20160701Reply Comments.pdf

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An IDACORP CompanvRECEIVED
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JULIA A. HILTON
Senior Counsel
[e-mail]
July 1 ,2016
VIA HAND DELIVERY
Jean D. Jewell, Secretary
ldaho Public Utilities Commission
472 West Washington Street
Boise, ldaho 83702
Re: Case No. IPC-E-16-06
Compliance-Filing Request Regarding Accounting Treatment of Exchange of
Certain Transmission Assets with PacifiCorp - ldaho Power Company's
Reply Comments
Dear Ms. Jewell:
Enclosed for filing in the above matter please find an original and seven (7) copies
of ldaho Power Company's Reply Comments.
JAH:csb
Enclosures
1221 W. ldaho St. (83702)
P.O. Box 70
Boise, lD 83707
Very truly yours,
JULIA A. HILTON (lSB No. 7740)
Idaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
i h i lton@ idahopower. com
Attorney for ldaho Power Company
IN THE MATTER OF IDAHO POWER'S
COMPLIANCE-FI LING REQUEST
FOLLOWING THE COMMISSION'S PRIOR
APPROVAL FOR THE COMPANY TO
EXCHANGE CERTAIN TRANSMISSION
ASSETS WITH PACIFICORP
fi[CEIVED
:116 JUL - I Pl{ l+: 02
II ,r'l .lr'i;iSSiCN
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-16-06
IDAHO POWER COMPANY'S
REPLY COMMENTS
ldaho Power Company ("ldaho Power" or "Company") respectfully submits the
following Reply Comments in response to comments filed by the ldaho Public Utilities
Commission ("Commission") Staff ("Staff') on June 9, 2016. ln these Reply Comments,
Idaho Power wishes to clarify or respond to Staff's recommendation regarding the
appropriate changes in transmission revenues associated with the asset exchange to
record in the regulatory deferral account. ldaho Power believes there are two options
that would lead to afair outcome in this proceeding: (1) accept Idaho Power's filing,
which tracks both increases and decreases in transmission revenues resulting
specifically from the transaction as compliant with Order No. 33313 or (2) eliminate the
IDAHO POWER COMPANY'S REPLY COMMENTS - 1
requirement to track and record any changes in transmission revenues resulting from
the transaction and instead address all changes to transmission revenues at the time
ldaho Power files its next general rate case.
I. BACKGROUND
On December 19, 2014, ldaho Power filed an application in Case No.
IPC-E-14-41 requesting Commission approval of the exchange of certain transmission
assets between ldaho Power and PacifiCorp as required under ldaho Code S 61-328.
Among other things, ldaho Code S 61-328 requires that the "cost and rates of existing
electric service in the state of ldaho" are not increased due to the transaction. ln its
Application, the Company requested approval of the asset exchange pursuant to ldaho
Code S 61-328 and did not request any regulatory accounting treatment associated with
changes in transmission revenues that would result from the transaction.
ln its Comments in Case No. IPC-E-14-41, Commission Staff stated that retail
rates of existing service in ldaho would not be increased by the transaction as required
by ldaho Code. Staff Comments at g. Staff then went into detail about the future
expected increase in the Open Access Transmission Tariff (.OATT') transmission
formula rate for ldaho Power, which would ultimately result in a greater revenue credit
for retail customers in future general rate case proceedings. Rather than wait until
ldaho Power files a general rate case, Staff advocated that ldaho Power retail
customers should gain benefits of the increased OATT transmission formula rate as
soon as benefits occur. Unfortunately, this approach does not take into account the
initial reduction in revenue associated with the transaction-it would isolate and track
IDAHO POWER COMPANY'S REPLY COMMENTS - 2
only specific benefits associated with the change in transmission revenues as a result of
the asset exchange.
ln its Reply Comments in Case No. IPC-E-14-41, ldaho Power addressed Staffs
position. ldaho Power explained that Staff's proposal did not take into account both
increases and decreases in transmission revenues that result from the asset exchange.
Furthermore, ldaho Power explained that if the Federal Energy Regulatory Commission
("FERC") did not approve ldaho Power's then pending proposed OATT transmission
formula rate change, the benefits of the asset exchange may be delayed, resulting in a
near term under recovery of transmission costs by Idaho Power.
On June 5, 2015, the Commission issued Order No. 33313 in Case No.
IPC-E-14-41 authorizing the exchange of transmission assets between ldaho Power
and PacifiCorp, finding that "rates will not increase as a direct result of the transaction."
