20220614IPC to Staff 22-23.pdf

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DONOVAN WALKER
Lead Counsel
[e-mail] i;r' iifiij
June 14,2022
VIA ELECTRONIC FILING
Jan Noriyuki, Secretary
ldaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg 8,
Suite 201-A (837'14)
PO Box 83720
Boise, ldaho 83720-0074
Re: Case No. IPC-E-22-06
!n the Matter of ldaho Power Company's Application for Approval of a
Replacement Special Contract with Micron Technology, lnc. and A Power
Purchase Agreement with Black Mesa Energy, LLC
Dear Ms. Noriyuki:
Attached for electronic filing is ldaho Power Company's Response to the Second
Production Request of the Commission Staff in the above-entitled matter.
PIease feel free to contact me directly with any questions you might have about this
filing.
Very truly yours,
i :: i'r
fuzdate-\-
Donovan E. Walker
DEW:sg
Enclosure
DONOVAN E. WALKER (lSB No. 5921)
ldaho Power Company
1221 West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
dwalker@ida hopower.com
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR
APPROVAL OF A REPLACEMENT
SPECIAL CONTRACT WTH MICRON
TECHNOLOGY, INC. AND A POWER
PURCHASE AGREEMENT WITH BLACK
MESA ENERGY, LLC.
CASE NO. |PC-E-22-06
IDAHO POWER COMPANY'S
RESPONSE TO THE SECOND
PRODUCTION REQUEST OF
THE COMMISSION STAFF TO
IDAHO POWER COMPANY
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COMES NOW, ldaho Power Company ("ldaho Powe/'or "Company"), and in
response to the Second Production Request of the Commission Staff ("!PUC or
Commission') dated May 24,2022, herewith submits the following information:
IDAHO PO\A'ER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 1
REQUEST FOR PRODUCTION NO.22: Please provide an analysis showing
that the cost-of-service and rates in Micron's existing Schedule 26larift 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 22: ldaho Power does not
contend that Micron's cost-of-service would not change if a cost-of-service study was
performed incorporating Micron's load shape net of Black Mesa PPA generation.
Therefore, the requested analysis is not available. lt should also be noted that Schedule
26 rates approved in the 2011 general rate case ("GRC") were reflective of a stipulated
uniform percentage increase that resulted in rates that were below Micron's full cost-to-
serve. Consequently, a comparative analysis between the existing below cost-of-service
Schedule 26 rates, and a current cost-of-service study reflecting load net of Black Mesa
PPA generation would have an inherent mismatch.
Because current Schedule 26 rates do not reflect Micron's exact cost-to-serve,
the Company performed a no harm analysis intended to provide a comparable analysis
for Micron's cost assignment at full energy requirement, and a scenario when Micron's
energy is net of the Black Mesa PPA. The "without" scenario calculates energy ratio
share, and load ratio share of Micron's forecasted 2021-2040 load projections
compared to system load. The energy ratio share is used to allocate Aurora-derived
future power supply expense. ln the'\^/ith" scenario inclusive of the Black Mesa PPA,
Micron's energy share is calculated net of the BIack Mesa PPA before assigning
Aurora-derived power supply expense to Micron. Micron's energy ratio for power supply
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY.2
cost assignment demonstrates an approximately 12 percent reduction in energy ratio
(e.9. in 2030 from 4.3 percent to 3.8 percent of system energy) when the BIack Mesa
PPA is nefted from Micron's energy requirement. The no harm analysis indicates that
while Micron's energy ratio and allocated portion of power supply expense decreases,
all other customers are not harmed by the change in cost assignment.
The response is to this Request is sponsored by Paul Goralski, Regulatory
Consultant, ldaho Power Company.
]DAHO PO\A'ER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISS]ON STAFF TO IDAHO POWER COMPANY - 3
REQUEST FOR PRODUCTION NO. 23: ls the Department of Commerce Anti-
Circumvention lnquiry, Barcode 4225929-02 A-570-979/C-570-980, into assembled
modules of solar panels in Cambodia, Malaysia, Vietnam, and Thailand, having a direct
impact to the Black Mesa power purchase agreement? If so, please explain.
RESPONSE TO REQUEST FOR PRODUCTION NO. 23: ldaho Power received
the following response from Black Mesa with respect to the impact of the Department of
Commerce Anti-Gircumvention lnquiry referenced in Staffs Request:
On June 6,2022, President Biden issued a 24-month suspension of any tariffs
that may result from the referenced investigation by the Department of
Commerce. Black Mesa is currently procuring solar panels that will be imported
and installed well within the 24-month window. However, due to the impact of this
investigation on the supply chain, supply is severely constrained and costs have
increased dramatically. Black Mesa is making allaftempts to timely procure and
import modules to achieve the scheduled COD (Commercial Operation Date).
The response is to this Request is sponsored by Donovan Walker, Lead
Counse!, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCT]ON REQUEST OF THE
COMMISSION STAFF TO ]DAHO POWER COMPANY - 4
Respectfully submitted this 14h day of June 2022.
A,*1datt4-
DONOVAN E. WALKER
Attorney for ldaho Power Company
IDAHO POT^/ER COMPANYS RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPAT.IY. S
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 14th day of June2022, lserved a true and
correct copy of the foregoing ldaho Power Company's Response to the Second
Production Request of the Commission Staff to ldaho Power Company upon the
following named parties by the method indicated below, and addressed to the following
Gommission Staft
Riley Newton
Deputy Attorney General
Idaho Public Utilities Commission
Po Box 83720
Boise, ldaho 83720-0074
lndustrial Customers of ldaho Power
Peter J. Richardson
Richardson Adams, PLLC
515 N. 27th Street
Boise, ldaho 83702
Dr. Don Reading
6070 Hill Road
Boise, ldaho 83703
Emailed to:
Ri lev. Newton@puc. ida ho.oov
Emailed to:
peter@richa rdsonadams.com
Emailed to:
[e-mail]
&r^j=
Stacy Gust, Regulatory Administrative
Assistant
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 6