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Home My WebLink About20260625Objection to IIPA Renewed Request for Production Based on Prior IPC Relevance Objections.pdf HIQAHO POWERO MEGAN GOICOECHEA ALLEN RECEIVED Corporate Counsel JUNE 25, 2026 mgoicoecheaallen(a)idahopower.com IDAHO PUBLIC UTILITIES COMMISSION June 25, 2026 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-26-07 Idaho Power Company's Petition to Evaluate Class Cost-of Service Methodology, Consider Alternative Class Cost-of-Service Studies, and Determine Cost of Service Considerations for New Large-Load Customers Dear Commission Secretary: Attached for electronic filing please find Idaho Power Company's Objections to Idaho Irrigation Pumpers Association, Inc.'s Renewed Requests for Production Based on Prior Idaho Power Relevance Objections in the above-entitled matter. If you have any questions about the attached documents, please do not hesitate to contact me. Very truly yours, \,�T I W&IA Megan Goicoechea Allen MGA:cd Attachments 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) 388-2664 Facsimile: (208) 388-6936 mgoicoecheaallen@idahopower.com dwalker@idahopower.com Attorneys for Idaho Power Company BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE PETITION OF ) IDAHO POWER COMPANY TO ) CASE NO. IPC-E-26-07 EVALUATE CLASS COST-OF-SERVICE ) METHODOLOGY, CONSIDER ) IDAHO POWER COMPANY'S ALTERNATIVE CLASS COST-OF- ) OBJECTIONS TO IDAHO SERVICE STUDIES, AND DETERMINE ) IRRIGATION PUMPERS COST OF SERVICE CONSIDERATIONS ) ASSOCIATION, INC.'S RENEWED FOR NEW LARGE-LOAD CUSTOMERS ) REQUESTS FOR PRODUCTION BASED ON PRIOR IDAHO POWER RELEVANCE OBJECTIONS COMES NOW, Idaho Power Company ("Idaho Power" or"Company"), pursuant to the Rule 225 of the Commission's Rules of Practice and Procedure and the Idaho Rules of Civil Procedure, objects to Idaho Irrigation Pumpers Association, Inc.'s ("IIPA") Renewed Requests for Production Based on Prior Idaho Power Relevance Objections to Idaho Power Company dated June 11, 2026 ("IIPA's First Set of Data Requests"), as follows: IDAHO POWER COMPANY'S OBJECTION TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S RENEWED REQUEST FOR PRODUCTION BASED ON PRIOR IDAHO POWER RELEVANCE OBJECTIONS - 1 GENERAL OBJECTIONS 1. Idaho Power objects generally to IIPA's First Set of Data Requests as procedurally improper. To the extent these requests purport to "renew" discovery requests from multiple prior Idaho Power proceedings,' this approach is not recognized or authorized under the Commission's rules and framework governing discovery and is unnecessary given that IIPA has the right of discovery in the current case independent of those other proceedings. Moreover, Idaho Power's relevance-based objections in those dockets were necessarily tied to the subject matter and scope of those particular proceedings and therefore are not determinative of the appropriate scope of discovery in this proceeding. 2. Idaho Power further objects to I IPA's characterization of its First Set of Data Requests as a "renewal" of prior discovery to the extent IIPA is expanding the scope of the original requests, posing new questions, or reframing prior responses or objections beyond their original context. 3. Idaho Power objects to these requests to the extent they seek information that Idaho Power and/or any third-party contends constitutes trade secrets, confidential business data, and/or other non-public records protected from disclosure under applicable law, including information subject to protective agreements in other proceedings insofar as it seeks to circumvent those protections. ' Including Case Nos.: IPC-E-25-23 (Idaho Power's 2025 Integrated Resource Plan), IPC-E-25-27 (Application for Approval of Power Purchase Agreement with Black's Creek Energy Center), IPC-E-25-29 (Application for Certificate of Public Convenience and Necessary ("CPCN")for the Bennett Gas Expansion Project), IPC-E-26-03 (Application for Approval of 2032 All-Source Request for Proposal ("RIFF)), IPC-E-26- 04 (Application for CPCN for the South Hills and Peregrine Power Plants), and IPC-E-26-09 (Application for CPCN for Segment E-8 of the Gateway West Transmission Line). IDAHO POWER COMPANY'S OBJECTION TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S RENEWED REQUEST FOR PRODUCTION BASED ON PRIOR IDAHO POWER RELEVANCE OBJECTIONS - 2 4. Idaho Power further objects to requests that seek information that is not relevant to the claims or issues presented in this proceeding or otherwise outside the permissible scope of discovery under the Commission's Rules of Practice and Procedure and the Idaho Rules of Civil Procedure. Idaho Power also objects to requests that seek data or analyses that do not exist or that would require Idaho Power to create new analyses or perform new studies in a form dictated by IIPA. Such requests undermine the intent of this docket to collaboratively identify alternative CCOS studies that will be presented for the Commission's consideration and unreasonably broaden the scope of issues in this docket in contravention of the Commission's rules and framework governing intervention. 5. Idaho Power also objects generally to those requests that are not reasonably calculated to lead to the discovery of admissible evidence and that are overly broad and unduly burdensome, including requests not limited to any stated period of time or relating to a stated period of time that is longer than is relevant for purposes of the issues in this docket. 6. Each discovery response below is given subject to these General Objections as appropriate, which are incorporated by this reference as if fully set forth below. 7. Except as set forth below, Idaho Power intends to provide responses to IIPA's First Set of Data Requests, subject to and notwithstanding all appropriate objections including these General Objections, in accordance with Commission Rule of Procedure 225. IDAHO POWER COMPANY'S OBJECTION TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S RENEWED REQUEST FOR PRODUCTION BASED ON PRIOR IDAHO POWER RELEVANCE OBJECTIONS - 3 REQUESTS FOR PRODUCTION REQUEST FOR PRODUCTION NO. 1-34: Please identify all Board of Directors presentations, executive committee presentations, management presentations, strategic planning presentations, or capital planning presentations discussing: 1. AFL; 2. Data center growth; 3. Large-load growth; 4. Resource adequacy impacts of AFL; 5. Transmission impacts of AFL; or 6. Customer cost responsibility associated with AFL. OBJECTION TO REQUEST FOR PRODUCTION NO. 1-34: Idaho Power objects to this request on the grounds it is overly broad and unduly burdensome insofar as it is not limited to any stated period of time and otherwise seeks information that is not relevant to the subject matter of this action and/or not reasonably calculated to lead to the discovery of admissible evidence. REQUEST FOR PRODUCTION NO. 1-38: Please identify: a. Every instance since January 1, 2023 in which Idaho Power responded to a regulatory data request by stating that: 1. It does not evaluate system need without AFL; 2. It does not evaluate capacity needs by customer class; 3. It does not forecast load by customer class; 4. It does not perform beneficiary studies; or 5. It has not performed a requested cost-allocation analysis. IDAHO POWER COMPANY'S OBJECTION TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S RENEWED REQUEST FOR PRODUCTION BASED ON PRIOR IDAHO POWER RELEVANCE OBJECTIONS - 4 b. For each instance identify: 1. Docket number; 2. Request number; 3. Witness responsible; and 4. Whether the analysis has since been performed. OBJECTION TO REQUEST FOR PRODUCTION NO. 1-38: Idaho Power objects to this request on the grounds it is not relevant to the issues presented in this proceeding or otherwise outside the scope of discovery. Idaho Power further objects on the grounds that the request is overly broad and unduly burdensome, including because it spans a time period broader than is reasonably relevant for this docket. Idaho Power also objects to the extent the request seeks information that is equally available to IIPA through its own records or publicly available filings. Dated at Boise, Idaho, this 25 day of June 2026. '-/�?I coc&la MM MEGAN GOIICOECHEA ALLEN Attorney for Idaho Power Company IDAHO POWER COMPANY'S OBJECTION TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S RENEWED REQUEST FOR PRODUCTION BASED ON PRIOR IDAHO POWER