20220422Staff 1-7 to IPC.pdf

DAYN HARDIE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 9917
Street Address for Express Mail:
I I331 W CHINDEN BVLD, BLDG 8, SUITE 2OI-A
BOISE, TD 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
AUTHORITY TO IMPLEMENT POWER
cosT ADJUSTMENT ("PCA") RATES FOR
ELECTRIC SERVICE FROM JTINE 1,2022,
THROUGH MAY 3I,2023
CASE NO.IPC.E.22.II
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
IDAHO POWER COMPANY
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The Staff of the Idaho Public Utilities Commission, by and through its attorney of
record, Dayn Hardie, Deputy Attorney General, request that Idaho Power Company (o'Company"
or "Idaho Power") provide the following documents and information as soon as possible, or by
TUESDAY, MAY 3,2022.1
This Production Request is 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 produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations. The Company is reminded that responses
I Stuff ir requesting an expedited response. If responding by this date will be problematic, please call Staff s
attomey at [phone].
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY I APRIL 22,2022
pursuant to Commission Rules of Procedure must include the name and phone number of the
person preparing the document, and the name, location, and phone number of the record holder
and if different the witness who can sponsor the answer at hearing if need be. See IDAPA
31.01.0t.228.
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. l: Please provide a list of all Idaho Power customers who purchased
Company-owned Renewable Energy Credits ("RECs") that are being passed through the Power
Cost Adjustment ("PCA") Schedule 55. Please include in the response the fuel type for the
RECs, purchase price, quantity of RECs, and date purchased.
REQUEST NO. 2: Please provide all workpapers used to derive the final figures
included in the exhibits in electronic format with all formulas intact.
REQUEST NO.3: Please provide the monthly number of megawatt-hours ("MWh")
associated with the system base and actual net power costs for all Net Power Supply Expense
("NPSE") Accounts including Federal Energy Regulatory Commission ("FERC") accounts 501
(Coal), account 536 (Water for power), account 547 (Gas), account 555 (Non-PURPA), account
565 (3rd party transmission), account 447 (Surplus Sales), account 555, (PURPA), and account
555 (Demand Response Incentives).
REQUEST NO.4: Did the Company re-distribute or smooth base NPSE in this year's
filing? If so, please provide workpapers that reflect the calculations/method used to derive the
revenue-smoothed (redistributed) base NPSE included in Exhibit No. 2 from the Aurora
generated NPSE that was last authorizedby the Commission for the deferral period for all NPSE
accounts. Please include all workpapers in electronic format with calculations intact.
REQUEST NO. 5: Please provide supporting data on the reservoir levels for the Upper
Snake River Basin for both current and2023 forecasted amounts.
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 2 APRIL 22,2022
REQUEST NO. 6: Please provide the length of time and amount of production in MWhs
lost for forced downtime (unscheduled) that Company-owned generation facilities/units
experienced each month during the deferral period. For each forced downtime, please explain the
cause and resolution of the downtime
REQUEST NO. 7: Please provide all Company-owned facility/unit unforced downtime
(scheduled) including the date range, length of time, and reason that occurred during the deferral
period.
DATED at Boise, Idaho, tnirDd day of Apri 12022.
Deputy General
i:umisc:prodreq/ipce22. I I dhkls prod req I
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 3 APRIL 22,2022
CERTIFICATE OF SERYICE
I HEREBY CERTIFY THAT I HAVE THIS 22ND DAY OF APRIL 2022,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF TIIE
CoMMISSION STArF TO IDAHO POWER COMPAIYY, IN CASE NO.
|PC.E-22-11, 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
MATTHEW LARKIN
TIMOTHY TATUM
JESSI BRADY
IDAHO POWER COMPANY
PO BOX 70
BOrSE rD 83707-0070
E-MAIL: mlarkin@.idahopower.com
ttatum@idahopower. com
i [e-mail]
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SECRETARY /
CERTIFICATE OF SERVICE