Order No. 33313 at 12. ln its order approving the asset exchange, the Commission
stated:
We agree that the financia! benefits of the exchange in this
case should be flowed to customers. However, consistent
with our prior Order No. 32821 [footnote omitted], we find
that a base level of third-party transmission revenues must
first be established through a general rate case before
changing the PCA methodology. We also want to be
consistent with Order No. 32540, in which we allowed
recovery of transmission costs associated with the
ratemaking treatment of three Legacy Agreements in a
FERC transmission rate case.
".t,oli3rl',-tXlil:fl 'J:iJ*i:::i[?%:']:*#""#;
revenues resulting specifically from the transaction and its
resulting change in the OATT rates."
ld. at 13 (emphasis added).
IDAHO POWER COMPANY'S REPLY COMMENTS - 3
On February 19, 2016, in compliance with Order No. 33313, ldaho Powerfiled
final asset exchange documents as well as a request for verification that its regulatory
accounting method for tracking the changes in transmission revenues resulting from the
asset exchange with PacifiCorp meets the requirements of the Commission's Order.
The Commission processed ldaho Power's request for verification as an application and
opened this case to review the Company's accounting treatment.
II. CHANGES IN TRANSMISSION REVENUES RESULTING
FROM THE ASSET EXCHANGE
ldaho Power's transmission formula rate for transmission service provided under
its OATT is determined using data from the most recent calendar year ending
December 31. The transmission formula rate is updated annually and in effect for the
following October 1 through September 30 time period. ln an attempt to minimize
regulatory lag associated with transmission revenue changes resulting from the asset
exchange, ldaho Power petitioned FERC for authorization to apply a one-time known
and measurable adjustment to the inputs of its transmission formula rate. This
adjustment would have resulted in an increase in the transmission formula rate charged
to all ldaho Power transmission customers taking OATT service, effective October 30,
2015. FERC declined to authorize an adjustment stating that ldaho Power's formula
rate did not allow for a one-time adjustment. Therefore, the full impact of the asset
exchange will not be reflected in the transmission formula rate until October 2017.
ln its Comments, Staff indicated that it believes the Company had the option to
revise the current OATT transmission formula rate in order to reduce the Company's
unrecovered revenues as a result of the transaction, but such an option would not have
resulted in a change prior to October 2017. ln order for ldaho Power to include fonruard-
IDAHO POWER COMPANY'S REPLY COMMENTS.4
looking adjustments in its OATT transmission formula rate, the Company would be
required to make a filing with FERC under Section 205 of the Federal Power Act. This
filing would open all components of ldaho Power's transmission formula rate for review
or challenge. FERC is required to publish all Section 205 filings in the Federal Register
and allow 21 days for intervention and protests. Following interventions and protests,
FERC generally has 180 days to issue an order in the docket, but as ldaho Power has
experienced, resolution in some cases can take much longer. ln FERC Docket No.
ER06-787, ldaho Power requested to move to an annually updated transmission
formula rate for determining transmission revenue requirement amounts. lt took nearly
three years to resolve all issues in the case.
ln Case No. IPC-E-14-41, ldaho Power proposed to offset retail customers'
revenue requirements with revenue credit amounts that incorporate the benefits of the
changes in the transmission revenues when the Company files its next general rate
case. Similarly, ldaho Power's Application in this case, verification that its regulatory
accounting is in compliance with Order No. 33313, was not a request for a change in
customer rates; instead, ldaho Power believes that a general rate case is the
appropriate time to adjust rates for the changes in transmission revenues because the
net impact in transmission revenues can be incorporated into the revenue credit applied
to retail customers' revenue requirement amounts.
Idaho Power's Application in this case detailed the four components of
transmission revenues that would change as a result of the transaction: Transmission
Facilities revenues, Long-term Point-to-Point ("PTP") Transmission Service revenues,
Network Transmission Service revenues, and Short-term/Non-firm Transmission
IDAHO POWER COMPANY'S REPLY COMMENTS - 5
Service Revenues. ldaho Power computed revenues in each of the categories with and
without an asset exchange scenario to quantify changes to transmission revenues
associated with the transaction. Although FERC's Order regarding ldaho Power's
requested adjustment to its formula rate prevented an immediate change in the
transmission formula rate charged to customers for PTP service, the Company
experienced immediate changes in other transmission revenues in 2015 as a result of
the asset exchange a $2.34 million decrease in Transmission Facilities revenues, a
$1.2 million increase in Long-term PTPTransmission Service revenues, and a $45,000
increase in Network Transmission Service revenues, for a total net decrease of $1.1
million in transmission revenues for the period November 1, 2015, through December
31, 2015. The primary driver of the net decrease in transmission facilities revenues is
the termination of numerous agreements between ldaho Power and PacifiCorp through
which the Jim Bridger power plant and associated transmission assets were owned and
operated (the "Legacy Agreements"). Transmission Facilities revenues from the Legacy
Agreements, a component of the revenue credit currently included in retail customers'
rates, ceased upon closing of the asset exchange and are identified on Line 1 of
confidential Attachment 3 to the Company's Application in this case, a component of the
Transmission Facilities revenues.
ldaho Power was aware and notified the Commission of the potential that the
Company would initially experience a decrease in transmission revenues and that the
decrease would last for a longer period if FERC denied ldaho Power's request for a
one-time known and measurable adjustment to the inputs of the OATT transmission
formula rate. As detailed in Exhibit No. 1 to Lisa Grow's testimony filed with the
IDAHO POWER COMPANY'S REPLY COMMENTS - 6
Application in Case No. IPC-E-1441, the loss in the near term is more than offset by
the gain over the long run. This was confirmed by Staff in its Comments in this case,
which state, "[t]he Company did not originally request deferral of transmission revenue
losses and Staff believes any such loss was factored in to the overall benefit of the
asset exchange." Staff Comments at 5. However, ultimately the Commission ordered
ldaho Power to establish a regulatory deferral account to track changes in transmission
revenues as a result of the asset exchange. Order No. 33313 at 13.
III. IDAHO POWER'S REPLY
A. ldaho Power's Long-Term Approach to Business Decisions.
ldaho Power believes it is important to elaborate upon information it provided in
Case No. IPC-E-14-41 because it demonstrates ldaho Power's commitment to making
business decisions that benefit its customers in the long term. ldaho Power is
concerned with Staffs assertion that it may not have recommended approval of the
asset exchange had it been aware that the asset exchange might, as Staff phrases it,
"in the short term . harm retail customers." Staff Comments at 4. ldaho Power
included Exhibit No. 1 to Lisa Grow's testimony in Case No. IPC-E-14-41 in order to
demonstrate that the transaction would result in an increase in the annual revenue
requirement in 2015 because of lower transmission revenues. In confidential
Attachment 6 provided with ldaho Power's response to the lndustrial Customers of
ldaho Power's Request for Production No. 15 in Case No. IPC-E-1441, the Company
explained the changes in transmission revenues, summarizing that "the financial
summary of this transaction is a modest near-term reduction in revenues followed by
increased overall revenues which net to the positive by the end of year three" and that
IDAHO POWER COMPANY'S REPLY COMMENTS. T
"these benefits from transmission customers will be reflected in lower retail rates and
associated revenues once they are included in fidaho Power's] next general retai! rate
cases." Such a long-term approach is ultimately beneficia! to customers and the
Commission found that costs would not increase as a result. Order No. 33313 at 12.
Staffs comments regarding harm to retai! customers indicate a misunderstanding
of the Company's intent. Staff also states that it does not believe the Commission
"intended the Company to defer unrecovered transmission related revenue, nor does
Staff believe these losses should be borne by retail customers." Staff Comments at 5.
ldaho Power did not propose an approach that would harm retail customers. ldaho
Power's Application in Case No. IPC-E-1441outlined an approach where the Company
would incorporate changes in transmission revenues as a result of the asset exchange
when ldaho Power files its next general rate case. ldaho Power agrees with Staff that
losses associated with the transaction should not be borne by retail customers; it was
not, nor was it ever, the intent of the Company for the transaction to result in an
increase to customer rates. ldaho Power was aware that there would be an initial
decrease in transmission revenues, and the loss in the near term would be more than
offset by the gain over the long term. Should the Commission choose to accept ldaho
Power's methodology outlined below to track al! transmission revenue components that
change as a result of the transaction, the Company wil! commit to not requesting
approval of the recovery of accumulated net reductions in transmission revenues
resulting from the transaction until the deferral tracking changes in the transmission
revenues turn positive, resulting in a net benefit to customers.
