20220311Staff 1-3 to IPC.pdf

TAYLOR BROOKS
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 11542
ji-. l';i\/Fli.'-L\/i-t / LU
Street Address for Express Mail:
1I33I W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, ID 83714
Attomey for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR A
DETERMINATION VALIDATING THE
NORTH VALMY POWER PLANT
BALANCING ACCOUNT TRUE.UP.
CASE NO. IPC.E-22-05
FIRST 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 Attorney General, hereby requests that Idaho Power Company
provide the following documents and information as soon as possible, but no later than
FRTDAY, MARCH 25, 2022.1
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 Stuff ir requesting an expedited response. If responding by this date will be problematic, please call Staff s
attorney at [phone].
FIRST PRODUCTION REQUEST
TO IDAHO POWER
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I MARCH II,2O22
the person preparing the documents. Please also identify the narne, 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 formulas intact and enabled.
REQUEST NO. 1: Please provide all workpapers, source documents, tables, and
exhibits presented in both Waites and Barretto Direct Testimonies in electronic format with
formulas intact.
REQUEST NO.2: In order to see how the Company's capital investment plans have
changed over time, please provide the Company's capital investment plan (such as the "ldaho
Power Capital Projects Budget, from 2010-2019, for Valmy Plant" provided in IPC-E-19-08 in
response to Staff Production Request No. 6) for the North Valmy Power Plant. Please include a
detailed project description, a justification of the need for each project, and the dollar amounts
completed by the Company in2019,2020,2021, and2022-2025 projected. Furtherrnore, please
provide a breakdown of each investment by Unit l, Unit 2, andlor common plant.
REQUEST NO. 3: With reference to Barretto Exhibit No. 2, please identiff the years
when the projects listed closed to plant-in-service. Please provide the "BudgetlD" or other
identifier to allow Staff to cross-reference the completed projects with the Idaho Power Capital
Budget detail request in Production Request No. 2.
Requested in Boise, Idaho, this day of March2022.
r_\tr.Tay
Technical Staff: Kathy Stockton
i:umisc:prodreq/ipce22.stbkls prod req I
FIRST PRODUCTION REQUEST
TO IDAHO POWER 2
Deputy Attorney General
MARCH II,2O22
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS l ITH DAY OF MARCH 2022,
SERVED THE FOREGOING F'IRST PRODUCTION REQUEST OF TIIE
COMMISSTON STAFF TO rDAHO POWER COMPAIYY, IN CASE NO.
IPC-E-22-05, 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]
dockets@idahopower. com
MATT LARKIN
IDAHO POWER COMPANY
PO BOX 70
BOrSE rD 83707-0070
E-MAIL: [e-mail]
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7-SECRETARY
CERTIFICATE OF SERVICE