HomeMy WebLinkAbout20241009IIPA 1-26 to IPC.pdf RECEIVED
Wednesday, October 09, 2024
IDAHO PUBLIC
UTILITIES COMMISSION
Eric L. Olsen(ISB#4811)
ECHO HAWK& OLSEN, PLLC
505 Pershing Ave., Ste. 100
P.O. Box 6119
Pocatello, Idaho 83205
Telephone: (208) 478-1624
Facsimile: (208) 478-1670
Email: elo a,echohawk.com
Attorney for Intervenor Idaho Irrigation Pumpers Association, Inc.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION CASE NO. IPC-E-24-07
OF IDAHO POWER COMPANY TO
INCREASE RATES FOR ELECTRIC IDAHO IRRIGATION PUMPERS
SERVICE TO RECOVER COSTS ASSOCIATION,INC.'S SECOND
ASSOCIATED WITH INCREMENTAL SET OF DATA REQUESTS
CAPITAL INVESTMENTS AND CERTAIN
ONGOING OPERATIONS AND
MAINTENANCE EXPENSES
Idaho Irrigation Pumpers Association, Inc., by and through counsel, hereby submits its
Second Data Requests to Idaho Power Company, pursuant to Commission Rule 225, as follows:
IIPA 2-1: Please refer to Attachment 1 - Response to IIPA Request No. 1-2 -D 10 D 13
E 1 O.xlsx.
a. Please provide the source for the values in cells C71:C82.
b. Please provide the source for the values in cells C114:C125.
c. Please provide the date and time used for each monthly coincident peak demand.
IIPA 2-2: Please provide the hourly real time energy prices for each market hub IPC
participates in from 2022 to present.
IIPA 2-3: Please provide IPC's actual system and Idaho jurisdictional net power costs by
month from 2020 to present.
IIPA 2-4: Please refer to Confidential Attachment- Response to IIPA Request No. 1-
6e.xlsx. Please provide these data for retail sales by jurisdiction.
IIPA 2-5: Please provide the day ahead high load hour and low load hour energy prices for
each market hub IPC participates in from 2022 to present.
IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.SECOND SET OF DATA REQUESTS—Page 1
CASE NO.IPC-E-24-07
IIPA 2-6: Please provide the forecasted market prices at the most granular level available
for 2025 for each market hub IPC participates in.
IIPA 2-7: Please provide all data, calculations, and workpapers used by IPC to support
claims of liquidated damages associated with any recent BESS fires. Please explain how the
Company intends to treat these amounts in rates.
IIPA 2-8: Please identify the total MW and MWh of battery storage, by facility, included in
net power cost underlying IPC's current rates.
IIPA 2-9: Please identify the total MW and MWh of battery storage, by facility, included in
IPC's current filing.
IIPA 2-10: Please provide a copy of any special contract which IPC expects to serve energy
under in 2025 or 2026.
IIPA 2-11: Please provide the following data for each customer over 10 MW:
a. Name, capacity, and location of each substation electrically connected to the
customer.
b. Capacity and length of each circuit connecting the customer to substations.
[IPA 2-12: Please refer to the 2023 IPC IRP.
a. Please provide the loss of load expectation or loss of load probability by month
and year under the 2023 IRP preferred portfolio.
b. Please provide IPC's LOLE or LOLP by month from 2024 to 2027 if IPC does
not acquire any additional capacity resources.
IIPA 2-13: Please provide a diagram of IPC's transmission, generation, and load topology.
Please identify the location of each BESS facility.
IIPA 2-14: Please provide the most recent substation level long term load forecast provided
by IPC's energy service division to IPC's transmission division.
IIPA 2-15: Please provide the Black Mesa Power Purchase Agreement.
IIPA 2-16: Please refer to Schedule 26. Please provide the Revised Exhibit 1 of Micron's
Special Contract, dated March 9, 2022, as amended.
IIPA 2-17: Was the Black Mesa PPA included in the final revenue requirement of the 2023
GRC?
IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.SECOND SET OF DATA REQUESTS—Page 2
CASE NO.IPC-E-24-07
IIPA 2-18: Please refer to Exhibit No. 2 Case No. IPC-E-23-11 Settlement Stipulation Page
26. Does the billed kwh of 591,344,540 reflect the total forecasted load of Micron, or the load
net of Black Mesa generation?
IIPA 2-19: Does the company currently have any schedule 20 customers?
IIPA 2-20: Does the company expect to have any schedule 20 customers in 2025?
IIPA 2-21: Please refer to In the Supreme Court of The State of Idaho Docket No. 49126,
Opinion Filed: May 17, 2023.
a. Please provide the total dollar value of property tax at issue in this proceeding by
year.
b. Please provide the total Idaho property tax assessed by year from 2019 to present.
