20230714Errata to Supplemental Application and Direct Testimony of Theresa Drake.pdf

MEGAN GOICOECHEA ALLEN
Corporate Counsel
[e-mail]

July 14, 2023

Jan Noriyuki, Secretary
Idaho Public Utilities Commission
11331 W. Chinden Boulevard
Building 8, Suite 201-A
Boise, Idaho 83714

Re: Case No. IPC-E-23-10
In the Matter of the Application of Idaho Power Company for a Determination
of 2022 Demand-Side Management Expenses as Prudently Incurred

Dear Ms. Noriyuki:

Attached for electronic filing in the above-entitled matter is an Errata to Supplemental
Application and Direct Testimony of Theresa Drake including, as described in the Errata,
Exhibit Nos. 4 through 6 to replace Exhibit Nos. 1 through 3 initially filed with the Drake
Testimony on June 30, 2023.

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

Sincerely,

Megan Goicoechea Allen
MGA:cd
Enclosures
RECEIVED
Friday, July 14, 2023 10:05:51 AM
IDAHO PUBLIC
UTILITIES COMMISSION
ERRATA TO SUPPLEMENTAL APPLICATION AND DIRECT TESTIMONY OF THERESA DRAKE - 1
MEGAN GOICOECHEA ALLEN (ISB No. 7623)
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]
[e-mail]

Attorneys for Idaho Power Company

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR A
DETERMINATION OF 2022 DEMAND-SIDE
MANAGEMENT EXPENSES AS
PRUDENTLY INCURRED.

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CASE NO. IPC-E-23-10

ERRATA TO SUPPLEMENTAL
APPLICATION AND DIRECT
TESTIMONY OF THERESA
DRAKE

Idaho Power Company (“Idaho Power” or “Company”) hereby respectfully submits
to the Idaho Public Utilities Commission (“Commission”) this Errata to the Company’s
Supplemental Application filed in this matter on June 30, 2023, and the Direct Testimony
of Theresa Drake (“Drake Testimony”) filed contemporaneously therewith, to correct a
labeling error to help ensure clarify of the record as follows:
1. The Direct Testimony of Robert Z. Thompson (“Thompson Testimony”)
accompanying the Company’s initial Application filed on March 15, 2023, included three
exhibits labeled Exhibit Nos. 1 through 3 based on the exhibit numbers assigned by the
Commission Secretary (Exhibit Nos. 1-100) in the Notice of Parties dated June 8, 2023.
ERRATA TO SUPPLEMENTAL APPLICATION AND DIRECT TESTIMONY OF THERESA DRAKE - 2
As a result, pursuant to Commission Rules of Procedure 2311 (IDAPA 31.01.01.231.03),
any subsequent exhibits offered by the Company should have been numbered
successively.
2. The three exhibits accompanying the Drake Testimony, however,
inadvertently used the same numbers as the Thompson Testimony exhibits, Exhibit Nos.
1 through 3, instead of continuing consecutively as Exhibit Nos. 4 through 6.
3. Though not material to the Company’s Supplemental Application or request
in this proceeding, for the sake of clarity of the record the Company has relabeled the
Exhibit Nos. 1 to 3 of the Drake Testimony, respectively, as follows: NEEA EM&V Report
(Exhibit No. 4), Idaho Power’s Net Market Effect NEEA Savings 1997 – 2022 (Exhibit No.
5), and the NEEA EM&V Report Addendum (Exhibit No. 6).
4. Exhibit Nos. 4 through 6, which are being provided with this Errata to
replace Exhibit Nos. 1 through 3 initially filed with the Drake Testimony on June 30, 2023,
rectify the exhibit numbering issuing only and do not otherwise change the information
set forth therein.
5. In addition, as a result of this update, the Company provides the following
substitutions to incorporate within the Supplemental Application and the Drake Testimony
for consistency and clarity as follows:
 Replace the references to Exhibit No. 1 with Exhibit No. 4 at:
o Pages 3 and 5 of the Supplemental Application, and
o Page 3 (line 11) and page 7 (line 20) of the Drake Testimony.

 Replace the references to Exhibit No. 2 with Exhibit No. 5 at:
o Page 3 of the Supplemental Application, and
o Page 3 (line 12) and page 6 (line 8) of the Drake Testimony.

1 See also IDAPA 31.01.01.230 and 31.01.01.267.
ERRATA TO SUPPLEMENTAL APPLICATION AND DIRECT TESTIMONY OF THERESA DRAKE - 3
 Replace the references to Exhibit No. 3 with Exhibit No. 6 at:
o Pages 3, 5, and 6 of the Supplemental Application, and
o Page 3 (line 14), page 12 (line 21), and page 15 (line 4) of the
Drake Testimony.

These updates do not change anything else about the Supplemental Application or the
Drake Testimony.
Respectfully submitted this 14th day of July 2023.

MEGAN GOICOECHEA ALLEN
Attorney for Idaho Power Company
ERRATA TO SUPPLEMENTAL APPLICATION AND DIRECT TESTIMONY OF THERESA DRAKE - 4
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the 14th day of July 2023, I served a true and correct
copy of Errata to Supplemental Application and Direct Testimony of Theresa Drake upon
the following named parties by the method indicated below, and addressed to the
following:

Commission Staff
Claire Sharp
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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Ed Jewell
Deputy City Attorney
Boise City Attorney’s Office
150 N. Capitol Blvd.
P.O. Box 500
Boise, ID 83701-500
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Wil Gehl
Energy Program Manager
Boise City Dept. of Public Works
150 N. Capitol Blvd.
P.O. Box 500
Boise, ID 83701-500
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Christy Davenport
Legal Administrative Assistant