20241002Staff 1-1 to IPC.pdf

RECEIVED
Wednesday, October 2, 2024 1:58:11 PM
IDAHO PUBLIC
UTILITIES COMMISSION
MICHAEL DUVAL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 11714
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 FOR ) CASE NO. IPC-E-24-36
APPROVAL OF A FIRST AMENDMENT TO )
THE ENERGY SALES AGREEMENT FOR )
THE SALE AND PURCHASE OF ELECTRIC ) FIRST PRODUCTION
ENERGY FROM THE MILE 28 HYDRO ) REQUEST OF THE
PROJECT ) COMMISSION STAFF
TO IDAHO POWER COMPANY
Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Michael Duval, Deputy Attorney General, requests that Idaho Power Company("Company")
provide the following documents and information as soon as possible, but no later than
WEDNESDAY, OCTOBER 23, 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.
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 1 OCTOBER 2, 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. 1: Page 3 of the Application states that Wood Hydro "has proposed an
alternative insurance arrangement that Idaho Power has determined creates equivalent protection
to the specified insurance requirements currently described in the ESA." Please respond to the
following:
a. Please explain the details of the alternative insurance arrangement;
b. Please explain why Idaho Power believed that the alternative insurance arrangement
created equivalent protection;
c. Please list all the criteria Idaho Power used in determining that the alternative
arrangement is equivalent to the insurance requirements in the ESA; and
d. After the execution of the ESA in 1993, the Commission issued Order No. 29482 in
2004, which approved new insurance requirements. Please explain why Parties did
not base the alternative insurance arrangement on the updated insurance requirements
approved in Order No. 29482 but instead based the alternative insurance arrangement
on the original insurance requirements in the ESA.
DATED at Boise, Idaho, this 2nd day of October 2024.
Michae Duv 1
Deputy Attorney General
I:\Utility\UMISC\PRDREQ\IPC-E-24-36 PR#Ldocx
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 2 OCTOBER 2, 2024

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS Z ODAY OF OCTOBER 2024,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION
STAFF TO IDAHO POWER COMPANY IN CASE NO. IPC-E-24-36, BY E-MAILING
A COPY THEREOF, TO THE FOLLOWING:
DONOVAN E WALKER ENERGY CONTRACTS
MEGAN GOICOECHEA ALLEN IDAHO POWER COMPANY
IDAHO POWER COMPANY PO BOX 70
PO BOX 70 BOISE ID 83707-0070
BOISE ID 83707-0070 E-MAIL: energycontracts&idahopower.com
E-MAIL: dwalker(cr�,idahopower.com
mgoicoecheaallen(a�idahopower.com
dockets(kidahopower.com
PATRICIA JORDAN, CRETARY
CERTIFICATE OF SERVICE