20210623ICIP 1-9 to IPC.pdf

Peter J. Richardson ISB # 3 195
Gregory M. Adams ISB # 7454
RICHARDSON ADAMS, PLLC
515 N. 27th Street
Boise, Idaho 83702
Telephone: [phone] I
Fax: [phone]
pete16r richardsonadams. com
gret(Orichardsonadams.conr
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR
APPROVAL OF THE CAPACITY
DEFICIENCY TO BE UTILIZED FOR
AVOIDED COST CALCULATIONS
CASE NO. IPC-E.21.09
FIRST PRODUCTION REQUEST OF
THE TNDUSTRIAL CUSTOMERS OF
IDAHO POWER and FIRST
REQUEST FOR ADMISSION
.*' . "..;rili'-t!i.-'*'--i {.-i.l
Attorneys for the Industrial Customers of ldaho Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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Pursuant to Rule 225 of the Rules of Procedure of the ldaho Public Utilities Commission
(the "Commission"), the Industrial Customers of Idaho Power ("ICIP") by and through its
attomey of record, Peter J. Richardson, hereby requests that Idaho Power Company ("ldaho
Power" or the "Company") provide responses to the following with supporting documents,
where applicable.
This production request is to be considered as continuing, and Idaho Power is requested
to provide by way of supplementary responses additional documents that it or any person acting
on its behalf may later obtain that will augment the responses or documents produced.
FIRST PRODUCTION REQUEST OF THE ICIP
IN CASE NO. IPC-E-21-09 _ PAGE I
Please provide an additional electronic copy, or if unavailable, a physical copy, to Dr.
Don Reading at 6070 Hill Road, Boise, Idaho 83703, Tel: [phone]; Fax: (208) 384-l5l l;
[e-mail].
For each item, please indicate the name of the person(s) preparing the answers, along
with the job title of such person(s) and the witness at hearing who can sponsor the answer.
Some of the following requests may include disclosures deemed to be confidential.
Counsel for the ICIP (Peter Richardson and Greg Adams) the ICIP's expert witness, Dr. Don
Reading, as well as counsel's legal assistant (Grace Hansen) are all prepared to execute an
appropriate confidentiality agreement should that be necessary in order to facilitate complete
responses.
REOUEST FOR PRODUCTION NO. I
Please provide, in electronic format with all formulae intact where possible, all workpapers and
other documents used in the development of tdaho Power's Application in this matter,
(hereinafter referred to as the "Application.")
REOUEST FOR PRODUCTION NO.2
Please provide copies of all communications with the ldaho Public Utilities Commission and its
Staff regarding the Application.
REOUEST FOR PRODUCTION NO.3
Please provide copies of all responses to production requests (both formal and informal)
provided to any other party to this proceeding.
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FIRST PRODUCTION REQUEST OF THE ICIP
IN CASE NO. IPC-E-2I.09 _ PAGE 2
REOUEST FOR ADMISSION NO. T
Please admit that Exhibit I to the Application of the ICIP for an Order to Show Cause in Docket
No. IPC-E-21-19 is a true and correct copy of Idaho Power's Notice of Intent 2021 All-Source
Request for Proposals with its Attachment A. (Herein referred to as the "NOI.")
REOUEST FOR PRODUCTION NO.4
At page I of the NOt Idaho Power states that, "The addition of new resources to meet peak
demand is critical to ensure IPC can continue to reliably meet the growing demands on its
electrical system and serve its customers." Idaho Power concludes by stating, "The need for
additional capacity resources has been identified as early as Summer 2023 at approximately
80MW, with peak deficits that grow to approximately 400 MW by Summer 2A25." Please
provide all workpapers, studies, notes and other documents (in electronic format with formulae
intact where possible) used to so 'identify' the need for "additional capacity resources as early as
Summer 2023, with peak deficits that grow to approximately 400 MW by Summer 2025."
REOUEST FOR PRODUCTION NO.5
Please identifu all individuals who assisted in the preparation of the
documents/studies/workpapers etc. that are provided in response to Request No. 4, above. For
each individual so identified, please indicate his/her job title and briefly describe their duties as
an ldaho Power employee or if they are not an employee identify the nature of their relationship
to ldaho Power and their status, e.g. as a contractor or subcontractor.
REOUEST FOR PRODUCTION NO.6
Please explain what is meant in the NOI where ldaho Power describes its need for "the addition
of new resources" as being "critical" if Idaho Power is to ensure it can continue to reliably serve
its customers. When did the "critical" nature of the need for new resources become known to
FIRST PRODUCTION REQUEST OF THE ICIP
IN CASE NO. IPC-E-21-09 _ PAGE 3
Idaho Power? How was the critical nature of the need for new resources discovered and by
whom? Please document your responses.
REOUEST FOR PRODUCTION NO. 7
Idaho Power's Application states on page 5 that "Attachment I [to the Application] shows a first
capacity deficiency of approximately 14 megawatts ("MW"), occurring in August 2028 based on
the 2019 IRP." Attachment I to the Application also indicates that the capacity deficit on ldaho
Power's system does not exceed 400 MW until August 2038. Please reconcile the first capacity
deficit year of 2028 in this docket with the assertion in ldaho Power's NOt that it will become
capacity deficit in 2023.
REOUEST FOR PRODUCTION NO.8
Please reconcile the assertion in the NOI that Idaho Power will be approximately 400 MW
capacity deficit in2025 with the indication on Attachment I to the Application that Idaho Power
will not be 400 MW capacity deficit until 2038.
REOUEST FOR PRODUCTION NO.9
The NOI states that ldaho Power anticipates "issuing a multiple all-source request for proposals
in202l (2021AS RFPs)." Has the Company issued the202l AS RFPs? If not, what is the
planned date of issue.
Dated this rd day ofJune 2021.
ISB # 3195
RICHARDSON ADAMS, PLLC
FIRST PRODUCTION REQUEST OF THE ICIP
TN CASE NO. IPC-8.21.09 - PAGE 4
J
I HEREBY CERTIFY that on the 23d day of June,202l,a true and correct copy of the within
and foregoing FIRST PRODUCTION REQUEST and FIRST REQUEST FOR ADMISSION of
the Industrial Customers of Idaho Power in Case No. IPC-E-21-09 was served, pursuant to
Commission Order No. 34602, by elecfronic copy only, to:
Jan Noriyuki
Commission Secretary
Idaho Public Utilities Commission
Jan. [e-mail]. gov
IdaHydro
c/o Tom Arkoosh
Arkoosh Law Offices
tom.arkoosh(@arkoosh.com
eri n. cec i I (darkoosh.com
Donovan Walker, Senior Counsel
Regulatory Dockets
dwalker@ idahopower.com
dockets@ idahopower.com
Michael Darrington, Energy Contracts
Idaho Power Company
mdarri nstont0idahooower.com
energycontracts@ idahopower. com
Karl Klein
Deputy Attorney General
Idatro Public Utilities Commission
karl.klein@puc. idaho. qov
R
rsB # 3195
FIRST PRODUCTION REQUEST OF THE ICIP
TN CASE NO. IPC-E-21.09 - PAGE 5