20200604Staff 1-3 to PAC.pdf

DAYN HARDIE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BARNO.9917
HEC T IVE D
i*i* -!lji{ -b pil L: 03
,ar t-4. .', t r/JL!u
a. ji, i: i. ;r ij,,3i,iir{lss,0,l'd
Steet Address for Express Mail:
11331 W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, TD 83714
Attomeys forthe Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF ROCKY MOUNTAIN
POWER'S 2019 ELECTRIC INTEGRATED
RBSOURCE PLAI\
CASE NO. PAC-8.19-I6
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO ROCKY MOUNTAIN
POWER
The Staffof the Idaho Public Utilities Commission, by and through its attorney of record,
Dayn Hardie, Deputy Attorney General, requests that Rocky Mountain Power provide the
following documents and information as soon as possible, but no later than THLIRSDAY,
JUNE 25,2020.
This Production Request is to be considered as continuing, and Rocky Mountain 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 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
the person preparing the documents. Please also identiff the name, job title, location, and
telephone number of the record holder.
FIRST PRODUCTION REQUEST
TO ROCKY MOI.]NTAIN POWER
)
)
)
)
)
)
)
)
I JI.JNE 4,2020
ln 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: Page 64 of the IRP details time-of-use and demand response
initiatives in Utah, where the stated objective is for rates to reflect costs.
a. Please describe similar planned PacifiCorp programs in other states and the
objective(s) of these programs (e.g., reduce demand in most critical hours to
address capacity availability, reduce energy use over a wider span of peak hours,
shift energy use from peak to off-peak).
b. If there are two or more objectives listed in response to "a" above, please rank the
objectives (most important to least important), if possible, and explain why
achieving the objectives is beneficial to the Company and its customers.
c. Please describe how time-of-use peak and/or shoulder time periods and pricing
differentials were chosen for both the Utah programs described in the IRP and for
PacifiCorp's programs in other states.
d. Were the Company's time-of-use rate designs influenced by past experience of
PacifiCorp or other utilities? Please explain.
e. If PacifiCorp is not planning to expand time-of-use and demand response
programs outside of Utah, please explain why program expansion is limited to
Utah.
REQUEST NO. 2: PacifiCorp states on page 7l of its IRP that Gateway West and
Boardman to Hemmingway are beyond the scope of acknowledgement for this IRP, but are
expected to bring deemed necessary future benefits to the region.
a. Please explain why these transmission assets were not more fully incorporated
given the level of investment already made (planning and permitting),
PacifiCorp's stated commitment to regional transmission, and Idaho Power's
inclusion of Boardman to Hemingway in its IRP planning process and preferred
portfolio.
b. Assuming that some of these transmission segments will be constructed, when
does PacifiCorp anticipate that these facilities would be more fully incorporated
FIRST PRODUCTION REQUEST
TO ROCKY MOI.INTAIN POWER JUNE 4,20202
into the IRP decision making analysis (and possibly included in the preferred
portfolio )? Please explain.
c. Please identiff the factors that influence the timing for including these segments
in the analysis and explain their impact
REQUEST NO. 3: PacifiCorp identifies scenario P-26 as a variant of the preferred
portfolio (P45-CNW). P-26 includes Boardman to Hemmingway but the preferred portfolio does
not (p. 378, IRP Vol II, App. M-R). If Boardman to Hemmingway is evaluated and included in
the analysis, please comment on the extent to which P-26 would approximate the preferred
portfolio.
DATED at Boise, Idaho, thts 4th day of June 2020.
Dayn Hardie
Deputy Attorney General
i:umisc:pro&eq/pacel9. I 6dhbe pod req I
FIRST PRODUCTION REQUEST
TO ROCKY MOI.JNTAIN POWER 3 JUNE 4,2020
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 4th DAY OF JUNE 2020, SERVED
THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMmSSION
STAFF TO ROCKY MOUNTAIN POWE& IN CASE NO. PAC-E-19-16, By
E-MAILING A COPY THEREOF, TO THE FOLLOWING:
TED WESTON
ROCKY MOUNTAIN POWER
1407 WN TEMPLE STE 330
SALT LAKE CITY UT 84116
E-MAIL: [e-mail]
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
datareq uest@Jracifi com.com
[e-mail]
ADAM LOWNEY
McDOWELL RACKNER GIB SON
419 SW l11r{ AVE STE 400
PORTLAND OR 97205
E-MAIL: [e-mail]
SECRETARY
CERTIFICATE OF SERVICE