20170810Reply Comments.pdf

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An IDACORP CompanY
LISA D. NORDSTROM
Lead Counse!
I [e-mail]
August 10,2017
VIA HAND DELIVERY
Diane Hanian, Secretary
Idaho Public Utilities Commission
472 West Washington Street
Boise, ldaho 83702
Case No. IPC-E-17-03
2016 Demand-Side Management Expenses - ldaho Power Company's Reply
Comments
Dear Ms. Hanian:
Enclosed for filing in the above matter please find an original and seven (7) copies
of ldaho Power Company's Reply Comments.
Very truly yours,
LDN:kkt
Enclosures
Re
Xrr-P?4'dd*
Lisa D. Nordstrom
LISA D. NORDSTROM (lSB No. 5733)
ldaho Power Company
1221 West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
Ln o rd stro m @ id a h oppweream
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR A
DETERMINATION OF 2016 DEMAND.SIDE
MANAGEMENT EXPENDITURES AS
PRUDENTLY INCURRED
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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CASE NO. IPC-E-17-03
IDAHO POWER COMPANY'S
REPLY COMMENTS
ldaho Power Company ("ldaho Powe/' or "Company') respectfully submits the
following Reply Comments in response to Comments filed by the ldaho Public Utilities
Commission ("Commission") Staff ("Staff'), the lndustrial Customers of ldaho Power
('lClP'), the Community Action Partnership Association of ldaho ('CAPAI') and the ldaho
Conservation League ("lCL"). ldaho Power appreciates the Comments provided in this
case and notes that both Staff and ICL recommend the Commission find that all or nearly
all of the Company's 2016 Demand-Side Management ("DSM') expenditures, as well as
all incremental DSM labor expenses incuned 2011 through 2016, were prudently
incuned.
ln these Reply Comments, the Company responds to and clarifies the proposed
adjustments and recommendations raised in Staffs, lClP's, CAPAI's and ICL's
Comments, asking that the Commissioh ultimately determine $31,305,157 in ldaho
]DAHO POWER COMPANY'S REPLY COMMENTS - 1
-lr
i il I';l i0t.
Energy Efficiency Rider ("Rider'') funds, $7,059,420 of demand response program
incentives funded through base rates and tracked annually through the Power Cost
Adjustment ('PCA'), and $1,860,901 of incremental DSM labor expenses incuned from
2011 through 2016, for a total of $40,225,477,were prudently incuned DSM expenses.
IDAHO POWER'S RESPONSE
A. lncremental Labor Expenses
ldaho Power appreciates both Staffs and !CL's support for ldaho Powe/s request
for a prudence determination on incremental labor incuned from 2011 through 2016. On
page 8 of its Comments, Staff also requests the Commission cap "rider-funded labor
expense at the 2016 levels." Because ldaho Power is only seeking a prudence
determination on expenses incuned through 2016, the Company believes it would be
premature and unnecessaryforthe Commission to issue a determination on the prudence
of expenses not yet incuned. The determination of prudence on any future expenses
necessary for the acquisition of cost-effective DSM savings is appropriately determined
at the time the Company submits a request with the Commission for review. Further,
while Staff ultimately supports the Company's request for a prudence determination on
the $1,860,901 of 2011-2016 incremental rider-funded labor expenses, there are a
number of issues raised by Staff in its Comments that deserve additiona! clarification so
as to provide the Commission with a clear understanding of the related facts.
