20240705IPC to Staff 11-22 (Redacted).pdf

0-10RHO POWER.
RECEIVED
DONOVAN WALKER Frday, July 5, 2024
Lead Counsel IDAHO PUBLIC
dwalker(a)idahopower.com UTILITIES COMMISSION
July 5, 2024
VIA ELECTRONIC FILING
Commission 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-24-16
In the Matter of Idaho Power Company's Application for a Certificate of
Public Convenience and Necessity for the Boise Bench Battery Storage
Facility
Dear Commission Secretary:
Attached for electronic filing please find Idaho Power Company's Response to the
Second Production Request of the Commission Staff to Idaho Power Company.
The confidential attachments will be sent separately to the 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:sg
Attachments

CERTIFICATE OF ATTORNEY
ASSERTION THAT INFORMATION CONTAINED IN AN IDAHO PUBLIC UTILITIES
COMMISSION FILING IS PROTECTED FROM PUBLIC INSPECTION
Application for a Certificate of Public Convenience and Necessity for the Boise
Bench Battery Storage Facility
IPC-E-24-16
The undersigned attorney, in accordance with Commission Rules of Procedure 67,
believes that Idaho Power Company's Response to the Second Production Request of
the Commission Staff to Idaho Power Company and Attachments, contain information
that Idaho Power Company and a third party claims are confidential trade secret as
described in Idaho Code § 74-101, et seq., and/or § 48-801, et seq. As such, they are
protected from public disclosure and exempt from public inspection, examination, or
copying.
DATED this 5t" day of July 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: [phone]
Facsimile: [phone]
dwalker(o-)idahopower.com
Attorney for Idaho Power Company
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 ) IDAHO POWER COMPANY'S
BENCH BATTERY STORAGE FACILITY. ) RESPONSE TO THE
CONFIDENTIAL SECOND
PRODUCTION REQUEST OF
THE COMMISSION STAFF TO
IDAHO POWER COMPANY
COMES NOW, Idaho Power Company ("Idaho Power" or "Company"), and in
response to the Second Production Request of the Commission Staff ("Commission" or
"Staff") dated June 14, 2024, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 1

REQUEST FOR PRODUCTION NO. 11: Please describe any differences in the
anticipated operational dispatch of the Boise Bench Battery Energy Storage System
("BESS") between summer and winter peak seasons.
RESPONSE TO REQUEST FOR PRODUCTION NO. 11: The Boise Bench BESS
is a flexible resource, as are all BESS systems on Idaho Power's system, and will be
dispatched throughout the year based on system needs to reliably serve customers. In
general, the Company assumes a BESS will operate through one complete charge and
discharge cycle each day regardless of the season and can be adapted to support real-
time needs. The Boise Bench BESS will generally be dispatched daily based on system
conditions and needs, although there may be times when the resource discharge is not
needed as other resources are generating and the system has sufficient resources to
serve customer load. Idaho Power's system peak occurs during the summer months, and
in the summer, it is anticipated that the Company will typically charge the Boise Bench
BESS in the early morning or midday hours and discharge the BESS capacity in the
evening hours. During the winter, when Idaho Power has higher loads both in the morning
and in the evening, Idaho Power would typically plan to charge either overnight or in
midday so that the BESS is available to discharge either in the early morning or evening
hours, or potentially both, depending on the need.
The response to this Request is sponsored by Eric Hackett, Projects and Resource
Development Director, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 2

REQUEST FOR PRODUCTION NO. 12: Please provide the RCAT model results
showing the charge and discharge hours for the winter months used to inform the "Most
Valuable Hours" table in Confidential Attachment 3 to Production Request No. 1. Please
note all hours where the battery is modeled as unable to charge.
** Note: In the response, please highlight confidential information.
RESPONSE TO REQUEST FOR PRODUCTION NO. 12: The Idaho Power
Evaluation Team provided the Most Valuable Hours table in Exhibit G to the 2026 All
Source Request for Proposals ("RFP")to all bidders as guidance on the Company's timing
of need. Bidders then completed the Most Valuable Hours table with the anticipated
project contribution in various hours for their submission to the Idaho Power Evaluation
Team. While bidders provided how the various resources could be expected to meet the
Company's most valuable hours, the Idaho Power Evaluation Team did not utilize this
information for modeling purposes. Instead, the Idaho Power Evaluation Team modeled
each project in the Reliability and Capacity Assessment Tool ("RCAT") and AURORA for
bid evaluation. Both the RCAT and AURORA utilize dispatch algorithms to model Battery
Energy Storage Systems ("BESS"), meaning the charge and discharge hours vary and
will not be a direct match to the hours reflected in the "Most Valuable Hours" table
provided by the bidder.
Once a portfolio buildout is established, the selected resources are input into the
RCAT. The RCAT combines all stand-alone 4-hour BESS in the dispatch algorithm to
maximize the benefit the technology can provide to the system. Figures 1 and 2 below
show the average hourly charge and discharge, respectively, for all stand-alone 4-hour
BESS by month. The data in these figures are a direct export from the RCAT and were
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 3

