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Home My WebLink About20250305IPC to IIPA 1-6.pdf "4%611—HIQAHO m Re MEGAN GOICOECHEA ALLEN RECEIVED Corporate Counsel March 5, 2025 mgoicoecheaallen(?D_idahopower.com Idaho Public Utilities Commission March 5, 2025 Commission Secretary Idaho Public Utilities Commission 11331 W. Chinden Boulevard Building 8, Suite 201-A Boise, Idaho 83714 Re: Case No. IPC-E-24-44 Idaho Power Company's Application for Approval of a Special Contract and Tariff Schedule 28 to Provide Electric Service to Micron Idaho Semiconductor Manufacturing (Triton) LLC Dear Commission Secretary: Attached for electronic filing, please find Idaho Power Company's Response to Idaho Irrigation Pumpers Association, Inc.'s First Set of Data Requests in the above- entitled matter. The confidential attachment will be provided to the parties who sign the Protective Agreement If you have any questions about the attached documents, please do not hesitate to contact me. Sincerely, n I fAPCC�I.e.a l�lJ(1Gv1. Megan Goicoechea Allen MGA:sg Attachments 1221 W. Idaho St(83702) P.O. Box 70 Boise, ID 83707 CERTIFICATE OF ATTORNEY ASSERTION THAT INFORMATION CONTAINED IN AN IDAHO PUBLIC UTILITIES COMMISSION FILING IS PROTECTED FROM PUBLIC INSPECTION Idaho Power Company's Application for Approval of Special Contract and Tariff Schedule 28 to Provide Electric Service to Micron Idaho Semiconductor Manufacturing (Triton) LLC Case No. IPC-E-24-44 The undersigned attorney, in accordance with Commission Rules of Procedure 67, believes that the Attachment to Idaho Power Company's Response to Idaho Irrigation Pumpers Association, Inc.'s Request No. 1-4 dated March 5, 2025, contains information that Idaho Power and/or a third party claim constitutes trade secrets or other confidential business data exempt from disclosure under Idaho Code § 74-101, et seq., and/or § 48- 801, et seq. As such, it is protected from public disclosure, inspection, examination, or copying. DATED this 5th day of March 2025. Megan Goicoechea Allen Counsel for Idaho Power Company MEGAN GOICOECHEA ALLEN (ISB No. 7623) DONOVAN 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 mgoicoecheaallen(a).idahopower.com dwalker(a)idahopower.com Attorneys for Idaho Power Company BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF IDAHO POWER ) COMPANY'S APPLICATION FOR ) CASE NO. IPC-E-24-44 APPROVAL OF SPECIAL CONTRACT AND ) TARIFF SCHEDULE 28 TO PROVIDE ) IDAHO POWER COMPANY'S ELECTRIC SERVICE TO MICRON IDAHO ) RESPONSE TO IDAHO SEMICONDUCTOR MANUFACTURING ) IRRIGATION PUMPERS (TRITON) LLC. ) ASSOCIATION, INC.'S FIRST SET OF DATA REQUESTS COMES NOW, Idaho Power Company ("Idaho Power" or "Company"), and in response to Idaho Irrigation Pumpers Association, Inc.'s ("IIPA") First Set of Data Requests to Idaho Power Company dated February 12, 2025, herewith responds to the following information: IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST SET OF DATA REQUESTS- 1 REQUEST FOR PRODUCTION NO. IIPA 1-1: Are the Procurement Estimate and Cost Estimate in attachments 3 and 4 to the special contract additive? RESPONSE TO REQUEST FOR PRODUCTION NO. IIPA 1-1: Yes, the Procurement Estimate and Cost Estimate are distinct and correspond to their respective contract scopes. As outlined in the respective agreements, Micron is responsible for initially funding the estimated cost, and total project costs are reconciled upon completion. The response to this Request is sponsored by Eric Hackett, Projects and Resource Development Director, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST SET OF DATA REQUESTS-2 REQUEST FOR PRODUCTION NO. IIPA 1-2: Do the Procurement Estimate and Cost Estimate recover any transmission investments? If yes, please provide an allocation of the estimates between substation and transmission costs. RESPONSE TO REQUEST FOR PRODUCTION NO. IIPA 1-2: The Procurement Estimate and Cost Estimate both include transmission system investments, such as transmission lines and/or substations. Transmission line costs account for approximately $12.2 million of the estimate, Substation costs account for approximately $87.3 million with the remaining amount attributed to adding Optical Ground Wire ("OPGW") communication circuit to existing transmission line ($400k) and rebuilding existing distribution line ($900k). As a reminder, total project costs will be reconciled upon completion and recovered directly from Micron. The response to this Request is sponsored by Eric Hackett, Projects and Resource Development Director, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST SET OF DATA REQUESTS- 3 REQUEST FOR PRODUCTION NO. IIPA 1-3: Has the company incurred any transmission costs or does the company expect to incur any transmission costs not covered by the Procurement Estimate or Cost Estimate? If yes, please identify such costs. RESPONSE TO REQUEST FOR PRODUCTION NO. IIPA 1-3: No. All incremental transmission and substation costs required to serve the customer will be reconciled at project completion and recovered directly from the customer. The response to this Request is sponsored by Eric Hackett, Projects and Resource Development Director, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST