR PRODUCTION NO. 12: Please provide further
explanation on the Near-Term Action Plan to "Install cost effective distribution-connected
storage between 2025 and 2028." Please provide examples the Company is considering
for distribution-connected storage locations and the assumed total amount of capacity in
MW to be acquired within the Action Plan. Additionally, please explain how the Company
will seek to receive Commission approval.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 12:
Further explanation and specific examples of the cost-effective distribution-
connected storage mentioned in the Near-Term Action Plan can be found in Table 5.1
and in the ‘Targeted Grid Storage’ section2 of the 2023 Integrated Resource Plan (“IRP”).
At this time, Idaho Power does not have any distribution-connected storage
projects planned for 2025 and beyond but is constantly evaluating various local needs to
see if distribution-connected storage could be a cost-effective solution. The Company
would seek approval for these projects in a future general rate case or other regulatory
proceeding where incremental distribution investments are under review.
The response to this Request is sponsored by Jared Ellsworth, Transmission,
Distribution & Resource Planning Director, Idaho Power Company.

2 Idaho Power’s 2023 Integrated Resource Plan, p. 57-58.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF- 15
STAFF REQUEST FOR PRODUCTION NO. 13: Please explain how much
available transmission capacity the Company assumed for each of the Gateway West
phases over the 20-year planning horizon.
a. Does the Company have contracts in place for each of the expected transmission
line phases?
b. Please provide supporting workpapers that detail the amount of transmission
capacity by year for the 20-year planning horizon.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 13:
Gateway West (“GWW”) Phase 1, which includes Midpoint-Hemingway #2
(Segment 8), Midpoint-Cedar Hill (Segment 10), and the Mayfield substation, is assumed
to increase Midpoint West and Boise East transmission path capabilities by approximately
2,000 megawatts (“MW”). Idaho Power has a one-third permitting interest in Segments
8 and 10, so the Company’s capacity is anticipated to be 667 MW for this phase. The
667 MW of capacity increase was assumed to enable 1,000 MW of incremental resources
on the system.
The Gateway West GWW Phase 2, which includes Cedar Hill-Hemingway
(Segment 9) and Cedar Hill substation, is assumed to increase the Midpoint West and
Boise East transmission path capabilities by approximately 2,000 MW. Similar to GWW
Phase 1 segments, Idaho Power has a one-third permitting interest, so the Company’s
capacity is anticipated to be 667 MW for this phase. The 667 MW of capacity increase
was also assumed to enable 1,000 MW of incremental resources on the system.
The third phase of GWW is a yet-to-be permitted transmission addition from
Midpoint-Mayfield and is expected to be a rebuild of an existing 230 kilovolt line. The