utilized to calculate the reduction of 116 MW' in the 2026 capacity deficiency of 236 MW
due to the addition of the Boise Bench BESS. For clarity, the stand-alone 4-hour BESS
projects included in this RCAT simulation total approximately 500 MW of nameplate
capacity. Please note that the RCAT is a capacity-only model and is currently set to cycle
all 4-hour BESS projects once per day, even in months when there is no significant
capacity need.
Figure 1. Average hourly charge by month for all stand-alone 4-hour BESS in 2026 from RCAT
50
January Charge 500 Febnn 400 400 ry Charge March Charge April Charge
2 �
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See Ellsworth Direct Testimony page 25.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY-4

Figure 2. Average hourly discharge by month for all stand-alone 4-hour BESS in 2026 from RCAT
January Discharge February Discharge March Discharge April Discharge
200 250 300 250
150 f •� 200 250 - 200 f!
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May Discharge 400 June Discharge 400 July Discharge 400 August Discharge
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September Discharge October Discharge Nowmber Discharge December Discharge
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l l i i i l l lTlf?i? TI i i i i? ?••••I l i i l i i i i i• i i i i l l i l l i i i l i i i i i i i i l l l i i i i l l l l
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As shown by Figure 2, the discharge shape of the stand-alone 4-hour BESS
closely follows the "Most Valuable Hours" table provided in Exhibit G to the RFP.
The response to this Request is sponsored by Andres Valdepena Delgado, System
Consulting Engineer, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 5

REQUEST FOR PRODUCTION NO. 13: Please explain if the assumed round trip
efficiency accounts for variations due to weather and associated parasitic loads.
RESPONSE TO REQUEST FOR PRODUCTION NO. 13: The minimum round trip
efficiency guarantee is a value established with the manufacturer and is not adjusted due
to variations in weather. While weather likely plays a role in actual measured round-trip
efficiency, the guaranteed minimum does not fluctuate as a function of the weather.
Parasitic load may or may not be factored into the round-trip efficiency guarantee value
depending on the manufacturer's design specifications and the site parameters. For
example, if the site parameters provide auxiliary load from an adjacent distribution line
service point, the guaranteed round-trip efficiency would be higher because
parasitic/auxiliary distribution service is not consumed within the measurement of round-
trip efficiency. Conversely, some systems have an integrated inverter and transformer
within the energy segments, and thus the round-trip efficiency would be lower to account
for the parasitic load. More importantly, the total capacity that the Boise Bench BESS is
guaranteed to provide to the Idaho Power system during a discharge is 150 MW during a
four-hour span, regardless of the round-trip efficiency value.
The response to this Request is sponsored by Eric Hackett, Projects and Resource
Development Director, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 6

REQUEST FOR PRODUCTION NO. 14: In the testimony of Company witness
Ellsworth, he describes a relation between solar photovoltaic ("PV") systems and energy
storage systems. Ellsworth at 26. Please provide the ratio of solar to storage resources
on the Company's system, the Effective Load Carrying Capacity ("ELCC") of solar
resources, and the ELCC of battery resources for the following cases:
a. Company's current system;
b. With the inclusion of the 150 MW BESS;
c. With the addition of the forecasted 525 MW solar PV resource described in
Ellsworth at 26;
d. With the addition of any other near-term resource additions;
e. With all of the above.
RESPONSE TO REQUEST FOR PRODUCTION NO. 14: The table below
includes the ELCC results and corresponding solar to storage ratios for the specified
cases in parts (a) through (e) above. Please note that Idaho Power assumes the current
system to reflect contracted near-term resource additions, meaning the results for part (a)
and (d) of this request are the same.
PV BESS PV to
Part Description ELCC ELCC BESS
Ratio
a. Current System ("CS") 54.1% 82.2% 1.76
b. 2 CS + 150 MW BESS 54.9% 71.8% 1.24
C. 2 CS + 525 MW PV 38.7% 97.8% 3.22
d. 1 CS 54.1% 82.2% 1.76
e. 2 CS + 150 MW BESS + 525 MW PV 43.7% 93.8% 2.27
Cases assumed a 2026 load and resource year.
2 Cases assumed a 2027 load and resource year.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 7