ldaho Power respectfully disagrees with Staffs conclusion on page 6 of its
Comments that the peer utility non-union wage adjustment data and local company
projected increases provided in Confidential Exhibit No. 4 were incorrect and "routinely
overstated" the actual generalwage adjustments ("GWA") awarded. Staffs assessment
mischaracterizes the nature and usage of the peer utility wage adjustment data used by
IDAHO POWER COMPANY'S REPLY COMMENTS - 2
ldaho Power to help inform GWA decisions. ln its assessment, Staff compares actual
wage adjustments made by peer utilities in the first quarter of each year against estimated
wage adjustments provided by peer utilities to ldaho Power many months prior and
inconectly concludes that the differences represent an overstating of the data points. As
more fully described on pages 47-48 of Company witness Connie Aschenbrenne/s
testimony, ldaho Power contacts its peer utilities each fall to obtain what that utility's
recommended or budgeted wage adjustment is expected to be forthe following year. The
information is solicited at the point in time when Idaho Power is consolidating information
for its final recommendation to the ldaho Power Board of Directors ("Board") and the
information presented in Ms. Aschenbrenne/s Confidential Exhibit No. 4 (supporting
documentation provided to Staff during its on-site audit) accurately represents the
information provided to ldaho Power by its peer utilities. Table 2 presented on page 7 of
Staffs Comments reflects that the ultimate increase granted in certain years by peer
utilities may have been different than what was shown in Ms. Aschenbrenne/s
Confidential Exhibit No. 4; Staff mischaracterizes the difference as a "discrepancy" and
raises concems about the "accuracy and completeness" of the analysis. However, the
information presented was an estimate and the best available data at the time the Board
made its wage adjustment decision.
On page 7 of its Comments, Staff references "Boise lnc., lntermountain Gas
Company, Micron, Qwest, Simplot, State of ldaho, and URS" and states: "ln several
instances, the projected wage increases included in ldaho Powe/s analysis overstated
the actual wage increases awarded by these local companies." After reviewing Staffs
Comments, ldaho Power requested that Staff provide the actual wage increase
information referenced for each of the local companies in Staffs Comments upon which
Staff based its assertion. ln response to the Company's request, Staff was unable to
IDAHO POWER COMPANY'S REPLY COMMENTS.3
provide the supporting wage increase infonnation for any of the listed companies except
for lntermountain Gas and the State of ldaho.
Again, in the case of both lntermountain Gas and the State of Idaho, Staff is
comparing an estimate from the fallto the actualwage adjustment made several months
later. The information that ldaho Power was provided by lntermountain Gas matches the
data shown on Confidential Exhibit No. 4 (the supporting documentation was provided to
Staff during its on-site audit). Further, when estimating the planned increase forthe State
of ldaho employees, which is gathered from the annual Report to the Govemor on State
Employee Compensation and Benefits - a report that is generally available between
August and December each year, ldaho Power relies upon the data that was available at
the time the GWA recommendation was made.
On page 7 of its Comments, Staff indicated a few instances where the salary
survey increases listed on Confidential Exhibit No. 4 were overstated. At ldaho Powe/s
request, Staff pointed out a single survey data point in 2012 and 2015 as inaccurate.
Upon further review, ldaho Power determined that the figures shown were incorrectly
collected by ldaho Powerfrom "totalwage increase" information instead of "merit increase
information" in each of the surveys. While the Company agrees with Staffs finding that
there were two inaccuracies amid multiple data points, it is important to note the Board-
approved GWA in each of those two years was not greaterthan the corrected data. Table
1 below shows the Board-approved GWA was in line with (in one instance lower than) the
conect merit increase information from the surveys.
Table 1
Year Survey Exhibit No.4 Source
Document Data
2012 Towers Watson 3.4-3.8o/o 3.Oo/o 2.75o/o
2015 Culpepper 3.4o/o 3.0%3.0o/o
IDAHO POWER COMPANY'S REPLY COMMENTS - 4
GWA Approved
On pages 7 and 8 of its Comments, Staff indicated that ldaho Powe/s GWAs have
outpaced average local and national wage growth. However, the data Staff references
spans all industries, not just the energy services industry (which ldaho Power benchmarks
against). Staff subsequently indicated to ldaho Power that the Bureau of Labor Statistics
does not have a breakdown by industry. Because ldaho Power hires skilled employees
from a limited pool, benchmarking wage increases for comparable positions within the
energy services industry is of critical importance, allowing the Company to attract and
retain its workforce by remaining competitive with other electric utilities. Therefore, ldaho
Power believes that the data shown in the "ldaho Wage lncreases" and "National Wage
lncreases" columns of Table 3 of Staffs Comments should be disregarded as it is not
representative of the energy services secto/s labor information, and therefore, is not
representative of the increases the Company must provide to recruit and retain the talent
needed to effectively serve customers.
