20240529Staff 1 to IPC.pdf

RECEIVED
Wednesday, May 29, 2024 12:42:30 PM
IDAHO PUBLIC
UTILITIES COMMISSION
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 AN ) CASE NO. IPC-E-24-14
ORDER AUTHORIZING INCLUSION IN THE )
BRIDGER BALANCING ACCOUNT OF ALL )
NON-FUEL OPERATIONS AND ) FIRST PRODUCTION
MAINTENANCE EXPENSES ASSOCIATED ) REQUEST OF THE
WITH PLANT OPERATIONS ) 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,JUNE 19, 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 MAY 29, 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 explain the Company's justification supporting its decision to
convert Bridger Units Nos. 1 and 2 to be fueled by natural gas in 2024. In the explanation,
please include, but not limit to, the following:
a. A list of all possible alternatives to converting the units to natural gas;
b. The rationale eliminating each of the possible alternatives by referencing and
including evidence such as any studies that were conducted, economic and risk
analysis comparing each alternative to natural gas conversion, reports produced by
the Company or from other sources, environmental regulatory documents (FERC,
EPA, etc.), and court orders, etc.; and
c. Agreement(s) with PacifiCorp that define the terms and conditions for the decision to
convert to natural gas.
DATED at Boise, Idaho, this 29"'day of May 2024.
D'�'A L/I
Chris Burdin
Deputy Attorney General
1:\Utility\UMISC\PRDREQ\IPC-E-24-14 PR#1.docx
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 2 MAY 29, 2024

CERTIFICATE OF SERVICE
�
I HEREBY CERTIFY THAT I HAVE THIS 11 0�` DAY OF MAY 2024,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION
STAFF TO IDAHO POWER COMPANY, IN CASE NO. IPC-E-24-14, BY E-MAILING
A COPY THEREOF, TO THE FOLLOWING:
LISA D NORDSTROM TIM TATUM
LEAD COUNSEL VP REGULATORY AFFAIRS
IDAHO POWER COMPANY IDAHO POWER COMPANY
PO BOX 70 PO BOX 70
BOISE ID 83707-0070 BOISE ID 83707-0070
E-MAIL: Inordstromai idahopower.com E-MAIL: ttatum(@idahopower.com
dockets(cDidahopower.com
PATRICIA JORD , SECRETARY
CERTIFICATE OF SERVICE