20230828CEO 9 to IPC.pdf

Kelsey Jae (ISB No. 7899)
Kelsey Jae LLC
920 N. Clover Dr., Boise, ID 83703
Phone: (208) 391-2961
[e-mail]
Attorney for Clean Energy Opportunities for Idaho
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO
POWER COMPANY’S
APPLICATION FOR AUTHORITY
TO INCREASE ITS RATES AND
CHARGES FOR ELECTRIC
SERVICE IN THE STATE OF
IDAHO AND FOR ASSOCIATED
REGULATORY ACCOUNT
TREATMENT
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CASE NO. IPC-E-23-11
CLEAN ENERGY OPPORTUNITIES
FOR IDAHO’S THIRD
PRODUCTION REQUEST TO
IDAHO POWER COMPANY
COMES NOW Clean Energy Opportunities for Idaho (“CEO”), by and through its
attorney of record, Kelsey Jae of the firm Kelsey Jae LLC, and requests that Idaho Power
Company (“the Company” or “Idaho Power”) provide the following documents within 21 days
or sooner if possible.
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
with supporting workpapers that provide detail or are the source of information used in
calculations. Please provide any Excel files with formulas active. Additionally, please 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
CLEAN ENERGY OPPORTUNITIES FOR IDAHO - THIRD PRODUCTION REQUEST - 1
IPC-E-23-11
RECEIVED
Monday, August 28, 2023 3:28:20 PM
IDAHO PUBLIC
UTILITIES COMMISSION
hearing if need be. As allowed by IDAPA 31.01.01.228.01, CEO agrees to the Company
depositing the response in an electronic depository.
CONTEXT/BACKGROUND. At the November 10, 2022 IRPAC meeting, John
Hildreth presented Idaho Power’s Hydro Generation forecast ( Hydro Modeling Results ). At the
August 15, 2023 IRPAC meeting, Idaho Power confirmed that there have been no changes to that
Hydro Generation forecast being used in the 2023 IRP. In IPC-E-23-11, Idaho Power’s
Normalized Power Supply Expenses (NPSE, Exhibit 30) are based on a substantially higher
Hydro Generation forecast (which is derived from average water conditions 1981-2017)
compared to the annual Hydro Generation forecasts the Company is using for the next five years
in developing its 2023 IRP.
REQUEST NO 9
9.1 Please re-run the AURORA model using the median Hydroelectric Generation
(MWh) forecasts for the five years 2023-2027 consistent with those presented to IRPAC in
November 2022. Please provide an updated version of Exhibit 30 NPSE Results in Excel format
with formula intact. Similar to the original Exhibit 30, please present results for each year and
the Average of the five years.
9.2 Please provide an updated version of Table 5 “2023 Base Level NPSE” contained
in Brady's Direct Testimony to reflect results from the above (9.1).
DATED this 28th day of August, 2023.
Respectfully submitted,
______________________________
Kelsey Jae, Attorney for CEO
CLEAN ENERGY OPPORTUNITIES FOR IDAHO - THIRD PRODUCTION REQUEST - 2
IPC-E-23-11
CERTIFICATE OF SERVICE
I hereby certify that on this 28th day of August, 2023. I delivered true and correct copies
of the foregoing THIRD PRODUCTION REQUEST to the following persons via the method of
service noted:
Electronic Mail Delivery
Idaho Public Utilities Commission
Jan Noriyuki
Commission Secretary
[e-mail]
Idaho PUC Staff
Dayn Hardie
Chris Burdin
Deputy Attorney General
Idaho Public Utilities Commission
[e-mail]
[e-mail]
Idaho Power Company
Megan Goicoechea Allen
Lisa D. Nordstrom
Donovan E. Walker
Timothy Tatum
Connie Aschenbrenner
Matt Larkin
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
CLEAN ENERGY OPPORTUNITIES FOR IDAHO - THIRD PRODUCTION REQUEST - 3
IPC-E-23-11
City of Boise
Ed Jewell
Darrell Early
Deputy City Attorney
[e-mail]
[e-mail]
[e-mail]
Wil Gehl, Energy Program Manager
[e-mail]
Federal Executive Agencies
Peter Meier
[e-mail]
Dwight Etheridge
[e-mail]
Industrial Customers of Idaho Power
Peter J. Richardson
Richardson Adams
[e-mail]
Dr. Don Reading
[e-mail]
Idaho Conservation League
Marie Callaway Kellner
Brad Heusinkveld
[e-mail]
[e-mail]
IdaHydro
Tom Arkoosh
[e-mail]
[e-mail]
Idaho Irrigation Pumpers Association, Inc.
Eric L. Olsen
Lance Kaufman
[e-mail]
[e-mail]
CLEAN ENERGY OPPORTUNITIES FOR IDAHO - THIRD PRODUCTION REQUEST - 4
IPC-E-23-11
Micron Technology, Inc.
Jim Swier
[e-mail]
Austin Rueschhoff
Thorvald A. Nelson
Austin W. Jensen
Holland & Hart, LLP
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
Northwest Energy Coalition
F. Diego Rivas
[e-mail]
_____________________________
Kelsey Jae
Attorney for CEO
CLEAN ENERGY OPPORTUNITIES FOR IDAHO - THIRD PRODUCTION REQUEST - 5
IPC-E-23-11