20220218CEO 1-4 to IPC.pdf

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Kelsey Jae, ISB No. 7899
KELSEY JAE LLC
920 N. Clover Dr.
Boise,ID 83703
Telephone : [phone]
[e-mail]
Attorney for Clean Energt Opportunities for ldaho
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Michael Heckler
Courtney White
Clean Energy Opportunities for Idaho
3778 N Plantation River Drive, Suite 102
Boise,ID 83703
m ike @c leanenergyopportunities.com
[e-mail]
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER COMPAI{Y'S
2021 INTEGRATED RESOURCE PLAN (IRP)
rPC-E-21-43
CLEAN ENERGY OPPORTUNITIES FOR IDAHO's
FIRST PRODUCTION REQUEST TO IDAHO POWER COMPANY
COMES NOW Clean Energy Opportunities for Idaho (CEO), by and through its attorney
of record, Kelsey Jae of the firm Kelsey Jae LLC, request that Idaho Power Company ("Idaho
Power" or "the Company") provide the following documents within 2l days.
This Production Request is continuing, and Idaho Power 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
with supporting workpapers that provide detail or are the source of information used in
calculations. Please provide any Excel files with formulas active. Additionally, please include the
CEO - First Production Request to Idaho Power Company - IPC-E-21-43 - |
name and phone number of the person 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. As allowed by IDAPA 31.01.01 .228.01, CEO agrees to Idaho Power
depositing the response in an electronic depository.
RROUF sr NO l. For each of the years 202l through 2040, please provide in Excel
format the total annual number of short tons of CO2 emissions forecasted for each of the nine
portfolios displayed on page 89 of 2021 IRP Appendix C: Technical Report.
REOUEST NO 2. For the future scenarios where rapid electrification scenarios were
evaluated (those being an increase of l0x the number of electric vehicles and residential heat
pumps over the baseline projections), please provide in Excel format the amount of incremental
electric load caused by the increased number of electric vehicles compared to the baseline
electric vehicle load assumptions. Please provide these load data for each year from 2021
through 2040 in a format which shows whether the increased load varied by hour of the day, day
of the week, month of the year or any other deviation from an application of the same amount of
load to each hour in each ofthose 20 years.
REOUEST NO 3. For the future scenarios where rapid electrification scenarios were
evaluated (those being an increase of l0x the number of electric vehicles and residential heat
pumps over the baseline projections) please provide in Excel format amount of incremental
electric load caused by the increased number of residential heat pumps compared to the baseline
residential heat pump load assumptions. Please provide these load data for each year from 2021
through 2040 in a format which shows whether the increased load varied by hour of the day, day
CEO - First Production Request to Idaho Power Company - IPC-E-21-43 - 2
of the week, month of the year or any other deviation from an application of the same amount of
load to each hour in each of those 20 years.
REOUT'.ST NO 4. For the years 2021 through 2040, please provide the hourly Mid-C
market enerry price estimate per MWh used in portfolio cost analyses. If other marginaUavoided
energy cost estimates from other than the Mid-C market were used for any periods when the
Mid-C market did not provide ttrat function within IPC's modeling, please so note. Please
provide in Excel format these forecasted MWh prices for all twenty years, noting the forecasted
market location (Mid-C or other market if required) as well as the year, day, month and hour
ending for each value provided.
Dated this lSth day of February,2022.
Respectfrrlly submitted,t\ht
Kelsey Jae, Attorney for CEO
CEO - First Production Request to ldaho Power Company - IPC-E-2143 - 3
CERTIFICATE OF SERVICE
I hereby certifr that on this l8th day of February,2022.1 delivered true and correct
copies of the foregoing PRODUCTION REQUESTS to the following persons via the method of
service noted:
Electronic Mail Delivery
Idaho Public Utilities Commission
Jan Noriyuki
Commission Secretary
[e-mail]. sov
Idaho PUC Staff
Dayn Hardie
Deputy Attorney General
Idaho Public Utilities Commission
davn.hardie@puc. idaho. sov
Idaho Power Compony
Lisa D. Nordstrom
Tim Tatum
Alison Williams
I [e-mail]
awi I I [e-mail]
ttatum @idahopower.com
dockets@ idahooower.com
Idaho Conservation League
Benjamin J. Otto
Emma E. Sperry
botto@idahoconservation. ors
esperry@ idahoconservation.org
Industrial Customers of ldaho Power
Peter J. Richardson
Richardson Adams, PLLC
[e-mail]
Dr. Don Reading
dreadi ng@m indspring.com
Kiki Leslie A. Tidwell, pro se
ktidweI 12022 @.smai l.com
rs\e
Kelsey Jae
Attorneyfor CEO
CEO - First Production Request to ldaho Power Company -IPC-E-2143 - 4