20240723Staff 28-31 to IPC (Redacted).pdf

RECEIVED
Tuesday, July 23, 2024 4:31:11 PM
IDAHO PUBLIC
UTILITIES COMMISSION
CHRIS BURDIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
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 FOURTH
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
FRIDAY,AUGUST 2, 2024.1
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
1 Staff is requesting an expedited response. If responding by this date will be problematic,please call Staff s
attorney at(208)334-0314.
FOURTH PRODUCTION REQUEST
TO IDAHO POWER COMPANY 1 JULY 23, 2024

the person preparing the documents. Please also identify the name,job title, location, and
telephone number of the record holder.
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. 28: In the Company's response to Production Request No. 10 -
Confidential Attachment, Final Short List Portfolio Nos. 10 and 1 are ranked as the top two least-
cost portfolios; however, neither include the 150 MW Boise Bench BESS project. Please explain
the following:
a. Please explain why the Company is not pursuing the resources identified in final
shortlist Portfolio No. 10; and
b. Please explain why the Company is not pursuing the resources identified in final
shortlist Portfolio No. 1; and
c. Please discuss whether each of the 11 portfolios was run through RCAT and met
the 0.1 loss-of-load-event("LOLE")threshold.
REQUEST NO. 29: Staff notes that in the Company's response to Production Request
No. 10 - Confidential Attachment, none of the modeled portfolios contain all three of the
selected resources as described in the Application. Please build two more portfolios, as described
below,perform the same set of 60 stochastic runs for the two new portfolios, and provide an
updated spreadsheet showing the new data alongside the previous runs. The projects described
below correspond to the bid rankings provided in Hackett's Confidential Exhibit No. 7.
a. Portfolio 12: The 2026 forced projects will be final shortlist Bid Nos. 1, 2, and 4.
b. Portfolio 13: The 2026 forced projects will be final shortlist Bid Nos. 1, 2, and 5.
c. Please confirm that Portfolio Nos. 12 and 13 meet the RCAT LOLE threshold.
REQUEST NO. 30: As a supplement to the Company's response to Production Request
No. 20,please explain why Project No. ` "was not selected as a resource,
when its levelized cost of capacity ("LCOC")was lower than the Boise Bench BESS project.
FOURTH PRODUCTION REQUEST
TO IDAHO POWER COMPANY 2 JULY 23, 2024

REQUEST NO. 31: Hacket's Confidential Exhibit No. 7 is the ranking of the
Company's final shortlist of bids for the 2026 RFP. Please provide the following information:
a. The LCOC of Bid No. 4 and Bid No. 5; and
b. The breakdown of estimated total capital cost for Bid No. 4 and Bid No. 5.
DATED at Boise, Idaho, this 23'd day of July 2024.
V 011
Chris Burdin
Deputy Attorney General
I:\Utkhty\UMISC\PRDREQ\IPC-E24-16 PR 04 Redaceoddocx
FOURTH PRODUCTION REQUEST
TO IDAHO POWER COMPANY 3 JULY 23, 2024

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 040 DAY OF JULY 2024,
SERVED THE FOREGOING REDACTED FOURTH 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: dwalker(widahopower.com E-MAIL: ttatum(didahopower.com
[e-mail]
AUSTIN RUESCHHOFF JIM SWIER
THORVALD A NELSON MICRON TECHNOLOGY INC
AUSTIN W JENSEN 8000 S FEDERAL WAY
HOLLAND & HART LLP BOISE ID 83707
555 17T" ST STE 3200 E-MAIL: jswier(cUmicron.com
DENVER CO 80202
E-MAIL: darueschhoff(ci)hollandhart.com
tnelson hollandhart.com
awj ensenahollandhart.com
aclee ,hollandhart.com
mamcm i l l en(a�ho l l andhart.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,cl eanenergyopportunities.com
mike(c�cleanenergyopportunities.com
ClIA—
PATMCIA JORDAN, S CRETARY
CERTIFICATE OF SERVICE