20220608Staff 32 to IPC.pdf

CHRIS BURDIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLTC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-007 4
[phone]
IDAHO BAR NO. 98IO
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Street Address for Express Mail:
I 133I 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
COMPANY'S APPLICATION FOR A
DETERMINATION VALIDATING THE
NORTH VALMY POWER PLANT
BALANCING ACCOUNT TRUE.UP.
CASE NO.IPC-E-22-05
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, Chris Burdin, Deputy Attorney General, hereby requests that Idaho Power Company
("Company" or "Idaho Power") provide the following documents and information as soon as
possible, but no later than WEDNESDAY, JUNE 15,2022.r
This Production Request is continuing, and Idaho Power 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 Staff s
attorney at [phone].
THIRD PRODUCTION REQUEST
TO IDAHO POWER
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1 JUNE 8,2022
the person preparing the documents. Please also identify 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 formulas intact and enabled.
REQUEST NO. 32: Please address the following questions related to the pdf file "BTU
and THERMS TONNAGE ADruSTMENT 2l-06" attachedto the email response made by Curtis
Bradfute of NV Energy on July 30,2021, as a request for clarification to the heat rate attributed to
Idaho Power's portion of the North Valmy Plant by Randall Henderson. The attachment by Mr.
Bradfute is provided within the email message file "_EXTERNAL_FinaI BTU and Therms Sheet
for Valmy 06-21(Question from Monthly Meeting)" submitted in response to Production Request
Response No. 9:
a. Please explain why Unit No. I shows both coal usage and generation for Idaho Power past
the December 2019 exit date.
b. Please explain why the coal usage and generation values for Unit #l provided in the
workpapers are not shown correctly on the summary sheet.
c. If the Company did take generation from Unit No. I and given that the Company is paying
early exit fees on Unit No. 1, please explain how the transaction does not harm the
Company's customers.
d. The email message states, "The values from usage report are reading IPC values from Unit
I but they are added to Unit 2 in the worksheet. I have reached out to our IT team to see
why IPC has reading from Unit I on this report but they are still researching this." Please
explain how this issue has been resolved.
THIRD PRODUCTION REQUEST
TO IDAHO POWER 2 JUNE 8,2022
DATED at Boise, Idaho, tfris (fi day of June 2022.
vlL-A
Chris Burdin
Deputy Attorney General
i:umisc:prodreq/ipce22.5cbrk prod req 3
THIRD PRODUCTION REQUEST
TO IDAHO POWER J JUNE 8,2022
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 8TH DAY oF JUNE 2022,
SERVED THE FOREGOING THIRD PRODUCTION REQI]EST OF TIIE
coMMrssloN STAFF TO IDAHO POWER COMPAIYY, IN CASE NO.
IPC-E-22-05, BY E.MAILING A COPY TTIEREOF, TO THE FOLLOWING:
LISA NORDSTROM
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: [e-mail]
dockets@ i dahopower. com
MATT LARKIN
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL : [e-mail]
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SECRETART
CERTIFICATE OF SERVICE