IDAHO POWER COMPANY'S REPLY COMMENTS. S
ldaho Power routinely makes business decisions based upon the customer
impact over the long term. ln this case and in Case No. IPC-E-15-17, as a result of
ldaho Power's request for approval of a long-term maintenance program contract with
Siemens Energy, lnc., the Company incurred higher costs in the near term in order to
obtain substantial benefits for customers in the long term. ln Case No. IPC-E-15-17,
ldaho Power illustrated that, without approval, the Commission would create a financial
disincentive for the Company to look for opportunities to manage its costs over the long
term. Ultimately, the Commission found merit in ldaho Power's request, granting
approval of the long-term program contract. Order No. 33391. The circumstances
surrounding the asset exchange are similar; the Company has gone to great lengths to
lower costs to customers by entering into a transaction that, although initially having a
negative financial impact, will provide customer benefits over the long term.
B. ldaho Power's lnterpretation of Order No. 33313.
ldaho Power and Staff have differing interpretations of the Commission's
language in Order No. 33313. Staff believes that the issue "is whether the deferral
account should include the negative cumulative differences in total transmission
revenue that the Company is now experiencing as a result of the asset exchange."
Staff Comments at 4. Staff believes that this was not the intent of the deferral account
in Order No. 33313 and that the Commission did not accept ldaho Power's proposal in
its Reply Comments in Case No. IPC-E-14-41 to allow for symmetrical tracking.
However, in its Order, the Commission states they "agree that the financial benefits of
the exchange in this case should be flowed to customers," acknowledging the benefits
ldaho Power presented in the case that were calculated inclusive of both the increases
IDAHO POWER COMPANY'S REPLY COMMENTS.9
and decreases in transmission revenues resulting from the transaction. Order No.
33313 at 13.
ln the above-referenced Reply Comments and as described above, the Company
clearly conveyed that revenue deficiencies existed for ldaho Power in 2015 regardless
of FERC's decision to allow for a one-time adjustment to the OATT transmission
formula rate and that customer rates would initially increase if immediate changes were
made to retail rates. ln Order No. 33313, the Commission acknowledged that if FERC
did not approve ldaho Power's one-time adjustment to the OATT transmission formula
rate, the Company may under recover transmission system costs. Order No. 33313 at
10. ldaho Power believes that with that knowledge, the Commission ordered the
establishment of a regulatory deferral account for transmission revenues resulting from
the transaction stating, "[t]hus, we . . direct ldaho Power to establish a regulatory
deferral account for transmission revenues resulting specifically from the transaction
and its resulting change in the OATT rafes." Order No. 33313 at 13 (emphasis added).
The Commission did not reject ldaho Power's proposed symmetrical tracking of
changes in transmission revenues. The Commission directed Idaho Power to track
transmission revenues resulting specifically from the transaction and resulting changes
in its OATT rate. ldaho Power believes that, based on the record in the case, the
Commission understood that such changes include both increases and decreases.
C. Idaho Power's Application Tracks All Components of Transmission
Revenues that Chanqe as a Result of the Asset Exchange.
The Company's Application includes accounting treatment that it believes meets
the Commission's directive to establish a regulatory deferral account for changes in
IDAHO POWER COMPANY'S REPLY COMMENTS - 1O
transmission revenues resulting from the transaction.l Idaho Power acknowledges
Staff's review of the Company's computation of changes in transmission revenues
resulting from the transaction and the proposed deferral amounts, but believes Staffs
recommendation is unjust because it tracks only positive changes in transmission
revenues resulting from the change in the OATT transmission formula rate. Staffs
recommendation isolates one component of transmission revenues affected by the
transaction without recognizing all components of transmission revenues that are
affected by the transaction, which is contrary to traditional ratemaking practice.
As described extensively in the Company's testimony in Case No. IPC-E-14-41,
revenues received under the Legacy Agreements predate the OATT, are not subject to
the OATT, and therefore are not used in the computation of the OATT transmission
formula rate. However, FERC required ldaho Power to include the contract demands
associated with the Legacy Agreements in the OATT transmission formula rate load
divisor rather than crediting the revenue against ldaho Power's transmission revenue
requirement. Consequently, although Legacy Agreement revenues ceased on October
30, 2015, because of the backward-looking OATT transmission formula rate, ldaho
Power will not recover its entire transmission revenue requirement amounts from
transmission customers until October 2017, when the OATT transmission formula rate
is updated and includes a full year of financial data after the asset exchange. The
decrease in Transmission Facilities revenues without a corresponding increase in the
' ldaho Power is required to record the impact of regulatory decisions on its financial statements.
