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Home My WebLink About20240603IPC to Staff 1-5.pdf mq% —HIQAHO Re DONOVAN WALKER RECEIVED Lead Counsel 2024 June 3, 3:51 PM dwaIker(cDidahopower.corn IDAHO PUBLIC UTILITIES COMMISSION June 3, 2024 VIA ELECTRONIC FILING Monica Barrios-Sanchez, Secretary Idaho Public Utilities Commission 11331 W. Chinden Blvd., Bldg 8, Suite 201-A (83714) PO Box 83720 Boise, Idaho 83720-0074 Re: Case No. IPC-E-24-18 In the Matter of Idaho Power Company's Application for Approval of a Clean Energy Your Way Construction Agreement with the City of Boise and the First Amendment Thereto Dear Ms. Barrios-Sanchez: Attached for electronic filing please find Idaho Power Company's Response to the First Production Request of the Commission Staff in the above matter. The confidential attachment will be provided separately via an encrypted email to parties who sign the protective agreement. Please feel free to contact me directly with any questions you might have about this filing. Very truly yours, Donovan E. Walker DEW:cd Attachment CERTIFICATE OF ATTORNEY ASSERTION THAT INFORMATION CONTAINED IN AN IDAHO PUBLIC UTILITIES COMMISSION FILING IS PROTECTED FROM PUBLIC INSPECTION Idaho Power Company's Application for Approval of a Clean Energy Your Way Construction Agreement with the City of Boise and the First Amendment Thereto Case No. IPC-E-24-18 The undersigned attorney, in accordance with Commission Rules of Procedure 67, believes that the Attachment No. 3 to Idaho Power Company's First Production Request of the Commission Staff dated June 3, 2024, may contain information that Idaho Power Company and a third party claims is a confidential trade secret and business records of a private enterprise required by law to be submitted to or inspected by a public agency as described in Idaho Code § 74-101, et seq., and/or § 48-801, et seq. As such, it is protected from public disclosure and exempt from public inspection, examination, or copying. DATED this Monday, June 3, 2024. Donovan Walker Counsel for Idaho Power Company DONOVAN E. WALKER (ISB No. 5921) Idaho Power Company 1221 West Idaho Street (83702) P.O. Box 70 Boise, Idaho 83707 Telephone: (208) 388-5317 Facsimile: (208) 388-6936 dwalker _idahopower.com Attorney for Idaho Power Company BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF IDAHO POWER ) COMPANY'S APPLICATION FOR ) CASE NO. IPC-E-24-18 APPROVAL OF A CLEAN ENERGY YOUR ) WAY CONSTRUCTION AGREEMENT WITH ) IDAHO POWER COMPANY'S THE CITY OF BOISE AND THE FIRST ) RESPONSE TO THE FIRST AMENDMENT THERETO. ) PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY COMES NOW, Idaho Power Company ("Idaho Power" or "Company"), and in response to the First Production Request of the Commission Staff ("Commission" or "Staff") dated May 13, 2024, herewith submits the following information: IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 1 REQUEST FOR PRODUCTION 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. RESPONSE TO REQUEST FOR PRODUCTION NO. 1: Please see Attachment 1 for the no-harm financial analysis. Please also see Attachment 2 and Confidential Attachment 3 for the supporting files for Micron and City of Boise, respectively. Attachments 2 and 3 model the allocation of the Black Mesa project to the City of Boise's two Schedule 19, Large Power service accounts. Below is a summary of the primary inputs and their respective source: Input Data Source Black Mesa output and degradation factors Project developer Energy sales forecast Idaho Power and customer forecast Tariff rates Idaho Power tariff Schedule 19, 26, and 62 Mid-Columbia forecast Idaho Power forecast from 2021 IRP Renewable Energy Facility Cost Black Mesa Power Purchase Agreement The response to this Request is sponsored by Grant T. Anderson, Regulatory Consultant, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 2 REQUEST FOR PRODUCTION 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. RESPONSE TO REQUEST FOR PRODUCTION NO. 2: No aspect of Micron's Special Contract or Schedule 26 will be modified due to the City of Boise's Clean Energy Your Way