20231213IPC to Staff 1-12.pdf

LISA D. NORDSTROM
Lead Counsel
[e-mail]

December 13, 2023

VIA ELECTRONIC FILING

Commission 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-23-31
In the Matter of the Application of Idaho Power Company for an Order
Approving the Transfer of Certain Assets Associated with Transmission
Plant Held for Future Use

Dear Commission Secretary:

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

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

Very truly yours,

Lisa D. Nordstrom

LDN:sg
Enclosures
RECEIVED
2023 DECEMBER 13, 2023 1:20PM
IDAHO PUBLIC
UTILITIES COMMISSION
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST
OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 1
LISA D. NORDSTROM (ISB No. 5733)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
[e-mail]

Attorney for Idaho Power Company

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR AN
ORDER APPROVING THE TRANSFER
OF CERTAIN ASSETS ASSOCIATED
WITH TRANSMISSION PLANT HELD
FOR FUTURE USE.
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CASE NO. IPC-E-23-31

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

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 22, 2023, herewith submits the following information:
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST
OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 2
REQUEST FOR PRODUCTION NO. 1: Please provide the signed Purchase and
Sale Agreement that details the "Intentionally Deleted" portions for the following sections:
a. 8.3.3;
b. 8.7; and
c. 8.8.
RESPONSE TO REQUEST FOR PRODUCTION NO. 1: Idaho Power utilizes a
standard Purchase and Sale Agreement template whenever possible. Because Sections
8.3.3, 8.7 and 8.8 were not applicable to this transaction, these items were removed from
this Purchase and Sale Agreement.
The response to this Request is sponsored by Chris Jacky, Senior Real Estate
Specialist, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST
OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 3
REQUEST FOR PRODUCTION NO. 2: Please provide a list of all assets, including
land and improvements, included in the transfer by ID, year in service, installed valuation,
and current book value.
RESPONSE TO REQUEST FOR PRODUCTION NO. 2: In 1985, Idaho Power
purchased 150.03 acres of land in Valley County, Idaho from Union Pacific Railroad
Company. This land is associated with Idaho Power asset identification number
000000036435 with an original cost of $100,126.00, reflecting the $100,000.00 purchase
price of the land and $126.00 in related transaction costs. See Attachment 1 – Response
to Request No. 2 for a copy of the 1985 Purchase and Sale Agreement with Union Pacific
Railroad Company.
There are no additional assets associated with the transaction and there have
been no improvements to the land since Idaho Power’s initial purchase. The Company
has, however, conveyed portions of the 150.03 acres of land since the original purchase
therefore the current book value of the remaining 59.40 acres of land is $63,748.47.
The response to this Request is sponsored by Donna Wheeler, Property
Accounting Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST
OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 4
REQUEST FOR PRODUCTION NO. 3: Are additional transfers planned in the
general vicinity of this proposed transfer? If so, please provide an explanation of potential
transfers, location, and when they may occur.
RESPONSE TO REQUEST FOR PRODUCTION NO. 3: No additional transfers
are planned in the general vicinity of this transaction as no additional property owners
have approached Idaho Power about the potential purchase of land.
The response to this Request is sponsored by Chris Jacky, Senior Real Estate
Specialist, Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST
OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 5
REQUEST FOR PRODUCTION NO. 4: Please provide an explanation and any
supporting evidence that the following requirements of Idaho Code § 61-328(3) are
satisfied:
a. That the transaction is consistent with the public interest;
b. That the cost and rates for supplying service will not be increased by reason of
such transaction.
RESPONSE TO REQUEST FOR PRODUCTION NO. 4:
a. This transaction is in the public interest as it relieves the Company of ownership
and maintenance responsibilities of the land while still allowing for use of the
land for its intended purpose, not impacting Idaho Power’s ability to provide
safe, efficient, and reliable service to customers.
b. As evidenced by the proposed journal entries provided as Attachment 2 to the
Application, if no additional expenses are recorded, the Company anticipates
a gain associated with this transaction. Therefore, the cost of and rates for
supplying service will not be increased by this transaction.
The response to this Request is sponsored by Matt Larkin, Revenue Requirement
Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST
OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 6
REQUEST FOR PRODUCTION NO. 5: Please provide supporting documentation
for the original purchase price and acreage of the land purchased in 1985 and at issue in
this case.
RESPONSE TO REQUEST FOR PRODUCTION NO. 5: Please refer to
Attachment 1 – Response to Staff Request No. 2 for the 1985 Purchase and Sale
Agreement with Union Pacific Railroad Company. In addition, Attachment 1 – Response
to Staff Request No. 5 includes a copy of the Quitclaim Deed associated with the
purchase.
The response to this Request is sponsored by Chris Jacky, Senior Real Estate
Specialist, Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST
OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 7
REQUEST FOR PRODUCTION NO. 6: Please indicate if any of the land referred
to in this case is currently used and useful.
RESPONSE TO REQUEST FOR PRODUCTION NO. 6: The land referred to in
this case is classified within Federal Energy Regulatory Commission (FERC) Account
105, Electric Plant Held for Future Use. The Company has plans to utilize portions of this
Valley County land acquired from Union Pacific Railroad Company for future transmission
lines in the coming years. At times, the Company must acquire land in advance of
