20201112Staff 1-7 to PAC.pdf

EDWARD JEWELL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83120-OO] 4
(208) 334-O3r4
IDAHO BAR NO. 10446
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Street Address for Express Mail:
11331 W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, D 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
ROCKY MOUNTAIN POWER TO UPDATE
CONTRACTS, LOAD AND GAS FORECASTS
USED IN THE INTEGRATED RESOURCE
PLAN AVOIDED COST MODEL
CASE NO. PAC.E.2O.I6
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO ROCKY MOUNTAIN
POWER
The Staff of the Idaho Public Utilities Commission, by and through its attorney of
record, Edward Jewell, Deputy Attorney General, requests that Rocky Mountain Power provide
the following documents and information as soon as possible, but no later than FRIDAY,
NOVEMBER 27,2020.r
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.
I Staff is requesting an expedited response. If responding by this date will be problematic, please call Staffs attorney
at (208) 334-03t4.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER
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I NOVEMBER I2,2O2O
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 identify 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 and electronic files on CD with formulas activated.
REQUEST NO. L: Please provide the date when the Company's annual GWh load
forecast data used in the 2019lntegrated Resource Plan in PAC-E-19-16 was developed.
REQUEST NO.2: Please provide the Company's annual GWh load forecast data used
in the 2019lntegrated Resource Plan in PAC-E-19-16 in the same format as Table 1 in the
Application in PAC-E-20-16.
REQUEST NO.3: Please provide any changes that the Company has made to its
annual GWh load forecast data, if any, from the data used in the 2OIg Integrated Resource Plan
in PAC-E-19-16 and explain why the changes were made.
REQUEST NO.4: Please provide the date when the Company's Official Forward Price
Curve data used in the 2019 Integrated Resource Plan in PAC-E-19-16 was developed.
REQUEST NO.5: Please provide the Company's Official Forward Price Curve data
used in the 2OI9Integrated Resource Plan in PAC-E-19-16 in the same format as Table 2 inthe
Application in PAC-E-20- 1 6.
REQUEST NO.6: Please provide the changes that the Company has made to the
Official Forward Price Curve data, if any, from the one used in the 2Olg lntegrated Resource
Plan in PAC-E-19-16 to the one filed in PAC-E-20-16, and explain why changes were made.
REQUEST NO.7: Please identify factors that make it difficult to submit these update
filings earlier to allow processing prior to an October 15 effective date.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 NOVEMBER I2,2O2O
DATED at Boise,Idaho, this \Qrn day of November 2020.
Deputy General
i:umisc:prodreq/pace20.l6ejyy prod req I
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 3 NOVEMBER 12,2020
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 12th DAY OF NOVEMBER 2020,
SERVED THE FOREGOING FIRST PRODUCTION REQUBST OF THE COMMISSIONSTAFF TO ROCKY MOUNTAIN POWER, IN CASE NO. PAC-E-2O-16, BY E-MAILINGA COPY THEREOF, TO THE FOLLOWING:
TED WESTON
ROCKY MOUNTAIN POWER
1407 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84116
E-MAIL: ted.weston @pacificorp.com
EMILY WEGENER
ROCKY MOUNTAIN POWER
1407 WN TEMPLE STE 320
SALT LAKE CITY UT 84I16
E-MAIL: emil)[e-mail]
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
datareque st @ pacificorp. com
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CERTIFICATE OF SERVICE