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Home My WebLink About20230726IPC to Staff 36 Supplemental.pdf DONOVAN WALKER Lead Counsel dwalker@idahopower.com July 26, 2023 VIA ELECTRONIC FILING Jan Noriyuki, Secretary Idaho Public Utilities Commission 11331 W. Chinden Blvd., Bldg 8, Suite 201-A (83714) PO Box 83720 Boise, Idaho 83720-0074 Re: Case No. IPC-E-23-05 In the Matter of Idaho Power Company’s Application for a Certificate of Public Convenience and Necessity to Acquire Resources to be Online by 2024 and Approval of a Power Purchase Agreement with Franklin Solar LLC Dear Ms. Noriyuki: Attached for electronic filing, please find Idaho Power Company’s Supplemental Response to the Amended Confidential Second Production Request of the Commission Staff to Idaho Power Company in the above matter. Confidential Attachment No. 2 will be provided to the parties who sign the Protective Agreement Please feel free to contact me directly with any questions you might have about this filing. Very truly yours, Donovan E. Walker DEW:cd Enclosures RECEIVED 2023 JULY 26, 2023 5:04PM IDAHO PUBLIC UTILITIES COMMISSION CERTIFICATE OF ATTORNEY ASSERTION THAT INFORMATION CONTAINED IN AN IDAHO PUBLIC UTILITIES COMMISSION FILING IS PROTECTED FROM PUBLIC INSPECTION Idaho Power Company’s Application for a Certificate of Public Convenience and Necessity to Acquire Resources to be Online by 2024 and Approval of a Power Purchase Agreement with Franklin Solar LLC Case No. IPC-E-23-05 The undersigned attorney, in accordance with Commission Rules of Procedure 67, believes that the Attachment No. 2 to Idaho Power Company’s Supplemental Response to the Amended Confidential Second Production Request of the Commission Staff to Idaho Power Company, dated July 26, 2023, may contain information that Idaho Power Company and a third party claims is a confidential trade secret as described in Idaho Code § 74-101, et seq., and/or § 48-801, et seq. As such, it is protected from public disclosure and exempt from public inspection, examination, or copying. DATED this 26th day of July, 2023. Donovan Walker Counsel for Idaho Power Company IDAHO POWER COMPANY’S SUPPLEMENTAL RESPONSE TO THE AMENDED CONFIDENTIAL SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 1 DONOVAN E. WALKER (ISB No. 5921) Idaho Power Company 1221 West Idaho Street (83702) P.O. Box 70 Boise, Idaho 83707 Telephone: (208) 388-5317 Facsimile: (208) 388-6936 dwalker@idahopower.com Attorney for Idaho Power Company BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF IDAHO POWER COMPANY’S APPLICATION FOR A CERTIFICATE OF PUBLIC CONVENIENCE AND NECESSITY TO ACQUIRE RESOURCES TO BE ONLINE BY 2024 AND FOR APPROVAL OF A POWER PURCHASE AGREEMENT WITH FRANKLIN SOLAR LLC. ) ) ) ) ) ) ) ) ) ) ) CASE NO. IPC-E-23-05 IDAHO POWER COMPANY’S SUPPLEMENTAL RESPONSE TO THE AMENDED CONFIDENTIAL SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), and in response to the Confidential Second Production Request of the Commission Staff (“Commission” or “Staff”) dated June 15, 2023, herewith submits the following information: IDAHO POWER COMPANY’S SUPPLEMENTAL RESPONSE TO THE AMENDED CONFIDENTIAL SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 2 REQUEST FOR PRODUCTION NO. 36: Page 24 of Mr. Ellsworth's Testimony states that Idaho Power's most recently updated L&R has identified a 2024 capacity need of 103 MW. Please respond to the following: a. What factors drove the increase of capacity needs to 103 MW from the previous deficit? b. When was the capacity need of 103 MW in 2024 identified? c. Please provide evidence of the 103 MW capacity need in the form of L&R. SUPPLEMENTAL RESPONSE TO REQUEST FOR PRODUCTION NO. 36: On July 11, 2023, the Company presented the Reliability and Capacity Assessment Tool (“R- CAT”) Position Overview to Staff, included as Attachment 1, describing the R-CAT modeling process that resulted in the identification of the 2024 capacity deficit of 103 MW. Confidential Attachment 2 to this response includes the 2024-2043 load scaling utilized in the R-CAT modeling to determine the 2024 capacity position while Attachments 3 and 4 include the historical hourly data and Equivalent Forced Outage Rates utilized in the R- CAT model, respectively. Finally, Attachments 5 and 6 present the resulting capacity positions identifying the 103 MW deficit and 4 MW length, respectively. The response to this Request is sponsored by Jared Hansen, Resource Planning Leader, Idaho Power Company. DATED at Boise, Idaho this 26th day of July 2023. DONOVAN E. WALKER Attorney for Idaho Power Company IDAHO POWER COMPANY’S SUPPLEMENTAL RESPONSE TO THE AMENDED CONFIDENTIAL SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 3 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 26th day of July 2023, I served a true and correct copy of Idaho Power Company’s Supplemental Response to the Amended Confidential 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 Chris Burdin 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 Chris.Burdin@puc.idaho.gov City of Boise Darrell Early Deputy City Attorney Boise City Attorney’s Office 150 N. Capitol Blvd. PO Box 500 Boise, ID 83701 Hand Delivered U.S. Mail Overnight Mail FAX FTP Site X Email dearly@cityofboise.org boisecityattorney@cityofboise.org Wil Gehl Energy Program Manager Boise City Dept. of Public Works 150 N. Capitol Blvd. P.O. Box 500 Boise, Idaho 83701-0500 Hand Delivered U.S. Mail Overnight Mail FAX FTP Site X Email wgehl@cityofboise.org Christy Davenport Legal Administrative Assistant BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-23-05 IDAHO POWER COMPANY SUPPLMENT TO DR NO 36 ATTACHMENT 1 SEE EXCEL SPREADSHEET BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-23-05 IDAHO POWER COMPANY SUPPLMENT TO DR NO 36 ATTACHMENT 2 SEE EXCEL SPREADSHEET CONFIDENTIAL BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-23-05 IDAHO POWER COMPANY SUPPLMENT TO DR NO 36 ATTACHMENT 3 SEE EXCEL SPREADSHEET BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-23-05 IDAHO POWER COMPANY SUPPLMENT TO DR NO 36 ATTACHMENT 4 SEE EXCEL SPREADSHEET BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-23-05 IDAHO POWER COMPANY SUPPLMENT TO DR NO 36 ATTACHMENT 5 SEE EXCEL SPREADSHEET BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-23-05 IDAHO POWER COMPANY SUPPLMENT TO DR NO 36 ATTACHMENT 6 SEE EXCEL SPREADSHEET