20210622Staff 24-26 to IPC.pdf

--: i:* l-)
i,:-..i:i,::a:,.J
- : --^-.. .-.:r..-_../a.i,r' .1 -E:,:::Ll'=l .L'li
MATT HUNTER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. I0655
Street Address for Express Mail:
I I33 I W CHINDEN BVLD, BLDG 8, SUITE 20 I -A
BOISE, ID 837T4
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
UTTLIZED FOR AVOIDED COST
CALCULATIONS.
CASE NO. IPC-E-21-09
FOURTH 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 MONDAY, JUNE
28.2021,1
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 Staff is requesting an expedited response. If responding by this date will be problematic, please call Staffs
attorney at (208) 334-03 I 8.
FOURTH PRODUCTION REQUEST
TO IDAHO POWER
)
)
)
)
)
)
)
)
JLINE 22,2021
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. 24: Response to Staff s Request No. 16 contains the proposed load
forecast in the L&R in an annual format. Response to Staff s Request No. I I contains the latest
forecast in an annual format. Comparing the two forecasts, the table below shows the latest load
forecast is greater than the proposed load forecast in the Application. However, Response to
Staff s Request No. l6 states that the first deficit date will change to July 2029 if all variables are
held constant except for using the latest load. Please explain why the updated first deficit date is
later than the originally proposed first deficit date of August 2028, when the new load is greater.
Please veri$ that the forecast used to determine the July 2029 detlcit date in response to
Production Request No. l6 uses the latest load forecast using 50th percentile loads.
,nlrli .r!t iy]:,
rw r+ i+sr r
)!irtr:
i:;'iit
!'.:
,':
,:, :i:,
*!,: :."::-
REQUEST NO. 25: Please provide both the forecast included in the Application and the
latest forecast using 50th percentile peak loads in annual format from 2021through 2040 and the
resulting first deficit date due to the change in the forecast.
REQUEST NO. 26: Response to Staff s Production Request No. l5 states that
generation from Valmy could be replaced by market purchases from Southern market hubs.
However, the amount of transmission capacity needs to change from 130 MW to 50 MW.
Comparing the updated L&R in this response and the proposed L&R in the Application, Staff
identifies that the difference between the two Market Purchase items in both L&Rs is
approximately 3 l0 MW, which is much greater than 80 MW ( 130 MW minus 50 MW). (See
example below.) Please explain in detail the additional adjustments the Company has made to
Market Purchases in addition to the 80-MW reduction.
FOURTH PRODUCTION REQUEST
TO IDAHO POWER 2 JUNE 22,2021
July 2025 August 2025 July 2026 August 2026
Market Purchases in
Proposed L&R 1054 MW 1079 MW 1054 MW 1078 MW
Market Purchases in
Response to Production
Request No. 15
744 MW 769 MW 744}/1W 768 MW
DATED at Boise,Idaho, this ),)jl day of June 2021.
m,frD
Maff Hunter
Deputy Attorney General
i:umisc:prodreq/ipce2l.9mh1y prod req4
FOURTH PRODUCTION REQUEST
TO IDAHO POWER J JUNE 22,2021
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 22ND DAY OF JUNE 2021, SERVED
THE FOREGOTNG FOURTH PRODUCTION REQUEST OF THE COMMSSTON
STAFF TO IDAHO POWER COMPAI\TY, 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]
dockets@idahopower. com
CAMILLE CHRISTEN
ENERGY CONTRACTS
P.O. BOX 70
BOISE,ID 83707
E-MAIL: [e-mail]
energy contracts@ idahopower. com
-bnhrrr.-SECRETAY
CERTIFICATE OF SERVICE