20220207ICIP 10 to IPC.pdf

Peter J. Richardson ISB # 3195
Gregory M. Adams tSB # 7454
RICHARDSON ADAMS, PLLC
515 N.27th Street
Boise, tdaho 83702
Telephone: [phone]
Fax: [phone]
oeter@ri chardsonadams. c,om
eret@.ri c hardsonadams. com
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR
APPROVAL OF THE CAPACITY
DEFICIENCY TO BE UTILIZED FOR
AVOTDED COST CALCULATIONS
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Attorneys for the Industrial Customers of [daho Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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CASE NO. IPC.E.21-09
SECOND PRODUCTTON REQUEST
OF THE INDUSTRIAL CUSTOMERS
OF IDAHO POWER
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Pursuant to Rule 225 of the Rules of Procedure of the Idatro Public Utilities Commission
(the "Commission"), the Indushial Customers of tdaho Power (*ICIP") by and through its
attorney of record, Peter J. Richardson, hereby requests that Idaho Power Company (*Idaho
Power" or the "Company") provide responses to the following with supporting documents,
where applicable.
This production request is to be considered as continuing, and tdaho 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.
SECOND PRODUCTION REQUEST OF THE ICIP
IN CASE NO. IPC.E.?L.Og _ 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: (208) 342-l7OO; Fax: [phone];
dreadin g@mi ndspring.com.
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. TO
Please provide updated 'published' avoided cost rates utilizing the SAR methodology for
wind, solar and battery projects 100 kW or smaller and all other tlpes of QF projects l0 MW or
smaller utilizing the first deficit year contained in the Company's Motion and Amended
Application filed on February 4,2022 in this docket.
Dated this 7th ofFebruary 2022.
Peter J. Richardson ISB # 3195
RICHARDSON ADAMS, PLLC
SECOND PRODUCTION REQUEST OF THE ICIP
IN CASE NO. IPC-E-2I-09 _ PAGE 2
I HEREBY CERTIFY that on the 7th day of February, a tnre and correct oopy of the within and
foregoing SECOND PRODUCTION REQUEST of the Industrial Customers of Idatro Power in
Case No. IPC-E-21-09 was serve{ pursuant to Commission Order No. 34602, by elechonic copy
only, to:
Jan Noriyuki
Commission Secrctary
Idaho Public Utilities Commission
Jan.norilzuki@nuc. idatro. gov
IdaHydro
c/o Tom Arkoosh
Arkoostr l"aw Offices
tom.arkoosh@n rkoosh.com
erin.ccci [e-mail]
flonovan Walker, Senior Counsel
Regularory Dockets
dwalkcr@ idahopower. com
dockets@ idahopower. com
Camille Christin, Energy Conhacts
Idalp PowerCompany
[e-mail]
enerwcontracts@ idahopower. com
ISB # 3195
SECOND PRODUCTION REQLJEST OF THE ICIP
TN CASE NO. IPC-E-2I.09 - PAGE 3
Matt Hunter
Deputy Attorney General
Idatro Public Utilities Commission
matt.hunter@puc. idaho. gov