20201029Staff 1-5 to IPC.pdf

EDWARD JEWELL
DEPUTY ATTORNEYS GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-007 4
[phone]
IDAHO BAR NO. T0446
IN THE MATTER OF IDAHO POWER
COMPANY'S ANNUAL COMPLIANCE
FILING TO UPDATE THE LOAD AND GAS
FORECASTS IN THE INCREMENTAL COST
INTEGRATED RESOURCE PLAN AVOIDED
COST MODEL
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Street Address for Express Mail:
11331 W CHINDEN BVLD, BLDG 8, SUITE 2OI-A
BOISE, D 837 T4
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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CASE NO.IPC.E.2O.35
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
IDAHO POWER COMPANY
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Edward Jewell, Deputy Attorney General, request that Idaho Power Company (Company) provide
the following documents and information as soon as possible, or by FRIDAY,
NOVEMBER 13, 2020.r
This Production Request is continuing, and the Company is requested to provide, by way of
supplementary responses, additional documents that it or any person acting on its behalf may later
obtain that will augment the documents produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations. The Company is reminded that responses pursuant
to Commission Rules of Procedure must include the name and phone number of the person
I Staffis requesting an expedited response. Ifresponding by this date will be problematic, please call Staff's attorney at
(208) 334-03t4.
FIRST PRODUCTION REQUEST
TO IDAHO POWER ocroBER 29,20201
preparing the document, and the name, location and phone number of the record holder and if
different the witness who can sponsor the answer at hearing if need be. Reference IDAPA
3t.01.0t.228.
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. 1: Please provide the date when the Company's average annual load
forecast data used in the Second Amended 2019Integrated Resource Plan in IPC-E-19-19 was
developed.
REQUEST NO.2: Please provide the Company's average annual load forecast data
used in the Second Amended 2019 Integrated Resource Plan in IPC-E-19-19 in the same format
as Table 1 in Annual Compliance Filing in IPC-E-20-35.
REQUEST NO.3: Please provide all changes that the Company has made to the average
annual load forecast, if any, from the one used in the Second Amended 2019 Integrated Resource
Plan in IPC-E-19-19 to the one filed in IPC-E-20-35 and explain why such changes were made.
REQUEST NO. 4: Page No. 8 of 2019 IRP Review Report: Process and Findings states
that the Company uses three natural gas price forecasts in the IRP: Platts' Henry Hub natural gas
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 2019lntegrated Resource
Plan.
REQUEST NO.5: Please identify factors that make it difficult to submit these update
filings earlier to allow processing prior to an October 15 effective date.
FIRST PRODUCTION REQUEST
TO IDAHO POWER ocroBER 29,20202
DATED at Boise,Idatro, this 29th day of October 2020
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Edward l. fery$tt
Deputy Attorney General
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FIRST PRODUCTION REQUEST
TO IDAHO POWER 3 ocToBER 29,2020
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 29TH DAY OF OCTOBER 2020,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION
STAFF TO IDAHO POWER COMPANY IN CASE NO. IPC-E-20-35, BY E-MAILING
A COPY TI{EREOF, TO THE FOLLOWING:
DONOVAN E WALKER
IDAHO POWER COMPANY
PO BOX 70
BOrSE rD 83707-0070
E-MAIL: [e-mail]
dockets @ idahopower.com
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SECRETAY/
CERTIFICATE OF SERVICE