20210712Staff 27-28 to IPC.pdf

MATT HUNTER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 10655
- ' ::,,. iI F# 3:28
Street Address for Express Mail:
I I331 W CHINDEN BVLD, BLDG 8, SUITE 2OI.A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORB THE IDAHO PUBLIC UTILTTIES 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
FIFTH 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 THURSDAY,
JULY 15.2021,1
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 Stuffis requesting an expedited response. If responding by this date will be problematic, please call Stafls
attorney at (208) 334-03 18.
FIFTH PRODUCTION REQUEST
TO IDAHO POWER
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JULY 12,2021
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.27: Please confirm that the transmission capacity Excel file provided in
Response to Production Request No. 9, which shows how Market Purchases are calculated in the
Load and Resource Balance, assumes Valmy Unit 2 retires in2022, instead of 2025. If so,
please submit an updated Excel file that calculate Market Purchases to reflect a2025 retirement
date of Valmy Unit 2.
REQUEST NO.28: Response to Staff s Production Request No. 26 states, "Recently,
the Company determined that firm transmission is not available from southem market hubs to
North Valmy through the NV Energy system" and "[a]dditional firm south-to-north transmission
is also not available on the PacifiCorp East transmission path through Utah to [daho." Please
answer the following questions:
a. What timeframe and contract length of firm transmission did the Company seek to
obtain that is not available from southern market hubs to North Valmy through the
NV Energy system? How much capacity did the Company request? Please provide
evidence.
b. What timeframe and contract length of firm transmission did the Company seek to
obtain that is not available from south-to-north transmission on the PacifiCorp East
transmission path through Utah to Idaho. How much capacity did the Company
request? Please provide evidence.
c. Please explain and provide evidence to show whether or not transmission from the
south transmission pathways will be available in the future.
FIFTH PRODUCTION REQUEST
TO IDAHO POWER 2 JULY 12,2027
DATED at Boise,Idaho, this
i:umisc:prodrcq/ipce2l.9mh5y prod req5
FTFTH PRODUCTION REQUEST
TO IDAHO POWER
l>*uurof July 2021.
Matt Hunter
Deputy Attomey General
3 JULY I2,2O2I
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS I2TH DAY OF JULY 2021, SERVED
THE FOREGOING FIFTH PRODUCTION REQUEST OF THE COMMISSION STAFF
TO IDAHO POWER COMPAII-Y, 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
BOISE ID 83707-0070
E-MAIL: [e-mail]
dockets@ idahopow'er.com
PETER J RICHARDSON
RICHARDSON ADAMS PLLC
515 N 27TH ST
BOISE ID 83702
E-MAIL: oeter(Erichardsonadams.com
C TOM ARKOOSH
ARKOOSH LAW OFFICES
913 RIVER ST STE 450
BOISE ID 83702
E-MAIL: [e-mail]
[e-mail]
CAMILLE CHRISTEN
ENERGY CONTRACTS
P.O. BOX 70
BOISE, ID 83707
E-MAIL: [e-mail]
energy contracts@ idahopower. com
DR DON READING
6070 HILL ROAD
BOISE ID 83703
E-MAIL:.corn
SECRET
CERTIFICATE OF SERVICE