20250212Staff 12-18 to IPC.pdf

RECEIVED
ADAM TRIPLETT 2025 February 12, 2:52PM
DEPUTY ATTORNEY GENERAL IDAHO PUBLIC UTILITIES
IDAHO PUBLIC UTILITIES COMMISSION 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 BATTERY )
STORAGE FACILITIES ) SECOND 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
WEDNESDAY,MARCH 5, 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.
SECOND PRODUCTION REQUEST
TO IDAHO POWER COMPANY I FEBRUARY 12, 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. 12: National news has reported several fires in utility scale Battery
Energy Storage Systems (`BESS") over the past year. Please provide the Company's analysis of
the BESS fire risk, and the measures the Company intends to implement to mitigate this risk.
REQUEST NO. 13: Please provide a copy of any reports the Company received or
produced concerning its recent Melba battery fire.
REQUEST NO. 14: If a fire occurs in a Company-owned BESS system after the
standard warranty has lapsed,please explain who the Company believes would bear the cost to
rebuild the BESS and why: the Company's insurer, its ratepayers, or its shareholders.
REQUEST NO. 15: Section 7(a) of Presidential Executive Order No. 14154
(Unleashing American Energy)pauses "the disbursement of funds appropriated through the
Inflation Reduction Act of 2022...." Please explain if the scope of this pause includes the
issuance of Investment Tax Credits ("ITCs") and Production Tax Credits ("PTCs").
Additionally,please explain how Executive Order No. 14154 impacts the Company's two BESS
projects proposed in the Application.
REQUEST NO. 16: For each of the two projects proposed in this case, please provide
the worksheets showing the assumptions and calculations to determine their life-cycle levelized
costs. Clearly identify how the ITCs or PTCs are incorporated into the calculation. Please add
these two projects to the list of all the 2026 Commercial Operational Date Standalone BESS
provided in Exhibit No. 3, Figure 15, and then provide the new list, sorted by levelized cost.
REQUEST NO. 17: Please provide a map and a more detailed explanation regarding the
transmission constraints that eliminated the 200 MW solar PV plus 50 MW BESS project from
viability. See Hackett Direct at 23.
SECOND PRODUCTION REQUEST
TO IDAHO POWER COMPANY 2 FEBRUARY 12, 2025

REQUEST NO. 18: On Page 52 in Exhibit No. 3 of Hackett's testimony, it shows that
the 100 MW BESS Hemingway project was rejected due to uncertainty in the overall cost of
interconnection. Please explain if the proposed Incremental 50 MW Hemingway BESS has the
same uncertainty.
DATED at Boise, Idaho, this 12th day of February 2025
AJLQ�
Adam Triplett
Deputy Attorney General
I:\Utility\UMISC\PRDREQ\IPC-E-24-45 PR#2.docx
SECOND PRODUCTION REQUEST
TO IDAHO POWER COMPANY 3 FEBRUARY 12, 2025

CERTIFICATE OF SERVICE
1A/' DAY OF FEBRUARY 2025
I HEREBY CERTIFY THAT I HAVE THIS ,
SERVED THE FOREGOING SECOND 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:P
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: ttatumgidahopower.com
docketsgidahopower.com
C_
PATRICIA JORDA , SECRETARY
CERTIFICATE OF SERVICE