construction to continue to provide safe, efficient, and reliable electric service to
customers.
The response to this Request is sponsored by Matt Larkin, Revenue Requirement
Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST
OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 8
REQUEST FOR PRODUCTION NO. 7: Please indicate if there are current plans
to use the easement rights in the future.
RESPONSE TO REQUEST FOR PRODUCTION NO. 7: Currently, Idaho Power
does not have specific plans to utilize the transmission easement rights associated with
the land subject to sale. However, the Company will retain the associated easement
rights, with an estimated historical value of $660.02 (reference the Company’s Response
to Request No. 11), for potential future use.
The response to this Request is sponsored by Matt Larkin, Revenue Requirement
Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST
OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 9
REQUEST FOR PRODUCTION NO. 8: Please indicate how the value of the
$1,320.04 was calculated for plant held for future use.
RESPONSE TO REQUEST FOR PRODUCTION NO. 8: The value of $1,320.04
for the land subject to sale was derived based upon the current cost per acre of the
remaining land asset. The current book value of the remaining 59.40 acres of land is
$63,748.47, resulting in a $1,073.21 per acre value. Applying the $1,073.21 per acre
value to the 1.23 acres subject to sale yields the $1,320.04 transaction value.
The response to this Request is sponsored by Donna Wheeler, Property
Accounting Manager, Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST
OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 10
REQUEST FOR PRODUCTION NO. 9: Please explain how the values of $30 and
$1,000 for closing costs and selling costs were determined. Please provide supporting
documentation.
RESPONSE TO REQUEST FOR PRODUCTION NO. 9: The $30 in closing costs
represents the Company’s estimated cost for recording the deed. Costs for deed
recording are based upon the number of pages, with the price of the first page being $15
and each additional page is $3 per State of Idaho recording requirements.
The $1,000 in selling costs represents estimated internal real estate labor costs
associated with coordinating and facilitating the sales transaction. An hourly labor rate of
$65 was applied to the estimated 15 labor hours, yielding approximately $1,000 in
estimated internal labor costs associated with this sales transaction.
The response to this Request is sponsored by Chris Jacky, Senior Real Estate
Specialist and Donna Wheeler, Property Accounting Manager, Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST
OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 11
REQUEST FOR PRODUCTION NO. 10: Please explain how the sale price of
$2,000 was determined. Please provide supporting documentation.
RESPONSE TO REQUEST FOR PRODUCTION NO. 10: The agreed upon sale
price of $2,000 was developed based upon an estimate of agricultural land in Valley
County, which appears to be in the range of $3,500 – $7,500 per acre. Due to the irregular
shape of the property and Idaho Power’s reserved transmission easement, the market
value of the property subject to sale is substantially reduced to an amount closer to the
agreed upon $2,000 sales price for 1.23 acres.
The response to this Request is sponsored by Chris Jacky, Senior Real Estate
Specialist, Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST
OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 12
REQUEST FOR PRODUCTION NO. 11: Please explain how the value of the
easement of $660.02 was calculated. Please provide supporting documentation.
RESPONSE TO REQUEST FOR PRODUCTION NO. 11: The estimated value of
the easement to be retained by Idaho Power is based upon the Company’s remaining
historical book value of the land and estimated transmission line easement valuation. To
value transmission line easements, the Company applies a 50 percent reduction to the
land owned in fee valuation. Applying this 50 percent reduction to the Company’s
remaining historical book value of the associated land asset subject to sale of $1,320.04
(reference the Company’s Response to Request No. 8) yields the $660.02 estimated
historical value of the transmission easement to be retained by Idaho Power.
The response to this Request is sponsored by Donna Wheeler, Property
Accounting Manager, Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST
OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 13
REQUEST FOR PRODUCTION NO. 12: Please clarify what would happen if the
land were to be used for farming and the Company needed to install a structure, such as
a tower, where crops are located.
a. Would the Company be able to build where crops or other obstacles are located?
b. Would the Company be required to reimburse the Buyer for damages?
RESPONSE TO REQUEST FOR PRODUCTION NO. 12: Idaho Power will be
retaining an easement over the entire disposed property and will have the right to install,
maintain, and operate any future electrical facilities. When installation of electrical
equipment takes place, the Company would apply customary working procedures which
entail working closely with landowners to coordinate around current crop or grazing uses.
There would be no requirement to reimburse the property owner when installation of
electrical equipment occurs.
The response to this Request is sponsored by Chris Jacky, Senior Real Estate
Specialist, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST
OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 14
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on this 13th day of December 2023 I served a true and
correct copy of foregoing Idaho Power Company’s Response to the First Production
Request of the Commission Staff to Idaho Power Company upon the following named
parties by the method indicated below, and addressed to the following:

Commission Staff
Adam Triplett
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]

Stacy Gust
Regulatory Administrative Assistant

BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-23-31
IDAHO POWER COMPANY
REQUEST NO. 2
ATTACHMENT 1
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-23-31
IDAHO POWER COMPANY
REQUEST NO. 5
ATTACHMENT 1