20240513Staff 1-5 TO IPC.pdf

RECEIVED
Monday, May 13, 2024 2.59.34 PM
IDAHO PUBLIC
UTILITIES COMMISSION
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 IDAHO POWER )
COMPANY'S APPLICATION FOR ) CASE NO. IPC-E-24-18
APPROVAL OF A CLEAN ENERGY YOUR )
WAY CONSTRUCTION AGREEMENT WITH ) FIRST PRODUCTION
THE CITY OF BOISE AND THE FIRST ) REQUEST OF THE
AMENDMENT THERETO ) 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
MONDAY,JUNE 3, 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 I MAY 13, 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: Please provide in electronic format, with all formulas intact and
enabled, all workpapers used to develop the Company's No-Harm Financial Analysis discussed
on pages 6-10 of the Application. Please include all data used as inputs and identify the source
of the data.
REQUEST NO. 2: Please explain if any part of Micron's Special Contract, the
Schedule 26 tariff, or both need to be modified if the proposed CEYW Renewable Construction
Agreement with the City of Boise and the First Amendment are approved. If any modification is
required,please explain the modification required and the process the Company plans to submit
the modification to the Commission.
REQUEST NO. 3: Please explain how the Renewable Energy Facility Credit will be
adjusted for each month that the City of Boise's share of output from Black Mesa is less than 10
MW.
REQUEST NO. 4: Please provide the Company's most recent City of Boise hourly
forecasted energy consumption at the Boise Airport and Lander Facility for September 1, 2024
through August 31, 2027. In addition, please explain how the energy use is forecasted for these
facilities.
REQUEST NO. 5: Please provide the Company's most recent Black Mesa hourly
generation forecast for September 1, 2024 through August 31, 2027. In addition,please explain
how the energy use is forecasted for this project.
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 2 MAY 13, 2024

DATED at Boise, Idaho, this 13"'day of May 2024.
:Aw A47
Adam Triplett
Deputy Attorney General
I:\Utility\UMISC\PRDREQ\IPC-E-24-18 PR#I.docx
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 3 MAY 13, 2024

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS i � DAY OF MAY 2024,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION
STAFF TO IDAHO POWER COMPANY, IN CASE NO. IPC-E-24-18, BY E-MAILING
A COPY THEREOF, TO THE FOLLOWING:
DONOVAN E WALKER TIM TATUM
IDAHO POWER COMPANY ALISON WILLIAMS
PO BOX 70 IDAHO POWER COMPANY
BOISE ID 83707-0070 PO BOX 70
E-MAIL: dwalker c,idahopower.com BOISE ID 83707-0070
dockets(@,idahopower.com E-MAIL: ttatum(@idahopower.com
awilliamsa,,idahopower.com
.N`
PATRICIA JORD , SECRETARY
CERTIFICATE OF SERVICE