20220325IPC to Staff 1-3.pdf

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t'!r:rli.'l\/il.i1li='.,u.iVLLJ AnD CORPCompeny
LISA D. NORDSTROM
Lead Counsel
[e-mail]
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March 25,2022
VIA ELECTRONIC FILING
Jan Noriyuki, Secretary
ldaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg 8,
Suite 201-A(83714\
PO Box 83720
Boise, ldaho 83720-0074
Case No. IPC-E-22-05
ln the Mafter of the Application for a Determination Validating the North
Valmy Power Plant Balancing Account True-Up
Dear Ms. Noriyuki:
Enclosed for electronic filing, pursuant to Order No. 35058, please find ldaho Power
Company's Response to the First Production Request of Commission Staff.
Please handle the confidential information in accordance with the Protective
Agreement executed in this matter.
lf you have any questions about the attached documents, please do not hesitate to
contact me.
Very truly yours,
. r'i in,'r.-ia- _ ...'t--luI: l i';-i4i-{lSSl$ii
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Lisa D. Nordstrom
LDN:sg
Enclosures
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]
ln o rd strom@ida h opower. com
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR A
DETERMI NATION VALIDAT! NG THE
NORTH VALMY POWER PLANT
BALANCING ACCOUNT TRU E-UP.
CASE NO. |PC-E-22-05
IDAHO PO\A/ER COMPANY'S
RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO
POWER COMPANY
COMES NOW, Idaho Power Company ('ldaho Powe/'or "Company"), and in
response to the First Production Request of the Commission Staff ("Staff) dated March
11,2022, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 1
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REQUEST FOR PRODUCTION NO. 1: Please provide allworkpapers, source
documents, tables, and exhibits presented in both Waites and Barrefto Direct
Testimonies in electronic format with formulas intact.
RESPONSE TO REQUEST FOR PRODUCTION NO. 1: Please see Confidential
Attachment 1, Attachment 2, and Confidential Attachment 3 for the workpapers, source
documents, tables and exhibits in electronic format with formulas intact.
The response to this Request is sponsored by Courtney Waites, Regulatory
Consultant and Lindsay Barrefto, 500 kV and Joint Projects Senior Manager, ldaho
Power Company.
IDAHO PO\A'ER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POVVER COMPANY - 2
REQUEST FOR PRODUCTION NO. 2: ln 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 Planf' 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 in 2019,2020,2021,and2022-2025 projected. Furthermore, please provide
a breakdown of each investment by Unit 1, Unit 2, andlor common plant.
RESPONSE TO REQUEST FOR PRODUCTION NO. 2: Please see Confidential
Attachment Nos. 1 and 2 for the Capita! Business Plan, which includes the detailed
capital forecast by project, unit and year, as provided in the Valmy Levelized Revenue
Requirement Balancing Account 2020 Annual Review and 2021 Annual Review,
respectively. ConfidentialAttachment 3 provided in Response to Request for
Production No. 1, which is Exhibit No. 3 to Company witness Ms. Barretto's testimony,
includes the most recent Capital Business Plan with the capita! forecast tor 2022
through 2025. ldaho Power has added a column to ConfidentialAttachment 3 to
include the project justification, if available, to each item included in the capita! forecast.
Attachment 2 provided in Response to Request for Production No. 1, which is Exhibit
No. 2 to Ms. Barretto's testimony, includes the detailed project description, a justification
for the need of each project over $20,000 and all Unit 1 investments, and the dollar
amounts for those projects closed to plant-in-service in 2019, 2020, and 2021.
The response to this Request is sponsored by Lindsay Barretto, 500 kV and Joint
Projects Senior Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 3
REQUEST FOR PRODUCTION 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 ldaho Power Capital Budget detail request in Production Request No.
2.
RESPONSE TO REQUEST FOR PRODUCTION NO. 3: Please see Attachment
1 for the Valmy plant additions closed to plant-in-service from January 1,2019, through
December 31,2021, by unit and by year.
The response to this Request is sponsored by Lindsay Barretto, 500 kV and Joint
Projects Senior Manager, ldaho Power Company.
IDAHO PO\A'ER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 4
DATED at Boise, ldaho, this 25m day of March 2022.
&-0.fl^,ut -*,
LISA D. NORDSTROM
Attorney for ldaho Power Company
IDAHO POWER COMPAT.IYS RESPONSE TO THE FIRST PRODUCTPN REQUEST OF THE
COMMISSION STAFF TO IDAHO POI^'ER COMPANY - 5
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 25th day of March 2022, ! served a true and
correct copy of ldaho Fower Company's Response to First Production Request of the
Commission Staff to Idaho Power Company upon the following named parties by the
method indicated below, and addressed to the following:
Commission Staff
Taylor Brooks
Deputy Attorney General
ldaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg No. 8,
Suite 201-A (83714)
PO Box 83720
Boise, lD 83720-0074
_Hand Delivered_U.S. Mail
Overnight Mail
_FAX
FTP SiteX Email: [e-mail]
&^J.
Stacy Gust, Regulatory Administrative
Assistant
IDAHO POVVER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY -6
BEFORE THE
IDAHO PUBLIC UTILITIES GOMMISSION
GASE NO. IPC-E-22-05
IDAHO POWER COMPANY
CONFIDENTIAL
REQUEST NO. 1
ATTACHMENT NO. 1
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
GASE NO. IPC-E-22-05
IDAHO POWER COMPANY
REQUEST NO, 1
ATTACHMENT NO.2
SEE ATTACHED SPREADSHEET
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
GASE NO. IPC-E,22-05
IDAHO POWER COMPANY
CONFIDENTIAL
REQUEST NO. 1
ATTACHMENT NO. 3
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
GASE NO. IPC-E-22-05
IDAHO POWER COMPANY
CONFIDENTIAL
REQUEST NO.2
ATTACHMENT NO. 1
BEFORE THE
IDAHO PUBLIC UTILITIES COMM]SSION
CASE NO. IPC-E-22-05
IDAHO POWER COMPANY
CONFIDENTIAL
REQUEST NO.2
ATTACHMENT NO.2
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
GASE NO. !PC-E-22-05
IDAHO POWER COMPANY
REQUEST NO.3
ATTAGHMENT NO. 1
SEE ATTACHED SPREADSHEET