20220406Staff 45-47 to IPC.pdf

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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:
1133I W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE,ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANYOS APPLICATION FOR
APPROVAL OF SPECIAL CONTRACT AND
TARIFF SCHEDULE 33 TO PROVIDE
ELECTRIC SERVICE TO BRISBIE, LLC'S
DATA CENTER FACILITY
CASE NO. IPC.E.2I-42
FOURTH PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO IDAHO POWER COMPANY
STAFF of the Idaho Public Utilities Commission, ("Staff') by and through its attomey 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, APRrL 13, 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 behall 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 Staffir requesting an expedited response. If responding by this date will be problematic, please call Staff s
attorney at [phone].
FOURTH PRODUCTION
REQUEST TO IDAHO POWER 1 APRTL 6,2022
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the person preparing the documents. Please also identifr 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.45: Please provide the rationale for using the Avoided Cost Averages
from the IRP to determine Supplemental Energy Prices in Block 2 and discuss any altemative
methods the Company considered.
REQUEST NO. 46: Please explain the method and the source of the inputs used to
calculate the Avoided Cost Averages in the IRP and how the Company modified it for use as
Supplemental Energy Prices in Block 2. Please also provide the actual calculation/workpapers in
Excel format with all formula enabled and include references for all inputs.
REQUEST NO. 47: Can the method for determining the Supplemental Energy Prices be
modified during the term of the contract? If so, please identiff the specific language in the
contract that allows such modifications.
-fhREQUESTED in Boise, Idaho, this L day of April2022.
i:umisc:prodreq/ipce2l.42tbme prod req 4
FOURTH PRODUCTION
REQUEST TO rDAHO POWER 2 APRIL 6,2022
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 6th DAY OF APzuL 2022, SERVED
THE FOREGOING FOURTH PRODUCTION REQUEST OF THE COMMISSION
STAFF TO IDAHO POWER COMPAIIY, 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]
MTCHAEL HECKLER
COURTNEY WHITE
CLEAN ENERGY OPPORTUNITIES FOR
IDAHO INC
3778 PLANTATION RIVER DR SUITE IO2
BOISE,ID 83703
E-MAIL : [e-mail]
courtney @cleanenergyopoortunities.com
TIM TATUM
VP REGULATORY AFFAIRS
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: [e-mail]
KELSEY JAE
LAW FOR CONSCIOUS LEADERSHIP
920 N. CLOVER DR.
BOISE,ID 83703
E-MAIL: [e-mail]
SECRETARY
CERTIFICATE OF SERVICE