20240816Staff 69-73 to IPC.pdf

RECEIVED
Friday, August 16, 2024 10:29:57 AM
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 THE APPLICATION )
OF IDAHO POWER COMPANY TO ) CASE NO. IPC-E-24-07
INCREASE RATES FOR ELECTRIC )
SERVICE TO RECOVER COSTS )
ASSOCIATED WITH INCREMENTAL ) REDACTED TENTH
CAPITAL INVESTMENTS AND CERTAIN ) PRODUCTION REQUEST OF
ONGOING OPERATIONS AND ) THE COMMISSION STAFF TO
MAINTENANCE EXPENSES ) 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, SEPTEMBER 6, 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.
TENTH PRODUCTION REQUEST
TO IDAHO POWER COMPANY 1 AUGUST 16, 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. 69: Please provide an excel spreadsheet with formulas intact listing all
buyer construction costs incurred to date for the Franklin BESS project. This information should
include date, amount, purpose, and payee.
REQUEST NO. 70: Please provide a copy of the Interconnection Agreement for the
Franklin BESS project.
REQUEST NO. 71: Please provide the following for each of the BESS projects listed in
Larkin workpaper 3 —incremental plant determination at 11.
a. Please provide the AURORA long-term capacity expansion model results showing
the cost-effectiveness of the Company's BESS resource compared to the resource
Staff used to establish the soft cap, as described in Hackett Direct at 13.
b. Please provide the forecasted portfolio capacity positions for the life of each project
at time of the associated CPCN filing.
c. Please indicate if the system is stand-alone or if it is paired with a renewable
generation facility. For any system paired with renewable generation, please explain
if the BESS resource is connected in series or in parallel to the generation facility.
d. Please provide the actual build capacity excluding any overbuild or augmentation.
e. Please provide any overbuild capacity, associated costs, and describe if the overbuild
costs were included in the resource bid.
f. Please provide a timeline showing planned augmentation, associated cost, and the
augmentation amount.
g. Please indicate the battery technology type, the associated maximum depth-of-
discharge specification, the amount of reserved capacity, the assumed degradation for
each year of plant life, the rated number of discharge cycles per year, and the source
for each of these metrics (i.e. Company assumption, manufacturer warranty, etc.)
TENTH PRODUCTION REQUEST
TO IDAHO POWER COMPANY 2 AUGUST 16, 2024

h. Please explain the effect that the additional overbuild capacity will have on battery
degradation and maximum dispatch time.
i. Please provide a total project cost breakdown showing total project budget, total
current spend, amounts already being recovered, ITC amounts received, and total
budget previously closed. Please separate these project costs by AFUDC, overhead,
and customer contribution categories.
REQUEST NO. 72: Paragraphs 31 and 32 of the Company's Application explain the
method used to estimate the incremental costs of the hypothetical distribution line approved in
the 2017 CPCN. Application at 12. Please explain the following:
a. Please explain why the Company removed "most of the distribution poles," rather
than all the poles; and
b. Please explain why the Company added the following two items:
i. The replacement of a portion of the existing wood poles with taller, steel
poles; and
ii. Distribution intersect poles.
REQUEST NO. 73: Please provide invoices for the sample selected in the confidential
attachment titled "Jan-May Capital Project Invoice Sample". For selections not linked to
specific invoices, please explain the accounting method used to determine the amount and
provide calculations that determine the amount in Excel format.
DATED at Boise, Idaho, this 16th day of August 2024.
�4 �A
Chris Burdin
Deputy Attorney General
1:\Utility\UMISC\PRDREQ\IPC-E-24-07 PR#l0.docx
TENTH PRODUCTION REQUEST
TO IDAHO POWER COMPANY 3 AUGUST 16, 2024

Confidential Attachment No. 1
Jan-May Capital Project Invoice Sample
Case No.IPC-E-24-07
Production Request No. 10
August 16,2024

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 16TH DAY OF AUGUST 2024,
SERVED THE FOREGOING REDACTED TENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY, IN CASE NO. IPC-E-24-07,
BY E-MAILING A COPY THEREOF TO THE FOLLOWING:
LISA D. NORDSTROM TIMOTHY TATUM
DONOVAN E WALKER CONNIE ASCHENBRENNER
MEGAN GOICOECHEA ALLEN MATT LARKIN
IDAHO POWER COMPANY IDAHO POWER COMPANY
PO BOX 70 PO BOX 70
BOISE ID 83707-0070 BOISE ID 83707-0070
E-MAIL: lnordstromcidahopower.com E-MAIL: ttatum(�vidahopower.com
dwalkercidahopower.com caschenbrenner,c idahopower.com
mgoicoecheaallencidahopower.coin mlarkin2,ldahopower.com
docketscidahopower.com
ERIC L OLSEN LANCE KAUFMAN PhD
ECHO HAWK& OLSEN PLLC 2623 NW BLUEBELL PLACE
PO BOX 6119 CORVALLIS OR 97330
POCATELLO ID 83205 E-MAIL: lance c aegi sins ight.com
E-MAIL: elocechohawk.com
PETER J RICHARDSON DR DON READING
RICARDSON ADAMS PLLC 280 S SILVERWOOD WAY
515 N 27TH STREET EAGLE ID 83616
BOISE ID 83702 E-MAIL: dreading mindspring.com
E-MAIL: peter;trichardsonadams.com
MATTHEW NYKIEL BRAD HEUSINKVELD
ID CONSERVATION LEAGUE ID CONSERVATION LEAGUE
710 N 6TH STREET 710 N 6TH STREET
BOISE ID 83702 BOISE ID 83702
E-MAIL: matthew.nykiel(d,�gmail.com E-MAIL:
heus ink veld(&idahoconsery ation.org
PETER MEIER EMILY W MEDLYN
US DEPT OF ENERGY US DEPT OF ENERGY
1000 INDEPENDENCE AVE SW 1000 INDEPENDENCE AVE SW
WASHINGTON DC 20585 WASHINGTON DC 20585
E-MAIL: peter.meier(Cthq.doe.go`v' E-MAIL: Emil y.medlvn<c�hp doe.gov
CERTIFICATE OF SERVICE

JIM SWIER AUSTIN RUESCHHOFF
MICRON TECHNOLOGY INC THORVALD A NELSON
8000 S FEDERAL WAY AUSTIN W JENSEN
BOISE ID 83707 KRISTINE A.K. ROACH
E-MAIL: iswier(-d,,micron.com HOLLAND & HART LLP
555 17TH ST STE 3200
DENVER CO 80202
E-MAIL: darueschhoff ihoollandhart.corgi
tnelsonLr hollandhart.com
awjensencholl andhart.corn
karoachLt.,hollandhart.com
acleeCahollandhart.corn
mamemillew,'Lthollandhart.com
ED JEWELL STEVEN HUBBLE
DEPUTY CITY ATTORNEY BOISE CITY DEPT OF PUBLIC WORKS
BOISE CITY ATTORNEY'S PO BOX 500
PO BOX 500 BOISE ID 83701-0500
BOISE ID 83701-0500 E-MAIL: shubbleLacityotboise.or.p,
E-MAIL: ejewellLtcitvotboise.org
boisecitvattorne_y c citvofboise.ort=
PATRICIA JORDA , SECRETARY
CERTIFICATE OF SERVICE