20230922IPC to Staff Supplemental 22.pdf

DONOVAN WALKER
Lead Counsel
[e-mail]

September 22, 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-23-20
In the Matter of Idaho Power Company’s Application for a Certificate of Public
Convenience and Necessity to Acquire Resources to be Online in Both 2024
and 2025 and for Approval of an Energy Storage Agreement with Kuna Bess,
LLC

Dear Ms. Noriyuki:

Attached for electronic filing please find Idaho Power Company’s Third Supplemental
Response to the Second Production Request of the Commission Staff in the above matter.

The confidential attachment will be provided separately via an encrypted email to
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
Friday, September 22, 2023 11:39:05 AM
IDAHO PUBLIC
UTILITIES COMMISSION

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 1

DONOVAN E. WALKER (ISB No. 5921)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
[e-mail]

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 IN BOTH
2024 AND 2025 AND FOR APPROVAL OF
AN ENERGY STORAGE AGREEMENT
WITH KUNA BESS LLC.
)
)
)
)
)
)
)
)
)
)

CASE NO. IPC-E-23-20

IDAHO POWER COMPANY’S
THIRD SUPPLEMENTAL
RESPONSE TO THE SECOND
PRODUCTION REQUEST OF
THE COMMISSION STAFF

COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), and in
response to the Second Production Request of the Commission Staff (“Commission” or
“Staff”) to Idaho Power Company dated August 22, 2023, herewith submits the following
information:

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 2

STAFF REQUEST FOR PRODUCTION NO. 22: Footnote Nos. 21 and 23 in Exhibit
No. 5 of Hackett's Direct Testimony mention price adjustments due to overbuilds.
a. Please explain what the bidders proposed regarding overbuilds in their bids; and
b. Please explain how and why overbuilds affect pricing.
SUPPLEMENTAL RESPONSE TO STAFF’S REQUEST FOR PRODUCTION
NO. 22: Following discussions with Staff on September 18, 2023, the Company is
including as Confidential Supplemental Attachment – Staff Request for Production No. 22
the total project capacity and total project costs, including overbuild, of the final shortlist
projects for both the 2024 and 2025 resources.
The response to this Request is sponsored by John Wonderlich, Finance Team
Leader, Idaho Power Company.

DATED at Boise, Idaho this 22nd day of September 2023.

DONOVAN E. WALKER
Attorney for Idaho Power Company

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 3

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the 22nd day of September 2023, I served a true and
correct copy of Idaho Power Company’s Response to the Second Production Request of
the Commission Staff 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 [e-mail]

Christy Davenport
Legal Administrative Assistant