The response to this Request is sponsored by Andres Valdepena Delgado, System
Consulting Engineer, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 8

REQUEST FOR PRODUCTION NO. 15: In response to Production Request No. I
- Confidential Attachment 3 at 3, the Bid states that the batteries can be recharged in
approximately . Please answer the following questions:
a. Please clarify if this is the minimum time needed to recharge.
b. Please explain if dispatch operations assume a different recharge time than the
stated recharge time.
c. Please provide the average duration of the recharging window in each month.
d. Please explain how the charge rate may affect battery degradation, cycle life, and
round-trip efficiency.
** Note: In the response, please highlight confidential information.
RESPONSE TO REQUEST FOR PRODUCTION NO. 15:
a. The general statement is accurate in relation to a typical four-hour BESS system.
BESS systems typically take slightly longer to charge than the expected discharge
timeframe. Because the round-trip efficiency is less than 100 percent, additional
megawatt-hours are required to charge the BESS than can be expected to
discharge, thus the timeframe to charge to a particular capacity takes longer than
the expected discharge. If a four-hour BESS was at a zero state of charge, it would
take four to five hours charging at full capacity to reach a full state of charge. That
said, the BESS is not required to always be charged to a full state of charge nor is
it required to always discharge at a full four hours at max capacity. For example, if
the BESS were only needed to discharge for one hour at the maximum capacity,
the charge timeframe may be less than two hours.
b. No. The BESS is assumed to need four to five hours charging at full capacity to
reach a full state of charge.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 9

c. With the assumption of 365 full charge and discharge cycles annually, the
assumed time to charge is approximately four to five hours daily depending on the
system discharge need in each day. This is highly flexible and may be adapted
daily, monthly, and annually based on system conditions. As an example, if the
BESS is fully charged on one day with the four-to-five-hour charge time, and is
fully discharged that same day, it would need to be charged again the next day
before it can be used. On the other hand, if the BESS is fully charged and then is
only partially discharged, then it would not need as much charging on a following
day. Further, there may be some days, particularly in shoulder seasons, where the
BESS may not be needed every single day. Finally, it is worth noting the point of
interconnection limits the amount of capacity that can flow to or from the BESS at
any given time. The BESS simply cannot be charged faster than the product of
the point of interconnection backfeed capacity limitation and the time it takes to
bring the BESS to a full state of charge.
d. The contract with the BESS manufacturer generally sets forth guaranteed
performance characteristics of the BESS, which are based on and address many
factors, including the assumed limitation of the charge rate, round trip efficiency,
and maximum cycles throughput per year. Therefore, the Company anticipates
battery degradation, cycle life, and round-trip efficiency will follow the
manufacturers' performance characteristics.
The response to this Request is sponsored by Eric Hackett, Projects and Resource
Development Director, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 10

REQUEST FOR PRODUCTION NO. 16: In response to Production Request No.
1 - Confidential Attachment 3 at 6, the Company describes that the discharge cycles from
months without critical hours can be shifted to months with both morning and evening
sets of valuable hours. Please provide workpapers quantifying the shoulder month cycles
and showing how they are redistributed.
** Note: In the response, please highlight confidential information.
RESPONSE TO REQUEST FOR PRODUCTION NO. 16: The referenced statement
is suggesting that the BESS is not strictly limited to one cycle per day, but rather 365
cycles per year, suggesting only that in some months the BESS could be cycled twice per
day as long as the total annual cycle count does not exceed 365.
The response to this Request is sponsored by Eric Hackett, Projects and Resource
Development Director, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 11

REQUEST FOR PRODUCTION NO. 17: In response to Production Request No.
1 - Confidential Attachment 3 at 3, the Bid states, '
-". Please specify the amount of the 365 annual discharge cycles anticipated
to be used
** Note: In the response, please highlight confidential information.
RESPONSE TO REQUEST FOR PRODUCTION NO. 17: The Boise Bench BESS
was selected on the final short list as a least-cost, least-risk resource necessary to fill the
identified capacity deficits in 2026, providing capacity to meet peak load needs. The
Company modeled the BESS as prioritizing net-demand hours for discharge, meaning
AURORA generally prioritizes charging the BESS at combined low demand and high
renewable output hours of the day, and discharging the BESS at high demand and low
renewable output hours. As described in the Response to Request for Production No. 7,
the Company intends to charge the BESS when it is most economical to do so and to
ensure the BESS is charged in time to be available to discharge in peak load hours or the
hours of highest need. The Company's Evaluation Team has not modeled or otherwise
forecasted frequency of use of this resource for
The response to this Request is sponsored by Camille Christen, Resource
Acquisition, Planning, and Coordination Manager, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 12

