20260204ICIP to IPC 1-17.pdf

I Peter J. Richardson ISB # 3195
515 N. 27th Street
2 Boise, Idaho 83702
3 [phone] DD RECEIVED
[phone] Cell FEBRUARY 4, 2026
4 UIcr�i��,richardsonadams.com IDAHO PUBLIC
UTILITIES COMMISSION
5
6 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
7
8 IN THE MATTER OF IDAHO POWER Case No.: IPC-E-25-35
9 COMPANY'S APPLICATION FOR A
PRUDENCE DETERMINATION OF HELLS
io CANYON COMPLEX RELICENSING COSTS FIRST PRODUCTION REQUEST AND
FROM JANUARY 1, 2016, THROUGH INTERROGATORIES OF THE
I DECEMBER 31, 2025.
INDUSTRIAL CUSTOMERS OF IDAHO
12 POWER TO IDAHO POWER COMPANY
13
14
Pursuant to Rule 225 of the Rules of Procedure of the Idaho Public Utilities
15
16 Commission (the "Commission"), the Industrial Customers of Idaho Power by and through its
17 attorney of record, Peter J. Richardson, hereby requests that Idaho Power Company ("Idaho
18 Power" or the "Company") provide responses to the following with supporting documents,
19
where applicable.
20
21 These Production Requests and Interrogatories are to be considered as continuing,
22 and Idaho Power is requested to provide by way of supplementary responses additional
23 documentation that it or any person acting on its behalf may later obtain that will augment the
24 responses or documents previously produced.
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FIRST PRODUCTION REQUEST AND INTERROGATORIES OF THE INDUSTRIAL CUSTOMERS OF
27 IDAHO POWER TO IDAHO POWER COMPANY
IPC-E-25-35
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I Please provide your responses to Peter Richardson at the address first noted
2
above.
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For each response, please indicate the name of the person(s)preparing the same
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5 along with the job title of such person(s) and the name of the witness at hearing who can sponsor
6 the answer.
7 REQUEST FOR PRODUCTIONANTERROGATORY NO. 1:
8 Please provide copies of all communications between Idaho Power and the Idaho Public
9
Utilities Commission (including its Staff, consultants and/or Commissioners) regarding any
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I aspect of the Company's Application, please include both the time period before the Application
12 was filed and the time period after the Application was filed.
13 REQUEST FOR PRODUCTION/INTERROGATORY NO. 2:
14 Please provide copies of all responses to production requests in this matter(whether forma
15
or informal) provided to any Party or person (including the Idaho PUC Staff).
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17 REQUEST FOR PRODUCTION/INTERROGATORY NO. 3:
18 Mr. Brady at page 3 line 24 of his direct testimony states that the Hells Canyon Comple
19 ("HCC") represents "approximately 24 percent of the Company's total generating capacity." Mr,
20 Dumas at page 2 of his direct testimony states that the"HCC provides . . . about 30 percent of the
21
Company's total generating capacity." Please provide the workpapers and documents relied oil
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23 by Mr. Brady and Mr. Dumas supporting their respective assertions noted above. Please also
24 reconcile the two different percentages and explain the two witnesses' apparent disagreement a
25 to the correct percentage.
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FIRST PRODUCTION REQUEST AND INTERROGATORIES OF THE INDUSTRIAL CUSTOMERS OF
27 IDAHO POWER TO IDAHO POWER COMPANY
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I REQUEST FOR PRODUCTION/INTERROGATORY NO. 4:
2 For each of the most recent ten years for which data is available, please identify the tota
3
net generation output in kWh for the HCC and its associated capacity factor.
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5 REQUEST FOR PRODUCTION/INTERROGATORY NO. 5:
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6 For each of the most recent ten years for which data is available, please identify the
7 percentage of total net generation(expressed in kWh)of Idaho Power's owned generating facilitie
8 that is represented by the HCC's net generation. Do not include purchased power volumes in you
9
calculations.
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11 REQUEST FOR PRODUCTION/INTERROGATORY NO. 6:
12 For each of the most recent ten years for which data is available, please identify the
13 percentage of total net retail energy sales (kWh) on Idaho Power's system that have been satisfie
14 by net energy generation (kWh) from the HCC.