While Staff is critical of the Company's analysis, Staff does recognize that some
level of wage increase is both appropriate and necessary, and ultimately recommends
that wage increases from 2011-2016 should be deemed prudent. On page 5 of its
Comments, ICL suggests that: "Acquiring energy savings requires a well-trained,
motivated, and professional staff. . . energy savings requires motivating individual
behavior and then accounting for the results. For these reasons, ICL supports adequate
funding for labor costs being accounted for as part of DSM programs."
ldaho Power agrees with Staff and ICL that wage increases are both appropriate
and necessary. Idaho Power believes that its 2011-2016 incremental DSM labor
expenses were prudently incuned and necessary to acquire the total energy savings and
demand response capacity achieved in each of those years. Although ldaho Power has
defened collection of these labor expenses for the past six years, the Company has
IDAHO POWER COMPANY'S REPLY COMMENTS. 5
included these expenses in the DSM cost-effectiveness tests in each of those years to
determine DSM program prudence. lt is for these reasons that the Company asks the
Commission to find its 2011-2016 incremental DSM labor expenses were prudent.
B. Demand Response Switch Inventory
On page 9 of its Comments, Staff expressed concerns about Advanced Metering
lnfrastructure ("AMl") switch inventory used in the Company's A/C Gool Credit Demand
Response program and stated that the switches "are not providing any benefit to cunent
customers." Staff also claims the Company has been "dismissive" of its concems and
requested that the Commission order ldaho Power to work with the Energy Efficiency
Advisory Group ("EEAG") to develop an inventory reduction plan. Absent such a plan,
Staff recommends the inventory value be removed from the Rider balance and charged
to the Rider when switches are placed in service.
ldaho Power disagrees that the existing switches are not providing value to cunent
customerc. The Company sought a prudence determination on the value of the switches
in Case No. IPC-E-13-08, where Staff and other parties recommended the Commission
deem those expenditures prudent, and the Commission ultimately ordered the expenses
as prudently incuned. The Company has not purchased any additional switches since
that time. ln compliance with the Settlement Stipulation, ldaho Power has not actively
marketed the program to new participants; however, it does solicit participation from past
participants,t as well as customers who move into a home that has a switch already
installed.z The Company will also accept new participants who request to participate.
Over the last two years, the number of new switches installed for former participants at
1 See Attachment 1 titled "We've Missed You."
2 See Attachment 2 titled "Congratulations On Moving lnto Your New Home."
IDAHO POWER COMPANY'S REPLY COMMENTS - 6
their new homes was approximately 875. The Company also needs an inventory on hand
to ensure it can replace existing switches that may fail.
The Company has reduced the inventory of switches significantly in the past year.
As of August, the cunent balance of on-hand switches is approximately 2,500 -
approximately 40 percent less than what was reported to the Gommission last year.
ldaho Power also disagrees with Staffs characterization that the Company has
been dismissive of its concems. During two recent EEAG meetings when Staff asked
about the switch inventory, the Company responded by informing Staff that it is continuing
to operate in compliance with the Seftlement Stipulation signed in ldaho Case No. IPC-
E-13-14 and Oregon Docket No. UM-1653. At the August2,2017, EEAG meeting, ldaho
Power provided an overview of the history of demand response at ldaho Power and
described the events Ieading up to the parties signing the Settlement Stipulation.
According to the 2017 lntegrated Resource PIan ("lRP"), recently filed in Case
No. !PC-E-17-11, the Company is not showing a capacity deficiency until 2026. Given
the absence of a near-term need identified in the 2017 lRP, the relatively recent adoption
of the Settlement Stipulation, and the Company's efforts around attracting and retaining
participants as described in the Settlement Stipulation, the Company continues to believe
it is not necessary or prudent to market the program beyond what was envisioned in the
Settlement Stipulation. ln light of the above, the Company believes the existing switch
inventory represents a reasonable level, and does not believe it is necessary for the
Commission to order the Company to work with EEAG to develop a plan to reduce the
inventory of switches.
C. DSM Program Management
ldaho Power continually strives to make improvements in the management of its
DSM programs and efforts. The Company appreciates feedback, both informally and
IDAHO POWER COMPANY'S REPLY COMMENTS. 7
formally, and wishes to respond to several issues and recommendations raised by parties
in this case.
