20220309IPC to IdaHydro 2.pdf

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DONOVAN WALKER
Lead Counse!
dwalker@ida hooower.com
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Enclosures
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March 9,2022
VIA ELECTRONIC FILING
Jan Noriyuki, Secretary
ldaho Public Utilities Commission
11331W. Chinden Blvd., Bldg 8,
Suite 201-A (83714)
PO Box 83720
Boise, ldaho 83720-0074
Re:Case No. IPC-E-2141
ln The Matter Of ldaho Power Company's Application For Authority to
Proceed with Resource Procurements to Meet ldentified Capacity
Deficiencies in 2023, 2024, and 2025 to Ensure Adequate, Reliable, and
Fair-Priced Service to its Customers
Dear Ms. Noriyuki:
Attached for electronic filing is ldaho Power Company's Response to ldaHydro's
Second Set of lnterrogatories and First Set of Requests for Production and Requests for
Admission to ldaho Power Company the above entitled matter. lf you have any questions
about the attached document, please do not hesitate to contact me.
Very truly yours,
Donovan E. Walker
DONOVAN E. WALKER (!SB No. 5921)
ldaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
dwa [e-mail]
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR
AUTHORITY TO PROCEED WITH
RESOURCE PROCUREMENTS TO MEET
IDENTIFIED CAPACITY DEFICIENCIES IN
2023,2024, AND 2025 TO ENSURE
ADEQUATE, RELIEABLE, AND FAIR.
PRICED SERVICE TO ITS CUSTOMERS.
CASE NO. |PC-E-2141
IDAHO POWER COMPANY'S
RESPONSE TO IDAHYDRO'S
SECOND SET OF
INTERROGATORIES AND
FIRST SET OF REQUESTS FOR
PRODUCTION AND ADMISSION
TO IDAHO POWER COMPANY
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COMES NOW, ldaho Power Company ("ldaho Powef or "Company'), and in
response to ldaHydro's Second Set of lnterrogatories and First Set of Requests for
Production and Requests for Admission to ldaho Power Company dated February 23,
2022, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO IDAHYDRO'S SECOND SET
OF INTERROGATORIES, FIRST SET OF REQUESTS FOR PRODUCTION
AND ADMISSION TO IDAHO POWER COMPANY.l
INTERROGATORY NO. 2: To what extent, if any, does Section V of the
Application request the Commission to allow ldaho Power to deviate from or be excused
from obeying the mandates of the Public Utilities Regulatory Policy Act ('PURPA") and
its interpreting decisions and regulations? lf deviation is requested, this request seeks
specific explanation of what aspects of PURPA, identified by citation to federal or state
law, either statutory, regulatory, case law, or administrative law, from which ldaho Power
seeks excuse or relief.
RESPONSE TO IDAHYDRO'S INTERRAGATORY NO. 2: Section V of the
Company's Application does not request the Commission allow ldaho Power to deviate
from or be excused from obeying the mandates of PURPA.
The response to this Request is sponsored by Tim Tatum, Vice President of
Regulatory Affairs of ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO IDAHYDRO'S SECOND SET
OF INTERROGATORIES, FIRST SET OF REQUESTS FOR PRODUCTION
AND ADMISSION TO IDAHO POWER COMPANY - 2
ADMISSION REQUEST NO. 1: Please admit that the below chart [see next page]
correctly represents the Commission-approved/endorsed initial cost per kWh of electricity
to ldaho Power from the identified sources. lf any cost is incorrect in the opinion of ldaho
Power, please provide ldaho Power's opinion of the correct cost.
ldaho Power Cott ($/kU,h)
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RESPONSE TO IDAHYDRO'S ADMISSION REQUEST NO. 1: ldaho Power
objects to this request on the grounds that it is unaware of the origin of the chart and so
cannot verify the accuracy of the information, which dates back over 38 years. The
Company is not aware of having previously developed an equivalent analysis for the
information displayed in the chart. Based on a partial review of the data, the Company
believes that the data originated as part of the public record in historical filings with the
ldaho Public Utilities Commission.
Notwithstanding the Company's objection, the Company has been able to trace
several of the amounts on the chart to the narrative of orders issued by the IPUC but the
IDAHO POWER COMPANY'S RESPONSE TO IDAHYDRO'S SECOND SET
OF INTERROGATORIES, FIRST SET OF REQUESTS FOR PRODUCTION
AND ADMISSION TO IDAHO POWER COMPANY - 3
te-e tD.rr3 fie.cla to3?5 t -t6 fo,r'ti
original souroe sf those amounts was not ahrays evldent nor was the methodology and
assumptions used to develop the amounb fully described.