FASB ASC 980, Under the Company's accounting for the asset exchange, the regulatory deferral
balance is a liability to customers once total transmission revenue collected after the asset exchange
exceeds what it would have been absent the asset exchange. Conversely, during the short term when
transmission revenues under the asset exchange are lower, the Company defers the difference as an
asset based on its expectation of probable future transmission revenues to offset the current
undercollection.
IDAHO POWER COMPANY'S REPLY COMMENTS - 11
OATT transmission formula rate is a reflection of the gap in recovery of transmission
revenue requirements and is directly related to the asset exchange with PacifiCorp.
Staff incorrectly assumes that the OATT transmission formula rate is the only
driver of transmission revenue changes. Staff's Comments state that it recognizes
FERC denied the Company's proposa! to increase the OATT transmission formula rate
and that additional transmission revenues that would have been deferred for the benefit
of retail customers are delayed. Staff Comments at 3. Yet, in testimony and exhibits
filed with ldaho Power's Application, the Company illustrated clearly that even absent an
immediate change in the OATT formula rate, the following transmission revenues
increased upon closing of the transaction: (1) Long-term PTP revenues due to
PacifiCorp's new OATT service and (2) Network Transmission Service revenues due to
the monthly update of the network customers' load ratio share applied to revenue
requirement amounts.2 Although the outcome of ldaho Power's FERC petition
regarding an immediate OATT rate adjustment did not result in an increase in ldaho
Power's OATT formula rate, the asset exchange resulted in an immediate increase to
some components of transmission revenues.
Because the Company's response to Order No. 33313 is a symmetrical tracking
of changes in transmission revenues in the deferral account, the increase in the Long-
term PTP revenues and Network Transmission Service revenues will help offset the
initial decrease in total transmission revenues that are a result of the transaction. Staffs
proposal to disconnect the transmission facilities revenue components that change as a
result of the transaction is unreasonable because they are all fundamentally connected.
Moreover, the asset exchange and the resulting termination of the Legacy Agreements
2 See confidentialAttachment 1 to ldaho Power's Application.
IDAHO POWER COMPANY'S REPLY COMMENTS. 12
and the associated reduction in the Transmission Facilities revenues is the primary
driver for the increase in the OATT formula rate beginning in October 2017. ln time,
the OATT transmission formula rate increase provides incremental revenues that will
more than offset reductions in the Transmission Facilities revenues, decreasing future
transmission revenue requirements for retail customers.
ldaho Power does not object to tracking changes in transmission revenues
resulting from the transaction and understands the Commission's desire to ensure
customers receive all benefits associated with the asset exchange. However, the
approach Staff advocates will create a financial disincentive for the Company to reduce
costs to customers over the long term by requiring an asymmetrical tracking of changes
in transmission revenues. Over the years, the Commission has supported the
Company's efforts to make business decisions that benefit customers in the long run by
authorizing the Company follow general regulatory principles by tracking and deferring
initial costs to offset with benefits when they occur. Staff's proposal is contrary to the
Commission's long-standing treatment of costs and benefits. At a minimum, eliminating
the requirement to track and record any changes in transmission revenues resulting
from the transaction and instead address the changes at the time the Company files its
next genera! rate case would allow ldaho Power to incorporate the net impact of
changes in transmission revenues to retail customers' revenue requirement amounts.
D. Staffs Recommendation to Offiset Deferral Amounts with the Amortization
Expense Approved in Order No. 32540 is lnappropriate.
!f the Commission approves a symmetrical tracking of the changes in
transmission revenues resulting from the asset exchange, Staff asserts that the
Company should be required "to recognize, as a credit to the deferral account, the
IDAHO POWER COMPANY'S REPLY COMMENTS - 13
annual amortization amount approved in Case No. IPC-E-12-06, Order No. 32540."
Staff Comments at 5. Staff contends that, because the Commission authorized an
amortization expense of $688,156 annually for three years on deferral amounts that
have been fully amortized but not yet removed from customer rates, the Company
should offset deferral amounts associated with changes in transmission revenues
resulting from the asset exchange.
ln Case No. IPC-E-12-06, ldaho Power requested approval to increase rates to
recover amortization expense associated with a deferral of amounts related to
unrecovered transmission costs. From March 2008 through May 31 ,2010,ldaho Power
was revenue crediting ldaho retail customers' revenue requirement amounts based on
an expected FERC decision in Docket No. ER06-787. However, the outcome of that
case further reduced the OATT transmission formula rate, and therefore corresponding
revenue credit amounts, resulting in significant unrecovered transmission costs. The
Commission approved the deferral, and subsequent amortization, of the revenue credit
amounts ldaho Power was providing to retail customers but ultimately never received
from transmission customers. Order Nos. 32177 and 32540.
