20240312Staff 1-1 to IPC.pdf

ADAM TRIPLETT
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334- 0318
IDAHO BAR NO. 10221
Street Address for Express Mail:
11331 W CHINDEN BLVD, BLDG 8, SUITE 201-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR
APPROVAL OR REJECTION OF AN
ENERGY SALES AGREEMENT WITH BP
HYDRO ASSOCIATES FOR THE SALE AND
PURCHASE OF ELECTRIC ENERGY FROM
THE ROCK CREEK II HYDRO PROJECT
CASE NO. IPC-E-24-09
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO IDAHO POWER COMPANY
Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Adam Triplett, Deputy Attorney General, requests that Idaho Power Company ("Company")
provide the following documents and information as soon as possible, but no later than
TUESDAY, APRIL 2, 2024.
This Production Request is to be considered as continuing, and the Company is requested
to provide, by way of supplementary responses, additional documents that it, or any person
acting on its behalf, may later obtain that will augment the documents or information produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name, job title, and telephone number of
the person preparing the documents. Please also identify the name, job title, location, and
telephone number of the record holder.
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 1 MARCH 12, 2024

In addition to the written copies provided as response to the requests, please provide all
Excel spreadsheets and electronic files with formulas intact and enabled.
REQUEST NO. 1: The current 1987 contract will expire on April 2, 2024, and it is
likely that the proposed Energy Sales Agreement ("ESA") will not be approved by the
Commission before the expiration date. Article XXI of the ESA states that "[t]his Agreement
shall only become effective upon the Commission's approval of all terms and provisions hereof
without change or condition and declaration that all payments to be made to Seller hereunder
shall be allowed as prudently incurred expenses for ratemaking purposes." This will likely lead
to a lapsed -contract period. Please respond to the following:
a. Does the Facility plan to continuously operate during the lapsed -contract period?
b. Page 12 of the Application states that "the Company proposes to pay the Seller for any
generation delivered from the Facility during the potential lapsed contract period (April
3, 2024, until the service date of the final order issued by the Commission) at the Surplus
Energy Price as defined in Section 7.2 of the Replacement ESA." Have the Company
and the Seller agreed to this arrangement?
DATED at Boise, Idaho, this 12 day of March 2024.
Adam Triplett
Deputy Attorney General
I:\Utility\UMISC\PRDREQ\IPC-E-24-09 PR# Ldocx
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 2 MARCH 12, 2024

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 12TH DAY OF MARCH 2O24,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY, IN CASE NO. IPC-E-24-09,
BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
DONOVAN E WALKER
MEGAN GOICOECHEA ALLEN
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: dwalkerawidahopower.com
meoicoecheaallen cr,idahopower.com
dockets amidahopower.com
CORY LAGERSTROM
BP HYDRO ASSOCIATES
ROCK CREEK II HYDRO
4603 HOMESTEAD DR
PRAIRIE VILLAGE KS 66208
E-MAIL: corv(a)hvdrolandcoro.com
ENERGY CONTRACTS
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: energvcontracts(@idahopower.com
SECRETARY
CERTIFICATE OF SERVICE