20230324Staff 38-41 to IPC .pdf

RILEY NEWTON
MICHAEL DUVAL
DEPUTY ATTORNEYS GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE,IDAHO 83720-0074
[phone]/334-0320
IDAHO BAR NOS.11202 &11714
Street Address for Express Mail:
11331 W CHINDEN BLVD,BLDG 8,SUITE 201-A
BOISE,ID 83714
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER )COMPANY'S APPLICATION FOR A )CASE NO.IPC-E-23-01
CERTIFICATE OF PUBLIC CONVENIENCE )AND NECESSITY FOR THE BOARDMAN TO )HEMINGWAY 5OO-KV TRANSMISSION )THIRD PRODUCTION
LINE )REQUESTOF THE
)COMMISSION STAFF
)TO IDAHO POWER COMPANY
Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Michael Duval,Deputy AttorneyGeneral,requests that Idaho Power Company ("Company"or
"Idaho Power")provide the followingdocuments and information as soon as possible,but no
later than FRIDAY,APRIL 7,2023.1
This Production Request is to be considered as 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
i Staff is requesting an expedited response.If responding by this date will be problematic,please call Staff's
attorney at [phone]/0320.
THIRD PRODUCTION REQUEST
TO IDAHO POWER l MARCH 24,2023
the documents or information produced.
Please provide answers to each question,supporting workpapers that provide detail or are
the source of information used in calculations,and the name,job title,and telephone number of
the person preparing the documents.Please also identify the name,job title,location,and
telephone number of the record holder.
In addition to the written copies provided as response to the requests,please provide all
Excel spreadsheets and electronic files with formulas intact and enabled.
REQUESTNO.38:Company witness Ellsworth refers to the 2021 IntegratedResource
Plan ("IRP")portfolios when describing how the proposed Boardman to Hemingway ("B2H")
transmission line is the least-cost least-risk option to fill the Company's expected 2026 capacity
deficit.Ellsworth Direct at 47.Please provide a worksheet that includes updated cost estimates
in 2023 dollars for the portfolio alternatives listed in Table 3 of Ellsworth's direct testimony.
Ellsworth Direct at 44.
REQUESTNO.39:In its response to Production Request No.6,the Company stated,
"While the Company is not seeking explicit approval of the partnership agreements in this case,
the agreements form the foundational information necessary to derive the estimated cost of the
project Idaho Power will ultimately seek to recover from its customers."Please provide
workpapers showing the estimated 20-yr levelized costs and revenues for each of the projects
and transactions listed in Production Request No.6.Please summarize the net estimated impact
to customers.
REQUESTNO.40:Please quantifythe expected cost of the Idaho Power 500 MW
Mid-Columbia ("Mid-C")hub to Longhorn point-to-point("PTP")Transmission Service
Agreement ("TSA")with Bonneville Power Administration ("BPA").Please provide supporting
documents and worksheets that include the terms of the TSA.
THIRD PRODUCTION REQUEST
TO IDAHO POWER 2 MARCH 24,2023
REQUESTNO.41:As a supplement to Company Response to Production Request No.
14:
a.For each event included in the table,please explain how the Company maintained
operations and served load for the Company's customers.
b.For ten of the listed outage events,the Company's actions are described as
"Limitation or reduction of scheduled energy between the Pacific Northwest and
Idaho Power (in both directions)."Please quantifythe limitation or reduction for
each event.
c.Please provide a detailed synopsis of the outage that occurred on 12/21/2022 due to
the "RAS transfer trip to HMWY-SMLK and Jim Bridger U4."Please include
additional explanation of the impact and actions.
DATED at Boise,Idaho,this day of March 2023.
Michael Duval
Deputy AttorneyGeneral
i:umisc:prodreq/ipce23.lrnms prod reg 3
THIRD PRODUCTION REQUEST
TO IDAHO POWER 3 MARCH 24,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 24TH DAY OF MARCH 2023,SERVED THE FOREGOING THIRD PRODUCTION REQUESTOF THECOMMISSIONSTAFFTOIDAHOPOWERCOMPANY,IN CASE NO.IPC-E-23-01,BY E-MAILING A COPY THEREOF,TO THE FOLLOWING:
DONOVAN E WALKER TIMOTHY TATUMIDAHOPOWERCOMPANYIDAHOPOWERCOMPANYPOBOX70POBOX70BOISEID83707-0070 BOISE ID 83707-0070E-MAIL:[e-mail] E-MAIL:[e-mail]@idahopower.com
ERIC L OLSEN LANCE KAUFMAN PhDECHOHAWK&OLSEN PLLC 2623 NW BLUEBELL PLACEPOBOX6119CORVALLISOR97330POCATELLOID83205E-MAIL:lance aegisinsight.comE-MAIL:[e-mail]
PETER J RICHARDSON DR DON READINGRICHARDSONADAMSPLLC280SSILVERWOODWAYPOBOX7218EAGLEID83616BOISEID83702E-MAIL:[e-mail]-MAIL:[e-mail]
ED JEWELL WIL GEHLDEPUTYCITYATTORNEYENERGYPROGRAM MANAGERBOISECITYATTORNEY'S OFFICE BOISE CITY DEPT OF PUBLIC WORKSPOBOX500POBOX500BOISEID83701-0500 BOISE ID 82701-0500E-MAIL:[e-mail] E-MAIL:[e-mail]
[e-mail]
boisecitvattorney citvofboise.ore
CERTIFICATE OF SERVICE
JIM SWIER AUSTIN RUESCHHOFFMICRONTECHNOLOGYINCTHORVALDANELSON8000SFEDERALWAYAUSTINWJENSENBOISEID83707HOLLAND&HART LLPE-MAIL:[e-mail] 555 17TH ST STE 3200
DENVER CO 80202
E-MAIL:[e-mail]
[e-mail]
[e-mail]
[e-mail]
MARIE CALLAWAY KELLNER BRAD HEUSINKVELDIDCONSERVATIONLEAGUEIDCONSERVATIONLEAGUE710N6THST710N6THSTBOISEID83702BOISEID83702E-MAIL:mkellner idahoconservation.ore E-MAIL:
bheusinkveld idahoconservation.org
SECRETARY
CERTIFICATE OF SERVICE