20220513IPC to Staff 8.pdf

JULIA A. HILTON
Deputy General Counsel and
Director of Legal
[e-mail]

May 13, 2022

Jan Noriyuki, Secretary
Idaho Public Utilities Commission
11331 W. Chinden Boulevard
Building 8, Suite 201-A
Boise, Idaho 83714

Re: Case No. IPC-E-22-11
Application of Idaho Power Company for Authority to Implement Power Cost
Adjustment (“PCA”) Rates for Electric Service from June 1, 2022, through May
31, 2023

Dear Ms. Noriyuki:

Attached for electronic filing is Idaho Power Company’s Response to the Second
Production Request of the Commission Staff in the above-entitled matter.

The confidential attachment will be provided in a separate encrypted email to the
parties who sign the protective agreement.

If you have any questions about the attached documents, please do not hesitate to
contact me.

Very truly yours,

Julia A. Hilton
JAH:sg
Enclosures
RECEIVED
2022 May 13, PM 12:10
IDAHO PUBLIC
UTILITIES COMMISSION

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 1
LISA D. NORDSTROM (ISB No. 5733)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
[e-mail]

Attorney for Idaho Power Company

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 JUNE
1, 2022, THROUGH MAY 31, 2023.

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CASE NO. IPC-E-22-11

IDAHO POWER COMPANY’S
RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE
COMMISSION STAFF

COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), and in
response to the Second Production Request of the Commission Staff dated May 6, 2022,
herewith submits the following information:

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 2
REQUEST FOR PRODUCTION NO. 8: Has anything changed with Bridger
settlement discussions, Environmental Protection Agency evaluations, or state of
Wyoming activities that could change Bridger availability as modeled in the PCA forecast?
If so, please provide the updated PCA calculations.
RESPONSE TO REQUEST FOR PRODUCTION NO. 8: As discussed on page
10, lines 1 through 11, of the Direct Testimony of Jessica G. Brady, Idaho Power’s filed
PCA in this case reflected Bridger Unit 1 availability for dispatch at the revised state
implementation plan (“SIP”) levels, and Bridger Unit 2 availability at a 25 percent level
from June through October 2022 in light of ongoing uncertainty related to Environmental
Protection Agency negotiations. Since the filing of the PCA, confidential settlement
discussions have progressed to a point where Idaho Power feels more confident in its
ability to operate the Bridger plant at levels higher than those included in the initial filing.
As a result, Idaho Power has calculated what the change in estimated net power supply
expenses (“NPSE”) would be if Bridger is fully available for the summer of 2022. By taking
the difference between Bridger dispatch costs and known gas and power purchase prices
from Risk Management Committee firm orders and multiplying that by the megawatt-
hours for June through September, the Company arrived at a total decrease of $9.34
million in system forecast NPSE. This equates to an estimated $8.5 million decrease in
total Idaho jurisdictional PCA collection. Please see Confidential Attachment 1 for the
change in NPSE and Attachment 2 for the updated PCA calculations.
The response to this Request is sponsored by Jessi Brady, Regulatory Analyst,
Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 3
DATED at Boise, Idaho, this 13th day of May 2022.

___________________for___________
LISA D. NORDSTROM
Attorney for Idaho Power Company

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 4
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the 13th day of May 2022, I served a true and correct
copy of Idaho Power Company’s Response to the Second Production Request of the
Commission Staff to Idaho Power Company upon the following named parties by the
method indicated below, and addressed to the following:

Commission Staff
Dayn Hardie
Deputy Attorney General
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg No. 8,
Suite 201-A (83714)
PO Box 83720
Boise, ID 83720-0074

Hand Delivered
U.S. Mail
Overnight Mail
FAX
_____ FTP Site
X Email: [e-mail]

Industrial Customers of Idaho Power
Peter J. Richardson
515 N. 27th Street
Boise, Idaho 83702
Hand Delivered
U.S. Mail
Overnight Mail
FAX
_____ FTP Site
X Email: [e-mail]

Dr. Don Reading
6070 Hill Road
Boise, Idaho 83703
Hand Delivered
U.S. Mail
Overnight Mail
FAX
_____ FTP Site
X Email: [e-mail]

________________________________
Stacy Gust, Regulatory Administrative
Assistant

BEFORE THE

IDAHO PUBLIC UTILITIES COMMISSION

CASE NO. IPC-E-22-11

IDAHO POWER COMPANY

CONFIDENTIAL

REQUEST NO. 8

ATTACHMENT NO. 1
SEE ATTACHED SPREADSHEET
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-22-11
IDAHO POWER COMPANY
REQUEST NO. 8
ATTACHMENT NO. 2
SEE ATTACHED SPREADSHEET