Home I morove ment Prooram
On pages 12-13 of its Comments, Staff raises concems about the Company's June
30, 2017, sunsetting of the Home lmprovement program primarily because the Utility Cost
Test ("UCT") was above 1 .0 for 2016. On page 13 of its Comments, Staff also described
that the Company's "decision to suspend the Home lmprovement program is significantly
different from the decision it made about the ductless heat pumps." Also, on page 4 of
its Comments, ICL recommends that the Company "work with EEAG to redesign the
Home lmprovement Program by considering changes to incentive structures and program
marketing."
Staffs comparison of the Home lmprovement program to the ductless heat pump
measure within the Heating and Cooling Efficiency program is not warranted. As
described on pages 28-31 in Ms. Aschenbrenne/s testimony, the projected cost-
effectiveness of the Home Improvement program from the Total Resource Cost ("TRC")
and UCT percpectives was one important factor considered, but other factors, such as
the impact on participating and nonparticipating customers and the relative amount of
savings derived from the program, were also considered prior to ldaho Power deciding to
end the program on June 30, 2017. Additionally, the cost-effectiveness numberc cited on
page 13 of Staffs Comments are for a group of measures within the Heating and Cooling
Efficiency program, not the entire Heating and Cooling Efficiency program. Unlike the
Home lmprovement program, the Heating and Cooling Efficiency program was cost-
effective in2O16 from the perspective of all three tests including the Participant Cost Test
('PCT'). Table 2 shows the cost-effectiveness ratios for both the Home lmprovement and
the Heating and Cooling Efficiency programs.
IDAHO POWER COMPANY'S REPLY COMMENTS - 8
Table 2: 2016 Cost-Effectiveness
Also of note, the cost-effectiveness of ductless heat pumps is a regional effort
supported by the Northwest Energy Efficiency Alliance ("NEEA'). lt does appear that with
regional involvement and NEEA's support, the long-term cost-effectiveness of ductless
heat pumps will improve. ldaho Power continues to improve awareness and education
of its ductless heat pump measures with contractors and customerc and will continue to
evaluate the progress made in determining whether to continue offering those measures
within the Heating and Cooling Efficiency program.
We ath e ri zati o n for Q u a l ifi e d C u sto m e r s ( " WAQ C" l
On page 4 of its Comments, CAPAI expressed a desire to collaborate with ldaho
Power and memberc of CAPAI's network to develop a strategy to improve the cost-
effectiveness of the WAQC program. On page 4 of its Comments, ICL recommends that
the Commission direct ldaho Power to work with the EEAG and CAPAI to redesign the
weatherization program.
Idaho Power has met with CAPAI staff and Community Action Partnership
("CAP') weatherization managers in the past to align with the ongoing strategy of
improving cost-effectiveness and the Company welcomes the willingness of the parties
to continue to collaborate informally. This coordination provides for effective
communication between ldaho Power, CAPAI, and the CAP agencies regarding feasibility
of potential improvements to the State Weatherization Program guidelines and the
Program TRC UCT PCT
Home lmprovement 0.60 2.54 0.80
Heating & Cooling Efficiency 1.26 2.33 1.76
IDAHO POWER COMPANY'S REPLY COMMENTS - 9
Company Iooks forward to continuing this informal process to add to or strengthen
processes that may lead to higherWAQC cost-effectiveness.
Fridoe and Freezer Recvclino
On page 4 of its Comments, ICL re@mmends the Commission direct ldaho Power
to work with the EEAG to refine the Fridge and Freezer Recycling program. ldaho Power
has worked with EEAG in the past to improve the cost-effectiveness of this program to no
avail; modifications to the program have included using an aray of multi-media marketing,
and the replacement of a $30 incentive in 2015 with two LED bulbs. Despite these efforts,
the Company recently determined that the Fridge and Freezer Recycling program would
not be cost-effective from the perspective of either the TRC or the UCT in 2017 at the
August 2,2017, EEAG meeting and the Company recommended sunsetting the program.
The members of EEAG in aftendance supported the sunsetting of the program effective
December 31, 2017. While unlikely given the number of regional utilities that have
eliminated their appliance recycling programs, if the Company ascertains new information
that suggests the cost-effectiveness of the program could improve to a ratio of 1.0 or
higher, the Company will work with EEAG to discuss program redesign and/or
implementation.
