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Home My WebLink About20250227IPC 1-2 to ICIP.pdf -UIQAW POWER, DONOVAN WALKER Lead Counsel dwal ker(@j da h o power.corn RECEIVED February 27, 2025 February 27, 2025 IDAHO PUBLIC UTILITIES COMMISSION VIA ELECTRONIC FILING Commission Secretary Idaho Public Utilities Commission 11331 W. Chinden Blvd., Bldg 8, Suite 201-A (83714) PO Box 83720 Boise, Idaho 83720-0074 Re: Case No. IPC-E-24-45 Application of Idaho Power Company for a Certificate of Public Convenience and Necessity for Two Battery Storage Facilities Dear Commission Secretary: Attached for electronic filing is Idaho Power Company's ("Idaho Power") Response to the First Production Request of the Industrial Customers of Idaho Power to Idaho Power Company in the above-referenced matter. If you have any questions about any of the aforementioned documents, please do not hesitate to contact me. Very truly yours, Donovan E. Walker DEW:sg Enclosures 1221 W. Idaho St(83702) P.O. Box 70 Boise, ID 83707 DONOVAN E. WALKER (ISB No. 5921) Idaho Power Company 1221 West Idaho Street (83702) P.O. Box 70 Boise, Idaho 83707 Telephone: (208) 388-5317 Facsimile: (208) 388-6936 dwalker(o-)idahopower.com Attorney for Idaho Power Company 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 ) IDAHO POWER COMPANY'S STORAGE FACILITIES. ) RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER TO IDAHO POWER COMES NOW, Idaho Power Company ("Idaho Power" or "Company"), and in response to the First Production Request of the Industrial Customers of Idaho Power ("ICIP") dated February 19, 2025, herewith submits the following information: IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF INDUSTRIAL CUSTOMERS OF IDAHO POWER TO IDAHO POWER- 1 REQUEST FOR PRODUCTION NO. 1: Please provide copies of all communications between Idaho Power and the Idaho Public Utilities Commission (including its Staff, consultants and/or Commissioners) regarding any aspect of Idaho Power's Application, please include both the time period before the Application was filed and the time period after the Application was filed. RESPONSE TO REQUEST FOR PRODUCTION NO. 1: There has been no communication between Idaho Power and the Commission and/or its Staff regarding Idaho Power's application in this proceeding. The response to this Request is sponsored by Tim Tatum, Vice President of Regulatory Affairs, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF INDUSTRIAL CUSTOMERS OF IDAHO POWER TO IDAHO POWER- 2 REQUEST FOR PRODUCTION NO. 2: Please provide copies of all responses to production requests in this matter (whether formal or informal) provided to any Party or person (including the Idaho PUC Staff). RESPONSE TO REQUEST FOR PRODUCTION NO. 2: The Company has provided no other responses, formal or informal, to Staff or other parties in this proceeding. As a matter of procedure, Idaho Power provides copies of responses to formal production requests to all intervening parties to the proceeding. The response to this Request is sponsored by Tim Tatum, Vice President of Regulatory Affairs, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF INDUSTRIAL CUSTOMERS OF IDAHO POWER TO IDAHO POWER- 3 DATED at Boise, Idaho this 27th day of February 2025. DONOVAN E. WALKER Attorney for Idaho Power Company IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER TO IDAHO POWER -4 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 27th day of February 2025, 1 served a true and correct copy of foregoing Idaho Power Company's Response to the First Production Request of Industrial Customers of Idaho Power to Idaho Power upon the following named parties by the method indicated below, and addressed to the following: Commission Staff Hand Delivered Adam Triplett U.S. Mail Deputy Attorney General Overnight Mail Idaho Public Utilities Commission FAX 11331 W. Chinden Blvd., Bldg No. 8 FTP Site Suite 201-A (83714) X Email Adam.Triplett(a puc.idaho.gov PO Box 83720 Boise, ID 83720-0074 Industrial Customers of Idaho Power Hand Delivered c/o Peter J. Richardson U.S. Mail Richardson Adams, PLLC Overnight Mail 515 N. 27' Street FAX Boise, Idaho 83702 FTP Site X Email peter(a)richardsonadams.com Dr. Don Reading Hand Delivered 280 S. Silverwood Way U.S. Mail Eagle, Idaho 83716 Overnight Mail FAX FTP Site X Email dreading(a mindspring.com Idaho Irrigation Pumpers Association, Hand Delivered Inc. U.S. Mail Eric L. Olsen Overnight Mail Echo Hawk & Olsen, PLLC FAX 505 Pershing Ave., Ste. 100 FTP Site P.O. Box 6119 X Email elo _echohawk.com Pocatello, Idaho 83205 IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER TO IDAHO POWER - 5 Lance Kaufman, Ph.D. Hand Delivered 2623 NW Bluebell Place U.S. Mail Corvallis, OR 97330 Overnight Mail FAX FTP Site X Email lance(a)aegisinsight.com Micron Technology, Inc. Hand Delivered Austin Rueschhoff U.S. Mail Thorvald A. Nelson Overnight Mail Austin W. Jensen FAX Kristine A.K. Roach FTP Site Holland & Hart LLP X Email 555 17' Street, Suite 3200 darueschhoff(a)hol land hart.com Denver, CO 80202 tnelson hol land hart.com awiensen(a)hol land hart.com karoach hollandhart.com aclee(a)hol land ha rt.com Stacy Gust Regulatory Administrative Assistant IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER TO IDAHO POWER - 6