20240625Staff 23-27 to IPC Redacted.pdf

RECEIVED
Tuesday, June 25, 2024 4.48.29 PM
IDAHO PUBLIC
UTILITIES COMMISSION
CHRIS BURDIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334- 0314
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 A ) CASE NO. IPC-E-24-16
CERTIFICATE OF PUBLIC CONVENIENCE )
AND NECESSITY FOR THE BOISE BENCH )
BATTERY STORAGE FACILITY ) REDACTED THIRD
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
TUESDAY,JULY 16, 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.
REDACTED THIRD PRODUCTION REQUEST
TO IDAHO POWER COMPANY 1 JUNE 25, 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. 23: In the Company's response to Production Request No. I —
Confidential Attachment 3, the Bid describes that there are 3 Capacity Augmentations Estimates
for this project:
Please explain if the estimated costs of each augmentation are included in the
Company's final cost estimate. If not, please explain why.
REQUEST NO. 24: The Company's response to Production Request No. 1 —
Confidential Attachment Nos. 3 and 7 refer to a
-. Please provide documentation detailing this warranty:
a. Please specify how the_ allows for multiple charge discharge cycles in a 24-
hour period.
REQUEST NO. 25: Based on the information provided in Ellsworth's testimony on
page 26, please provide justification, any necessary documentation, and analysis showing the
timeline when the Company projects to utilize the full effective BESS capacity of 150 MW.
REQUEST NO. 26: The Company stated it did not include the 200 MW large load
inquiries in its most recent system reliability evaluation as identified in 2023 IRP. Ellsworth at
18. Based on the information, please provide the following:
a. An explanation why the Company did not consider this large load scenario in its
assessment; and
b. An explanation of any potential impact on the projected 2026 deficit and system
reliability if the Company included the large load scenario in its analysis.
REQUEST NO. 27: Please provide the following information regarding the BESS
resource bids of the 2026 RFP:
REDACTED THIRD PRODUCTION REQUEST
TO IDAHO POWER COMPANY 2 JUNE 25, 2024

a. A detailed final scorecard for the top 10 BESS resource bids (out of 21 BESS bids
that the Company received. Hackett at 27); and
b. A detailed cost-benefit and risk analysis on why the 150 MW Boise Bench BESS
resource was selected compared to the other shortlisted BESS bids.
DATED at Boise, Idaho, this 25d`day of June 2024.
bju-
Chris Burdin
Deputy Attorney General
1:\Utility\UMISC\PRDREQ\IPC-E-24-16 PR#3 Redacted.docx
REDACTED THIRD PRODUCTION REQUEST TO
IDAHO POWER COMPANY 3 JUNE 25, 2024

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS a� DAY OF JUNE 2024,
SERVED THE FOREGOING REDACTED THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY IN CASE NO. IPC-E-24-16,
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: [e-mail] E-MAIL: ttatum(c-6dah power.com
docketsAidahopo wer.com
AUSTIN RUESCHHOFF JIM SWIER
THORVALD A NELSON MICRON TECHNOLOGY INC
AUSTIN W JENSEN 8000 S FEDERAL WAY
HOLLAND & HART LLP BOISE ID 83707
555 17TH ST STE 3200 E-MAIL: iswier(@,micron.com
DENVER CO 80202
E-MAIL: darueschhoffa-hollandhart.com
tnel son(a),hollandhart.com
awjensen ,hollandhart.com
aclee hollandhart.com
mamcmillen(c-bhollandhart.com
KELSEY JAE COURTNEY WHITE
LAW FOR CONSCIOUS LEADERSHIP MIKE HECKLER
920 N CLOVER DR CLEAN ENERGY OPPORTUNITIES
BOISE ID 83703 3778 PLANTATION RIVER DR
E-MAIL: kelsey(@,,kelseyjae.com STE 102
BOISE ID 83703
E-MAIL:
courtney a,cleanene=opportunities.com
mike&cleanenergyopportunities.com
PATRICIA JORDAN, SECRETARY
CERTIFICATE OF SERVICE