20210615Staff 18-23 to IPC.pdf

MATT HUNTER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-007 4
[phone]
IDAHO BAR NO. 10655
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Street Address for Express Mail:
I133I W CHINDEN BVLD, BLDG 8, SUITE 2OI-A
BOISE, ID 83714
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-E-2I-09
THIRD PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
IDAHO POWER COMPANY
The Staff of the Idaho Public Utilities Commission requests that Idaho Power Company
(Idaho Power; Company) provide the following documents and information as soon as possible,
by TUESDAY, JUNE 22,2021.1
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 Stafls
attorney at (208) 334-03 I 8.
THIRD PRODUCTION REQUEST
TO IDAHO POWER
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JUNE I5,2O2I
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. 18: Should the load and resource balance ("L&R") and the capacity
deficiency date filed in Case No. IPC-E-21-09 be updated to include the following items? In the
Company's response, please explain why the deficit date should or should not change by
considering each item below:
a. The growth in peak loads referenced in the Company's Notice of Intent ("NOI")
driving the issuance of 2021All-Source Request for Proposals ("RFP";.
b. The constraints of the transmission system external to the IPC service territory also
referenced in the Company's NOI.
REQUEST NO. 19: Are there any transmission or firm energy contracts recently signed
and not specifically included in the Company's filed L&R or in the L&R provided in response to
Staff Production Request No. I 7? If so, are these contracts incremental to the amount of Market
Purchases in the L&Rs or are these contracts considered already included in Market Purchases?
REQUEST NO. 20: Please identifu the amount of peak capacity that the Company
needs to acquire through the RFP broken down by the following:
a. Load Growth
b. Lack of external firm transmission capacity
c. Early exit date of Valmy Unit#2
REQUEST NO. 21: Is the amount of peak capacity to be acquired through the RFP for
purposes of resolving the lack of external firm transmission capacity incremental to the amount
of Market Purchases in the L&R or is it considered already included in Market Purchases?
THIRD PRODUCTION REQUEST
TO IDAHO POWER 2 JUNE 15,2021
REQUEST NO.22: Does the Company's peak load forecast used in the Company's
filing and included in response to StaffProduction Request Nos. l1 and 17 include the load
growth referenced in the NOI? Please explain.
REQUEST NO. 23: Please answer the following:
a. Does the Company consider the fundamentals driving the load growth discussed in
the NOI permanent or temporary? Please explain.
b. Does the Company consider the fundarnentals driving constraints in the transmission
market as discussed in the NOI to be permanent or temporary? Please explain.
c. Given the temporary or permanent nature of these two drivers, how would the
existence of a new QF avoid capacity cost for the Company.
friDATED at Boise, Idatro, this lS day ofJune 2021.
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Matt Hunter
Deputy Attorney General
i:umisc:prodreq/ipce2l.9mhyy prod req3
THIRD PRODUCTION REQUEST
TO IDAHO POWER J JUNE I5,2O2I
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 15TH DAY OF JUNE 2021, SERVED
THE FOREGOING THIRD PRODUCTION REQUEST OF TIIE COMMISSION STAFF
TO IDAHO POWER COMPAI\IY, IN CASE NO. IPC-E-21-09, BY E-MAILING A
COPY THEREOF, TO THE FOLLOWING:
DONOVAN E WALKER
IDAHO POWER COMPANY
PO BOX 70
BOrSE ID 83707-0070
E-MAIL : [e-mail]
[e-mail]
MICHAEL DARRINGTON
ENERGY CONTRACTS
P.O. BOX 70
BOISE, LDAHO 83707
E-MAIL: [e-mail]
enerey contracts@idahopower. com
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SECRETry
CERTIFICATE OF SERVICE