20201207Sierra Club to IPC 1-6.pdf

Benjamin J. Otto (ISB No. 8292) 710 N 6th Street Boise, ID 83701 Ph: [phone] x 12
Fax: [phone]
[e-mail]
Attorney for the Idaho Conservation League Local Council for the Sierra Club
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
POWER COMPANY’S 2019 INTEGRATED RESOURCE PLAN. ) ) ) SIERRA CLUB’S FIRST PRODUCTION REQUEST TO IDAHO
Idaho Conservation League and Sierra Club (“Requesters”) hereby serves this request for
production regarding the above docket on Idaho Power’s counsel only.
INSTRUCTIONS
1. Please provide copies of responses to the following contacts:
PO Box 844, Boise, ID 83701
[e-mail]
Michael Heckler Sierra Club Idaho Chapter
503 W Franklin Street
Boise, Idaho 83702
2. Whenever possible, Requesters prefers to receive electronic copies of data responses
either by email or on CD.
3. Responses to any and all of Requesters’ requests for production should be supplied toRequesters as soon as they become available to Idaho Power.
4. The requests herein shall be deemed to be continuing in nature and Idaho Power isrequested to supplement its responses as necessary and as additional information
becomes available.
RECEIVED
Monday, December 7, 2020 11:53:23 AM
IDAHO PUBLIC
UTILITIES COMMISSION
5. In responding to each data request, please consult every document source which is in
your possession, custody, or control, including all documents in the possession of experts
or consultants.
6. For each response, identify the person who prepared the answer to the data request as well as his or her position with Idaho Power or any Idaho Power affiliate or parent.
7. Please reproduce the data request being responded to before the response.
8. If the responses include computer modeling input and output files, please provide those
data files in electronic machine readable or txt format.
9. If the responses include spreadsheet files, please provide those spreadsheet files in useable electronic Excel readable format.
10. In responses providing computer files, list the file names with cross-reference to the data
request, and if necessary to the understanding of the data, provide a record layout of the computer files. Computer files provided with a response must be in or compatible with the current version, or the immediately prior version, of Microsoft Office.
11. For each dollar amount provided in response to a discovery request please state if the amount is in nominal or constant dollars and what years dollars.

1. For each generator or resource addition or subtraction represented in the Aurora capacity expansion model (including both IPC and any non-IPC resources represented) under the Preferred Portfolio, please identify the following characteristics: a. Generation technology
b. Fuel type
c. Maximum rated capacity d. Year added for resource additions e. Year removed for resource subtractions f. Zone or node
g. If the resource is part of IPC's resource portfolio, or assumed to be owned by
another entity h. If the resource was added or removed endogenously by Aurora, or manually by IPC
2. For the years 2019 through 2038 under the preferred portfolio, please provide, in MWh
per year or at the finest level of granularity available: a. IPC retail sales b. IPC firm wholesale sales c. IPC market sales (exclusive of a-b, above)
d. Any other energy sales not included in a-c, above
e. Spot market purchases f. Purchases from PURPA suppliers g. Purchases from other power purchase agreements h. Generation from each IPC-owned generating unit, identifying the unit, generating
technology, and fuel
i. Any other generation or energy acquisition not included in e-h, above 3. Page 53 of the Second Amended 2019 IRP states “Multiple CCCT plants, like Idaho Power’s Langley Gulch project, are planned in the region”. Please list all such plants
IPC believes are planned in the “OWI – Oregon, Washington, northern Idaho” zone and
used in the Aurora capacity expansion modeling. 4. Please provide a map showing the geographic coverage of the North Idaho, South Idaho and IPC areas used in defining zones within the Aurora capacity expansion model.

5. Please provide the resource adequacy study that demonstrates IPC peak hour reserve requirements. 6. Please provide evidence, based on the same resource adequacy study identified in
response to question 6 or otherwise, that Valmy unit 2 capacity will be needed during the
2023 through 2025 period.

CERTIFICATE OF SERVICE
I hereby certify that on this 7th day of December 2020, I delivered true and correct copies of the foregoing SIERRA CLUB’S FIRST PRODUCTION REQUEST TO IDAHO POWER CLUB to the following persons via the method of service noted:
____/s/ Benjamin Otto_______
Idaho Conservation League Electronic Mail only (See Order 34602): Idaho Public Utilities Commission
Jan Noriyuki, Commission Secretary [e-mail] Edward Jewell, Deputy Attorney General Idaho Public Utilities Commission
[e-mail]
Idaho Power Lisa D. Nordstrom Matthew Larkin
[e-mail] [e-mail] [e-mail] Idahydro
C. Tom Arkoosh, Arkoosh Law Office [e-mail] [e-mail] Industrial Customers of Idaho Power
Peter J. Richardson
Richardson, Adams, PLLC [e-mail] Dr. Don Reading
[e-mail]

Stop B2H Coalition Jack Van Valkenburgh Van Valkenburg Law, PLLC
[e-mail]
Jim Krieder, STOP B2H Coalition [e-mail]