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF- 16
Company expects to own all the capacity for this upgrade and assumes 2,000 MW of
incremental resources will be enabled with this upgrade.
The Company offers the following in response to parts (a) and (b) of this request:
a. Idaho Power is currently in discussions with PacifiCorp regarding GWW
development. More precisely, the Company does not yet have a contract in place
with PacifiCorp for GWW construction sequencing and capacity allocation.
b. Please see Table 7.7 from the 2023 IRP for the detailed transmission capacity
modeled by year over the 20-year planning horizon.
The response to this Request is sponsored by Curtis Westhoff, System Consulting
Engineer, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF- 17
STAFF REQUEST FOR PRODUCTION NO. 14: In the November 2026 B2H
portfolio, the transmission capacity of Gateway West phase three ("GWW3") becomes
available in 2041, compared to 2040 in the preferred portfolio. Appendix C at 45. Please
explain why and how a delay in B2H results in a year delay in the availability of GWW3
from the preferred portfolio.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 14:
Gateway West phase three (“GWW3”) is available to integrate incremental solar
and wind resources as early as end-of-year 2039 in both portfolios. However, the
November 2026 B2H Valmy 1 & 2 portfolio did not select solar or wind resources in 2040
but, rather, built solar starting in 2041 and, therefore, necessitated the GWW3 addition in
2041 rather than 2040.
The response to this Request is sponsored by Curtis Westhoff, System Consulting
Engineer, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF- 18
STAFF REQUEST FOR PRODUCTION NO. 15: Please explain what the
Company assumed for customer generation adoption over the 20-year planning horizon
in the preferred portfolio. Please provide supporting workpapers that detail expected
customer generation growth by year for the 20-year planning horizon.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 15:
The Company uses a polynomial distributed lag model to forecast customer
generation adoption over the 20-year planning horizon. Unique model and training
assumptions are used for the residential, commercial, and irrigation classes. However,
no customer adoption forecast is created for the industrial class, as the current number
of industrial-class installations is one. This customer segmentation allows for model
assumptions and characteristics that are flexible to and reflective of each customer class.
Please see the attached Excel spreadsheet for the requested workpapers.
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 THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF- 19
STAFF REQUEST FOR PRODUCTION NO. 16: Please explain the Company's
assumptions for electric vehicle adoption over the 20-year planning horizon in the
preferred portfolio. Please provide supporting workpapers that detail expected electric
vehicle adoption growth by year for the 20-year planning horizon.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 16:
Over the 20-year planning horizon of the Preferred Portfolio, the Company expects
a twentyfold increase in the number of electric vehicles relative to 2022 in its anticipated
load forecast. This would represent a compound annual growth rate of 5.6 percent per
year in vehicle adoption. Please see the attached Excel spreadsheet for the requested
workpapers.
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 THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF- 20
STAFF REQUEST FOR PRODUCTION NO. 17: On page 31 of Appendix C, the
Company stated, "From IRP year 2030 and onward, weather modification levels in the
Upper Snake, Wood, and Boise River basins were increased due to an anticipation of
expanding the cloud seeding program." Please explain how the Company modeled the
expanded cloud seeding program within the 20-year planning horizon. Please provide
supporting workpapers that detail the expanded cloud seeding program.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 17:
Idaho Power’s current cloud seeding program aims to augment snowpack in the
middle and south forks of the Payette, the Boise, the Wood, and the Upper Snake River
basins. The Payette project is the longest running and most mature with respect to silver
iodide seeding equipment and weather instrumentation. As such, the Company used the
density of seeding equipment targeting the Payette as a basis to estimate the additional
equipment needed to expand the seeding capability in the Boise, Wood, and Upper Snake
basins to be on-par with the Payette. The additional equipment considered includes
remote ground silver iodide seeding generators and aircraft. The precipitation benefits
expected from built-out programs were estimated based on results in the middle and
south forks of the Payette and the ability to adequately target the rest of the basins.
Once the built-out precipitation benefits were estimated, the process for
determining the hydro resource impact followed the same modeling procedures as with
the current build-out precipitation benefits. However, the adjustments to the winter
precipitation were modified in the built-out years to reflect the increased precipitation
benefits of an expanded program.
Please see the attached Excel spreadsheet for supporting workpapers.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF- 21
The response to this Request is sponsored by Shaun Parkinson, Meteorology and
Cloud Seeding Leader, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF- 22
STAFF REQUEST FOR PRODUCTION NO. 18: Please explain why the Company
did not run a sensitivity analysis on a portfolio with the Southwest Intertie Project — North
("SWIP-N") transmission capacity in the 2023 IRP, like it did in the 2021 IRP.
a. Please provide an updated cost estimate to participate in SWIP-N with the same
assumptions made for the 2023 IRP preferred portfolio; and
b. Additionally, please provide the transmission capacity the Company assumed for
the SWIP-N project and any supporting documentation or workpapers.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 18:
The Company did not include a sensitivity analysis portfolio with Southwest Intertie
Project — North (“SWIP-N”) in the 2023 Integrated Resource Plan (“IRP”) report, because
the Company is in active discussions with the project developer regarding the potential
terms and conditions of Idaho Power’s participation in the project. Additionally, the
potential SWIP costs at the time of IRP modeling were highly speculative. As a result, the
Company was not comfortable using the information to inform a scenario.
a. An updated cost estimate is not yet available for SWIP-N. The Company is working
with the project developer, Great Basin Transmission, to produce an updated cost
estimate for the Company’s analysis. Should negotiations with the project
developer result in mutually acceptable terms and conditions, the SWIP-N cost
estimate would then be shared with Staff as part of this or a future filing.
b. The SWIP-N project has a Western Electricity Coordinating Council (“WECC”)
approved rating of 2,070 megawatts (“MW”) in the north-to-south direction and
1,920 MW in the south-to-north direction. NV Energy is entitled to some of this
capacity due to the FERC-filed Transmission Use Agreement between Great Basin