Renewable Construction Agreement. Please note, however, that while there is no need to modify the Micron Special Contact as a result of the City of Boise's agreement, the pricing exhibits of both the Micron and Brisbie Special Contracts have been revised to incorporate clarifying language that ensures all three agreements have consistent terminology and definition. These same refinements resulted in the City of Boise's First Revised Exhibit 1 . The Micron and Brisbie amendments were filed with the Commission in a separate proceeding (IPC-E-24-23) on May 30, 2024. The response to this Request is sponsored by Alison Williams, Regulatory Policy and Strategy Leader, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 3 REQUEST FOR PRODUCTION 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. RESPONSE TO REQUEST FOR PRODUCTION NO. 3: See First Revised Exhibit 1 of City of Boise's Renewable Power Purchase Agreement, as amended, Table 1: Renewable Energy Facility Credit, to see how the Renewable Energy Facility Credit is calculated. The Project Nameplate in column (a) represents the Buyer's Share of Project Nameplate capacity. Therefore, the Renewable Energy Facility Credit calculation will account for the City of Boise's share of Black Mesa accordingly and apply the monthly pro rata share in accordance with Table 2. Please note that this is the same method of calculating the Renewable Energy Facility Credit as used and authorized by the Commission for Micron. The response to this Request is sponsored by Grant T. Anderson, Regulatory Consultant, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY -4 REQUEST FOR PRODUCTION 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. RESPONSE TO REQUEST FOR PRODUCTION NO. 4: Confidential Attachment 3 from the Company's Response to Request for Production No. 1 includes the City of Boise's forecasted energy consumption at the Boise Airport on the tab labeled "Airport Forecast." For the Lander Facility, the City of Boise did not forecast a change in energy consumption; therefore, the Company relied on historical energy consumption, which is included in the tab labeled "Lander Plant." The response to this Request is sponsored by Grant T. Anderson, Regulatory Consultant, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 5 REQUEST FOR PRODUCTION 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. RESPONSE TO REQUEST FOR PRODUCTION NO. 5: Confidential Attachment 3 from the Company's Response to Request for Production No. 1 includes the 8,760 hourly generation forecast for Black Mesa, unadjusted for degradation on the tabs labeled "BlackMesa8760" and "BlackMesaShape," and the annual and cumulative degradation factor for this project is included on the tab labeled "Degradation." The modeled output for September 1, 2024, through August 31, 2027, is calculated on the tab labeled "HrlyCalc" and summarized on the tab labeled "MthlyGen." The response to this Request is sponsored by Grant T. Anderson, Regulatory Consultant Idaho Power Company. Respectfully submitted this 3rd day of June 2024. c: Cl�aP.�t DONOVAN E. WALKER Attorney for Idaho Power Company IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 3rd day of June, 2024, 1 served a true and correct copy of Idaho Power Company's Response to the First Production Request of the Commission Staff to Idaho Power Company upon the following named parties by the method indicated below, and addressed to the following: Commission Staff Hand Delivered Adam Triplett U.S. Mail Deputy Attorney General Overnight Mail Idaho Public Utilities Commission FAX 11331 W. Chinden Blvd., Bldg No. 8 FTP Site Suite 201-A (83714) X Email Ada m.Triplett(a),puc.idaho.gov PO Box 83720 Boise, ID 83720-0074 Christy Davenport Legal Administrative Assistant IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-24-18 IDAHO POWER COMPANY ATTACHMENT 1 SEE EXCEL SPREADSHEET BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-23-18 IDAHO POWER COMPANY ATTACHMENT 2 SEE EXCEL SPREADSHEET BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-23-18 IDAHO POWER COMPANY ATTACHMENT 3 SEE EXCEL SPREADSHEET