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REQUEST FOR PRODUCTION/INTERROGATORY NO. 7:
16
17 Please explain the derivation of the assertion by Mr. Brady at page 11 line 8 of his direc
18 testimony that"Approximately$228.2 million, or 88 percent, of the $258 in AFUDC is associate
19 with CWIP balances deemed prudent in Order No. 3403 L" Please provide your calculations along
20 with copies and citations for the preparation of your calculations to the necessary documents and/o
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workpapers.
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FIRST PRODUCTION REQUEST AND INTERROGATORIES OF THE INDUSTRIAL CUSTOMERS OF
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I REQUEST FOR PRODUCTION/INTERROGATORY NO. 8:
2 Please explain why there are negative numbers reflected on Exhibit 1 and what theN
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represent.
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5 REQUEST FOR PRODUCTION/INTERROGATORY NO. 9:
6 Under the column "WO Status" on Exhibit 1 please explain the significance of the tern
7 "Closed" and the significance of the word "Complete" and whether and how the two terms are
8 related.
9
IZ_EWIE,ST FOR PRODUCTION/INTERROGATORY NO. 10:
10
I On page 10 at line 17 of Mr. Dumas' testimony, he states that, "Work on the Grand Vieii
12 Project continues to this day, but the costs under review in this case are limited to those associates.
13 with the initial proof-of-concept phase. " Please explain why Exhibit 1 (at the second row on pag
14 2) indicates that the WO [workorder] Status for the "Grand View Irrigation Upgrade Research
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Project" is "Closed"? Please identify all additional costs associated with this project that are no
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17 "under review in this case" including costs that have been incurred and costs that are reasonabl
18 anticipated to be incurred.
19 REQUEST FOR PRODUCTION/INTERROGATORY NO. 11:
20 At page 10, beginning on line 21, of his direct testimony Mr. Dumas is asked, 'T,11(<
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requirements for total dissolved gas were established in the CWA Section 401 certifications?" h
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23 response (at page 11, beginning on line 1) Mr. Dumas states that `flow deflectors are proposed t(
24 be installed and operated at Brownlee, Oxbox, and Hells Canyon dams. " Please clarify "vhethel
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FIRST PRODUCTION REQUEST AND INTERROGATORIES OF THE INDUSTRIAL CUSTOMERS OF
27 IDAHO POWER TO IDAHO POWER COMPANY
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I "flow deflectors" are "requirements" or whether they are a "proposal." If they are "proposal[s]'
2 please clarify whether Idaho Power will be accepting or rejecting the proposals.
3
REQUEST FOR PRODUCTION/INTERROGATORY NO. 12:
4
5 Are the costs of"flow deflectors" reflected on Exhibit 1, if not please explain why not an
6 document the anticipated expenses associated with design, installation and operation of the
7 referenced"flow deflectors."
8 REQUEST FOR PRODUCTION/INTERROGATORY NO. 13:
9
At pages 6 — 7 of his direct testimony Mr. Dumas addresses the "final section 40
10
11 certifications. " With respect to the section 401 certifications, Mr. Dumas testifies that Idah
12 Power has requested FERC to incorporate the terms of the 401 certifications into the "new HCC
13 license." Please detail the anticipated impact of full compliance with referenced section 401
14 certifications on the electric output potential of the HCC. Provide all documentation, studies
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analysis or evaluations available to the Company that address the impact of the section 401
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17 certifications on the output potential of the HCC. When addressing output potential please addres
18 annual, seasonal and diurnal kWh and kw output impacts.
19 REQUEST FOR PRODUCTIONANTERROGATORY NO. 14:
20 Exhibit A to the section 401 certifications referenced by Mr. Dumas contains specific HCC
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operational constraints including such constraints as "ramp rates", "target elevations", "reservoi
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23 elevation changes", "minimum bypass flows", "maximum reservoir elevation", "minimurn
24 reservoir elevation", "maximum daily flow fluctuation" and "project outflows." Please explaii
25 whether and, if so how, the section 401 operational constraints are different from the operations
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FIRST PRODUCTION REQUEST AND INTERROGATORIES OF THE INDUSTRIAL CUSTOMERS OF
27 IDAHO POWER TO IDAHO POWER COMPANY
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I constraints the HCC is currently operated under and detail how the new or revised operationa
2 constraint(s) impact the anticipated electrical output potential of the HCC under expecte
3
operating conditions. When addressing impacts on electrical output potential under expecte
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operating conditions please address annual, seasonal and diurnal kWh and kw modeled outpu
6 impacts. Provide copies of all related studies and analyses available or referenced.