REQUEST FOR PRODUCTION NO. 18: In response to Production Request No.
1 - Confidential Attachment 3 at 6, the "Most Valuable Hours" table shows discharge
during hours of - in summer months. Please explain why the Company Bid
selected battery dispatch during a time frame when renewable resources are still
expected to be generating as opposed to hours after sundown.
a. Additionally, please explain how the Company Bid models capacity availability of
the 4-hour Boise Bench BESS resource across
** Note: In the response, please highlight confidential information.
RESPONSE TO REQUEST FOR PRODUCTION NO. 18: As referenced in the
Response to Request for Production No. 12, the specified "Most Valuable Hours" table
for the Boise Bench BESS was prepared by the Idaho Power Internal Bid Team, separate
and independent from the Idaho Power Evaluation Team. The table appears to show how
the Boise Bench BESS could be dispatched to meet the "Most Valuable Hours" identified
in Exhibit G of the 2026 RFP. Exhibit G identified the critical need hours for Idaho Power's
deficit and indicated the Company will favor resources that can meet these identified
hours. Thus, the Response to Production Request No. 1 - Confidential Attachment 3 at 6
illustrated how the resource could meet those RFP-identified "Most Valuable Hours."
a. See Response to Request for Production No. 12 for an explanation of the
modeling assumptions related to the "Most Valuable Hours."
The response to this Request is sponsored by Andres Valdepena Delgado, System
Consulting Engineer, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 13

REQUEST FOR PRODUCTION NO. 19: In response to Production Request No.
1 - Confidential Attachment 3 at 6, the "Most Valuable Hours" table shows discharge
during the evening most valuable hours . Please explain why
the Company Bid prioritized discharge during the evening period over the morning period.
** Note: In the response, please highlight confidential information.
RESPONSE TO REQUEST FOR PRODUCTION NO. 19: The table in the
referenced Confidential Attachment was prepared by the Idaho Power Bid Team, without
input from or direct knowledge of the Idaho Power Evaluation Team. Regardless, the
Evaluation Team's understanding is the table shows when the resource could be
discharged. See the Response to Request for Production No. 12 for a discussion on how
modeling of the charging and discharging of the Boise Bench BESS was performed.
The response to this Request is sponsored by Eric Hackett, Projects and Resource
Development Director, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 14

REQUEST FOR PRODUCTION NO. 20: Company witness Hackett describes that
the Company received 21 BESS resource bids for the 2026 RFP. Hackett at 27. Please
provide a table similar to the one contained in the Company's response to Production
Request No. 4 for each of the RFP bids for BESS resources. Additionally, for each bid
please also include the proposed operational date, cost estimates, battery supplier,
location and total MW that could have been provided by the BESS resource.
RESPONSE TO REQUEST FOR PRODUCTION NO. 20: See the Company's
Response to Staff's Request No. 20 — Confidential Attachment. Please note, only the two
self-build BESS resources have the level of detail provided in Production Request No. 4
because the remaining projects were either Build Transfer Agreements ("BTA"), projects
are lump-sum bids, or Battery Storage Agreements ("BSA"), projects that are owned and
operated by third-party entities. The details for the self-build BESS resources are
presented on the tabs labeled IPC75BEAP10026 and IPC76BEAP15026.
Although the Company cannot provide the level of detail provided in Production
Request No. 4 for the 21 bids referenced, Idaho Power instead included the total capital
cost and the levelized cost of capacity ("LCOC") of the BTA bids, and the first-year annual
payment, total estimated contract life payments, and the LCOC for the BSA bids. The
RFP did not require bidders to provide battery supplier information as part of their bid
therefore that information is not available. Please note, the 21 bids referenced were bids
that made up the initial shortlist, therefore the bid information was provided prior to any
pricing updates. For comparison purposes, Idaho Power has also provided the initial
pricing information for those bids that moved on to the final shortlist.
The response to this Request is sponsored by John Wonderlich, Finance Team
Leader II, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 15

