20240613Staff 6 to IPC.pdf

RECEIVED
Thursday, June 13, 2024 5.26.23 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 IDAHO POWER )
COMPANY'S APPLICATION FOR ) CASE NO. IPC-E-24-18
APPROVAL OF A CLEAN ENERGY YOUR )
WAY CONSTRUCTION AGREEMENT WITH ) SECOND 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
THURSDAY, JULY 4, 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 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. 6: Please provide the proportion and number(assuming fraction of
RECs are possible) of system generated RECs the City of Boise would receive on an annual
basis if the allocation of the system generated RECs they receive for their net load (load minus
renewable energy facility generation) is adjusted for the hourly differences in RECs generated by
the system versus if the RECs are allocated based on their net load without an adjustment.
Please provide all workpapers used in the analysis and include all data used as inputs and
identify the source of the data.
DATED at Boise, Idaho, this 131h day of June 2024.
ez
Adam Triplett
Deputy Attorney General
I:\Utility\UMISC\PRDREQ\IPC-E-24-18 PR#2.docx
SECOND PRODUCTION REQUEST
TO IDAHO POWER COMPANY 2 JUNE 13, 2024

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS )5 DAY OF JUNE 2024,
SERVED THE FOREGOING SECOND 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 a,idahopower.com BOISE ID 83707-0070
dockets i,idahopower.com E-MAIL: ttatum(@,idahopower.com
awilliams(a,idahopower.com
ED JEWELL STEVEN HUBBLE
DEPUTY CITY ATTORNEY BOISE CITY DEP OF
BOISE CITY ATTORNEY'S PUBLIC WORKS
PO BOX 500 PO BOX 500
BOISE ID 83701-0500 BOISE ID 83701-0500
E-MAIL: ejewell(a,cityofboise.org E-MAIL: shubble@,cityofboise.org
boisecilyattomey a,cityofboise.or�
JIM SWIER AUSTIN RUESCHHOFF
MICRON TECHNOLOGY INC THORVALD A NELSON
8000 S FEDERAL WAY AUSTIN W JENSEN
BOISE ID 83707 HOLLAND & HART LLP
E-MAIL: [e-mail] 555 17TH ST STE 3200
DENVER CO 80202
E-MAIL: darueschhoff&hollandhart.com
tnelson a,hollandhart.com
awjensen @ hollandhart.com
[e-mail]
mamcmillenOe—hollandhart.com
'm� 062,11y�
PAT ICIA JORDAN, SE R TARY
CERTIFICATE OF SERVICE