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF- 23
Transmission and NV Energy from previous development of the southern portion
of SWIP, the One Nevada line. Through this agreement, Great Basin Transmission
also gains a capacity entitlement on the One Nevada line that corresponds with
their capacity on SWIP-N. The expected available capacity on SWIP-N between
Great Basin Transmission and NV Energy is listed in the table below.
North to South Capacity South to North Capacity
Great Basin Transmission 1,117.5 MW 1072.5 MW
NV Energy 952.5 MW 847.5 MW
Total 2,070 MW 1,920 MW

Idaho Power is working with Great Basin Transmission to explore terms for an
interest in 500 MW of south-to-north capacity in the project. However, discussions
between Idaho Power and Great Basin Transmission are ongoing, and more details on
the potential SWIP-N arrangement will be shared when they become available.
The response to this Request is sponsored by Curtis Westhoff, System Consulting
Engineer, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF- 24
STAFF REQUEST FOR PRODUCTION NO. 19: Please explain if the 2023 IRP
preferred portfolio used the Western Resource Adequacy Program's ("WRAP") capacity
benefit of 14 MW as a reduction to its Planning Reserve Margin ("PRM") starting in 2027,
therefore reducing the amount of firm future resources needed. If so, please provide a
workpaper that shows the Company's PRM without WRAP's capacity benefit.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 19:
Yes, the Company includes the Western Resource Adequacy Program (“WRAP”)
capacity benefit in the 2023 Integrated Resource Plan (“IRP”) Preferred Portfolio starting
in 2027, the assumed date in which the Company will be a fully binding WRAP participant.
However, please also see the Company’s response to Staff’s Request for Production No.
23 in case No. IPC-E-23-08, Application for Participation in the WRAP:
As introduced in the Integrated Resource Plan (“IRP”)
Advisory Council meeting on March 9, 2023, and further
discussed in the Company’s discussion with Staff on June 14,
2023, Idaho Power is modeling WRAP’s benefit (associated
with leveraging the program one day per year) as a 14 MW
resource starting in year 2027 of the IRP’s 20-year planning
horizon. That is, the avoided capacity benefit of WRAP will
result in an approximate 14 MW reduction to the year’s
calculated resource need… WRAP will show up as a
reduction of generation need in the calculation of the PRM,
rather than a direct percentage reduction of the PRM.