Please indicate if these amounts include or exclude the contested amount
identified in response to part a.
c. Please provide the amount of Idaho property tax included in the 2023 GRC.
IIPA 2-22: Please provide each IPC credit opinion available to IPC issued by Moody's or
Standard and Poor's from 2020 to present.
IIPA 2-23: Please provide all communications between IPC or IPC's parent and Moody's or
Standard and Poor's in 2023 and 2024.
IIPA 2-24: Please refer to Attachment - Response to IIPA Request No. 1-9.xlsx.
a. Please confirm that the amount in Attachment-Response to IIPA Request No. 1-
9.xlsx line 45 of$1,287,899,827 reflects the Idaho firm jurisdictional sales
approved in IPC's most recent general rate case.
b. Please confirm that this revenue is based on the 14,907,835,244 kWh of sales
identified in the incremental revenue tab of"Attachment 7 - Response to Staff
Request No. 3 -Larkin Workpaper 7 - Revenue Growth Offset".
c. Please provide the workpaper used to calculate a revenue of$1,287,899,827 based
on the rates and load approved in IPC's last general rate case.
d. Does IPC agree that the "Mill Rate", or revenue per kWh, approved in the prior
rate case was $0.090061? If no, what was the revenue per kWh approved in the
prior case?
e. Does IPC agree that if the mill rate of$0.090061 is applied to the 124,724,470
incremental kWh included in"Attachment 7 - Response to Staff Request No. 3 -
Larkin Workpaper 7 - Revenue Growth Offset", the total incremental revenue is
$11,232,852.81? If no, what is the total incremental revenue?
f. Please refer to Attachment 10 -Response to Staff Request No. 3 - Tatum Exhibit
No. 4.xlsx which indicates Idaho retail revenue of$1,358,973,000, which is $16.3
million more than the revenue reported in Attachment-Response to IIPA Request
IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.SECOND SET OF DATA REQUESTS—Page 3
CASE NO.IPC-E-24-07
No. 1-9.xlsx line 45. Please explain why the incremental revenue reported in
Attachment 10 -Response to Staff Request No. 3 - Tatum Exhibit No. 4.xlsx
differs from that calculated when the mill rate is applied to incremental sales.
IIPA 2-25: Please refer to Attachment 10 -Response to Staff Request No. 3 - Tatum Exhibit
No. 4.xlsx. Please also refer to Confidential Attachment-Response to IIPA Request No. I-
4.xlsx.
a. Please indicate where the load associated with Simplot on Columns D and G
appear in Attachment 10 - Response to Staff Request No. 3 - Tatum Exhibit No.
4.xlsx and explain any differences between the 2024 amounts in IIPA 1-4 and
Tatum Exhibit 4.
b. Please indicate where the load associated with Lamb Weston on column D
appears in Attachment 10 -Response to Staff Request No. 3 - Tatum Exhibit No.
4.xlsx and explain any differences between the 2024 amounts in IIPA 1-4 and
Tatum Exhibit 4.
IIPA 2-26: Confidential Attachment-Response to IIPA Request No. 1-4.xlsx. Please
provide the large customer forecast used in IPC's last general rate case. Please provide in the
format used in Confidential Attachment- Response to IIPA Request No. 1-4.xlsx.
DATED this 91h day of October, 2024.
ECHO HAWK& OLSEN
ERIC L. OLSEN
IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.SECOND SET OF DATA REQUESTS—Page 4
CASE NO.IPC-E-24-07
CERTIFICATE OF SERVICE
I HEREBY CERTIFIY that on this 9th day of October, 2024, I served a true, correct and
complete copy of the Idaho Irrigation Pumpers Association, Inc.'s First Set of Data Requests to
each of the following, via the method indicated below:
Monica Barrios-Sanchez, Commission Secretary ❑ U.S. Mail
Idaho Public Utilities Commission ❑ Hand Delivered
P.O. Box 83720 ❑ Overnight Mail
Boise, ID 83720-0074 ❑ Telecopy (Fax)
monica.barriossanchez(&,puc.idaho.gov ® Electronic Mail (Email)
Chris Burdin ❑ U.S. Mail
Deputy Attorney General ❑ Hand Delivered
