20200427IPC to ICIP 1-6.pdf

LISA D. NORDSTROM
Lead Counsel
[e-mail]

April 27, 2020

VIA ELECTRONIC FILING

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

Re: Case No. IPC-E-19-19
2019 Integrated Resource Plan – Idaho Power Company’s Response to the
First Production Request of the Industrial Customers of Idaho Power

Dear Ms. Hanian:

Attached for electronic filing in the above matter is Idaho Power Company’s
Response to the First Production Request of the Industrial Customers of Idaho Power.
Please handle the confidential information in accordance with the Protective Agreement
executed in this matter.

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

Very truly yours,

Lisa D. Nordstrom

LDN:kkt
Enclosures
RECEIVED
2020 April 27,PM3:39
IDAHO PUBLIC
UTILITIES COMMISSION
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER COMPANY - 1
LISA D. NORDSTROM (ISB No. 5733)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
[e-mail]

Attorney for Idaho Power Company

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF IDAHO POWER
COMPANY’S 2019 INTEGRATED
RESOURCE PLAN

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CASE NO. IPC-E-19-19

IDAHO POWER COMPANY’S
RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
THE INDUSTRIAL CUSTOMERS
OF IDAHO POWER COMPANY

COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), and in
response to the First Production Request of the Industrial Customers of Idaho Power
Company dated April 7, 2020, herewith submits the following information:

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER COMPANY - 2
REQUEST 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.
RESPONSE TO REQUEST NO. 1: To date, Idaho Power has provided only
responses that were served on the Industrial Customers of Idaho Power at the time of
filing.
The response to this Request is sponsored by Kimberly Towell, Regulatory
Affairs Executive Assistant, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER COMPANY - 3
REQUEST 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.
RESPONSE TO REQUEST NO. 2: The statements do not suggest an extension
of the timing of the Jim Bridger unit exit. Rather, the Integrated Resource Plan (“IRP”)
Action Plan statement indicates the need for a resource, in general, in 2026 and the
need for a resource is accelerated with the exit of a second Jim Bridger unit. The 2019
IRP analysis indicates that B2H is the least-cost resource to meet projected future
needs. If B2H were not available as a resource option in 2026, Idaho Power would re-
evaluate resource options.
The response to this Request is sponsored by Mitch Colburn, Engineering &
Construction Director, Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER COMPANY - 4
REQUEST 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 vary." (At page 15). Please provide, in electronic format, the 12 regression
equations and the 25 years of historical data used as input to the regression equations.
RESPONSE TO REQUEST NO. 3: Please refer to the attachment
accompanying this response for the 12 model designs, historic data used, and model
statistics used for peak forecasting for the months of January through December.
The response to this Request is sponsored by Jordan Prassinos, Manager Load
Forecasting and Research, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER COMPANY - 5
REQUEST 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.
RESPONSE TO REQUEST NO. 4: Please refer to the attachment
accompanying this response for the irrigation sales forecasting model referenced
above.
The response to this Request is sponsored by Jordan Prassinos, Manager Load
Forecasting and Research, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER COMPANY - 6
REQUEST 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.
RESPONSE TO REQUEST NO. 5: The attachment accompanying this
response contains the Renewable Energy Credit (“REC”) price forecast by year (dollars
per megawatt-hour), the estimated annual generation for the Jackpot Solar project
(megawatt-hour), and the estimated REC revenue stream from the Jackpot Solar
project.
The response to this Request is sponsored by Jared Hansen, Resource Planning
Leader, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER COMPANY - 7
REQUEST 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 B2H." (p. 3) Please provide, on an annual basis, the
transmission revenue credits Idaho Power expects to receive over the expected life of
B2H.
Please provide, in electronic format, the forecast model data used as input to the
model.
RESPONSE TO REQUEST NO. 6: The forecast of transmission revenue credits
can be found in the confidential attachment accompanying this response. The
confidential attachment will be provided to those parties that have executed the
Protective Agreement in this matter.
The response to this Request is sponsored by Jared Hansen, Resource Planning
Leader, Idaho Power Company.
DATED at Boise, Idaho, this 27th day of April 2020.

LISA D. NORDSTROM
Attorney for Idaho Power Company
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER COMPANY - 8
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on this 27th day of April 2020 I served a true and
correct copy of IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER
COMPANY upon the following named parties by the method indicated below, and
addressed to the following:

Commission Staff
Edward Jewell
Deputy Attorney General
Idaho Public Utilities Commission
11331 W. Chinden Boulevard
Building 8, Suite 201-A
Boise, Idaho 83714

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IdaHydro
C. Tom Arkoosh
ARKOOSH LAW OFFICES
802 West Bannock Street, Suite LP 103
P.O. Box 2900
Boise, Idaho 83701

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Idaho Conservation League
Benjamin J. Otto
Idaho Conservation League
710 North 6th Street
Boise, Idaho 83702

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STOP B2H Coalition
Jack Van Valkenburgh
Van Valkenburg Law, PLLC
P.O. Box 531
Boise, Idaho 83701

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Jim Kreider
60366 Marvin Road
La Grande, Oregon 97850
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Idaho Sierra Club
Julian Aris, Associate Attorney
2101 Webster Street, Suite 1300
Oakland, California 94612

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IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER COMPANY - 9
Gloria D. Smith, Managing Attorney
2101 Webster Street, Suite 1300
Oakland, California 94612
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Ana Boyd, Research Analyst
2101 Webster Street, Suite 1300
Oakland, California 94612
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Industrial Customers of Idaho Power
Peter J. Richardson
RICHARDSON ADAMS, PLLC
515 North 27th Street (83702)
P.O. Box 7218
Boise, Idaho 83707

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Dr. Don Reading
6070 Hill Road
Boise, Idaho 83703
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Micron Technology, Inc.
Austin Rueschhoff
Thorvald A. Nelson
Holland & Hart, LLP
555 Seventeenth Street, Suite 3200
Denver, Colorado 80202

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Jim Swier
Micron Technology, Inc.
8000 South Federal Way
Boise, Idaho 83707
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Kimberly Towell, Executive Assistant