20230919Staff 1-3 to IPC.pdf

RECEIVED
2023 September 19 4:27PM
IDAHO PUBLIC
UTILITIES COMMISSIONMICHAEL DUY AL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 11714
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 THE APPLICATION )
OF IDAHO POWER COMPANY FOR )
APPROVAL OF AMENDMENTS TO )
AGREEMENTS FOR DELIVERY OF POWER )
AND ENERGY WITH KING HILL )
IRRIGATION DISTRICT )
)
) ___________________ )
CASE NO. IPC-E-23-21
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO IDAHO POWER COMPANY
Staff of the Idaho Public Utilities Commission, by and through its attorney ofrecord,
Michael Duval, Deputy Attorney General, requests that Idaho Power Company ("Company")
provide the following documents and information as soon as possible, but no later than
TUESDAY, OCTOBER 10, 2023.
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 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.
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY SEPTEMBER 19, 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.
REQUEST NO. 1: The original agreements from 1979 ("the 1979 Agreements")
included an option for a fifth pump "specifically to serve only that land owned by Eugene and
Aurora Ascuena, husband and wife .... " Over the ensuing forty-four years the King Hill
Irrigation District ("KHID") has not exercised that option. Please explain why the Company and
KHID chose to keep that option in the Agreements, even while modifying the Agreements to add
a sixth pump.
REQUEST NO. 2: Please explain if the Company is incurring any uncompensated costs
associated with providing electricity infrastructure to the newly constructed Hammett pump
station. Please explain which party is responsible to pay for the additional power implied by
raising the April Agreement's horsepower limit from 10,000 to 10,100.
REQUEST NO. 3: Please clarify if the Agreements include an expiration date. Please
describe any other tennination options included in the Agreements.
t4
DATED at Boise, Idaho, this / ' day of September 2023.
i:umisc:prodreq/lPC-E-23-21 PR #I
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 2
~d/ Michael Duval
Deputy Attorney General
SEPTEMBER 19, 2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 19th DAY OF SEPTEMBER 2023,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER, IN CASE NO. IPC-E-23-21, BY E­
MAILING A COPY THEREOF, TO THE FOLLOWING:
DONOVAN E WALKER
MEGAN GOICOECHEA ALLEN
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: [e-mail]
[e-mail]
[e-mail]
JEFFREY BLANKSMA JR
CHAIRMAN
KING HILL IRRIGATION DISTRICT
PO BOX 993
GLENNS FERRY ID 83623
E-MAIL: [e-mail]
TIM TATUM
CONNIE ASCHENBRENNER
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: [e-mail]
[e-mail]
SECRETARY
CERTIFICATE OF SERVICE