The response to this Request is sponsored by Tim Tatum, Vrce President of
Regulatory Affairs of ldaho Power Company in consultation wlth Donovan Walker, Lead
Counselof ldaho Power.
IDAHO POWER COMPAI.IYS RESPONSE TO IDAHYDRO'S SECOND SET
OF INTERROCTATORIES, FIRST SET OF REQUESTS FOR PRODUCTION
AND ADMISSION TO IDAHO POI/VER COMPANY - 4
PRODUCTION REQEUST NO. 1: PIease produce the source of your "opinion of
the correct cost" with citations and workpapers.
RESPONSE TO IDAHYDRO,S PRODUCTION REQUEST NO. 1: P|ease see the
Company's response to ldaHydro's Request for Admission No. 1
The response to this Request is sponsored by Tim Tatum, Vice President of
Regulatory Affairs of ldaho Power Company.
Respectfully submitted this 9th day of March 2021
fuzrlettn-
DONOVAN E. WALKER
Attorney for ldaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO IDAHYDRO'S SECOND SET
OF INTERROGATORIES, FIRST SET OF REQUESTS FOR PRODUCTION
AND ADMISSION TO IDAHO POWER COMPANY - 5
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the gthday of March 2022, I served a true and correct
copy of the within and foregoing IDAHO POWER COMPANY'S RESPONSE TO
IDAHYDRO'S SECOND SET OF INTERROGATORIES AND FIRST SET OF
REQUESTS FOR PRODUCTION AND ADMISSION TO IDAHOPOWER COMPANY
upon the following named parties by the method indicated below, and addressed to the
following:
Dayn Hardie
!daho Public Utilities Commission
Po Box 83720
Boise, ldaho 83720-0074
Peter J. Richardson
RICHARDSON ADAMS, PLLC
515 N,27th Street
Boise, ldaho 83702
Dr. Don Reading
6070 Hil! Road
Boise, !D 83703
ldaHydro
C. Tom Arkoosh
Amber Dresslar
ARKOOSH LAW OFFICES
913 w. River Street, Suite 450
P.O. Box 2900
Boise, lD 83701
ldaho Conservation League
Benjamin J. Otto
Emma E. Sperry
710 North 6th Street
Boise, lD 83701
Greg M. Adams
RICHARDSON ADAMS, PLLC
515 N.27th Street
Boise, ldaho 83702
Spencer Gray
NIPPC
P.O. Box 504
Emailed to:
davn.hardie@puc. idaho.qov
Emailed to:
peter@ richa rdsonadams. com
Emailed to:
d read inq @mindsprinq.com
Emailed to:
tom. a rkoosh@arkoosh=eon0
a mber.d resslar@a rkoosh. com
erin [e-mail]
Emailed to:
botto@ ida h oco nse rvatio n. o rq
esperry@idahoconse rvation.orq
Emailed to:
o req@ richa rdsonadams. com
Emailed to:
[e-mail]
IDAHO POWER COMPANY'S RESPONSE TO IDAHYDRO'S SECOND SET
OF INTERROGATORIES, FIRST SET OF REQUESTS FOR PRODUCTION
AND ADMISSION TO IDAHO POWER COMPANY - 6
Mercer lsland, WA 98040
Abigail R. Germaine
Elam & Burke, P.A.
251 E. Front St., Suite 300
P.O. Box 1539
Boise, lD 83701
Scott Miller
Western Power Trading Forum
1540 River Park Dr., Suite 211
Sacramento, CA 95815
Max Greene
Renewable Northwest
421 SW 6th Ave., Suite 1400
Portland, OR 97204
Jim Kreider
STOP BB2H Coalition
60366 Marvin Road
La Grande, OR 97850
Jack Van Valkenburgh
Van Valkenburgh Law, PLLC
P.O. Box 531
Boise, !D 83701
Ed Jewell
Boise City Attorneys Office
P.O. Box 500
Boise, lD 83701
Wil Gehl
Boise City Dept. of Public Works
P.O. Box 500
Boise, lD 83701
Emailed to:
[e-mail]
Emailed to:
[e-mail]
Emailed to:
[e-mail]
Emailed to:
[e-mail]
Emailed to:
iack@va nva lken bu ro h law. com
Emailed to:
eiewe [e-mail]
bo isecitvattornev@citvofboise. o rq
Emailed to:
wqeh l@citvofboise. orq
Christy Davenport, Legal Assistant
IDAHO POWER COMPANY'S RESPONSE TO IDAHYDRO'S SECOND SET
OF INTERROGATORIES, FIRST SET OF REQUESTS FOR PRODUCTION
AND ADMISSION TO IDAHO POWER COMPANY _ 7