20241031Staff 1-5 to PAC.pdf

RECEIVED
Thursday, October 31, 2024 1:04:23 PM
IDAHO PUBLIC
UTILITIES COMMISSION
MICHAEL DUVAL
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 THE APPLICATION OF )
ROCKY MOUNTAIN POWER TO UPDATE ) CASE NO. PAC-E-24-12
LOAD AND GAS FORECASTS USED IN THE )
INTEGRATED RESOURCE PLAN AVOIDED )
COST MODEL ) FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO ROCKY MOUNTAIN
POWER
Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Michael Duval, Deputy Attorney General, requests that Rocky Mountain Power, a division of
PacifiCorp, ("Company")provide the following documents and information as soon as possible,
but no later than THURSDAY,NOVEMBER 21, 2024.
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 ROCKY MOUNTAIN POWER 1 OCTOBER 31, 2024

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: On Page 2 of the Application, the Company states that the change
between the June 2024 load forecast and the May 2023 load forecast is "primarily due to growth
expectations for industrial and commercial customers in Utah and Oregon." Please explain why
the change starts after 2030, as shown in Figure No. 1. Additionally, given the fact that the May
2023 load forecast already considered the commercial and industrial customers' increase as
noted in the previous case (Case No. PAC-E-23-20), please explain why the June 2024 load
forecast has a higher load than the May 2023 load forecast "primarily due to growth expectations
for industrial and commercial customers in Utah and Oregon."Application at 2.
100,000
80,000 -0-0-o- - -o-'o-Q-
L
C7
� 60,000
m
u
N
O
40,000
c�a -Load Forecast-June 2024
0
J 20,000 --0--Load Forecast-May 2023
0
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
N N N N N N N N N N N N N N N N N N N N
Figure No. 1: System Load Forecast Comparison
REQUEST NO. 2: Please explain why the 2024 load forecast for Idaho is consistently
lower than the 2023 load forecast for Idaho throughout the entire forecast period from 2024
through 2043, as shown in Figure No. 2.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 OCTOBER 31, 2024

4,000
3,900 a
r �o a_o
3,800 a-o-o-a-o-o-o
v
0
LL 3,700
m
0
J f Load Forecast-June 2024 i n Idaho
3,600
--0--Load Forecast-May 2023 in Idaho
3,500
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
N N N N N N N N N N N N N N N N N N N N
Figure No.2: Comparison of Load Forecast in Idaho
REQUEST NO. 3: Please explain why the"Load Forecast—June 2024"in the Figure
No. 3 is lower than the"Draft 2025 IRP Load Forecast"presented in the 2025 Integrated
Resource Plan("IRP") Public Input Meeting on June 26-27, 2024, as shown in Figure No. 3.
Load Forecast
120,000
100,000 -
80,000 y
60,000
3
u
40,000
20,000
0
2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 2038 2039 2040 2041 2042 2043 2044
--*--Load Forecast-June 2024
fDratt 2025 IRP load Forecast t20231RP Update t2023IRP
Figure No. 3: Comparison of Load Forecast between June 2024 Forecast to 2025 IRP Load
Forecast(draft)
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 3 OCTOBER 31, 2024

REQUEST NO. 4: Please explain why the 2024 gas forecast for Henry Hub proposed in
this case is lower than the 2023 gas forecast approved in Case No. PAC-E-23-20 in the near
term, as shown below. Also, please explain why the 2024 gas forecast proposed in this case is
approximately the same as the 2023 gas forecast starting in 2029.
Gas Forecast for Henry Hub
10
9
8
7
6
S
4
3
2
1
0
�� tiro �A �1 ti� ,�O �N ";V 1'5 3R �� 30 :,5�
,ti0 ,ti0 �0 ,ti0 <ti0 -6) ,LO O ,ti0 ,ti0 ,ti0 .IO 4) ,55 45 ,ti0 'ti0 ti0 ti0
2024 Gas Forecast for Henry Hub 2023 Gas Forecast for Henry Hub
REQUEST NO. 5: Please explain whether monthly Official Forward Price Curve
("OFPC") is used in the IRP model to determine IRP-based avoided cost rates. If hourly OFPC
is used, please explain how monthly OFPC is converted to hourly OFPC.
DATED at Boise, Idaho, this 31 st day of October 2024.
-��4 11�-�- c;0< --
Michael Duval
Deputy Attorney General
L•\Utility\UMISC\PRDREQ\PAC-E-24-12 PR#Ldocx
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 4 OCTOBER 31, 2024

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS AY OF OCTOBER 2024,
SERVED THE FOREGOING FIRST PRODUCTION EQUEST OF THE
COMMISSION STAFF TO ROCKY MOUNTAIN POWER, IN CASE NO. PAC-E-24-
12, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
MARK ALDER JOE DALLAS
ROCKY MOUNTAIN POWER ROCKY MOUNTAIN POWER
1407 WEST NORTH TEMPLE STE 330 825 NE MULTNOMAH ST
SALT LAKE CITY UT 84116 STE 2000
E-MAIL: mark.alder(cpacificoKp.com PORTLAND OR 97232
E-MAIL: Jose 2h.dallas(&pacificorp.com
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
datarequestgpacificorp.com
� �
PATRICIA JORDAN, SE RETARY
CERTIFICATE OF SERVICE