20200713ICL 1-3 to IPC.pdf

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3*?* iUL 13 PH tr: 13Benjamin J. Otto (ISB No. 8292)
710 N 6m Street
Boise,ID 83701
Ph: [phone]x12
Fax: [phone]
botto@idahoconservation. org
:,P,,
Attorney for the Idaho Conseration [rague
BEFORE THE IDAHO PUBLIC UTILITIES COMMSSION
IN THE MATTER OF IDAHO
POWER COMPAI\Y'S 2019
INTEGRATED RESOURCE PLAN.
CASE NO. IPC-E-I9-1,9
ICL'S FIRST PRODUCTION
REQUEST TO IDAHO POWER
The Idaho Public Utilities Commission granted the Idaho Conservation League's (ICL)
Petition to Intervene in this docket in Order 3440l.ICL submits the following production request
to Idaho Power, pursuant to IDAPA 31.01.01.216 - 240
This production request is ongoing, and ICL requests the Company 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 produced.
Please provide answers to each question along with all supporting workpapers that
provide detail or are the source of information used in formulating Idaho Power's answers.
Commission's Rules of Procedure require Idaho Power to include the name and phone number of
the person preparing the document, and the name, location, and phone number of the record
holder and, if different, the witness who can sponsor the answer at hearing. IDAPA
31.01.01.228.
Pursuant to Order 34602, please provide all responses electronically, via email to ICL's
council at [e-mail], including any supporting materials in Excel format with
formulas activated.
Please provide responses on or before August 3,2020.
rPC-E-19-19 r
ICL I't Production Request to ldaho Power
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July 13,2020
PRODUCTION REQUEST 1:
On July l,2020Idaho Power filed a Motion to Suspend Procedural Schedule and Update
Regarding Boardman to Hemingway Transmission Line Project. In that Update Idaho Power
describes a potential increase in the Company's ownership of the Boardman to Hemingway Line
from the original 2lo/o to 45%. ldaho Power asserts "the practical implications of this potential
ownership arrangement for the Company's Amended IRP are limited" and the "Commission also
possess all relevant current information, despite the fact that the agreement remains under
negotiations at this point".
A. Please identify all quantitative and qualitative support for the assertion that more than
doubling the Company's ownership share has limited practicable impact.
B. Please identify where in the record is "all relevant information" about the impact of an
ownership agreement that is still being negotiated.
PRODUCTION REQUEST 2:
ln the July I Update Idaho Power writes "as described in Idaho Power's Reply Comments, the
B2H co-participants are exploring several alternative asset, service, and ownership
arrangements." Yet no Reply Comments appear in the record in this docket.
A. Please provide the Reply Comments the Company referred to in the July l, 2020 Update.
PRODUCTION REQUEST 3:
In the July I update Idaho Power concludes that "these negotiations represent a positive step in
the development of B2H."
A. Please provide all quantitative and qualitative support for this assertion.
Respectfully submitted this 13ft day of July 2020
/s/ Beniamin Otto
Idaho Conservation League
rPC-E-19-19 2
ICL I't Production Request to Idaho Power July 13, 2020
CERTIFICATE OT SERYICE
I hereby certify that on this 13th day of July 2020,I delivered ffue and correct copies of
the foregoing FIRST PRODUCTION REQUEST TO IDAHO POWER to the following persons
via the method of service noted:
/s/ Beniamin Otto
Idaho Conservation League
Electronic Mail only (See Order 34602):
Idaho Public Utilities Commission
Diane Hanian, Commission Secretary
secretary@puc. idaho. gov
Edward Jewell, Deputy Afforney General
Idaho Public Utilities Commission
Edward j [e-mail]. gov
Idaho Power
Lisa D. Nordstrom
Matthew Larkin
[e-mail]
mlarkin@idahopower. com
dockets@idahopower. com
Idahydro
C. Tom Arkoosh, Arkoosh Law Office
Tom. [e-mail]
Erin. cecil@arkoosh. com
Industrial Customers of ldaho Power
Peter J. Richardson
Richardson, Adams, PLLC
peter@richardsonadams. com
Dr. Don Reading
dreading@mindspring. net
Stop B2H Coalition
Jack Van Valkenburgh
Van Valkenburg Law, PLLC
j ack@vanvalkenburglaw. com
Jim Krieder, STOP B2H Coalition
[e-mail]
IPC-E-19-19 3
ICL l't Production Request to Idaho Power
Micron Technologt,Inc
Jim Swier, Micron
[e-mail]
Austin Rueschhoff
Thorvald A. Nelson
Holland & Hart, LLP
darueschho ff@hol landhart. com
tnelson@hollandhart. com
aclee@hollandhart. com
glgarganoamari@hollandhart. com
Sierra Club
Julian Aris
Gloria D. Smith
Sierra Club
Julian. aris@sierraclub. org
Gloria. smith@sierraclub. org
JuJy 13,2020