Because the benefit associated with WRAP participation is included as an
estimated 14 MW reduction to the Company’s calculated capacity need rather than a
direct reduction to planning reserve margin (“PRM”), WRAP participation has a minimal
downward impact on PRM throughout the planning period.
Please see the attached Excel spreadsheet for recalculated annual capacity
positions for the Preferred Portfolio without WRAP.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF- 25
The response to this Request is sponsored by Jared Ellsworth, Transmission,
Distribution & Resource Planning Director, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF- 26
STAFF REQUEST FOR PRODUCTION NO. 20: Please provide a table similar to
Table 10.7 - July Peak Hour and Resource Balance as shown in the 2021 IRP on pages
142-143, updated for the 2023 IRP.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 20:
Idaho Power agreed upon an extension for Request No. 20 after a discussion with
Staff on Friday, November 17, 2023, to ensure the Company would be able to provide
information consistent with Staff’s expectations.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF- 27
STAFF REQUEST FOR PRODUCTION NO. 21: Please answer the following
regarding the 70th percentile energy load forecast and the 70th percentile peak load
forecast used in the 2023 IRP.
a. Please list all the study areas and the analysis models in the 2023 IRP where the
70th percentile of energy load forecast and the 70th percentile of peak load
forecast are used;
b. Please explain why and how the Company determined that the 70th percentile
energy load forecast was the right level to use for its planning case. Please provide
evidence and any workpapers to explain the answer; and
c. Please explain why and how the Company determined that the 70th percentile
peak load forecast was the right level to use for its planning case. Please provide
evidence and any workpapers to explain the answer.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 21:
a. The 70th percentile energy and 70th percentile peak forecast were used throughout
the 2023 Integrated Resource Plan (“IRP”) analysis except where otherwise noted
for scenarios such as “Extreme Weather.” Please note that for the Company’s
Reliability and Capacity Assessment Tool (“RCAT”), historical hourly load is
adjusted to reflect only the forecasted monthly 70th percentile peak loads.
b. The 70th percentile energy load forecast was utilized in response to the selection
of the 70th percentile peak load forecast for reliability purposes. The Company
considers it important to maintain consistency in the relationship between the
energy and peak load forecast percentiles.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF- 28
c. The adjustment to the 70th percentile peak load forecast was made in conjunction
with moving back to a 0.1 event-days per year Loss of Load Expectation (“LOLE”)
threshold from a 0.05 LOLE threshold. In response to Staff’s Comments on the
Company’s 2021 IRP in Case No. IPC-E-21-433, Idaho Power moved forward with
the combination of the 70th percentile peak load forecast and a 0.1 event-days per
year LOLE threshold for the 2023 IRP, as it produced similar reliability results when
compared to the combination of the 50th percentile peak load forecast and a 0.05
event-days per year LOLE threshold. Please see the attached Excel spreadsheet
for supporting workpapers.
The response to this Request is sponsored by Jared Hansen, Resource Planning
Leader, Idaho Power Company.

3 IPC-E-21-43, Staff’s Comments, p. 9 (“Instead of using a more stringent target to compensate for the
variability of weather, it is more appropriate to incorporate year-to-year variability in both the Company’s
load forecast and availability of hydro generation in its resource assumptions rather than assuming
average weather conditions in the IRP.”)

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF- 29
STAFF REQUEST FOR PRODUCTION NO. 22: The "Extreme Weather" scenario
listed on Page 128 of the 2023 IRP uses (1) 70th percentile energy and 95th percentile
peak load forecast, and (2) a mix of wet and dry cycles to replace 50th percentile of the
distribution. Please explain why and how the Company determined that these were the
proper levels to test extreme weather. Please provide evidence and any workpapers to
explain the answer.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 22:
To account for extreme weather events that have a probability of occurrence
outside of the base planning forecast, the Company used the 70th percentile energy and
95th percentile peak load forecast for the “Extreme Weather” scenario. As shown in Table
1 of Appendix A: Sales and Load Forecast4, the probability of exceeding a 95th percentile
peak demand forecast is one in twenty years, while the probability of exceeding a 70th
percentile peak demand forecast is three in ten years. Based on this analysis, the
Company is confident that the 95th peak load forecast, and its relative probability of
exceedance, reasonably represents a more extreme weather future compared to the base
planning forecast.
Additionally, the “Extreme Weather” scenario used a mix of wet and dry cycles to
replace the 50th percentile of the distribution used in the base planning hydrogeneration
forecast. This differing hydro forecast reasonably represents the potential to see more
year-to-year hydro variance caused by extreme weather. Because Idaho Power has
significant hydro resources, the hydro variance used in this scenario helped the Company
assess what resources could be needed in the future to mitigate potential extreme swings

4 Case No. IPC-E-23-23, Appendix A: Sales and Load Forecast, p.7, Table 1.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF- 30
in hydro output from year-to-year.
The response to this Request is sponsored by Jared Hansen, Resource Planning
Leader, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF- 31
STAFF REQUEST FOR PRODUCTION NO. 23: Please respond to the following
questions regarding natural gas forecasts used in the AURORA LTCE model and in the
AURORA dispatch model.
a. Please explain whether different zones in the AURORA model use different gas
hub forecasts across the Western Electricity Coordinating Council region.
b. Please identify the sources of data and adjustments used for each hub forecast in
the model; and
c. Does the Idaho Power zone only use the Henry Hub long-term forecast, adjusted
for the basis differential and transportation costs from Sumas, Washington? If not,
what other hub forecasts are used for the Idaho Power zone?
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 23:
a. The gas forecast used within AURORA for both the Long-Term Capacity
Expansion (“LTCE”) and portfolio costing analysis is a forecast of the Henry Hub
natural gas spot market. Once the base forecast is established, differentials are
applied to the Henry Hub price to approximate regional differences in the gas
market based on different natural gas trading hubs.
b. The differentials are based on the AURORA default Western Electricity
Coordinating Council (“WECC”) model with the exception of the Sumas
(Washington state) and Opal (Wyoming) natural gas trading hubs. For Sumas and
Opal, a forecast differential is applied based on the Platts forecast.
c. The Idaho Power zone uses two basis differentials. The Jim Bridger plant, once
converted to gas, is modeled using the Opal basis plus a transportation fee

