20240610Staff 20-23 to IPC.pdf

RECEIVED
Monday, June 10, 2024 10.40.44 AM
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 IDAHO POWER )
COMPANY'S APPLICATION FOR ) CASE NO. IPC-E-24-12
APPROVAL OF A MARKET PURCHASE )
AGREEMENT )
SECOND 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
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.
SECOND PRODUCTION REQUEST
TO IDAHO POWER COMPANY 1 JUNE 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. 20: Company witness Ellsworth's testimony describes how each of the
Request for Proposal ("RFP")resource selections reduces the 236-megawatt("MW") deficit.
The Powerex Agreement reduces the deficit by approximately 50 MW, the solar plus battery
facility reduces the deficit by approximately 110 MW, and the Company-owned battery storage
facility reduces the deficit by approximately 66 MW. Ellsworth at 25-26. Please reconcile the
10 MW difference between the 236 MW deficit and the total 226 MW of described deficit
reductions.
REQUEST NO. 21: Please answer the following questions about the Company's
response to Production Request No. 15:
a. The Company stated, "The additional amount of capacity that could be reasonably
achieved at Langley is expected to be under 100 megawatts without significant
enhancements to the permits and facilities." (Emphasis added). The Company also
stated, "An expansion project at Langley was not submitted because of the time it
would take to first develop an air permit application...." Please answer the following:
1. Please clarify if a capacity expansion project under 100 megawatts can occur
without triggering a multi-year air permit delay; and
2. Please describe the scope of work of this reduced-scale project and its
approximate timeline.
b. Please clarify why the application for a generator interconnection expansion with the
Federal Energy Regulatory Commission will unacceptably delay an expansion at
Langley, but other RFP projects do not have the same delay.
REQUEST NO. 22: Please explain how AURORA accounted for the annual fixed cost
of the Powerex Market Purchase Agreement in its analysis. Please provide data excerpts that
show AURORA accounting for this cost, similar to the Company's response to Production
Request No. 17c.
SECOND PRODUCTION REQUEST
TO IDAHO POWER COMPANY 2 JUNE 10, 2024

REQUEST NO. 23: Figure 10 in Confidential Exhibit No. 5 provides the pricing score
and associated data for the Initial Short List projects with a 2026 commercial operating date. For
the top-ranked project in each of the four generation technology types (Solar, G2H, Wind,
Geothermal), please provide the following:
a. Please provide the cost details, assumptions, and calculations used to determine the
"Sum of LCOE ($/mwh)"; and
b. Please provide the associated AURORA input values the Company assigned to each
of these resources in the Long-Term Capacity Expansion module.
DATED at Boise, Idaho, this 10"'day of June 2024.
O�A AX-
Chris Burdin
Deputy Attorney General
I:\Utility\UMISC\PRDREQ\IPC-E-24-12 PR#2.docx
SECOND PRODUCTION REQUEST
TO IDAHO POWER COMPANY 3 JUNE 10, 2024

CERTIFICATE OF SERVICE
A�
I HEREBY CERTIFY THAT I HAVE THIS -VoDAY OF JUNE 2024,
SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY, IN CASE NO. IPC-E-24-12,
BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
DONOVAN E WALKER TIM TATUM
IDAHO POWER COMPANY IDAHO POWER COMPANY
PO BOX 70 PO BOX 70
BOISE ID 83707-0070 BOISE ID 83707-0070
E-MAIL: dwalker gidahopower.com E-MAIL: ttatum t jdahopower.com
dockets nidahopower.com
PAARICIAJORDA , SECRETARY
CERTIFICATE OF SERVICE