20240410Staff 1-6 to IPC.pdf

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Wedriesday,Apri110,202412 56.52 PM
IDAHOPUILIC
UIIIITIES Cb1VMS4ON
CHRIS BURDIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 9810
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 ITS ) CASE NO. IPC-E-24-15
ANNUAL UPDATE TO MARGINAL PRICING )
USED IN CERTAIN SCHEDULES )
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,
Chris Burdin, Deputy Attorney General, requests that Idaho Power Company ("Company")
provide the following documents and information as soon as possible, but no later than
WEDNESDAY,MAY 1, 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 APRIL 10, 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 Company proposes to apply the same marginal cost to both
Schedule No. 20 customers and Lamb Weston. Please respond to the following:
a. Please confirm that the incremental 15 MW used in the "base-plus-I 5-MW" is based
on Lamb Weston's expected incremental load alone, without considering potential
Schedule No. 20 loads;
b. If confirmed,please explain why Schedule No. 20 customers should use Lamb
Weston's marginal cost, if Schedule No. 20 customers will have their own additional
loads, causing the marginal cost to change; and
c. Please explain whether the Company has received any Schedule No. 20 requests so
far.
REQUEST NO. 2: The Company used"expected streamflow conditions for the April
2024-March 2025 test year"in the model run. Application at 7. Please define "expected
streamflow conditions" and explain how they are determined.
REQUEST NO. 3: The Company used"expected load for the test year." Application at
4. Please respond to the following.
a. Please define "expected load for the test year";
b. Please explain how"expected load for the test year" is determined; and
c. If the "expected load for the test year" is not the 50th percentile load, please explain
why the 50th percentile load is not used.
REQUEST NO. 4: Please explain how the annual marginal cost of energy for Lamb
Weston($0.04689 1/kWh) is calculated and provide the workpaper for the calculation with
formula intact.
REQUEST NO. 5: In reference to Attachment No. 3 of the Application(Marginal
Costs),please explain how the values in Table "Updated Marginal Cost of Energy for Schedule
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 2 APRIL 10, 2024

20" are calculated and provide workpapers for the calculation with formula intact. In addition,
please describe the relationship between the values in Table"Updated Marginal Cost of Energy
for Schedule 20" and the proposed rates in Schedule No. 20.
REQUEST NO. 6: Please explain after the two model runs (with and without the
incremental 15 MW)how the modeled results are used to establish rates for Large General
Service for both Primary and Transmission Service, as well as rates for Large Power Service for
both Primary and Transmission Service. In support of the answer, please provide workpapers
that calculate the proposed rates for each category with formula intact.
DATED at Boise, Idaho, this 10th day of April 2024.
kA/,,/1-
Chris Burdin
Deputy Attorney General
I:\Utility\UMISC\PRDREQ\IPC-E-24-15 PR#I.docx
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 3 APRIL 10, 2024

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS loch DAY OF APRIL 2024, SERVED
THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO
IDAHO POWER COMPANY, IN CASE NO. IPC-E-24-15, BY E-MAILING A COPY
THEREOF, TO THE FOLLOWING:
MEGAN GOICOECHEA ALLEN MATTHEW T. LARKIN
IDAHO POWER COMPANY CONNIE ASCHENBRENNER
PO BOX 70 IDAHO POWER COMPANY
BOISE ID 83707-0070 PO BOX 70
E-MAIL: BOISE ID 83707-0070
mgoicoecheaallen(@,idahopower.com E-MAIL: mlarkinOidahopower.com
[e-mail] caschenbrenner(u,idahopower.com
rIM-
PAT ICIA JORDA , SECRETARY
CERTIFICATE OF SERVICE