20220510Staff 9 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:
1I33I W CHINDEN BVLD, BLDG 8, SUITE 2OI-A
BOISE,ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPAI\IY FOR
AUTHORITY TO IMPLEMENT POWER
cosT ADJUSTMENT ("PCA") RATES FOR
ELECTRTC SERVICE FROM JIINE 1,2022,
THROUGH MAY 31,2023
CASE NO.IPC.E.Z2.II
THIRD PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
IDAHO POWER COMPANY
)
)
)
)
)
)
)
)
The Staff of the Idaho Public Utilities Commission, by and through its afforney of
record, Dayn Hardie, Deputy Attorney General, request that Idaho Power Company ("Company"
or "Idaho Power") provide the following documents and information as soon as possible, or by
FRTDAY, MAY 13,2022.1
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 StafPs
attorney at [phone].
THIRD PRODUCTION REQUEST
TO IDAHO POWER COMPANY 1 MAY 10,2022
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
3r.0t.01.228.
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. 9: Regarding Production Request (PR) No. 6, please respond to the
following for Hells Canyon #3 relative to the forced downtime that started on 41112021 through
41112022 (according to the response).
(a) Please provide a detailed explanation for the cause of the downtime including the
root cause(s).
(b) Is unit #3 still offline? If so, when is it expected to come back on-line?
(c) Why has it been down for over ayear? What has the Company done to rectiff the
situation to bring the unit back online? If the unit is not currently online, what is the
Company currently doing to rectifu the situation and bring the unit back online?
(d) Was it possible to bring the unit on-line sooner? If so, please explain how and
describe the associated cost compared to the Company's chosen timeline.
(e) According to the response to PR No. 6, I , I 43,1 80 Megawatt-hours during the 2021-
2022PCA deferral period of zero-fuel cost generation were lost. Please calculate
the additional cost of replacing the generation from that unit due to the outage.
(0 Please provide any documentation showing the Company's analysis of the
downtime that address the questions above.
DATED at Boise, Idaho, this lALauv of May 2022
Deputy Attorney General
i:umisc:prodreq/ipce22.l I dhml prod req3
THIRD PRODUCTION REQUEST
TO TDAHO POWER COMPANY 2 MAY 10,2022
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 1OTH DAY OF MAY 2022,
SERVED THE FOREGOING THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY, IN CASE NO.
IPC-E-Z2-II, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
LISA NORDSTROM
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: [e-mail]
[e-mail]
PETER J RICHARDSON
RICHARDSON ADAMS PLLC
515 N 27TH STREET
BOISE ID 83702
E-MAIL: [e-mail]
MATTHEW LARKIN
TIMOTHY TATUM
JESSI BRADY
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL : mlarkin@,idahopower.com
[e-mail]
j brady @ idahopower.com
DR DON READING
6070 HILL ROAD
BOISE ID 83703
E-MAIL : [e-mail]
Jr4,h*-
SECRETAP.Y-
CERTIFICATE OF SERVICE