Proorams for Small Business Customers
On page 14 of its Comments, Staff stated that Idaho Power has not made progress
around program development specifically for small business customers. Staff believes
small business customers often do not participate in Company-sponsored programs
because they Iack the resources and expertise to evaluate available options.
IDAHO POWER COMPANY'S REPLY COMMENTS - 10
Slnce 2007, the offerings within the Commercial and lndustrial ("C&1") energy
efficiency program have been a consistent source of commercial energy savings. The
C&l energy efficiency program is specifically designed for all business customerc (small,
medium, and large) and encompasses savings measures for retrofits, new construction,
and a custom option for non-prescriptive measures. Small businesses make up a
significant portion of the program's overall participation in any given year - 74 percent of
the energy efficiency projects in 2016 were for customers with capacity billing demand of
less than 100 kilowatts ("kW") per year and 85 percent of participating customers are less
than 200 kW. These eligibility thresholds are common to small commercial direct install
programs offered regionally and nationally.
ldaho Power continues to improve the effectiveness of its outreach and marketing
efforts to small businesses. Recently, the Company's customer service center started an
outbound calling campaign contacting these customers to raise awareness of its
programs. The Company is also working on a Commercial Energy Efficiency Kit offering
that it believes wil! help with the marketing and awareness of energy efficiency for its small
business customerc. ldaho Power will continue to update EEAG on its progress and
invites any ideas to improve the energy efficiency experience of its small business
customers.
D. DSM Gost-Effectiveness Determination
On page 2 of its Comments, ICIP states that "the Commission does not have
sufficiently reliable information" to make a prudence determination on energy efficiency
and demand response program expenses based upon ldaho Powe/s Application.
Specifically, lClP takes exception with ldaho Power using the DSM altemate costs from
IDAHO POWER COMPANY'S REPLY COMMENTS - 11
the 2013 IRP as a measurement for cost-effectiveness of the Company's 2016 energy
efficiency and demand response programs. ldaho Power disagrees with lClP's
conclusion that the Commission does not have sufficient information available to make a
prudence determination.
To determine cost-effectiveness of its energy efficiency programs, the Company
uses the DSM altemate costs from the most recently acknowledged IRP that were relied
upon for program year budgeting and program planning purposes. Forthe 2016 program
year, the Company used the most recently acknowledged lRP. This process has been
relied upon by ldaho Powe/s Customer Relations and Energy Efficiency department
since 2014 and has been discussed with and aligned on with members of the Company's
EEAG.
ldaho Powe/s assumptions surrounding the use of DSM altemate costs, energy
savings, and the timing of these assumptions have been shared with EEAG severaltimes.
The EEAG has been supportive of these methods and assumptions. Specifically, in the
November 5,2015, EEAG meeting, the Company gave a presentation titled Future EE
Measure Savings & IRP Avoided Cosfs which contained the assumptions for DSM
altemate costs and other inputs for the 2015,2016, and 2017 program years.3
lClP also asserts on page 4 of its Comments that "lt appears that none of the
inputs to the annual valuation of demand response have been updated since the initial
valuation was calculated four years ago." To the contrary, ldaho Power has updated the
levelized capacity cost of a Simple Cycle Combustion Turbine ("SCCT') to $18.5 million
3 See Attachment 3 for presentation slide titled "Program and Measure Cost-Effectiveness
Assumptions."
IDAHO POWER COMPANY'S REPLY COMMENTS - 12
in the 2015 lRP. ldaho Power has also published this value in the 2015 and 2016 Flex
Peak Program End-of-Season Annual Reports. ln the 2017 lRP, ldaho Power updated
the levelized capacity cost of a new SCCT to $122 kWyear which increased from $119
kWyear in the 2015 lRP. ln each IRP since 2013,ldaho Power has assessed the need
for demand response in the load and resource balance analysis.
ln light of the foregoing, ldaho Power believes that its policy of using the best
available information at the time of budgeting and program planning complies with utility
standards, is consistent with third-party evaluator re@mmendations, has been presented
to EEAG, and has been published in multiple reports and filings to both the ldaho and
Oregon Commissions. Consequently, the Company does not agree with lClP that the
Commission should initiate a process to update the inputs and measures used to
measure cost-effectiveness of the Company's DSM programs.
