20241104Staff 1-5 to IPC - Redacted.pdf

RECEIVED
Monday, November 4, 2024 4:31:17 PM
IDAHO PUBLIC
UTILITIES COMMISSION
ADAM TRIPLETT
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334- 0318
IDAHO BAR NO. 10221
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 ANNUAL COMPLIANCE ) CASE NO. IPC-E-24-40
FILING TO UPDATE THE LOAD AND GAS )
FORECAST IN THE INCREMENTAL COST )
INTEGRATED RESOURCE PLAN AVOIDED ) REDACTED FIRST
COST MODEL ) PRODUCTION REQUEST OF
THE COMMISSION STAFF TO
IDAHO POWER COMPANY
Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Adam Triplett, Deputy Attorney General, requests that Idaho Power Company("Company")
provide the following documents and information as soon as possible, but no later than
MONDAY,NOVEMBER 25, 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 IDAHO POWER COMPANY 1 NOVEMBER 4, 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 3 of the Application, the Company states the major reason
for the increase of September 2024 load forecast is the re-estimation of all customer usage and
growth as well as updates of service agreements and special contracts.
Additionally,
please provide each customer class usage and growth in the two forecasts and support the answer
with evidence.
REQUEST NO. 2: Page 3 of Confidential Attachment 1 of the Application includes
Figure No. 2 below and states that:
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 2 NOVEMBER 4, 2024

REQUEST NO. 3: Please provide the Platts'Henry Hub forecast without the adjustment
for Sumas basis and transport costs for Idaho City Gate delivery, published on September 3,
2024.
REQUEST NO. 4:
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 3 NOVEMBER 4, 2024

REQUEST NO. 5: The purpose of the Peak and Premium Peak Hours Analysis is to
determine when energy storage QFs should be paid for avoided cost of capacity., Please explain
why the Company used a 50°i percentile of load forecast for this purpose, instead of a 70''
percentile of load forecast.
DATED at Boise, Idaho, this 4th day of November 2024.
A"�� C/'
A am Triplett
Deputy Attorney General
I:\Utility\UMISCIPRDREQ\IPC-E-24-40PR#1 Redacted.docx
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 4 NOVEMBER 4, 2024

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS q4fDAY OF NOVEMBER 2024
SERVED THE FOREGOING REDACTED FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY, IN CASE NO. IPC-E-24-40,
BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
MEGAN GOICOECHEA ALLEN
DONOVAN E WALKER
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL:
mgoicoecheaallenOidahopower.com
dwalker c lidahopower.com
dockets ii)idahopower.com
PAT CIA fdRdAN, S 5CRETARY
CERTIFICATE OF SERVICE