Idaho Public Utilities Commission ❑ Overnight Mail
P.O. Box 83720 ❑ Telecopy (Fax)
Boise, ID 83720-0074 ® Electronic Mail (Email)
chri s.burdin(apuc.Idaho.gov
Lisa D. Norstrom ❑ U.S. Mail
Donovan E. Walker ❑ Hand Delivered
Megan Goicoechea Allen ❑ Overnight Mail
Idaho Power Company ❑ Telecopy (Fax)
1221 W. Idaho Street (83702) ® Electronic Mail (Email)
PO Box 70
Boise, ID 83707-0070
lnordstrom(a,idahopower.com
dwalkergidahopower.com
mgoicoecheaallen(d),idahopower.com
dockets&idahopower.com
Tim Tatum ❑ U.S. Mail
Connie Aschenbrenner ❑ Hand Delivered
Matt Larkin ❑ Overnight Mail
Idaho Power Company ❑ Telecopy (Fax)
1221 W. Idaho Street(83702) ® Electronic Mail(Email)
PO Box 70
Boise, ID 83707-0070
ttatumkidahopower.com
caschenbrenner(cr�,idahopower.com
mlarkin&idahopower.com
IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.SECOND SET OF DATA REQUESTS—Page 5
CASE NO.IPC-E-24-07
Lance Kaufman, Ph.D. ❑ U.S. Mail
Idaho Irrigation Pumpers Association, Inc. ❑ Hand Delivered
2623 NW Bluebell Place ❑ Overnight Mail
Corvallis, OR 97330 ❑ Telecopy (Fax)
lance(caegisinsi_hg t.com ® Electronic Mail (Email)
Peter J. Richardson ❑ U.S. Mail
Richardson, Adams, PLLC ❑ Hand Delivered
Industrial Customer of Idaho Power ❑ Overnight Mail
515 N. 271h St. ❑ Telecopy (Fax)
P.O. Box 7218 ® Electronic Mail (Email)
Boise, ID 83702
petergrichardsonadams.com
Dr. Don Reading ❑ U.S. Mail
Industrial Customer of Idaho Power ❑ Hand Delivered
280 S. Silverwood Way ❑ Overnight Mail
Eagle, ID 83616 ❑ Telecopy (Fax)
dreadinggmindspring.com ® Electronic Mail (Email)
Matthew Nykiel ❑ U.S. Mail
Attorney for Idaho Conservation League ❑ Hand Delivered
710 N. 61h St. ❑ Overnight Mail
Boise, ID 83702 ❑ Telecopy (Fax)
matthew.n. kel(&,gmail.com ® Electronic Mail (Email)
Brad Heusinkveld ❑ U.S. Mail
Idaho Conservation League ❑ Hand Delivered
710 N. 6th St. ❑ Overnight Mail
Boise, ID 83702 ❑ Telecopy (Fax)
beusinkveld(a idahoconservation.org ® Electronic Mail (Email)
Peter Meier ❑ U.S. Mail
U.S. Department of Energy ❑ Hand Delivered
1000 Independence Ave., S.W. ❑ Overnight Mail
Washington, D.C. 20585 ❑ Telecopy (Fax)
peter.meier(chq.doe.gov ® Electronic Mail (Email)
IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.SECOND SET OF DATA REQUESTS—Page 6
CASE NO.IPC-E-24-07
Emily W. Medlyn ❑ U.S. Mail
U.S. Department of Energy ❑ Hand Delivered
1000 Independence Ave., S.W. ❑ Overnight Mail
Washington, D.C. 20585 ❑ Telecopy (Fax)
Emily.medIyn(chq.doe.gov ® Electronic Mail (Email)
Jim Swier ❑ U.S. Mail
Micron Technology, Inc. ❑ Hand Delivered
8000 South Federal Way ❑ Overnight Mail
Boise, ID 83707 ❑ Telecopy (Fax)
jswierµn.com ® Electronic Mail (Email)
Austin Rueschhoff ❑ U.S. Mail
Thorvald A. Nelson ❑ Hand Delivered
Austin W. Jensen ❑ Overnight Mail
Kristine A.K. Roach ❑ Telecopy (Fax)
Holland& Hart, LLP ® Electronic Mail (Email)
Micron Technology, Inc.
555 17a' Street Suite 3200
Denver, CO 80202
darueschhoff khollandhart.com
tnelson(d,hollandhart.com
awj ensen(khollandhart.com
karoach(&,,hollandhart.com
acleenhollandhart.com
mamcillen(&,,hollandhart.com
Ed Jewell ❑ U.S. Mail
Deputy City Attorney ❑ Hand Delivered
Boise City Attorney's Office ❑ Overnight Mail
150 N. Capitol Blvd. ❑ Telecopy (Fax)
PO Box 500 ® Electronic Mail (Email)
Boise, ID 83701-0500
eiewellAcityofboise.org
boisecityattomey&cityofboise.org
Steven Hubble ❑ U.S. Mail
Climate Action Senior Manager ❑ Hand Delivered
Boise City Dept. of Public Works ❑ Overnight Mail
150 N. Capitol Blvd. ❑ Telecopy (Fax)
P.O. Box 500 ® Electronic Mail (Email)
Boise, ID 83701-0500
shubble(kcityofboise.org
IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.SECOND SET OF DATA REQUESTS—Page 7
CASE NO.IPC-E-24-07
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ERIC L. OLSEN
IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.SECOND SET OF DATA REQUESTS—Page 8
CASE NO.IPC-E-24-07