20200407ICIP to IPC 1-6.pdf

Peter J. Richardson ISB # 3195
Greg Adams ISB # 7454
RICHARDSON ADAMS, PLLC
515 N. 27th Street
Boise, Idaho 83702
petcrlrÙrichardsonadams.com
gree@rishff lÐlú¡t¡.q ura
Attorneys for the Industrial Customers of Idaho Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S 2OI 9 INTEGRATED
RESOURCE PLAN
CASE NO. IPC.E.I9-I9
FIRST PRODUCTION REQUEST OF
THE INDUSTRIAL CUSTOMERS OF
IDAHO POWER TO IDAHO POWER
COMPANY
Pursuant to Rule 225 of the Rules of Procedure of the Idaho Public Utilities Commission
(the "Commission"), the Industrial Customers of Idaho Power ("ICIP") by and through their
attorney of record, Peter J. Richardson, hereby requests that Idaho Power Company ("Idaho
Power" or the "Company") provide the following documents.
This production request is to be considered as continuing, and the Company is requested
to provide by way of supplemental responses additional documents that it or any psrson acting
on its behalf may later obtain that will augment the documents produced.
Please provide one physical copy and one electronic copy, if available, of your answer to
Mr. Richardson at the address noted above. Please provide an additional electronic copy, or if
unavailable a physical copy, to Dr. Don Reading at: 6070 Hill Road, Boise, Idaho 83703,
dreadrni¡l¿rmi ndspring.com.
For each item, please indicate the name of the person(s) preparing the answer(s), along
with the job title of such person(s) and the witness at hearing who can sponsor the answer.
First Production Request of the lndustrial Customers of Idaho Power
rPC-E-19-19
Page I
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RECEIVED
2020 April 7,PM2:46
IDAHO PUBLIC
UTILITIES COMMISSION
REQUEST FOR PRODUCTTON NO. 1:
Please provide copies of all of the company's responses to data requests from the IPUC
Staff (or any other party) in this matter. Please include responses to informal as well as formal
requests and oral as well as written requests.
REQUEST FOR PRODUCTION NO. 2:
Idaho Power's 2009 IRP states the Company's proposed Boardman to Hemingway
Transmission line's (B2H) in-service date is June 2016. The Amended (in January 2020) 2019
IRP states the in-service date is ten years later, in 2026. The Action Plan in the Amended IRP
states:
Subject to coordination with PacifiCorp, exit Jim Bridger unit (as yet undesignated) by
December 31,2026. Timing of the exit from the second Jim Bridger unit is tied to the
need for a resource addition (B2H). Source, Idaho Power Amended 2019 IRP at
Summary p. 15.
At an investor presentation in March 2020,Idaho Power stated that its expected "in-service" date
for the B2H line will be *2026 or beyond." Source, Bank of America 2020 Conference, March 3,
2020, Boston, MA at p. A-16.
Do the above statements suggest that if B2H's in-service date is extended beyond 2026,
that Idaho Power's financial involvement with the "undesignated" Jim Bridger Unit will also be
extended. Please explain fully the relationship between the two, if any.
REQUEST FOR PRODUCTTON NO.3:
Idaho Power's 2019 Amended IRP Appendix A (Sales and Load Forecast) states, "Peak-
hour demands are forecast using a system of 12 regression equations, one for each month of the
year. For most monthly models the regressions are estimated using 25 years of historical data,
however, the estimation periods yary." (At page 15). Please provide, in electronic format, the
First Production Request of the Industrial Customers of Idaho Power
IPC-E-19-19
Page 2
l2 regression equations and the 25 years of historical data used as input to the regression
equations.
R-EQUEST FOR PRODUCTION NO.4.
Idaho Power's 2019 Amended IRP Appendix A (Sales and Load Forecast) states
The 2019 irrigation sales forecast model considers several factors affecting electricity
sales to the irrigation class, including temperature; precipitation; spring rainfall; Palmer Z
Index (calculated by the National Ocean and Atmospheric Administration [NOAA] from
a combination of precipitation, temperature, and soil moisture data); Moody's Producer
Price Index: Prices Received by Farmers, All Farm Products; and annual maximum
irrigation customer counts.
Source: Idaho Power Amended 2019 IRP, Appendix A at page 29.
Please provide in, electronic format, a copy of the referenced model and the model data used as
inputs.
REQUEST FOR PRODUCTTON NO. 5:
Idaho Power's 2019 Amended IRP, Executive Summary states the amended analysis
includes the potential benefits associated with the REC sales from the Jackpot Solar PPA. (p. 3.)
Please provide the Jackpot Solar REC revenue stream along with the value of the REC's each
year along with the expected output for the duration of the PPA.
REQUEST FOR PRODUCTION NO.6:
Idaho Power's 2019 Amended IRP, Executive Summary states, in relation to the B2H
transmission revenue credits that, "These credits reflect the estimated incremental transmission
wheeling revenue from non-native load customer as a result of 82H." (p. 3 ) Please provide, on
an annual basis, the transmission revenue credits Idaho Power expects to receive over the
expected life of 82H.
First Production Request of the Industrial Customers of tdaho Power
rPC-E-19-19
Page 3
Please provide, in electronic format, the forecast model data used as input to the model.
Dated this 7th day of April2020.
RICHARDSON ADAMS, PLLC
BY
Peter Richardson, ISB # 3195
Attorneys for the Industrial Customers
of ldaho Power
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 7th of April 2020,a true and correct copy of the within
and foregoing FIRST PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF
IDAHO POWER TO IDAHO POWER in Docket No. IPC-E-19-19 was served, pursuant to
Commission Order No. 34602, exclusively via electronic mail to:
Idaho Public Utilities Commission
Diane Hanian, Secretary
D iane. hanianldlpLrc. idaho. go v
Edward. i ewe ll(Ðpuc. idaho. sov
Idaho Power Company
lnordstromlDi dahopower.com
@
m lark in tØ; i clahopower. co m
IdaHydro
C. Tom Arkoosh
Tom.arkoosh@)arkoosh. com
Erin.cecil sh.conr
Micron Technology, Inc.
Thorvald Nelson
tne i sonlrD,ho I I andh art. co ni
Austin Rueschhoff
darueschho lf r,rÐ ho I Iandhart.com
aç l.c çú=ùh o I I ardha$. celt
Jim Swier
rs-ruçr@!ût9ra0.ç-oJ11
First Production Request of the Industrial Customers of Idaho Power
IPC-E-19-19
Page 4
Sierra Club
Julian Aris
.l ul ian. anli?sierrac I uþ " org
Ana Boyd
AUa.hg;ad@ð1qllê c h"r b . o r g
Gloria D. Smith
G loria. sm ith(@,tierrac I ub. org
Stop B@H
Jack VanValkenburg
iack(avanvalkenbursh.com
Jim Kreider
iim@,stopb2h.org
Idaho Conservation League
@
[¿,q.By:
Peter Richardson,
Attomey for the Industrial Customers of ldaho Power
First Production Request of the Industrial Customers of Idaho Power
IPC-E-19-19
Page 5