RELEVANCE OBJECTIONS - 5 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 251" day of June 2026, 1 served a true and correct copy of Idaho Power Company's Objection to Idaho Irrigation Pumpers Association, Inc.'s Renewed Production Based on Prior Idaho Power Relevance Objections upon the following named parties by the method indicated below, and addressed to the following: Commission Staff Hand Delivered Erica Melanson 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 erika.melanson(a-)puc.idaho.gov Boise, ID 83720-0074 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 Pocatello, Idaho 83205 elo echohawk.com tayshaC@.echohawk.com Lance Kaufman, Ph.D. Hand Delivered Deborah Glosser, Ph.D. U.S. Mail 2623 NW Bluebell Place Overnight Mail Corvallis, OR 97330 FAX FTP Site X Email lance aegisinsight.com deborah.glosserCa)_gmail.com Bayer Corporation Hand Delivered Ethan Waltermire U.S. Mail P4 Production, L.L.C. Overnight Mail P.O. Box 816 FAX Soda Springs, Idaho 83276 FTP Site X Email Ethan.waltermire(c)_bayer.com IDAHO POWER COMPANY'S OBJECTION TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S RENEWED REQUEST FOR PRODUCTION BASED ON PRIOR IDAHO POWER RELEVANCE OBJECTIONS - 6 Thomas J. Budge Hand Delivered Racine Olson, PLLP U.S. Mail P.O. Box 1391 Overnight Mail 201 E. Center FAX Pocatello, Idaho 83204 FTP Site X Email tj(a racineolson.com Brian C. Collins Hand Delivered Greg Meyer U.S. Mail Brubaker & Associates Overnight Mail 16690 Swingley Ridge Road No. 140 FAX Chesterfield, MO 63017 FTP Site X Email bcollins consultbai.com gmeyer(a)_consultbai.com City of Boise City Hand Delivered Ed Jewell U.S. Mail Deputy City Attorney Overnight Mail Boise City Attorney's Office FAX 150 N. Capitol Blvd. FTP Site P.O. Box 500 X Email Boise, Idaho 83701 BoiseCityAttorney(a)_cityofboise.org ejewell cityofboise.org Katie O'Neal Hand Delivered Energy Program Manager U.S. Mail Boise City Dept. of Public Works Overnight Mail 150 N. Capitol Blvd. FAX P.O. Box 500 FTP Site Boise, Idaho 83701-0500 X Email koneil cityofboise.org Clean Energy Opportunities for Idaho Hand Delivered Kelsey Jae U.S. Mail 521 E. 41 st Street, #506 Overnight Mail Garden City, Idaho 83714 FAX FTP Site X Email kelsey kelseylae.com IDAHO POWER COMPANY'S OBJECTION TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S RENEWED REQUEST FOR PRODUCTION BASED ON PRIOR IDAHO POWER RELEVANCE OBJECTIONS - 7 Courtney White Hand Delivered Mike Heckler U.S. Mail Clean Energy Opportunities for Idaho Overnight Mail 3778 Plantation River Drive, Suite 102 FAX Boise, Idaho 83703 FTP Site X Email courtney(a cleanergyopportunities.com mike cleanenergyopportunities.com Federal Executive Agencies Hand Delivered Emily W. Medlyn U.S. Mail Jelani A. Freeman Overnight Mail U.S. Department of Energy FAX 1000 Independence Ave., S.W. FTP Site Washington, D.C. 20585 X Email Emily.medlyn(q)_hg.doe.gov Jelani.freeman(g-),hg.doe.gov Dwight Etheridge Hand Delivered Exeter Associates, Inc. U.S. Mail 10480 Little Patuxent Parkway, Suite 300 Overnight Mail Columbia, MD 21044 FAX FTP Site X Email detheridg�exeterassociates.com Industrial Customers of Idaho Power Hand Delivered c/or Peter J. Richardson U.S. Mail Richardson Adams, PLLC Overnight Mail 515 N. 27t" Street FAX Boise, Idaho 83702 FTP Site X Email peter richardsonadams.com IDAHO POWER COMPANY'S OBJECTION TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S RENEWED REQUEST FOR PRODUCTION BASED ON PRIOR IDAHO POWER RELEVANCE OBJECTIONS - 8 Micron Technology, Inc. Hand Delivered Austin Rueschhoff U.S. Mail Thorvald A. Nelson Overnight Mail Richard A. Arnett FAX Holland & Hart LLP FTP Site 555 17t" Street, Suite 3200 X Email Denver, CO 80202 darueschhoff(@hollandhart.com tnelson(c)_hollandhart.com raarnett _hollandhart.corn aclee(a)_hol land hart.corn tlfriel hol land hart.com Northwest Energy Coalition Hand Delivered Benjamin J. Otto U.S. Mail 1407 W Cottonwood Crt. Overnight Mail Boise, Idaho 83702 FAX FTP Site X Email Ben(aD_nwenergy.org lauren nwenergy.orq derek(c)-nwenergy.org (T) Christy Davenport Legal Administrative Assistant IDAHO POWER COMPANY'S OBJECTIONS TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S RENEWED REQUESTS FOR PRODUCTION TO IDAHO POWER COMPANY- 9