20201113IPC to Staff 1-5.pdf

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DONOVAN E. WALKER
Lead Counsel
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November 13,2020
VIA ELECTRONIC FILING
Jan Noriyuki, Secretary
11331 W. Chinden Boulevard
Building 8, Suite 201-A
Boise, ldaho 83714
Re: Case No. IPC-E-20-35
ldaho Power Company's Annual Compliance Filing to Update the Load and
Gas Forecast Components of the lncremental Cost lntegrated Resource
Plan Avoided Cost Methodology
Dear Ms.Noriyuki:
Attached for electronic filing is ldaho Power Company's Response to the
Commission Staffs First Production Request. lf you have any questions about the
attached documents, please do not hesitate to contact me.
Very truly yours,
Donovan E. Walker
DEWcd
cc: Edward Jewell, Commission Staff
Enclosures
DONOVAN E. WALKER (!SB No. 5921)
ldaho Power Company
1221West Idaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]'t7
Facsimile: [phone]
dwa lker@ idahopower.com
Attorney for ldaho Power ComPanY
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IDAHO POWER COMPANY'S ANNUAL
COMPLIANCE FILING TO UPDATE THE
LOAD AND GAS FORECASTS IN THE
I NCREMENTAL COST INTEGRATED
RESOURCE PLAN AVOIDED COST
MODEL.
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CASE NO. ]PC-E-20-35
IDAHO POWER COMPANY'S
RESPONSE TO THE COMMISSION
STAFF'S FIRST PRODUCTION
REQUEST
coMES NOW, ldaho Power company ("ldaho Powe/' or "company"), and in
response to the First Production Request of the Commission Staff to ldaho Power
Company dated October 29,2020, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE COMMISSION
STAFF'S FIRST PRODUCTION REQUEST - 1
REQUEST No. 1: Please provide the date when the company's average
annual load forecast data used in the Second Amended 2019 lntegrated Resource plan
in IPC-E-19-19 was developed.
RESPONSE TO REQUEST NO. 1: The load forecast used in the Second
Amended 2019 lntegrated Resource Plan ('lRP') in IPC-E-1g-19 was developed in
October 2018 and presented to the lntegrated Resource PIan Advisory Council
("|RPAC") on October 11,2018.
The response to this Request is sponsored by Michael Danington, Energy
Contracts Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE COMM]SSION
STAFF'S FIRST PRODUCTION REQUEST - 2
REQU NO. 2:Please provide the Company's average annual load forecast
data used in the Second Amended 2019 lntegrated Resource Plan in IPC-E-19-19 in
the same format as Table 1 in Annual Compliance Filing in IPC-E-20-35'
RESPONSE TO REQUEST NO. 2: The requested load forecast information for
Case No. IPC-E-19-19 is presented below. This same load forecast information was
provided in Case No. IPC-E-18-13, the October 15,2018, update to the load and gas
forecasts used in the lncremental Cost lntegrated Resource Plan Avoided Cost
Methodology.
Year
2018
2019
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
2036
October 2018 Load
Forecast (aMW)
1,805
1,833
1,849
1,876
1,899
1,923
1,946
1,972
1,990
2,008
2,022
2,048
2,066
2,084
2,096
2,117
2,134
2,154
2,168
The response to this Request is sponsored by Michael Darrington, Energy
Contracts Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE COMMISSION
STAFF'S FIRST PRODUCTION REQUEST - 3
REQUEST NO. 3: Please provide any changes that the Company has made to
average annual load forecast, if any, from the one used in the Second Amended 201g
lntegrated Resource Plan in IPC-E-19-19 to the one filed in IPC-E-20-35 and explain
why such changes were made.
RESPONSE TO REQUEST NO.3: ldaho Power's load forecast used in the
Second Amended 2019 lntegrated Resource Plan in Case No. IPC-E-1g-1g was
developed in October 2018, as noted in the Company's Response to Request No. 1,
and the forecast filed in Case No.lPC-E-20-35 was developed in October 2020. As
described in ldaho Power's October 11,2018, presentation to the IRPAC, numerous
factors may contribute to changes in the Company's load forecast.
