20240603Staff 1-6 to IPC.pdf

RECEIVED
Monday, June 3, 2024 12:17:23 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 OF IDAHO POWER )
COMPANY'S APPLICATION FOR ) CASE NO. IPC-E-24-20
APPROVAL OF THE FIRST AMENDMENT )
TO THE POWER PURCHASE AGREEMENT )
WITH PVS 2, LLC ) 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
MONDAY,JUNE 244 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 JUNE 3, 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 Application states that compared to the original Scheduled
Commercial Operation Date of December 31, 2026, the proposed Scheduled Commercial
Operation Date of May 31, 2026, "better aligns the new generation with Brisbie's anticipated
load and Idaho Power's anticipated 2026 summer peak load." Application at 2. Please respond
to the following:
a. Please provide evidence supporting the Company's assertion that the proposed
Scheduled Commercial Operation Date better aligns the new generation with
Brisbie's anticipated load, compared to the original Scheduled Commercial Operation
Date;
b. What are the impacts if the capacity of PVS 2 comes online before Brisbie's load
materializes and how will the Company mitigate the impacts? Please include, but not
limit the explanation to: (i.) the amount of excess generation credits; (ii.) how
compliance of the 110% annual energy limit in Schedule 62 will be affected; (iii.) the
feasibility of curtailing PVS 2 generation to match Brisbie's load ramp, etc.; and
c. What are the impacts if the capacity of PVS 2 comes online after Brisbie's load
materializes? Please include, but not limit the explanation to: (i.) the sufficiency of
system capacity to meet system load with Brisbie's load included; (ii.) the accuracy of
Brisbie's rates for supplemental energy and demand charges due to the higher loads
the Company must meet with its system resources, etc.
REQUEST NO. 2: The Application states that the proposed Scheduled Commercial
Operation Date of May 31, 2026, better aligns the new generation with Idaho Power's
anticipated 2026 summer peak load. Please respond to the following:
a. Please provide the expected amount of excess capacity of PVS 2 that can contribute
to meeting the anticipated 2026 summer peak load;
b. Please explain whether the proposed Scheduled Commercial Operation Date will
lower the Company's summer capacity need of 2026 for other projects; and
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 2 JUNE 3, 2024

c. If so, does the Company plan to change the scheduled commercial operation dates of
other 2026 projects?
REQUEST NO. 3: Please explain whether there is a possibility that Brisbie's load
grows ahead of May 31, 2026. If so, please explain whether the Company has enough resources
to meet Brisbie's load.
REQUEST NO. 4: Schedule 62 requires that customers pursuing the Construction
option limit requests to size the Renewable Energy Facilities to 110 percent of the participating
service point annual energy amounts. Please provide evidence supporting that the capacity size
of PVS 2 meets this requirement.
REQUEST NO. 5: Page numbers of First Amendment to the Power Purchase
Agreement("First Amendment") show 3 pages. However, only 2 pages were filed with the
Commission. Please file a complete First Amendment, if the third page is missing.
REQUEST NO. 6: Page 2 of First Amendment states that"IN WITNESS WHEREOF,
the Parties hereto have caused this Second Amendment to duly executed as of the date above
written." Please confirm whether"Second Amendment" should have been "First Amendment".
Idaho this day of June 2024.
DATED at Boise, � y
Adam Triplett
Deputy Attorney General
I:\Utility\UMISC\PRDREQ\IPC-E-24-20 PR#Ldocx
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 3 JUNE 3, 2024

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS DAY OF JUNE 2024,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION
STAFF TO IDAHO POWER COMPANY IN CASE NO. IPC-E-24-20, BY E-MAILING
A COPY THEREOF, TO THE FOLLOWING:
DONOVAN E WALKER ENERGY CONTRACTS
MEGAN GOICOECHEA ALLEN IDAHO POWER COMPANY
IDAHO POWER COMPANY PO BOX 70
PO BOX 70 BOISE ID 83707-0070
BOISE ID 83707-0070 E-MAIL: [e-mail]
E-MAIL: dwalkerAidahopower.com
mgoicoecheaal len(cidahopower.coin
[e-mail]
PATRICIA JORDAN" SECRETARY
CERTIFICATE OF SERVICE