20191119Staff 1-3 to IPC.pdf

DA\N HARDIE,
DEPUTY ATTORNEY GENERAL
IDAIIO PUBLIC UTILTIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720.0074
[phone]
IDAHO BAR NO.9917
:I:C E IVED
,il'l i:t'l l9 PH 12: 03
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Street Address lbr Express Mail:
I I33I W CHINDEN BLVD, BLDG 8, SUITE 20I-A
BOISE, ID 83714
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S ANNUAL COMPLIANCE FILING
UPDATING THE LOAI} AND GAS FOIIECASTS
IN THE INCREMENTAL COST INTEGRATED
RESOURCE PLAN AVOIDED COST MODtrL
CASE No. IPC.E.I9.3I
FIRST PRODIJCTION
REQUEST OF THE
COMMISSION STAFF
TO IDAHO POWER COMPANY
The Staffofthe Idaho Public Utilities Commission. by and through its attorney ofrecord,
Dayn Hardie, Deputy Attorney Gencral. rcquests that Idaho Power Company provide the
fbllowing documents and information as soon as possible, but no latcr than TUESDAY,
NOVEMBER 26,2019,1
This Production Request is to be considered as continuing. and Idaho Power Company is
requested to provide, by way of supplementary responses, additional documents that i1, or any
person acting on its behalf, may later obtain that will augmcnt thc documcnts or infonnation
produced.
Pleasc provide answers to each question, supporting workpapcrs that providc dctail or are
the source of information used in calculations, and the name,.iob title and telephone number of
I Staffis requesting an expedited response. Ifresponding by this date will be problematic, please call Staffs
attom€y at (208) 334-03 12.
FIRST PRODUCTION REQUESl'
TO IDAHO POWER
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NoVEMBER I9,20I9I
the person preparing the documents. Please also identily the name, job title, location, and
telephone number ofthe record holder.
In addition to the wdtten copies provided as response to the requests, please provide all
Excel spreadsheets and electronic tlles on CD with formulas intact and cnabled.
REQUEST NO. l: Pages 82 and 83 ofthe Integrated Resource Plan filed on June 28,
2019 in IPC-E-19-19 states that "Idaho Power concluded that Platts' natural gas fbrecast is
appropriate for the planning case forecast in the 2019 IRP. Platts' 201 8 Henry Hub long+erm
forecast, after applying a basis dillerential and transportation costs from Sumas, Washington (he
Iocation from which most ofthe supply is procured to fuel the company's fleet of natural gas
generation in Idaho), served as the planning case forecast oftueling costs fbr existing and
potential new natural gas generation on the Idaho Power system." However, the Company's
Application in this case states that "Idaho Power will update the natural gas price lorecast within
the incremental cost integrated resource plan (ICIRP) avoided cost model to reflect the most
recent EIA Natural Gas Henry Hub Spot Pricc: High Oil and Gas Resource and Technology
fbrecastpublishedonJanuary24,2019;'Pleaseanswerthefollowingquestions:
a. Please explain why the Company has changed the source ofthe natural gas forecast to
the EIA Natural Gas llenry Hub Spot Price: High Oil and Gas Resource and
Technology forecast from the source ofthe forecast filed in thc Junc 28, 2019 IRP.
b. Has the Company determined the forecast and the source to be used in the natural gas
planning cases for its supplemental IRP analysis that will be filed no later than
January 31, 2020?
c. If the Company has changed the source of the IRP fbrecast Ibr its supplemental IRP
analysis, which source and forecast will be used? Please explain the rationale for the
change.
d. Please provide the Platts's Henry Hub Spot Price forccast as well as the Platts's
Henry Hub Spot Price forecast adjusted for the Sumas differential and transportation
costs from 2020 through 2040.
REQUEST NO.2: Stalf underslands that the natural gas lbrecast proposed in this casc
ultimately affects the IRP-method avoided cost. Please explain in detail how this lbrecast is
FIRST PRODUCTION REQUES'I'
TO IDAIIO POWER 2 NOVEMBER 19,2019
utilized in the ICIRP model to ultimately determine an avoided cost. In addition to the
Company's explanation, please answer the following:
A. Staff understands that Aurora uses natural gas forecasts for each hub in the WECC to
establish market electricity prices. Does the forecast in the filing establish the basis for each of
these hub forecasts or does the model use forecasts from some other source? Please explain.
B. Please list all the natural gas hubs used in the ICIRP model and provide the natural
gas forecast for each.
REQUEST NO. 3: The EIA Natural Cas Henry Hub Spot Price: Fligh Oil and Gas
Resource and Teohnology lbrecast in the 2019 Annual Energy Outlook report published on
lanuary 24,2019 does not match the lorecast submitted by the Company in the filing (see Table
I ). Please explain why there is a difference and provide workpapers to reconcile the difference.
Table I : Cornparing EIA's Forccast and IPCO's Forccasl
2019
2020
202L
2022
2023
2024
2025
2026
2027
2028
2029
2030
203t
2032
2033
2034
203s
2036
TIRSI' PRODUCI'tON RI]QUEST.IO IDAHO POWI]R
EIA's Forecast
2.90
2.90
2.81
2.82
2.97
3.19
3.47
3.56
3.79
3.88
3.97
4.05
4.15
4.29
4.45
4.5 6
4.7L
4.83
IPCO's Forecast
3.01
3.07
3.11
3.14
3.18
3.4
3.67
3.86
3.99
4.08
4.L6
4.24
4.33
4.46
4.63
4.74
4.89
5.01
3 NOVEMBER 19.2019
DATED at Boise, Idaho, this 14t4^day ofNovember 201 9.
Hardic
Deputy Attorney General
i:umisc:prodreq/ipcel9.3 !dhyy prod req I
FIRST PRODUCTION REQUEST
TO IDAHO POWER 4 NOVEMBER 19,2019
CERTIFICATE OF SERVICE
DONOVAN WALKER
REGULATORY DOCK!.TS
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E - m a i I : d r,r'al k e r[a-]idahoDorvcr.com
dock idaho .coln
SECRET,,\R
CERTIFICATE OF SERVICE
I HEREBY CI,RTIFY THAT I HAVE THIS 19TH DAY OF NOVEMBER 2019,
SERVED THE FOREGOING FIRST PRODUCTION RXQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY, IN CASE NO.
IPC.E.I9-31, BY MAII,ING A COPY THEREOF. POSTAGE PRI]PAID, TO THE
FOLLOWING:
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