20250226Staff 1-8 to IPC.pdf

RECEIVED
Wednesday, February 26, 2025 9:38:30 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 THE APPLICATION )
OF IDAHO POWER COMPANY FOR ) CASE NO. IPC-E-25-03
APPROVAL OF THE NORTH VALMY )
POWER PLANT NATURAL GAS )
CONVERSION AGREEMENT WITH NV ) FIRST PRODUCTION
ENERGY ) REQUEST OF THE
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,MARCH 19, 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 26, 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: Please provide the most recent total cost estimate for the following:
a. The total cost breakdown for converting Valmy Units 1 and 2 to natural gas. Please
provide the share of each cost that NV Energy and Idaho Power will be responsible
for.
b. The decommissioning, demolition, and closure activities costs associated with the
retirement of coal. Please provide the share of each cost that NV Energy and Idaho
Power will be responsible for.
c. The reimbursement of past costs for Unit 1. Please provide the share of each cost NV
Energy and Idaho Power will be responsible for.
d. The operation and maintenance costs after gas conversion including fuel
transportation cost. Please provide the share of each cost NV Energy and Idaho
Power will be responsible for.
REQUEST NO. 2: Page 13 of Ellsworth's Direct Testimony discusses an additional
AURORA analysis performed by the Company. Please provide a side-by-side comparison
showing the numerical values for all the specific differences in input assumptions from the
additional analysis described and used in this case and the 2023 IRP analysis used to justify
Valmy in the preferred portfolio.
REQUEST NO. 3: Did the Company consider or conduct an analysis operating Unit 1
as a coal unit beyond 2019 since Order No. 33771 was issued, in subsequent IRPs, or in
preparation for this case? If not, why not? If so,please provide a description and the results of
the Company's analysis.
REQUEST NO. 4: Did the Company consider or conduct an analysis operating Unit 2
as a coal unit past 2025 since Order No. 33771 was issued, in subsequent IRPs, or in preparation
for this case? If not, why not? If so,please provide a description and the results of the
Company's analysis.
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 2 FEBRUARY 26, 2025

REQUEST NO. 5: Please provide all the limitations of operating Valmy Units 1 and/or
2 as a coal plant beyond 2025 other than the current agreements in place for the Valmy plant and
the negotiated dates for ceasing burning coal from the 2017 Settlement approved in Order No.
33771.
REQUEST NO. 6: Did the Company conduct any analysis beyond what was described
in the Application or in Ellsworth's Direct testimony? If so, please provide a description of the
analysis, the assumptions used, and the results of the Company's analysis.
REQUEST NO. 7: Please provide an excel spreadsheet with formulas intact, showing
all costs and fees incurred by the Company related to the exit of Valmy Unit 1. This should
include a brief description of the fees and if they are part of the Framework Agreement's Exit
Fee, Exit Fee Cost Basis, Shared Costs, or were incurred in another manner.
REQUEST NO. 8: Please provide an excel spreadsheet with formulas intact, showing
all estimated Reimbursement of Past Costs for Unit 1 identified in the proposed Natural Gas
Conversion Agreement Section 5. This should include a brief description of the costs, how they
were incurred, and if they are agreed to by both parties or are still under review.
DATED at Boise, Idaho, this 26th day of February 2025.
N,,-prL,vA-
Chris Burdin
Deputy Attorney General
I:AUtility\UMISC\PRDREQAIPC-E-25-03 PR#I.docx
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 3 FEBRUARY 26, 2025

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS -k DAY OF FEBRUARY 2025,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION
STAFF TO IDAHO POWER COMPANY, IN CASE NO. IPC-E-25-03, BY E-MAILING
A COPY THEREOF TO THE FOLLOWING:
LISA D. NORDSTROM TIM TATUM
MEGAN GOICOECHEA ALLEN IDAHO POWER COMPANY
IDAHO POWER COMPANY PO BOX 70
PO BOX 70 BOISE ID 83707-0070
BOISE ID 83707-0070 E-MAIL: ttatum�cuidahopower.com
E-MAIL: iiiordstrorii(�6,idahopower.com
Ingoicoecheaallennidahopower.com
docketsaidahopower.com
PAT ILIA JORDAN, CRETARY
CERTIFICATE OF SERVICE