20240703IPC to Staff 6.pdf

IQAW POWER.
RECEIVED
DONOVAN WALKER Wednesday, July 3, 2024
Lead Counsel IDAHO PUBLIC
dwalker(Mclahopower.com UTILITIES COMMISSION
July 3, 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-24-18
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 Commission Secretary:
Attached for electronic filing please find Idaho Power Company's Response to the
Second Production Request of the Commission Staff in the above matter.
Please feel free to contact me directly with any questions you might have about
this filing.
Very truly yours,
Donovan E. Walker
DEW:sg
Attachment

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 _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 SECOND
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 Second Production Request of the Commission Staff ("Commission" or
"Staff") dated June 13, 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. 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 6: The requested
information is not generated on an hourly basis and, further, would require the Company
to assume and apply different operational and programmatic standards that the Company
has used since it began selling system-generated RECs, as authorized by Idaho Power's
REC Management Plan. As an additional point of clarification, fractions of RECs are not
possible. One REC is generated per 1 megawatt-hour of qualifying renewable energy
generation delivered to the grid.
The response to this Request is sponsored by Alison Williams, Regulatory Policy
and Strategy Leader, Idaho Power Company.
Respectfully submitted this 3rd 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- 2

CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 3rd 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 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 Adam.Triplett(a).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 FTP Site
555 17t" Street, Suite 3200 X Email darueschhoff(a-hol land hart.corn
Denver, CO 80202 tnelson(D-hol land hart.com
awjensen hollandhart.com
Jim Swier Hand Delivered
Micron Technology, Inc. U.S. Mail
8000 South Federal Way Overnight Mail
Boise, ID 83707 FAX
FTP Site
X Email jswier(c�micron.com
City of Boise Hand Delivered
Ed Jewell U.S. Mail
Deputy City Attorney Overnight Mail
Boise City Attorney's Office FAX
150 N. Capitol Blvd. FTP Site
P.O. Box 500 X Email BoiseCityAttorney�a cityofboise.org
Boise, Idaho 83701 ejewell(a-cityofboise.org
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 3

Steven Hubble Hand Delivered
Climate Action Senior Manager U.S. Mail
Boise City Dept. of Public Works Overnight Mail
150 N. Capitol Blvd. FAX
P.O. Box 500 FTP Site
Boise, Idaho 83701 X Email hubble cityofboise.org
Stacy Gust
Regulatory Administrative Assistant
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY-4