As more relevant and current data was available, the load forecast was updated
from Case No. IPC-E-19-19 relevant to Case No. IPC-E-20-35 for factors inctuding, but
not limited to, changes in population growth rates, customer usage pattems, energy
efficiency, and temperatures. ldaho Power forecasts are prepared using relevant
demographic and economic factors, and account for various economic fluctuations to
provide a reliable forecast.
The Company has not revised the Second Amended IRP load forecast inputs
from the October 2018 data to ensure the same basis for comparison to earlier versions
of the 2019 IRP in Case No. IPC-E-19-19.
The response to this Request is sponsored by Michael Darrington, Energy
Contracts Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE COMMISSION
STAFF'S FIRST PRODUCTION REQUEST . 4
REQUEST NO. 4: Page No. 8 of 2019 IRP Review Report: Process and
Findings states that the Company uses three natura! gas price forecast in the IRP:
Platts' Henry Hub naturalgas price forecast, the EIA Henry Hub Low Oil and Gas
forecast, and EIA's Henry Hub Reference Mid natural gas price forecast. Please
confirm that the EIA Natural Gas Henry Hub Spot Price: High Oil and Gas Resource
and Technology is not used in the Second Amended 2019 lntegrated Resource Plan.
RESPONSE TO REQUEST NO. 4: As stated on page 106 of the second
Amended 2019 lntegrated Resource Plan, "ldaho Power used the adjusted Platts 2018
Henry Hub natural gas price forecast as the planning case forecast in the 2019 IRP'
ldaho Power also developed portfolios under the two additional gas price forecasts: 1)
the 2018 EIA Reference Case and 2) the 2018 EIA Low Oiland Gas (LOG) case." The
EIA Natural Gas Henry Hub Spot Price: High Oil and Gas Resource and Technology is
not used in the Second Amended 2019 lRP.
The response to this Request is sponsored by Michael Danington, Energy
Contracts Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE COMMISSION
STAFF'S FIRST PRODUCTION REQUEST - 5
REQUEST NO. 5: Please identify factors that make it difficult to submit these
update filings earlier to allow processing prior to an October 1S effective date.
RESPONSE TO REQUEST NO. 5: The October 15 update to the gas and load
forecast utilized in the ICIRP methodology was originally directed in the final order from
Case No. GNR-E-11-03 to be made at the same time as the June 1 update to the SAR
model. However, upon ldaho Power's Petition for Clarification and/or Reconsideration
of Order No. 32697, the Commission directed that, "updates to each utility's natural gas
price forecast used in the SAR methodology shall be based on the EIA gas forecast and
shall occur annually on June 1 or within 30 days of the final release of the EIA Annual
Energy Outlook, whichever is later. Further, updates to gas and load forecasts used in
the lRP methodologies shall occur annually on October 15." Order No. 32802, page 3.
ldaho Power requested that the update to the load and gas forecasts for the
ICIRP methodology be moved to October 15 because ldaho Power does not have a
completed, final, and approved load forecast prior to October each year. That remains
the case today.
The response to this Request is sponsored by Michael Darrington, Energy
Contracts Leader of ldaho Power Company.
Respectfully submitted this 13th day of November 2O2O
Mrilarq
DONOVAN E. WALKER
Aftorney for ldaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE COMMISSION
STAFF'S FIRST PRODUCTION REQUEST . 6
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 13th day of November 20201 served a true and
correct copy of IDAHO POWER COMPANY',S RESPONSE TO THE COMMISSION
sTAFF,S rlnsr pRoDUcTloN REQUEST upon the following named parties by the
method indicated below, and addressed to the following:
Gommission Staff
Edward Jewell
Deputy Attorney General
ldaho Public Utilities Commission
1 1331 W. Chinden Boulevard
Building 8, Suite 201'A
Boise, ldaho 83714
_Hand Delivered
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Mail
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Christy Davenport, Legal Assistant
IDAHO POWER COMPANY'S RESPONSE TO THE COMMISSION
STAFF'S FIRST PRODUCTION REQUEST - 7