20250206Staff 1-11 to IPC.pdf

RECEIVED
Thursday, February 6, 2025 4:51:17 PM
IDAHO PUBLIC
UTILITIES COMMISSION
ADAM TRIPLETT
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334- 0318
IDAHO BAR NO. 10221
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 A ) CASE NO. IPC-E-24-45
CERTIFICATE OF PUBLIC CONVENIENCE )
AND NECESSITY FOR TWO BATTER )
STORAGE FACILITIES ) FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO IDAHO POWER COMPANY
Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Adam Triplett, Deputy Attorney General, requests that Idaho Power Company("Company")
provide the following documents and information as soon as possible, but no later than
THURSDAY, FEBRUARY 27, 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 FEBRUARY 6, 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: Company Witness Ellsworth stated the Company updated its
AURORA modeling inputs to include a wildfire risk factor. Ellsworth Direct at 11. Please
provide supporting workpapers that demonstrates how the wildfire risk factor was calculated.
Additionally,please explain how the wildfire risk factor impacted the model.
REQUEST NO. 2: For each of the 50 MW Battery Energy Storage System (`BESS")
projects,please explain the following:
a. Please explain whether the additional 50 MW will be on the same site, adjacent site,
or non-contiguous to the original project. In the response, please provide a geospatial
PDF map;
b. Please explain the method of electrical integration to the original project; and
c. Please provide the estimated operation and maintenance ("O&M") costs and explain
how it was factored into the project's cost-effectiveness.
REQUEST NO. 3: Please provide an updated total cost estimate for the development
and construction of the Boise Bench 50 MW Expansion BESS project, similar to the table
contained in Response to Production Request No. 4 in Case IPC-E-24-16. In the table, please
include an updated cost estimate for the total 200 MW Boise Bench BESS project.
REQUEST NO. 4: Please provide an updated total cost estimate for the development
and construction of the Hemingway Incremental 50 MW BESS project, similar to the table
contained in Response to Production Request No. 4 in Case IPC-E-24-16.
REQUEST NO. 5: The Company's two projects are the Boise Bench 50 MW
Expansion and the Hemingway Incremental 50 MW. Please explain what the difference is
between the terms "Expansion" and"Incremental".
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 2 FEBRUARY 6, 2025

REQUEST NO. 6: In IPC-E-24-16, Hackett's testimony referred to a Long-Term
Services Agreement for O&M services performed for the energy storage project following
commercial operation of the project. IPC-E-24-16 Hackett at 47. Please explain if the
Agreement has been updated to include the Boise Bench 50 MW Expansion BESS.
Additionally,please answer the following:
a. If the Company has an executed Long-Term Services Agreement, please provide the
Agreement; and
b. Please provide the updated cost of the Long-Term Services Agreement.
REQUEST NO. 7: Please answer the following questions regarding the Boise Bench 50
MW Expansion project:
a. Please explain if the project includes any amount of overbuild capacity. If so please
specify the capacity amount, associated cost, and estimated degradation offset;
b. Please describe the expected annual battery degradation of the project and provide
any documentation supporting the estimate;
c. Please explain if the Company has any assumptions for augmentation of the capacity
of this project;
d. Please provide a table of the expected capacity contribution in MW for the Boise
Bench 50 MW expansion for each year across the life of the batteries and include any
planned augmentations; and
e. Please provide a list of milestones that must be met before the project can begin
commercial operation.
REQUEST NO. 8: Please answer the following questions regarding the Hemingway
Incremental 50 MW project:
a. Please explain if the project includes any amount of overbuild capacity. If so please
specify the capacity amount, associated cost, and estimated degradation offset;
b. Please describe the expected annual battery degradation of the project and provide
any supporting documentation;
c. Please explain if the Company has any assumptions for augmentation of the capacity
of this project;
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 3 FEBRUARY 6, 2025

d. Please provide a table of the expected capacity contribution in MW for the project for
each year across the life of the batteries and include any planned augmentations; and
e. Please provide a list of milestones that must be met before the project can begin
commercial operation.
REQUEST NO. 9: Figure No. 22 in Exhibit No. 3 of Hackett's testimony represents the
initial shortlist bids for the 2026 commercial online date. Please respond to the following:
a. Please explain whether these initial shortlist projects were considered to replace
Savion's projects;
b. If yes, for each project in Figure No. 22, please explain why they were not selected,
and provide any analysis and/or documentation (i.e. cost comparison, and project
limits) showing why they were not selected when compared to the two battery storage
projects included in the Company's proposal; and
c. If not, please explain why these initial shortlisted projects were not reviewed or
considered.
REQUEST NO. 10: Table No. 2 in Hackett's testimony shows ten projects that were
selected in the AURORA Modeling Scenarios and considered to move to the final shortlist. For
each of the four projects that were not included in the final short list, please explain why they
were not considered as an alternative to replace Savion's two projects. Please provide any
documentation supporting the Company's reasons.
REQUEST NO. 11: Please explain the feasibility of additional market purchases as an
alternative to replace the capacity of Savion's projects.
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 4 FEBRUARY 6, 2025

DATED at Boise, Idaho, this 6th day of February 2025
Adam Triplett
Deputy Attorney General
I:\Utility\UMISC\PRDREQ\IPC-E-24-45 PR#I.doex
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 5 FEBRUARY 6, 2025

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS � DAY OF FEBRUARY 2025,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION
STAFF TO IDAHO POWER COMPANY , IN CASE NO. IPC-E-24-45, BY E-MAILING
A COPY THEREOF, TO THE FOLLOWING:
DONOVAN E. WALKER TIM TATUM
IDAHO POWER COMPANY IDAHO POWER COMPANY
PO BOX 70 PO BOX 70
BOISE ID 83707-0070 BOISE ID 83707-0070
E-MAIL: dwalkergidahopower.com E-MAIL: ttatumkidahopower.com
docketsgidahopower.com
V/
PATRICIA JORDAN, S RETARY
CERTIFICATE OF SERVICE