20221102Staff 1-6 to IPC.pdf

MICHAEL DUVAL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. II7I4
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Street Address for Express Mail:
1 I33I W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, ID 837I4
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THB APPLICATION
OF IDAHO POWER COMPANY'S ANNUAL
COMPLIAIICE FILING TO UPDATE THE
LOAD AND GAS FORECASTS IN THE
INCREMENTAL COST INTEGRATED
RESOURCE PLAN AVOIDED COST MODBL
CASE NO.IPC.E.22.26
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO IDAHO POWER COMPANY
Staff of the Idaho Public Utilities Commission, by and through its attomey of record,
Michael Duval, Deputy Attorney General, requests that Idaho Power Company ("Company")
provide the following documents and information as soon as possible, but no later than
WEDNESDAY, NOVEMBER 16, 2022.r
This Production Request is to be considered as 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 or information produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name, job title, and telephone number of
I Stuff ir requesting an expedited response. If responding by this date will be problematic, please call Staff s
attorney at [phone].
FIRST PRODUCTION REQUEST
TO IDAHO POWER
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I NOVEMBEP.z2022
the person preparing the documents. Please also identiff the name, job title, location, and
telephone number of the record holder.
In addition to the written copies provided as response to the requests, please provide all
Excel spreadsheets and electronic files on CD with formulas intact and enabled.
REQUEST NO. 1: Please confirm whether the years are misaligned with the load data
in the "October 2021 (aMW)" column in Table No. I of the Compliance Filing. For example,
should the total load for 2022havebeenl,924 aMW?
REQUEST NO. 2: Please veriff whether the years are misaligned with the load data in
"October 2022 (aMW)" column in Table No. I of the Compliance Filing.
REQUEST NO. 3: The following graph compares the202l load forecast and the2022
load forecast.
ldaho Power Annual Load Forecast
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FTRST PRODUCTION REQUEST
TO IDAHO POWER
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N .n $ 6 (o N @ Ol O d.{ rO if ln (' N OO o) 0 d Ncl N N N N N N N .n m m m m m m (n cn co <f <t $(f o o o o () o o o o o o o o o o () o <f c) oN C\I N N N N N N N N N N N N N N C.] N GI N N
...... 2021 Load Forecast
-2A22
Load Forecast
a. Please provide a breakdown of the 2021 andthe2022 forecasts by customer class
(residential, commercial, and industrial, etc.) in Excel format.
b. Please explain the method and basis used to determine the 2022 forecast for each
customer class.
c. The Compliance Filing states: "Idaho Power's most recent load forecast from
September 2022 shows a slight increase in customer loads in the near term,
2 NOVEMBER2,2022
followed by significant increases beginning in2025 through the remainder of the
forecast period..." Please explain why there is only a slight increase in the near
term, but there is a significant increase beginning in2025 through the remainder
of the forecast period. In the explanation, please identifu the major drivers or
causes for each customer class affecting the change.
REQUEST NO. 4: Order No. 33357 requires utilities to create a queue to track the order
in which QF projects have entered negotiations with a utility to ensure proposed prices
(indicative pricing in the IRP Methodology) are more accurate. Please respond to the following.
a. Please describe the types of projects in Idaho Power's queue. Specifically, which
"":' TTTfi :::*: ."ntracts in negotiation
o Non-PURPA projects with contracts in negotiation
o PURPA projects with signed contracts but not yet Commission approved
o Non-PURPA projects with signed contracts but not yet Commission
approved
o PURPA projects with Commission-approved contracts
b. Please describe in detail how Idaho Power manages its queue. Specially, what
criteria are used to determine additions and removals of projects in the queue?
c. Please describe in detail how Idaho Power determines the sequence of projects in
the queue.
d. Please describe in detail how a QF's position in the queue determines its
indicative pricing.
REQUEST NO. 5: Please confirm that the final IRP-based avoided cost rates used in a
signed contract (not the initial indicative pricing) are determined based on "projects approved by
the Commission" at the time when the lRP-based contract is signed, which do not include
"projects in negotiation" or "projects with a signed contract but not yet Commission approved."
lf not, please explain.
FIRST PRODUCTION REQUEST
TO IDAHO POWER J NOVEMBER2,2022
REQUEST NO. 6: The Compliance Filing states: "Idaho Power also evaluated Loss of
Load Probability ("LOLP") data from the 2021 IRP's Preferred Portfolio..." Please respond to
the following.
a. Please provide the LOLP data from the 2021 IRP's Preferred Portfolio. (Please
use the format of Table 3 of Idaho Power's Compliance Filing in Case No. IPC-E-
20-02.)
b. Please explain why the LOLP data from the202l IRP's Preferred Portfolio,
instead of a LOLP data based on actual resources in the Company's system, is a
reasonable benchmark to determine Peak Hours and Premium Peak Hours.
DATED at Boise,Idatro, this Z *
day of November 2022.
Michael Duval
Deputy Attorney General
i:umisc:prodreq/ipce22.26mdyy prod req I
FIRST PRODUCTION REQUEST
TO IDAHO POWER 4 NOVEMBERZ,2022
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 2Nd DAY OF NOVEMBER 2022,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF TIIE COMMISSION
STAFF TO IDAIIO POWER COMPAI\IY, N CASE NO. IPC.E-22-26, BY E.MAILING
A COPY THEREOF, TO THE FOLLOWING:
MEGAN GOICOECHEA ALLEN
DONOVAN E WALKER
IDAHO POWER COMPANY
PO BOX 70
BOISE rD 83707-0070
E-MAIL: [e-mail]
dwalker@ idahopower.com
dockets @ idahopower. c om
Y
CERTIFICATE OF SERVICE