SET OF DATA REQUESTS-4 REQUEST FOR PRODUCTION NO. IIPA 1-4: Please provide all transmission and interconnection studies performed as a result of the requested load. RESPONSE TO REQUEST FOR PRODUCTION NO. IIPA 1-4: The Idaho Power Planning department conducts the necessary transmission and interconnection studies by modeling the request in power flow software to assess potential thermal and voltage violations. The results of this power flow analysis — which demonstrated the required transmission upgrades required to serve the requested load — are communicated to the Company's Transmission & Distribution Project ("T&D") team. The T&D team leverages the results from this power flow study to scope out the required transmission upgrades, including the estimated cost and timeline to construct said upgrades. This solution was ultimately communicated to Micron in a cost breakdown of the scope of work and the solution to meet the proposed load (see file labeled "Confidential Attachment— Response to IIPA Request No. 14"). It is important to acknowledge that in addition to analyzing Company system requirements, customer reliability needs influence the ultimate transmission design. For example, a request to maintain service during the loss of one transmission line for maintenance, combined with a forced outage of another (N-1-1), requires a different solution than maintaining service with only a single unavailable element (N-1). As Idaho Power collaborates with the customer and receives feedback on the proposed scope of work, elements of the solution are often adjusted. The power flow analysis completed for the Micron FAB project lives within the power flow software and thus is not readily shareable. However, the Company is willing IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST SET OF DATA REQUESTS- 5 to conduct a demonstration with interested parties seeking to better understand the scope and detail of this type of transmission analysis. The response to this Request is sponsored by Jared L. Ellsworth, Transmission, Distribution & Resource Planning Director, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST SET OF DATA REQUESTS-6 REQUEST FOR PRODUCTION NO. IIPA 1-5: Please provide all workpapers generating the marginal cost energy price calculations described in Paragraphs 21 and 22 of the application. RESPONSE TO REQUEST FOR PRODUCTION NO. IIPA 1-5: The marginal cost-based energy price was determined in the AURORA model, which simulates the hourly economic dispatch of the Company's resources based on inputs for forecast fuel prices, hydro generation, and load. As such, workpapers containing the calculations for the energy price do not exist. Please refer to the Company's response to Staff Production Request No. 1(b) and Attachments 2-6 to that response for the workpapers containing the AURORA inputs for coal, natural gas, load, and hydro generation. The response to this Request is sponsored by Jessi Brady, Senior Regulatory Analyst, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST SET OF DATA REQUESTS- 7 REQUEST FOR PRODUCTION NO. IIPA NO. 1-6: Please provide the market price curves used to calculate the marginal cost energy price. RESPONSE TO REQUEST FOR PRODUCTION NO. IIPA 1-6: As described in the Company's response to IIPA's Request No. 1-5, the marginal cost-based energy price was determined in the AURORA model. AURORA models electricity prices in a wholesale energy market where prices are based on the marginal cost of production. Accordingly, market price curves were not used to calculate the marginal cost-based energy price. The response to this Request is sponsored by Jessi Brady, Senior Regulatory Analyst, Idaho Power Company. Respectfully submitted this 5t" day of March 2025. U I� U n ��fNL I MEGAN GOICOECHEA ALLEN Attorney for Idaho Power Company IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST SET OF DATA REQUESTS- 8 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 5th day of March 2025, 1 served a true and correct copy of Idaho Power Company's Response to Idaho Irrigation Pumpers Association, Inc.'s First Set of Data Requests upon the following named parties by the method indicated below, and addressed to the following: Commission Staff Hand Delivered Chris Burdin 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 PO Box 83720 Chris.Burdin(a)-puc.idaho.gov 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 peterC@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 Lance Kaufman, Ph.D. Hand Delivered 2623 NW Bluebell Place U.S. Mail Corvallis, OR 97330 Overnight Mail FAX FTP Site X Email lance aegisinsight.com IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST SET OF DATA REQUESTS- 9 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 17t" Street, Suite 3200 darueschhoff ja�hol land hart.com Denver, CO 80202 tnelson((2-)hol land hart.com awjensen hol land hart.corn karoach(a)hol land hart.com aclee hollandhart.com Stacy Gust Regulatory Administrative Assistant IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST SET OF DATA REQUESTS- 10 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-24-44 IDAHO POWER COMPANY CONFIDENTIAL REQUEST NO. 1 - 4 ATTACHMENT