20210602Staff 13-17 to IPC.pdf

MATT HLINTER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 10655
SECOND PRODUCTION REQUEST
TO IDAHO POWER
Street Address for Express Mail:
1I331 W CHINDEN BVLD, BLDG 8, SUITE 2OI-A
BOISE, ID 837I4
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR APPROVAL
OF THE CAPACITY DEFICIENCY TO BE
UTILIZED FOR AVOIDED COST
CALCULATIONS
CASE NO. IPC-8.21-09
SECOND PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
IDAHO POWER COMPANY
The Staff of the Idaho Public Utilities Commission requests that Idaho Power Company
(ldaho Power; Company) provide the following documents and information as soon as possible,
by WEDNESDAY, JUNE 16,2021.t
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 preparing the document, and the name, location and phone number of the record holder
I Stuff it requesting an expedited response. If responding by this date will be problematic, please call Staff s
attorney at (208) 334-03 I 8.
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I JUNE 2,2021
and if different the witness who can sponsor the answer at hearing if need be. Reference IDAPA
31.01.01.228.
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. 13: Page 3 of Mr. Ellsworth Direct Testimony in Case No.
IPC-E-21-12 states that Valmy Unit 2 is 134 MW. Attachment 1 of the Application in Case No.
IPC-E-21-09 states that Valmy Unit 2 is 136 MW. Table LI (Prefened Portfolio additions and
coal exits) shows that Valmy Unit 2 is 133 MW. Please reconcile the three amounts and provide
the correct capacity amount.
REQUEST NO. 14: The Preferred Portfolio in the Second Amended 2019 IRP shows
the total capacity of the Bridger units is 708 MW, whereas the Load and Resource Balance in
this case shows the total capacity is 703 MW. Please reconcile the two amounts and provide the
correct amount.
REQUEST NO. 15: According to Response to Staff s Production Request No. 5, exit
from each North Valmy coal plant was assumed to make available approximately 130 MW of
transmission capacity for purchases from Southwest markets. The assumption from the Second
Amended 2019 IRP was that generation from North Valmy could be replaced by market
purchases from Southern market hubs. As stated on page I 8 of the 2nd Amended 201 9 IRP,
(under the Valmy Unit 2 Exit Date section) and on pages 77-78 (under the Nevada Transmission
without North Valmy section), these assumptions require future testing. Please answer the
following questions:
a. It is assumed that the statement from the Amended2019IRP, as stated above, applies
regardless of whether Valmy Unit#2 exits in 2022 or 2025. Please verifu whether
this is the case.
b. Does the assumption about the 130 MW increase in market purchases still currently
apply after 2025 based on the latest available information? Please explain.
SECOND PRODUCTION REQUEST
TO IDAHO POWER 2 JUNE 2,2021
c. If the assumption does not still apply, please provide an update to the market
purchase amounts in the same format as provided in response to Production Request
No.9.
REQUEST NO. 16: Please provide the load forecast that was included in the
Application in the same annual format as the updated forecast provided in response to Production
Request No. 1l and the change in the first deficit date due to the update in the load forecast.
REQUEST NO. 17: Please provide the Load and Resource Balance in Excel format and
the deficit dates for the following scenarios:
a. Hold all assumptions the same as filed in the original Application but with updates for
capacity amounts included in Production Request Nos. 7, l3 and 14.
b. Hold all assumptions the same as filed in the original Application, with updates for
capacity amounts included in Production Request Nos. 7, 13 and 14, and market
purchases from Production Request No. l5c (if assumption have changed).
c. Hold all assumptions the same as filed in the original Application, with updates for
capacity amounts included in Production Request Nos. 7, 13 and 14, and with the latest
load forecast as provided in response to Production Request No. I 1.
d. Hold all assumptions the same as filed in the original Application, with updates for
capacity amounts included in Production Request Nos. 7, 13 and 14, market purchases
from Production Request No. l5c (if assumption have changed), and the latest load
forecast as provided in response to Production Request No. 1 1.
DATED at Boise,Idaho, this y day of June 2021
Matt Hunter
i:umisc:prodreq/ipce2 l.9mhyy prod req2
SECOND PRODUCTION REQUEST
TO IDAHO POWER J
Deputy Attorney General
JUNE 2,2021
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 2Nd DAY OF JUNE 2021, SERVED
THE FOREGOING SECOND PRODUCTION REQUEST OF THE COMMISSION
STAFF TO IDAHO POWER COMPAI{Y, IN CASE NO. IPC.E.2I.Og, BY E.MAILING
A COPY THEREOF, TO THE FOLLOWING:
DONOVAN E WALKER
IDAHO POWER COMPANY
PO BOX 70
BOrSE rD 83707-0070
E-MAIL: [e-mail]
dockets@idahopower. com
MICHAEL DARRINGTON
ENERGY CONTRACTS
P.O. BOX 70
BOISE, LDAHO 83707
E-MAIL: [e-mail]
energy contracts@ idahopower. com
i./l/*,^"YSECRET
CERTIFICATE OF SERVICE