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF- 32
because of its location closest to that trading hub. The remaining Idaho Power gas
plants are based on the Sumas basis plus an associated transport fee.
The response to this Request is sponsored by Jared Hansen, Resource Planning Leader,
Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF- 33
STAFF REQUEST FOR PRODUCTION NO. 24: Page 111 of the 2023 IRP states
that "Idaho Power also relied on EIA's alternative forecasts (High Oil and Gas Supply,
and Low Oil and Gas Supply) from their Annual Energy Outlook 2023 to examine the
impact of gas prices on the IRP." Please respond to the following for the AURORA LTCE
model and in the AURORA dispatch model.
a. Please explain the purpose of using the EIA forecasts and why these forecasts are
reasonable alternatives; and
b. Please explain whether the EIA forecasts are adjusted in the same way as the
Platt's forecasts (i.e., to reflect different basins, transport costs, etc.)
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 24:
a. The United States Energy Information Administration (“EIA”) forecasts show the
Long-Term Capacity Expansion (“LTCE”) build-out and dispatch cost differences
created by both a greater and lesser forecast natural gas price. The EIA forecasts
also validate the stochastic gas price forecast spread. Idaho Power considers
these forecasts reasonable because the EIA is an respected provider of energy-
related forecasts, their source is consistent with the acknowledged 2021 Integrated
Resource Plan (“IRP”), and consistent with the data presented to the IRP Advisory
Council (“IRPAC”) and feedback received.
b. The alternative EIA forecasts are used as the input to the Henry Hub forecast with
the same process to create the regional forecasts as described in the Company’s
response to Request No. 23.
The response to this Request is sponsored by Jared Hansen, Resource Planning
Leader, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF- 34
STAFF REQUEST FOR PRODUCTION NO. 25: Please explain why "California
Energy Commission's Integrated Energy Policy Report Preliminary GHG Allowance Price
Projections" is a reasonable planning condition. Also, please explain how this adder is
applied in the AURORA LTCE model and the AURORA dispatch model.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 25:
Idaho Power continues to use the “California Energy Commission's Integrated
Energy Policy Report Preliminary GHG Allowance Price Projections” because it remains
one of the few established carbon pricing policies in the United States. Throughout the
development of the 2023 Integrated Resource Plan (“IRP”), Idaho Power monitored
developments in carbon price projections but did not find a new source that provided
meaningful improvements or more established policy to the California Energy
Commission’s planning condition carbon price forecast, as used in the 2021 IRP. The
Company also presented this data to the IRP Advisory Council (“IRPAC”) and reached
alignment on using this forecast as a reasonable planning condition.
The carbon price forecast is a variable dollar per ton (“$/ton”) of emissions adder
to carbon emitting resources in both the AURORA Long-Term Capacity Expansion
(“LTCE”) and portfolio costing model in the planning conditions-based portfolios.
The response to this Request is sponsored by Jared Hansen, Resource Planning
Leader, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF- 35
STAFF REQUEST FOR PRODUCTION NO. 26: Please explain why "Social Cost
of Carbon, Methane, and Nitrous Oxide, Interim Estimates under Executive Order 13990"
is a reasonable high carbon adder. Also, please explain how this adder is applied in the
AURORA LTCE model and the AURORA dispatch model.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 26:
Similar to the Company’s response to Request No. 25, Idaho Power continues to
use the “Social Cost of Carbon, Methane, and Nitrous Oxide, Interim Estimates under
Executive Order 13990” because it remains one of the few established carbon pricing
policies in the United States. Absent federal legislation or a federal agency mandate,
Idaho Power is confident that the carbon pricing information provided by the United States
Government is the best option for a high-carbon case. The Company also presented this
data to the IRP Advisory Council (“IRPAC”) and reached alignment on using this forecast
as a reasonable high carbon adder.
The carbon price forecast is a variable dollar per ton (“$/ton”) of emissions adder
to carbon emitting resources in both the AURORA Long-Term Capacity Expansion
(“LTCE”) and portfolio costing model in the high carbon conditions-based portfolio.
The response to this Request is sponsored by Jared Hansen, Resource Planning
Leader, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF- 36
STAFF REQUEST FOR PRODUCTION NO. 27: Page 128 of the 2023 IRP states
the policy conditions in Idaho that have resulted in no Idaho-based Public Utilities
Regulatory Policy Act ("PURPA") projects in recent years. Please respond to the
following:
a. What does "recent years" mean?
b. Does Idaho-based PURPA projects in the statement mean both Surrogate Avoided
Resource ("SAR")-based projects and IRP-based projects?
c. Has the analysis considered Oregon-based PURPA projects? Why?
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 27:

