20220629Staff 22-27 to IPC.pdf

DAYN HARDIE
RILEY NEWTON
DEPUTY ATTORNEY GENERALS
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-OO
(208) 334-03r2t0318
IDAHO BAR NO. 9917111202
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR A
CERTIFICATE OF PUBLIC CONVENIENCE
AND NECESSITY TO ACQUIRE RESOURCES
TO BE ONLINE BY 2023 TO SECURE
ADEQUATE AND RELIABLE SERVICE TO
ITS CUSTOMERS
CASE NO.IPC.E.22-I3
SECOND PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
IDAHO POWER COMPANY
'i -- l)*! rr- 3 1:r- l:-: .1:1 ,'
Street Address for Express Mail:
I 1331 W CHINDEN BVLD, BLDG 8, SUITE 2OI-A
BOISE,ID 83714
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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The Staff of the Idaho Public Utilities Commission, by and through its attomey of
record, Riley Newton, Deputy Attorney General, request that Idaho Power Company
("Company" or "Idaho Power") provide the following documents and information as soon as
possible, or by WEDNESDAY. JULY 20,2022.
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
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
SECOND PRODUCTION REQUEST
TO IDAHO POWER COMPANY 1 JUNE 29,2022
and if different the witness who can sponsor the answer at hearing if need be. See IDAPA
31.01.01.228.
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. 22: Please explain whether the 40MW BESS co-located at the 40 MW
solar PV generation facility at Black Mesa can be charged directly from the grid.
REQUEST NO.23: Please provide the following information related to the 80 MW
stand-alone battery storage facility potentially installed at the Hemmingway substation:
a. A detailed listing of all remaining costs outside the BESS contract required to
complete the battery storage facility.
b. Company analysis detailing the annualized Operations and Maintenance ("O&M")
costs expected over the life of the battery storage facility.
REQUEST NO.24: Please provide the following information related to the 40MW
BESS co-located at the 40 MW solar PV generation facility at Black Mesa:
a. A detailed listing of all remaining costs outside the BESS contract required to
complete the battery storage facility.
b. Company analysis detailing the annualized O&M costs expected over the life of the
battery storage facility.
REQUEST NO. 25: Does the Company plan to enter a Long-Term Service Agreement
with the contracted BESS supplier to maintain the stated capacity for the two facilities? If so,
what is the duration of the agreement and the yearly cost for each facility? [f not, please explain
the Company's approach to maintaining the two facilities and the expected costs.
REQUEST NO. 26: Are federal tax credits available for the 40MW BESS co-located at
the 40 MW solar PV generation facility at Black Mesa? If so, please provide Company analysis
showing the value of the tax credits over the life of the facility. [f not, please explain why.
SECOND PRODUCTION REQUEST
TO IDAHO POWER COMPANY 2 JUNE 29,2022
REQUEST NO. 27: Are federal ta:r credits available for the 80MW BESS facility
potentially installed at the Hemmingway substation? If so, please provide Company analysis
showing the value of the tax credits over the life of the facility. If not, please explain why.
DATED at Boise, Idatro, this 29ft day of hne2022
Riley
Deputy ttomey General
i:umisc:prodreq/ipce22. l3mrk prod reql
SECOND PRODUCTION REQUEST
TO IDAHO POWER COMPANY 3 JI-INE 29,2022
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 29TH DAY OF JITNE 2022,
SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THE
coMMrssroN STAFF To IDAHO POWER COMPAI\Y, IN CASE NO.
IPC-E-22.13, BY E.MAILING A COPY THEREOF, TO THE FOLLOWING:
DONOVAN E WALKER
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL : [e-mail]
dockets@,idahopower.com
PETER J RICHARDSON
RICHARDSON ADAMS PLLC
5I5 N 27TH STREET
BOISE ID 83702
E-MAIL: [e-mail]
C. TOM ARKOOSH
AMBER DRESSLAR
ARKOOSH LAW OFFICES
913 W. RIVER STREET, SUITE 450
P.O. BOX 2900
BOISE,ID 83701
E-MAIL : [e-mail]
Amber koosh.com
erin. cecil @arkoosh. com
AUSTIN RUESCHHOFF
THORVALD A. NELSON
AUSTIN W. JENSEN
HOLLAND & HART, LLP
555 ITTH STREET SUITE 32OO
DENVER, CO 80202
E-MAIL : darueschhoff@hol landhart. com
tnelson@hollandhart. com
awj ensen@ho I land hart. com
acl ee@hol landhart.com
TIMOTHY E TATUM
IDAHO POWER COMPANY
PO BOX 70
BOrSE ID 83707-0070
E-MAIL: [e-mail]
DR DON READING
6070 HILL ROAD
BOISE ID 83703
E-MAIL : [e-mail]
JIM SWIER
MICRON TECHNOLOGY, INC
8OOO SOUTH FEDERAL WAY
BOISE, ID 83707
E-MAIL: i conl
MARIE KELLNER
IDAHO CONSERVATION LEAGUE
710 N. 6TH STREET
BOISE,ID 83702
E-MAIL: mkellner(Eidahoconservation.org
CERTIFICATE OF SERVICE
EMMA E. SPERRY
IDAHO CONSERVATION LEAGUE
7IO N. 6TH STREET
BOISE,ID 83702
E-MAIL: [e-mail]
SECRETARY
CERTIFICATE OF SERVICE