Staff states that "while the current request by the Company is significantly
different than the 2009 request to establish a deferral account for unrecovered
transmission revenues, unrecovered transmission revenues previously approved by the
Commission are still being collected by the Company Staff Comments at 6. Staff
is correct, amounts included in the 2009 deferral account were associated with a
forecasted OATT transmission formula rate that was overstated; however, they are not
components of the Company's transmission revenues that are changing as a result of
IDAHO POWER COMPANY'S REPLY COMMENTS.l4
the transaction with PacifiCorp. While both are attributed to overstated revenue credits
applied to ldaho retail customers' revenue requirement amounts, ldaho Power believes
it is inappropriate to include an unrelated revenue credit in the calculation of the
proposed deferral.
As explained above, all transmission revenue components that change as a
result of the asset exchange are a part of the total revenue credit applied to ldaho retail
customers' revenue requirement amounts. Equivalent to the 2009 deferral, the
decrease in the Transmission Facilities revenues the Company will experience as a
result of the termination of the Legacy Agreements would decrease the revenue credit
ldaho retail customers would receive. However, because the Company has not filed a
general rate case updating revenue credit amounts and absent the ability to include
amounts in the current deferral, the decrease in the Transmission Facilities revenues
would result in unrecovered transmission costs, identical to unrecovered transmission
costs approved for recovery in Case No. IPC-E-12-06. By approving the symmetrical
tracking of changes in transmission revenues, consistent ratemaking principles would
be applied.
It is also important to note that the amortization expense included in customer
rates in Case No. IPC-E-12-06 is no different than other rate base, revenue, and
expense amounts included in a test year used to develop ldaho Power's revenue
requirement; assets are added and retired, revenues fluctuate, and expenses increase
and decrease through the normal course of business. lt is impractical to update test
year amounts with an exact revenue requirement to capture changes in the Company's
revenues and expenses. ldaho Power believes it is inappropriate to include a credit to
IDAHO POWER COMPANY'S REPLY COMMENTS - 15
deferral amounts authorized under Order No. 33313 equal to amortization expenses
approved for recovery in Case No. IPC-E-12-06 and that such treatment should be
appropriately dealt with in the Company's next general rate case.
IV. CONCLUSION
Regardless of FERC's decision to deny ldaho Power's request to make a one-
time known and measurable adjustment to the inputs to the Company's OATT
transmission formula rate, the asset exchange with PacifiCorp will provide substantial
net customer benefits over the long term. However, a deferral that tracks only one
component of changes in transmission revenues that result from the transaction would
overstate the benefits of the transaction, resulting in a financial detriment to the
Company. Such a result would create a financial disincentive for ldaho Power to look
for opportunities to manage its costs and revenues in ways that benefit customers over
the long term. For this reason, ldaho Power respectfully requests that the Commission
either: (1) accept ldaho Power's filing to track both increases and decreases in
transmission revenues resulting specifically from the transaction as compliant with
Order No. 33313 or (2) eliminate the requirement to track any changes in transmission
revenues resulting from the transaction and instead address all changes to transmission
revenues when Idaho Power files its next general rate case.
DATED at Boise, ldaho, this 1"t day of July 2016.
for ldaho Power Company
IDAHO POWER COMPANY'S REPLY COMMENTS. 16
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 1't day of July 2016 I served a true and correct
copy of IDAHO POWER COMPANY'S REPLY COMMENTS upon the following named
parties by the method indicated below, and addressed to the following:
Commission Staff
Daphne Huang
Deputy Attorney Genera!
ldaho Public Utilities Commission
472 West Washington (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
lndustrial Customerc of ldaho Power
Peter J. Richardson
Gregory M. Adams
RICHARDSON ADAMS, PLLC
515 North 27th Street (83702)
P.O. Box 7218
Boise, ldaho 83707
Dr. Don Reading
6070 Hil! Road
Boise, ldaho 83703
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IDAHO POWER COMPANY'S REPLY COMMENTS - 17