a. “Recent years” refers to the past five years.
b. The statement primarily refers to Incremental Cost Integrated Resource Plan
(“ICIRP”)-based projects, as the Company has not had any new ICIRP-based
projects develop in its Idaho service area since prior to January 1, 2018. However,
Idaho Power has had three new Surrogate Avoided Resource (“SAR”)-based
projects come online since 2018.
c. No, only Idaho-based projects were considered in this statement as Idaho’s Public
Utility Regulatory Policies Act of 1978 (“PURPA”) contracting rules differ from
Oregon’s. Idaho Power has had five new qualifying facilities come online in Oregon
since 2018, four of which were ICIRP-based and one of which was SAR-
methodology-based.
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 THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF- 37
STAFF REQUEST FOR PRODUCTION NO. 28: Page 128 of the 2023 IRP states
that for the "New Forecasted PURPA" scenario, the PURPA wind renewal rate is set at
100% and new PURPA contracts are modeled at an additional 57 MW each year, starting
in 2028. Please confirm that both the 100% renewal rate and the additional 57 MW starts
in 2028.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 28:
For the “New Forecasted PURPA” scenario, the 100 percent renewal rate was
assumed to begin in 2025 as existing wind contracts expire. Meanwhile, the additional 57
megawatts of development was assumed to begin in 2028.
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 THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF- 38
STAFF REQUEST FOR PRODUCTION NO. 29: Page 128 of the 2023 IRP states
that the 57 MW of forecasted PURPA resources was derived by identifying the average
amount of new PURPA development the Company experienced over the ten-year period
from 2012 through 2021. Please explain whether this analysis considers Idaho-based
PURPA projects, Oregon-based PURPA projects or both. Also, please explain whether
this analysis considers both the SAR-based projects and IRP-based projects.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 29:
The analysis considered all Public Utility Regulatory Policies Act of 1978
(“PURPA”) projects across Idaho Power’s service area, without differentiation based on
state or pricing methodology. While actual development has varied based on those
parameters, future development could differ from historical. Thus, the generalized
analysis was reasonable for this scenario.
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 THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF- 39
STAFF REQUEST FOR PRODUCTION NO. 30: Page 162 of the 2023 IRP states
that Idaho Power applied the new Qualified Facility development assumptions after the
Action Plan window, starting in 2029, to prevent distorting resource selection in the critical
near-term window and inaccurately reshaping actions for regulatory acknowledgement.
In addition, page 126 of the 2023 IRP states that the purpose of different future scenarios
is to compare "the resources selected in the Preferred Portfolio, developed under
planning constraints and conditions, to resources selected in other possible scenarios.
This is especially useful for near-term resources." Please respond to the following:
a. If the "New Forecasted PURPA" scenario applies after the near-term window,
please explain whether the purpose of a future scenario is defeated; and
b. Please explain why the Company is concerned with distorting resource selection
and inaccurately reshaping actions for regulatory acknowledgement from the "New
Forecasted PURPA" scenario, but not from other scenarios such as "Extreme
Weather", which eventually impacts resource selections starting in 2026 inside the
Action Plan window.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 30:
As an initial matter, Idaho Power performed the new PURPA scenario because it
is a requirement from the Public Utility Commission of Oregon Order No. 23-004 adopting
Staff Recommendation 24. The Company would not have conducted this particular
scenario were it not for this directive, but as a result of the requirement, the Company
endeavored to identify the best way to develop the scenario without distorting the
selection of resources within the model.
a. The “New Forecasted PURPA” scenario illustrates that an additional forecasted