REQUEST FOR PRODUCTION NO. 21: Please provide supporting
documentation for the "Civil Construction, Site Work, Underground Conduit, and
Grounding, Fencing, Concrete Foundations" cost estimate of listed in the
table in the Company's response to Production Request No. 4.
RESPONSE TO REQUEST FOR PRODUCTION NO. 21: The total cost estimate
for the Boise Bench BESS utilized for modeling of the final short list, reflective of the
pricing revisions submitted in September 2023, is , which includes BESS
equipment, interconnection facilities costs, Balance of System ("BOS") costs, Allowance
for Funds Used During Construction ("AFUDC"), and taxes. See the Bid Submittal tab of
the Company's Response to Staff's Request for Production No. 21 — Confidential
Attachment for the cost detail provided in the bid submitted. The estimate for the BOS
utilized to develop the total estimate is further detailed on the BOS Estimate tab which
includes the components of the quantification that make up the BOS before taxes and
AFUDC. Finally, the DR 4 Submittal tab shows how Idaho Power initially split the total
estimate of into the requested line items from the Company's Response to
Staff's Request for Production No. 4 because the bid submittal did not provide the
necessary level of detail. The BOS was spread to the cost categories based on the
percentages obtained from the cost estimate prepared in Response to Production
Request No. 11 in Case No. IPC-E-23-20 and the basis for the cost estimate provided in
Response to Production Request No. 4 in this proceeding. Subtracting the BESS
Equipment and the Interconnection Facilities costs from the total estimate equates to an
all-inclusive BOS cost estimate of , which includes taxes and AFUDC.
The response to this Request is sponsored by Eric Hackett, Projects and Resource
Development Director, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 16

REQUEST FOR PRODUCTION NO. 22: As follow up to the Company's response
to Production Request No. 4, please explain why the Electrical Construction and BESS
Installation cost estimates are both-.
RESPONSE TO REQUEST FOR PRODUCTION NO. 22: Please see Response
to Request for Production No. 21 for an explanation of how the BOS cost estimate was
prepared. The Electrical Construction and BESS Installation costs included in Response
to Production Request No. 11 in Case No. IPC-E-23-20 were approximately 10 percent
of the total BOS estimate. Applying approximately 10 percent to the total Boise Bench
BESS BOS cost estimate of results in Electrical Construction costs of
- and BESS Installation costs of
The response to this Request is sponsored by Eric Hackett, Projects and Resource
Development Director, Idaho Power Company.
DATED at Boise, Idaho this 5t" day of July 2024.
DONOVAN E. WALKER
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 17

CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 5th day of July, 2024, 1 served a true and correct
copy of Idaho Power Company's Response to the Second Production Request of the
Commission Staff upon the following named parties by the method indicated below, and
addressed to the following:
Commission Staff Hand Delivered
Chris Burdin 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 Chris.Burdin(cr puc.idaho.gov
PO Box 83720
Boise, ID 83720-0074
Micron Technology, Inc. Hand Delivered
Austin Rueschhoff U.S. Mail
Thorvald A. Nelson Overnight Mail
Austin W. Jensen FAX
Holland & Hart LLP X Email darueschhoff(a�hol land ha rt.corn
555 17th Street, Suite 3200 tnelson(a)hol land hart.com
Denver, CO 80202 awjensen hollandhart.com
aclee(a)hol land hart.com
mamcmiIlen(a-).hol land hart.com
Micron Technology, Inc. Hand Delivered
Jim Swier U.S. Mail
8000 S. Federal Way Overnight Mail
Boise, ID 83707 FAX
X Email jswier micron.com
Clean Energy Opportunities for Idaho Hand Delivered
Kelsey Jae U.S. Mail
Law for Conscious Leadership Overnight Mail
920 N. Clover Dr. FAX
Boise, ID 83703 X EMAIL Kelsey(a-)_kelseyjae.com
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 18

Courtney White Hand Delivered
Mike Heckler U.S. Mail
Clean Energy Opportunities for Idaho Inc. Overnight Mail
3778 Plantation River Dr., Suite 102 FAX
Boise, Idaho 83703 X EMAIL
Courtney(c)cleanenergyopportunities.com
mike(a�_cleanenergyopportunities.com
Stacy Gust, Regulatory Administrative
Assistant
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 19

BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-24-16
IDAHO POWER COMPANY
CONFIDENTIAL
REQUEST NO. 20
ATTACHMENT NO. 1

SEE ATTACHED SPREADSHEET

BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-24-16
IDAHO POWER COMPANY
CONFIDENTIAL
REQUEST NO. 21
ATTACHMENT NO. 1

SEE ATTACHED SPREADSHEET