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Home My WebLink About20241009IIPA 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) jswier&micron.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 �Z2�p�- ERIC L. OLSEN IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.SECOND SET OF DATA REQUESTS—Page 8 CASE NO.IPC-E-24-07