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Home My WebLink About20240725IPC to Staff 5.pdf 0-10AM POWER. RECEIVED LISA D. NORDSTROM Thursday, July 25, 2024 Lead Counsel IDAHO PUBLIC Inordstrorn(Widahopower.com UTILITIES COMMISSION July 25, 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-24-07 Application of Idaho Power Company for Authority to Increase Rates for Electric Service to Recover Costs Associated with Incremental Capital Investments and Certain Ongoing Operations and Maintenance Expenses Dear Commission Secretary: Attached for electronic filing, please find Idaho Power Company's Supplemental Response to the Second Production Request of the Commission Staff to Idaho Power Company. Due to the collectively voluminous confidential and non-confidential information provided in response to data requests in this case, the Company is posting the attachments to these requests to the secure FTP site to allow parties to view the requested information remotely unless otherwise noted in the response. Because certain attachments contain confidential information, the FTP site is divided between confidential and non-confidential information. The login information for the non-confidential portion of the FTP site has been provided to all parties that have intervened to date. The login information for the confidential portion of the FTP site will be provided to the parties that execute the Protective Agreement in this matter. If you have any questions about the attached filing, please do not hesitate to contact me. Very truly yours, ate. ,� ��...,,..., Lisa D. Nordstrom LDN:sg Enclosures CERTIFICATE OF ATTORNEY ASSERTION THAT INFORMATION CONTAINED IN AN IDAHO PUBLIC UTILITIES COMMISSION FILING IS PROTECTED FROM PUBLIC INSPECTION Case No. IPC-E-24-07 Idaho Power Company's Application for Authority to Increase Rates for Electric Service to Recover Costs Associated with Incremental Capital Investments and Certain Ongoing Operations and Maintenance Expenses The undersigned attorney, in accordance with Commission Rules of Procedure 67, believes that the attachments to Idaho Power Company's Supplemental Response to the Second Production Request of the Commission Staff dated July 25, 2024, contain information that Idaho Power Company and/or a third party claim are trade secrets, business records of a private enterprise required by law to be submitted to or inspected by a public agency, and/or public records exempt from disclosure by state or federal law (material nonpublic information under U.S. Securities and Exchange Commission Regulation FD) as described in Idaho Code § 74-101, et seq., and/or § 48-801, et seq. As such, it is protected from public disclosure and exempt from public inspection, examination, or copying. DATED this 25' day of July 2024. LISA D. NORDSTROM Attorney for Idaho Power Company LISA D. NORDSTROM (ISB No. 5733) DONOVAN E. WALKER (ISB No. 5921) MEGAN GOICOECHEA ALLEN (ISB No. 7623) Idaho Power Company 1221 West Idaho Street (83702) P.O. Box 70 Boise, Idaho 83707 Telephone: (208) 388-5825 Facsimile: (208) 388-6936 Inordstrom(aMdahopower.com dwalker idahopower.com mgoicoecheaallenCabidahopower.com Attorneys for Idaho Power Company BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE ) APPLICATION OF IDAHO POWER ) CASE NO. IPC-E-24-07 COMPANY TO INCREASE RATES FOR ) ELECTRIC SERVICE TO RECOVER ) IDAHO POWER COMPANY'S COSTS ASSOCIATED WITH ) SUPPLEMENTAL RESPONSE TO INCREMENTAL CAPITAL ) THE SECOND PRODUCTION INVESTMENTS AND CERTAIN ) REQUEST OF THE COMMISSION ONGOING OPERATIONS AND ) STAFF TO IDAHO POWER MAINTENANCE EXPENSES. ) COMES NOW, Idaho Power Company ("Idaho Power" or "Company"), and in response to the Second Production Request of the Commission Staff ("Commission" or "Staff") to Idaho Power Company dated June 21, 2023, herewith supplements the following information: IDAHO POWER COMPANY'S SUPPLEMENTAL RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER- 1 REQUEST FOR PRODUCTION NO. 5: Please provide an Excel spreadsheet with formulas intact and enabled showing all capital projects that make up the $860,366,584 of Capital Project Cost the Company is proposing for recovery in this case. For each project, please include the following: a. Plant Account Description (Such as "Intangible Plant", "Hydro Production Plant", etc. as shown in Larkin's Workpaper No. 3, page 1); b. Project Type Description (As shown in Larkin's Workpaper No. 3, page 8— Column 2); c. Project ID/Unique Project Identifier; d. Project Name/Title; e. Detailed Project Description; f. Business Need; g. Actual