20220308IPC to 2140 Labs 1-2.pdf

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Lisa D. Nordstrom
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LISA D. NORDSTROM
Lead Gounsel
[e-mail]
March 8,2022
Jan Noriyuki, Secretary
ldaho Public Utilities Commission
11331 W. Chinden Boulevard
Building 8, Suite 201-A
Boise, ldaho 83714
Dear Ms. Noriyuki:
LDN:sg
Enclosure
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Re Case No. IPC-E-2'|-37
Application of ldaho Power Company for Authorrty to Establish A New
Schedule to Serve Speculative High-Density Load Customers
Attached for electronic filing, pursuant to Order No. 35058, is ldaho Power Company's
Response to the First Production Request of 2140 Labs LLC in the above entitled matter.
lf you have any questions about the attached documents, please do not hesitate to
contact me.
Sincerely,
P.O. Box 70 (83707)
l2tl W. H.hoSt
Boisc, lD 83702
LISA D. NORDSTROM (lSB No. 5733)
ldaho Power Company
1221 West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
[e-mail]
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
AUTHORITY TO ESTABLISH NEW
SCHEDULE TO SERVE SPECULATIVE
HIGH-DENSITY LOAD CUSTOMERS.
CASE NO. IPC-E-21-37
IDAHO POWER COMPANY'S
RESPONSE TO FIRST
PRODUCTION REQUEST OF 2140
LABS LLC TO IDAHO POWER
COMPANY
COMES NOW, ldaho Power Company ('ldaho Powef or "Company"), and in
response to the First Production Request of 2140 Labs LLC ("2140 Labs") dated
February 15,2022, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF 2140 LABS LLC
TO IDAHO POWER COMPANY - 1
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REOUEST FOR PRODUCTION NO. 1:
The Company uses'speculative" to define load, a commodity, and the industry
as a whole. Application at2,13, Schedule 20. Please clariff how the Company
evaluates and classifies a load, a commodity, and the industry as "speculative."
RESPONSE TO REQUEST FOR PRODUCTION NO. 1:
The Company's proposed Schedule 20 - Speculative High Density Load tariff
defines the requirements for customers to qualiff for service under the schedule:
primary or transmission service level customers with a registered demand not
exceeding 20,000 kW from service at one or more Points of Delivery on the same
Premises who have the ability to relocate quickly in response to short-term economic
signals, and meet four (4) or more of the following characteristics:
o High every use density;
o High load factor;
. Load that is portable and distributable;
o Highly variable load growth or load reduction as an individual customer and/or
in aggregate with similar customers in the Company's service area;
o High sensitivity to volatile commodity or asset prices;
o Part of an industry with potential to quickly become a large concentration of
power demand;
o Lack of credit history or ability to demonstrate financial viability.
The Company's evaluation and classification of industry and commodity as
speculative in the Application are captured in the requirements for service under
Schedule 20 and include factors such as volatility, lack of credit history, or ability to
IDAHO POVVER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF 2140 I3BS LLC
TO IDAHO POVVER COMPANY - 2
demonstrate financialviability which are evaluated in conjunction with the remaining
crtteria to meet both 1) the ability to relocate quickly in response to short-term economic
signals, plus2l at least four additional listed characteristics.
The response to this Request is sponsored by PaulGoralski, Regulatory
Consultant, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF 2140 I.ABS LLC
TO IDAHO POV"ER COMPAI.IY . 3
REQUEST FOR PRODUCTION NO. 2:
The Company stated that it received 17 .viable" and unique inquiries totaling over
1,950 MW. Application at 5. Please provide the criteria used by the Company to
evaluate which projects are "viable".
When the Company receives a new request for service from a large business
customer, such as a cryptocurrency mining project, ldaho Power conducts an initial
conversation with the prospective customer to discuss rates, deposit requirements (Rule
L), the requirement for the prospective customer to fund any required infrastructure
upgrades to serve the requested load, and other project specific information. ll after
that initial conversation, the prospective customer continues discussions with ldaho
Power to evaluate specific sites and/or requests continued assistance from ldaho Power
to further develop the project's business case, the project is considered 'viable."
The response to this Request is sponsored by Megan Ronk, Economic
Development & tnnovation Director, ldaho Power Company.
TDAHO POV\'ER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF 2140 ISBS LLC
TO IDAHO POWER COMPANY - 4
DATED at Boise, ldaho, this 8th day of March 2A22.
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LISA D. NORDSTROM
Attomey for ldaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF 2140 IABS LLC
TO IDAHO POWER COMPANY - 5
CERTIFICATE OF SERVICE
! HEREBY CERTIFY that on the 8th day of March 2022,1 served a true and correct
copy of ldaho Power Company's Response to First Production Request of 2140 Labs
LLC to ldaho Power Company upon the following named parties by the method indicated
below, and addressed to the following:
Commission Staff
Riley Newton
Depu$ Attorney General
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg No. 8,
Suite 201-A (83714)
PO Box 83720
Boise, lD 83720-0074
lndustrial Customers of ldaho Power
Peter J. Richardson
Richardson Adams, PLLC
515 N.27th Street
P.O. Box 7218
Boise, ldaho 83702
Dr. Don Reading
6070 Hill Road
Boise, lD 83703
2140 Labs LLC
Elizabeth A. Koeckeritz
Givens Pursley LLP
601 W. Bannock Street
Boise, ldaho 83702
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Stacy Gust, Regulatory Administrative
Assistant
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF 2'I4O I.ABS LLC
TO IDAHO POWER COMPANY.6