20220316Staff 44 to IPC.pdf

TAYLOR BROOKS
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-007 4
[phone]
IDAHO BAR NO. 11542
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Street Address for Express Mail:
I 1331 W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, TD 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPAI\-Y'S APPLICATION FOR
APPROVAL OF SPECIAL CONTRACT AI\D
TARIFF SCHEDULE 33 TO PROVIDE
ELECTRIC SERVICE TO BRISBIE, LLC'S
DATA CENTER FACILITY
CASE NO. IPC.E.2I.42
THIRD PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO IDAHO POWER COMPANY
STAFF of the Idaho Public Utilities Commission, ("Staff') by and through its attorney of
record, Taylor Brooks, Deputy Attomey General, hereby requests that Idaho Power Company
provide the following documents and information as soon as possible, but no later than
WEDNESDAY, MARCH 23, 2022.r
This Production Request is continuing, and Idaho Power 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
I Stuffir requesting an expedited response. If responding by this date will be problematic, please call Stafls
attorney at [phone].
THIRD PRODUCTION
REQUEST TO IDAHO POWER I MARCH 16,2022
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the person preparing the documents. Please also identiff the name, job title, location, and
telephone number of the record holder.
In addition to the written copies provided as response to the requests, please provide all
Excel spreadsheets and electronic files with formula intact and enabled.
REQUEST NO. 44: Please explain how the Company will allocate the cost of both
Excess Generation credits and the Renewable Capacity credits between its jurisdictions in future
base rates and in the Power Cost Adjustment.
thREQUESTED in Boise,Idaho, this lb day of March2022
General
i:umisc:prodreq/ipce2l.42tbfrrcklsme prod req 3
THIRD PRODUCTION
REQUEST TO rDAHO POWER 2 MARCH 16,2022
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 16th DAY OF MARCH 2022,
SERVED THE FOREGOING THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPAIYY, IN CASE NO. IPC-E-2L-42,
BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
DONOVAN E WALKER
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: [e-mail]
[e-mail]
MICHAEL HECKLER
COURTNEY WHITE
CLEAN ENERGY OPPORTUNITIES FOR
IDAHO INC
3778 PLANTATION RIVER DR SUITE 102
BOISE,ID 83703
E-MAIL : [e-mail]
courtney @cleanenergyopportunities. com
TIM TATUM
VP REGULATORY AFFAIRS
IDAHO POWER COMPANY
PO BOX 70
BOrSE rD 83707-0070
E-MAIL: [e-mail]
KELSEY JAE
LAW FOR CONSCIOUS LEADERSHIP
920 N. CLOVER DR.
BOISE,ID 83703
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE