20220302Staff 18-20 to IPC.pdf

RILEY NEWTON
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-007 4
[phone]
IDAHO BAR NO. 11202
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Street Address for Express Mail:
1 133 I W CHINDEN BLVD, BLDG 8, SUITE 201-A
BOISE, ID 83114
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
IDAHO POWER COMPANY FOR AUTHORITY
TO ESTABLISH A NEW SCHEDULE TO SERVE
SPECULATIVE HIGH.DENSITY LOAD
CUSTOMERS
CASE NO.IPC.E-21-37
SECOND PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO IDAHO POWER COMPANY
The Staff of the Idaho Public Utilities Commission, by and through its attomey of record,
Riley Newton, Deputy Attorney General, requests that Idaho Power Company ("Company")
provide the following documents and information as soon as possible, but no later than
WEDNESDAY, MARCH 23, 2022.
This Production Request is to be considered as continuing, and the Company 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 documents or information produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name, job title, and telephone number of
the person preparing the documents. Please also identifu the name, job title, location, and
telephone number of the record holder.
SECOND PRODUCTION REQUEST
TO IDAHO POWER
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1 MARCH 2,2022
In addition to the written copies provided as response to the requests, please provide all
Excel spreadsheets and electronic files on CD with formulas intact and enabled.
REQUEST NO. 18: In the Application, page 5, the Company states, "Within the span of
several months, Idaho power received seventeen (17) viable and unique inquires totaling over
1,950 MW." Please respond to the following:
a. Have any of the 17 inquiries continued to pursue obtaining service with the Company
after the initial inquiry?
b. For each of the inquiries that have continued pursuit of service with the Company,
what service schedule did they request and which of the current schedules provides
the best fit for their service requirements.
c. For each of the 17 inquiries that did not pursue service, please provide the reasons for
discontinuing pursuit of service.
REQUEST NO. 19: Because of the Company's obligation to serve, if the Company was
to establish a schedule for High Density Load Customers that was not intemrptible, what
protections would need to be included that would protect remaining customers from paying for
potential stranded assets? Please include any specific changes that would need to be made to
existing schedules or rules, including but not limited to changes to Rule L: Deposits.
REQUEST NO. 20: In reference to the 90 percent Effective Load Carrying Capability
("ELCC") and the required 225 hours of possible curtailment mentioned in Response to Staff s
Production Request No. 6. Please respond to the following:
a. Please explain how the 90 percent ELCC threshold was determined.
b. Please provide the workpapers with formulae enabled used to determine 225 hours of
possible curtailment.
SECOND PRODUCTION REQUEST
TO IDAHO POWER 2 MARCH 2,2022
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DATED at Boiee,Idaho, Ut L day of March 2022.
RileyNewton
Deputy
i:urniseprcdreq/iped1.37m*e prsd rcq 2
sEcoND PR ODUCTION REQUEST
TO IDAHO POUTER.3 MARCII2,2A22
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 2ND DAY OF MARCH 2022,
SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY, IN CASE NO.
IPC-E-21-37, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
LISA NORDSTROM
IDAHO POWER COMPANY
PO BOX 70
BOISE rD 83707-0070
E-MAIL: [e-mail]
do ckets (@i dahopo wer. co m
PETER J RICHARDSON
RICHARDSON ADAMS PLLC
515 N 27TH ST
PO BOX 7218
BOISE TD 83702
E-MAIL: [e-mail]
ELIZABETH A KOECKERITZ
GIVENS PURSLEY LLP
60I W BANNOCK ST
BOISE TD 82702
E-MAIL : eak@ givenspursley.com
CONNIE ASCHENBRENNER
RATE DESIGN SENIOR MGR
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: [e-mail]
DON READING
6070 HILL ROAD
BOISE ID 83703
E-MAIL: dreadine@mindsprine. com
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SECRETARr
CERTIFICATE OF SERVICE