20230623Staff 1-2 to IPC.pdf

CHRIS BURDIN
DEPUTY ATTORNEY GENERAL M (:22
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE,IDAHO 83720-0074
[phone]
IDAHO BAR NO.9810
Street Address for Express Mail:
11331 W CHINDEN BLVD,BLDG 8,SUITE 201-A
BOISE,ID 83714
Attorney 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-23-20
CERTIFICATE OF PUBLIC CONVENIENCE )
AND NECESSITY TO ACQUIRERESOURCES )TO BE ONLINE IN BOTH 2024 AND 2025 AND )FIRST PRODUCTION
FOR APPROVAL OF AN ENERGY STORAGE )REQUESTOF THE
AGREEMENT WITH KUNA BESS,LLC )COMMISSION STAFF
)TO IDAHO POWER COMPANY
Staff of the Idaho Public Utilities Commission,by and throughits attorney of record,
Chris Burdin,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,JULY 14,2023.
This Production Request is to be considered as continuing,and the Company is requested
to provide,by way of supplementaryresponses,additional documents that it,or any person
acting on its behalf,may later obtain that will augment 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 telephonenumber of
the person preparing the documents.Please also identify the name,job title,location,and
telephone number of the record holder.
FIRST PRODUCTION
REQUEST TO IDAHO POWER l JUNE 23,2023
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.1:Please outline any differences in the future recovery process,if
KUNA BESS is considered a capital lease as opposed to an operating lease.
REQUESTNO.2:For a lease to be classified as a capital lease under GAAP,it must
meet at least one of the followingfive criteria:
a.Transfer of ownership to the lessee at the end of the lease.
b.A bargain purchase option,which allows purchase of the asset at a significantly
lower price than the fair market value of the asset,in which the lessee is
reasonably certain to exercise.
c.The term of the lease is equal to or greater than 75%of the asset's useful life.
d.The lease payments have a present value which equal to or greater than 90%of
the asset's fair market value.
e.The asset has a specialized use in which the lessor would have no alternate use
after the lease ends.
Please indicate for each of the criteria if the lease satisfies the requirement or not.If one or more
of the criteria is met by the lease,please explain why.Please provide all assumptions and
comparative calculations.
DATED at Boise,Idaho,this /day of June 2023.
C¾s Burd ,
Deputy AttorneyGeneral
i:umisc:prodreq/ipce23.20cbje prod req l
FIRST PRODUCTION
REQUEST TO IDAHO POWER 2 JUNE 23,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 23"DAY OF JUNE 2023,SERVED
THE FOREGOING FIRST PRODUCTION REQUESTOF THE COMMISSION STAFF
TO IDAHO POWER COMPANY,IN CASE NO.IPC-E-23-20,BY E-MAILING A
COPY THEREOF,TO THE FOLLOWING:
DONOVAN E WALKER TIM TATUM
IDAHO POWER COMPANY IDAHO POWER COMPANY
PO BOX 70 PO BOX 70
BOISE ID 83707-0070 BOISE ID 83707-0070
E-MAIL:[e-mail] E-MAIL:ttatum idahopower.com
dockets(Nidahopower.com
SECRETARY
CERTIFICATE OF SERVICE