Project Start Date; h. Anticipated/Actual In-Service Date; i. Budgeted Cost by Year; j. Annual Actual Project Cost to Date (Broken out by year); k. Cost Benefit Analysis Completed (Yes/No); I. Request for Proposal Completed (Yes/No); m. Wildfire Mitigation Related (Yes/No); and n. Grant Funding Awarded (Yes/No). SUPPLEMENTAL RESPONSE TO REQUEST FOR PRODUCTION NO. 5: Please see the Supplemental Response to Request for Production No. 5 — Confidential Attachment 1 for a list of all capital projects that have been placed in-service IDAHO POWER COMPANY'S SUPPLEMENTAL RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER- 2 during the January 1, 2024, through June 30, 2024, time period. The list includes the project type (part (b)) as well as an actuals to budget comparison by year (part (i) and (j)). In addition, Supplemental Response to Request for Production No. 5 — Confidential Attachment 2 includes the 2024 plant closings tracker, comparing the forecasted plant closings through June 2024 used to develop the 2024 test year in this case, to the actual closings through June 2024. Please note, the primary driver of the difference between actuals and forecast are associated with two projects over$8 million, the Franklin 60 MW Battery Energy Storage System ("BESS") and the Hemingway 36 MW BESS, that were anticipated to close to plant in June 2024 but have not yet been placed in service. The response to this Request is sponsored by Matt Larkin, Revenue Requirement Senior Manager, Idaho Power Company. IDAHO POWER COMPANY'S SUPPLEMENTAL RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER- 3 DATED at Boise, Idaho, this 25th day of July 2024. LISA D. NORDSTROM Attorney for Idaho Power Company DONOVAN E. WALKER Attorney for Idaho Power Company MEGAN GOICOECHEA ALLEN Attorney for Idaho Power Company IDAHO POWER COMPANY'S SUPPLEMENTAL RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER-4 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 25th day of July 2024, 1 served a true and correct copy of Idaho Power Company's Supplemental Response to the Second Production Request of the Commission Staff to Idaho Power 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(c�puc.idaho.gov PO Box 83720 Boise, ID 83720-0074 Industrial Customers of Idaho Power Hand Delivered Peter J. Richardson U.S. Mail Richardson Adams, PLLC Overnight Mail 515 N. 27' Street FAX Boise, Idaho 83702 FTP Site X Email peterC@richardsonadams.com Dr. Don Reading Hand Delivered 280 Silverwood Way U.S. Mail Eagle, Idaho 83616 Overnight Mail FAX FTP Site X Email dreading(@mindspring.com Idaho Irrigation Pumpers Association, Hand Delivered Inc. U.S. Mail Eric L. Olsen Overnight Mail ECHO HAWK & OLSEN, PLLC FAX 505 Pershing Avenue, Suite 100 FTP Site P.O. Box 6119 X Email elo _echohawk.com Pocatello, Idaho 83205 Lance Kaufman, Ph.D. Hand Delivered 2623 NW Bluebell Place U.S. Mail Corvallis, OR 97330 Overnight Mail FAX FTP Site X Email lance aegisinsight.com IDAHO POWER COMPANY'S SUPPLEMENTAL RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER- 5 Idaho Conservation League Hand Delivered Matthew Nykiel U.S. Mail 710 N. 6t" Street Overnight Mail Boise, Idaho 83702 FAX FTP Site X Email Matthew.n kiel mail.com Brad Heusinkveld Hand Delivered Idaho Conservation League U.S. Mail 710 N. 6t" Street Overnight Mail Boise, Idaho 83702 FAX FTP Site X Email bheusinkveld(a)idahoconservation.org Micron Technology, Inc. Hand Delivered Austin Rueschhoff U.S. Mail Thorvald A. Nelson Overnight Mail Austin W. Jensen FAX Kristine A.K. Roach FTP Site Holland & Hart LLP X Email 555 17' Street, Suite 3200 darueschhoff(c)_hol land hart.com Denver, CO 80202 tnelson(a)-hol land hart.com awjensen _hol land hart.com karoach(a)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 iswier(a)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 Boise, Idaho 83701 BoiseCityAttorneyCa�cityofboise.org ejewell cityofboise.org IDAHO POWER COMPANY'S SUPPLEMENTAL RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER- 6 Steven Hubble Hand Delivered Boise City Dept. of Public Works U.S. Mail 150 N. Capitol Blvd. Overnight Mail P.O. Box 500 FAX Boise, Idaho 83701-0500 FTP Site X Email shubble cityofboise.org Federal Executive Agencies Hand Delivered Peter Meier U.S. Mail Emily W. Medlyn Overnight Mail U.S. Department of Energy FAX 1000 Independence Ave., S.W. FTP Site Washington, DC 20585 X Email Pete r.meier(a�hg.doe.gov emily.medlyn(o)_hg.doe.gov Stacy Gust Regulatory Administrative Assistant IDAHO POWER COMPANY'S SUPPLEMENTAL RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER- 7