E. Results of Staffs Financial Audit
I nanect Accou ntinq Entrv
In the process of preparing responses to Staffs audit requests, ldaho Power
discovered an accounting eror in one of the transactions requested in Staffs sample.
During 2016, the use of a fleet vehicle was incorrectly entered into the Company's
accounting system using equipment No. 6636 at a rate of $37.35 per hour instead of the
conect equipment No. 1992 at a rate of $0.33 per mile. The Company reviewed all other
similar vehicle charges in 2016 and no other similar accounting errors were found. The
accounting eror was corected upon discovery, and the net impact of the conecting
entries resulted in $16,705 being credited back to the Rider.
IDAHO POWER COMPANY'S REPLY COMMENTS - 13
Recommended Adiustment of Certain Expenses
On page 5 of its Comments, Staff discovered expenses charged to the Rider for
expenses associated with the Rotary Club and the Boise Metro Chamber of Commerce
and recommends this expense be removed from the Rider. After reviewing the expenses
identified by Staff in its Comments and the Commission's past rate case treatment of such
dues, ldaho Power does not believe the $192 amount should be removed from the Rider
expenses. While the Company acknowledges that these dollars are relatively small
compared to the total 2016 prudence request, the Company would like to clarify certain
points sunounding these charges with the @ncem that the treatment ordered by the
Commission in this case may be precedent setting.
ln reviewing past rate case treatment, ldaho Power found that Commission
practice for adjusting dues and memberchip fees for Rotary and Chamber of Commerce
organizations is removal of 33 percent of the historical actual amounts, not 100 percent,
as suggested by Staff. Upon review of the charges identified by Staff, the Company found
that only $88 of the total$192 represents membership dues; $48 was related to business
meals and $57 was related to employee training. Neither of these cost categories
(business meals or employee training) are subject to the 33 percent membership dues
and fees adjustment.
ldaho Powe/s Energy Efficiency Program Specialists participate in these civic
organizations to meet business professionals in the commercial real estate, banking,
industrial operations, architecture/engineering, and property management fields. Having
a presence in these organizations provides value to ldaho Powe/s energy efficiency
efforts via building relationships, contacts, and promotion of its programs to potential
IDAHO POWER COMPANY'S REPLY COMMENTS - 14
participants within these organizations and their businesses. For these reasons, ldaho
Power does not believe these expenses should be subject to the 33 percent adjustment
detailed above.
CONCLUSION
Idaho Power respectfully requests that the Commission issue an order to approve
the Company's proposed 20'16 DSM expenditures (including correcting entries to remove
$16,705 from the Rider) and find the Rider expenditures of $31,305,157, $7,059,420 ot
demand response program incentives included in the 2016 PCA, and $1,860,901 in
incremental labor from 2011 through 2016 for a total of $40,225,477, were prudently
incurred DSM expenses.
DATED at Boise, ldaho, this 1Oth day of August 2017.
LISA D.
Attorney for ldaho Power Company
IDAHO POWER COMPANY'S REPLY COMMENTS - 15
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 10th day of August 2017 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:
Gommission Staff
Daphne Huang
Deputy Attomey General
ldaho Public Utilitles Commission
472 West Washington (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
lndustrial Gustomers of ldaho Power
Peter J. Richardson
RICHARDSON ADAMS, PLLC
515 North 27h Street (83702)
P.O. Box 7218
Boise, ldaho 83707
Dr. Don Reading
6070 Hill Road
Boise, ldaho 83703
Community Action Partnershi p
Association of ldaho
Brad M. Purdy
Attomey at Law
2019 North 17s Street
Boise, Idaho 83702
ldaho lrrigation Pumpers Association, lnc.
Eric L. Olsen
ECHO HAWK & OLSEN, PLLC
505 Pershing Avenue, Suite 100
P.O. Box 6119
Pocatello, ldaho 83205
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IDAHO POWER COMPANY'S REPLY COMMENTS - 16
Anthony Yanke!
12700 Lake Avenue, Unit 2505
Lakewood, Ohio 44107
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T Assistant
IDAHO POWER COMPANY'S REPLY COMMENTS - 17
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13
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
GASE NO. IPC-E-17-03
IDAHO POWER COMPANY
REPLY COMMENTS
ATTACHMENT 3
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