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF- 40
amount of Public Utility Regulatory Policies Act of 1978 (“PURPA”) reduces deficits
on the system, which, in turn, reduces the need for similar types of identified
resources5. These findings are relevant regardless of the timing of the additional
PURPA forecast. While it is true that a direct comparison of the “New Forecasted
PURPA” scenario to other scenarios or the Preferred Portfolio may not illustrate
resource differences in the near-term, the scenario still allows for a comparison of
resource selections in later years.
b. The “New Forecasted PURPA” scenario is unique among the other scenarios
analyzed in the IRP because it is the only case in which the Company artificially
forces a particular type of resource contract to be selected in the model. To be
clear, resources selected in any other portfolio could be PURPA projects—
resources in AURORA are defined by their resource characteristics not by
procurement mechanism. The Company has not historically, and does not in this
IRP, require resources to be selected based on a particular contract arrangement.
Considering this, this scenario is also unique in the IRP in that it decreases the
system deficit. The purpose of the other scenarios is to determine what changes
Idaho Power would need to make to meet the identified increased demand. “New
Forecasted PURPA” has the opposite effect; resource selections are decreased
because the scenario assumes a particular type of resource contract is developed
in a particular timeframe—Idaho Power’s development of this scenario is purely
speculative, as the Company does not control when or if a PURPA project will be
brought to the Company. Thus, relying on this scenario could have serious and

5 Idaho Power’s 2023 Integrated Resource Plan, p. 162

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF- 41
negative implications for actual procurement of resources to meet capacity
needs—all based on the unproven assumption that additional PURPA resources
will be developed. If, in the future, those hypothetical PURPA resources do not
materialize, Idaho Power would then need to procure additional resources to meet
its forecast load obligations, but with a shortened notice timeline relative to the
need. Increasing the procurement need, with less time to fill it, creates reliability
risk.
In the alternative, if Idaho Power does not make an assumption regarding
future PURPA development, all else being equal, resource selections to meet load
in the Integrated Resource Plan (“IRP”) will be greater. If PURPA resources
actually are developed closer to the time of need, Idaho Power will be able to then
decrease its resource procurements at that time. Because decreasing the quantity
of resource procurement is much easier in the near-term than increasing
procurement needs, the Company is concerned about emphasis on this scenario
outcome which may underestimate procurement needs.
The response to this Request is sponsored by Jared Hansen, Resource Planning
Leader, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF- 42
STAFF REQUEST FOR PRODUCTION NO. 31: Page 125-126 and Figure 9.2 list
ten Portfolio Options. Please explain why Valmy conversions need to be individually
specified and tested, and why the Company does not let the AURORA model select
conversion decisions.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 31:
Given the importance of the Valmy conversion decision and the relative timing in
the action plan window, Idaho Power felt it was important to test and analyze the full
combination of conversion scenarios to determine the optimal conversion strategy under
planning conditions. By testing each combination and the validation and verification runs
used to confirm the optimal strategy, Idaho Power is confident that the selected
conversion is least cost and least risk.
The response to this Request is sponsored by Jared Hansen, Resource Planning
Leader, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF- 43
DATED at Boise, Idaho, this 22nd day of November 2023.

LISA NORDSTROM
Attorney for Idaho Power Company

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF- 44
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the 22th day of November 2023, I served a true and
correct copy of Idaho Power Company’s Response to the First Production Request of
the Commission Staff upon the following named parties by the method indicated below,
and addressed to the following:

Commission Staff
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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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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________________________________
Christy Davenport
Legal Administrative Assistant