20231010IPC to Staff 1-3.pdf

MEGAN GOICOECHEA ALLEN
Corporate Counsel
[e-mail]

October 10, 2023

Jan Noriyuki, Secretary
Idaho Public Utilities Commission
11331 W. Chinden Boulevard
Building 8, Suite 201-A
Boise, Idaho 83714

Re: Case No. IPC-E-23-21
Application for Approval of Amendments to Agreements for Delivery of Power
and Energy with King Hill Irrigation District

Dear Ms. Noriyuki:

Attached for electronic filing is Idaho Power Company’s Response to the First
Production Request of the Commission Staff to Idaho Power Company in the above-
entitled matter.

If you have any questions about the attached documents, please do not hesitate
to contact me.

Sincerely,

Megan Goicoechea Allen
MGA:sg
Enclosures
RECEIVED
Tuesday, October 10, 2023 2:59:46 PM
IDAHO PUBLIC
UTILITIES COMMISSION

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY – 1
DONOVAN E. WALKER (ISB No. 5921)
MEGAN GOICOECHEA ALLEN (ISB No. 7623)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]

Attorneys for Idaho Power Company

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
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CASE NO. IPC-E-23-21

IDAHO POWER COMPANY’S
RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
THE COMMISSION STAFF TO
IDAHO POWER COMPANY

COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), and in
response to the First Production Request of the Commission Staff (“Commission” or
“Staff”) dated September 19, 2023, herewith submits the following information:

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY – 2
REQUEST FOR PRODUCTION 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 1: It is unclear whether there
will ever be a desire or need to add the fifth pumping station referenced in the 1979
Agreements. The parties were therefore hesitant to completely remove the references at
this time. It also seemed unnecessary to further analyze the issue considering references
to the fifth pumping station make no difference to the current amendments. Finally, the
parties desired to leave the 1979 Agreements as close to the original documents as
possible to avoid necessitating substantial review of inconsequential revisions by the
Commission.
The response to this Request is sponsored by Shelli Stewart, Lead Counsel, Idaho
Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY – 3
REQUEST FOR PRODUCTION 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 2: The King Hill Irrigation
District paid for all necessary infrastructure upgrades and new facilities associated with
the new Hammett pumping station in accordance with Rule H.
The change from 10,000 to 10,100 horsepower in the First Amendment to the April
Agreement is to account for the amount of horsepower currently installed at each of the
five pumping stations.
The response to this Request is sponsored by Zack Thompson, Regulatory
Analyst, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY – 4
REQUEST FOR PRODUCTION NO. 3: Please clarify if the Agreements include
an expiration date. Please describe any other termination options included in the
Agreements.
RESPONSE TO REQUEST FOR PRODUCTION NO. 3: Part 3, Sections 3 and 4
of the February 1979 Agreement, provides that the obligations of the parties under the
Agreement will terminate when Idaho Power Company (“Idaho Power”) ceases to operate
its Lower Malad, Bliss, and AJ Wiley (if constructed) power plants due to lack of regulatory
authority.
Paragraph 1 of the April 1979 Agreement identifies the term of the Agreement as
the date of execution (April 1979) to March 1, 1989. Thereafter, the April 1979 Agreement
is automatically renewed year to year unless the District terminates the Agreement by
providing 12-month notice or the April 1979 Agreement terminates concurrently with the
February 1979 Agreement.
The response to this Request is sponsored by Shelli Stewart, Lead Counsel, Idaho
Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY – 5
DATED at Boise, Idaho, this 10th day of October 2023.

MEGAN GOICOECHEA ALLEN
Attorney for Idaho Power Company

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY – 6
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the 10th day of October 2023, I served a true and
correct Idaho Power Company’s Response to the First 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
Dayn Hardie
Michael Duval
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

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Stacy Gust, Regulatory Administrative
Assistant