20220524Staff 22-23 to IPC.pdf

RILEY NEWTON
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03r8
IDAHO BAR NO. II2O2
IN THE MATTER OF IDAHO POWER
COMPAI\Y'S APPLICATION FOR APPROVAL
OF A REPLACEMENT SPECIAL CONTRACT
WITH MICRON TECHNOLOGY,INC. AND A
POWER PURCHASE AGREEMENT WITH
BLACK MESA ENERGY,LLC
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Street Address for Express Mail:
1 133I W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE,ID 83714
Attomey for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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CASE NO.IPC.E.22-06
SECOND PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO IDAHO POWER COMPANY
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Riley Newton, Deputy Attorney General, requests that Idaho Power Company ("Company")
provide the following documents and information as soon as possible, but no later than
TUESDAY, JUNE 14,2022.
This Production Request is to be considered as continuing, and the 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
the person preparing the documents. Please also identifr the name, job title, location, and
telephone number of the record holder.
SECOND PRODUCTION REQUEST
TO IDAHO POWER 1 MAY 24,2022
In addition to the written copies provided as response to the requests, please provide all
Excel spreadsheets and electronic files on CD with formulas intact and enabled.
REQUEST NO. 22: Please provide an analysis showing that the cost-of-service and
rates in Micron's existing Schedule 26 tariff does not change when considering Micron's load
shape net of the Black Mesa PPA generation. Please provide all workpapers from the analysis in
electronic format with all formulae intact.
REQUEST NO.23: Is the Department of Commerce Anti-Circumvention Inqurry,
Barcode 4225929-02 A-570-9791C-570-980, into assembled modules of solar panels in
Cambodi4 Malaysia, Vietnam, and Thailand, having a direct impact to the Black Mesa power
purchase agreement? If so, please explain.
DATED at Boise, Idaho, thi, 2{Sa ay of May 2022
Riley Newton
Deputy Attorney General
i:umisc:prodreq/ipce22.6mlc prod req 2
SECOND PRODUCTION REQUEST
TO IDAHO POWER 2 MAY 24,2022
CERTIFICATE OF SERVICE
I HEREBy cERTIFy rHAT I HAvE THIS 24m DAy oF MAy 2022, SERvED
THE FOREGOTNG SECOr\D PRODUCTION REQUEST OF TrrE COMIITSSION
STAFF TO IDAHO POWER COMPAIYY, IN CASE NO. IPC-E-22-06, By E-MAILING
A COPY THEREOF, TO THE FOLLOWING:
DONOVAN E WALKER
IDAHO POWER COMPANY
PO BOX 70
BOISE rD 83707-0070
E-MAIL: [e-mail]
dockets@idahopower. com
TIM TATUM
CONNIE ASCHENBRENNER
IDAHO POWER COMPANY
PO BOX 70
BOrSE ID 83707-0070
E-MAIL: [e-mail]
caschenbrenner@ idahopower.com
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CERTIFICATE OF SERVICE