7 REQUEST FOR PRODUCTION/INTERROGATORY NO. 15:
8 Beginning on the bottom of page 8, Mr. Dumas' testimony addresses the Snake rive
9
Stewardship Program (SRSP") which he describes as, "Idaho Power's long-term effort to address
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I elevated water temperatures in the Snake River by improving river and tributary habitat. '
12 Continuing on to page 9 Mr. Dumas identifies:
13 One key project implemented under the SRSP is the Bayha Island Project, which was
completed in 2016. . . . The Completion of this project [Bayha Island Project] wa
l4 instrumental in demonstrating to the Idaho and Oregon DEQs that the SRSP is a viabl
15 temperature mitigation program, Ultimately supporting the issuance of CWA Section 40
certifications.
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17 Please identify the modeled thermal benefits for the Bayha Island Project and also express
18 those modeled thermal benefits as a percentage of the cumulative goal for offsets to the 11('(
19 outflow cumulative thermal load exceedance discussed in detail in the Company's Urc ion am
20 Idaho HCCE Section 401 Application and as adopted in the final Section 401 permit.
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https://www2.dea.idghp,goy/ad__min/LEWapi/document/download/10601
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27 IDAHO POWER TO IDAHO POWER COMPANY
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I REQUEST FOR PRODUCTION/INTERROGATORY NO. 16:
2 Has Idaho Power confirmed and documented through independent performance audits tha
3
the Bayha Island Project has been consistently maintained and is currently functioning iii
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accordance with the project's specifications? Please provide copies of all such audits an
6 evaluations.
7 REQUEST FOR PRODUCTION/INTERROGATORY NO. 17:
8 Mr. Dumas' discussion of the Bayha Island Project is in response to a question regarding
9
the "types of projects that have been implemented under the SRSP. " Please identify the othe
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11 restoration projects for thermal benefits that have been implemented under the SRSP by Idah
12 Power. For each such project please identify that project's modeled thermal benefits and alsc
13 express those modeled thermal benefits as a percentage of the cumulative goal for offsets to the
14 HCC outflow cumulative thermal load exceedance discussed in detail in the Company's Ore go
15
and Idaho HCCE Section 401 Application and as adopted in the final Section 401 permit.
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17 Dated this 4ch day of February 2026.
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19 By; �:/ `
Peter ichardson
20 Richardson Adams, PLLC
21 Attorneys for Industrial Customers of Idaho Power
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FIRST PRODUCTION REQUEST AND INTERROGATORIES OF THE INDUSTRIAL CUSTOMERS OF
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1
2 CERTIFICATE OF SERVICE
3
I HEREBY CERTIFY that on the 41h day of February 2026, a true and correct copy of the within
4 and foregoing FIRST PRODUCTION REQUEST of the INDUSTRIAL CUSTOMERS OF
5 IDAHO POWER in Docket No. IPC-E-25-35 was served by electronic copy only, to:
6 Monica Barrios-Sanches Lisa Lance
Commission Secretary Regulatory Dockets
7 Idaho Public Utilities Commission Idaho Power Company
PO Box 83720 1221 West Idaho Street(83702)
8 Boiie, ID 83720-0074 P.O. Box 70
9 secretaryr-&uc.idaho.gov Boise, Idaho 83707
monica.bariossanchesgl2Ltc.idaho.gov [e-mail]
10 dockets(i4idahopowerxom
11 Connie Aschenbrenner
12 Jessi Brady
Idaho Power Company
13 1221 West Idaho Street (83702)
P.O. Box 70
14 Boise, Idaho 83707
15 caschenbrenner c idahopower.com
ibr,,[e-mail]
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24 By: Peter J. ichardson ISB # 3195
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27 IDAHO POWER TO IDAHO POWER COMPANY
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