20250108Staff 1-5 to IPC.pdf

RECEIVED
Wednesday, January 8, 2025 11:20:54 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 IDAHO POWER )
COMPANY'S APPLICATION FOR ) CASE NO. IPC-E-24-44
APPROVAL OF A SPECIAL CONTRACT )
AND TARRIFF SCHEDULE 28 TO PROVIDE )
ELECTRIC SERVICE TO MICRON IDAHO ) FIRST PRODUCTION
SEMICONDUCTOR MANUFACTURING ) REQUEST OF THE
(TRITON)LLC ) COMMISSION STAFF
TO 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
WEDNESDAY,JANUARY 29, 2025.
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 JANUARY 8, 2025

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: In reference to the proposed Demand and Energy Charges discussed
on pages 7-9 of the Application, please respond to the following:
a. Please provide all workpapers used to determine the Demand Charges. Please
provide all workpapers in electronic format with formulas enabled
b. Please provide all model runs and workpapers used to determine the Energy Charge.
For the model runs, please provide the assumptions used for each model run. Please
provide all files in electronic format with formulas enabled.
c. Please explain if the Company considered any other methods to determine the Energy
Charge for Schedule 28 besides the marginal cost method discussed in the
Application. If other methods were considered,please explain the method(s)
considered and why these method(s)were not selected. If no other method(s) were
considered,please explain why no other methods were considered.
d. Please explain if the Company evaluated the proposed Energy Charge differentiated
by season and by On, Mid, and Off-peak hour pricing similar to Demand-Side
Management Avoided Cost Averages. If the Company did evaluate the time periods,
please explain why the time periods were not used and provide the Company's
workpapers from the evaluation. If the Company did not evaluate these time periods,
please explain why these time periods were not evaluated.
e. Please provide a proposal for Energy Charges differentiated by season and by On,
Mid, and Off-peak hours with electronic workpapers documenting the method.
REQUEST NO. 2: In reference to the option under Section 7.2 to reevaluate the basis
for Energy Charges discussed on page 9 of the Application,please respond to the following:
a. Please explain the rationale for allowing a reevaluation after the schedule ramp period
end versus a different time period; and
b. Please provide examples of when the Company would consider pricing the Micron
FAB facility at its then embedded variable energy costs.
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 2 JANUARY 8, 2025

REQUEST NO. 3: Please provide all annual and hourly load forecasts for the years
2025 through 2031 the Company has for the Micron FAB facility. Please provide files in
electronic format with formulas enabled.
REQUEST NO. 4: Please explain how the Company plans to incorporate Schedule 28
into future rate cases.
REQUEST NO. 5: Please explain if Micron FAB's Scheduled Ramp Contract Demand
set forth in Exhibit 3 of the Special Contract is still accurate based on any changes that have
occurred in their schedule for expanding operations.
DATED at Boise, Idaho, this 8th day of January 2025.
al-kk4-1
Chris Burdin
Deputy Attorney General
I:\Utility\UMISC\PRDREQ\IPC-E-24-44 PR#Ldocx
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 3 JANUARY 8, 2025

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS A&DAY OF JANUARY 2025,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION
STAFF TO IDAHO POWER COMPANY, IN CASE NO. IPC-E-24-44, BY E-MAILING
A COPY THEREOF, TO THE FOLLOWING:
MEGAN GOICOECHEA ALLEN CONNIE ASCHENBRENNER
DONOVAN E. WALKER GRANT ANDERSON
IDAHO POWER COMPANY IDAHO POWER COMPANY
PO BOX 70 PO BOX 70
BOISE ID 83707-0070 BOISE ID 83707-0070
E-MAIL: mgoicoecheaallen(a,idahopower.com E-MAIL: caschenbrenner(a,idahopower.com
dwalker(&idahopower.com gandersongidahopower.com
dockets gidahol2ower.com
PAT ICIA JORDAN, S RETARY
CERTIFICATE OF SERVICE