20201130Staff 8 to PAC.pdf

EDWARD JEWELL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE,IDAHO 83720-0074
[phone]
IDAHO BAR NO.10446
Street Address for Express Mail:
11331 W CHINDEN BLVD,BLDG 8,SUITE 201-A
BOISE,ID 83714
Attorneyfor the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )ROCKY MOUNTAIN POWER TO UPDATE )CASE NO.PAC-E-20-16
CONTRACTS,LOAD AND GAS FORECASTS )USED IN THE INTEGRATED RESOURCE )
PLAN AVOIDED COST MODEL )SECOND PRODUCTION
)REQUESTOF 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 AttorneyGeneral,requests that Rocky Mountain Power provide
the followingdocuments and information as soon as possible,but no later than MONDAY,
DECEMBER 7,2020.1
This Production Request is to be considered as continuing,and Rocky Mountain Power is
requested to provide,by way of supplementaryresponses,additional documents that it or any
person acting on its behalf may later obtain that will augment the documents or information
produced.
*Staff is requesting an expedited response.If responding by this date will be problematic,please call Staffs attorney
at [phone].
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 1 NOVEMBER 30,2020
RECEIVED
2020November 30,PM 4:12
IDAHO PUBLIC
UTILITIES COMMISSION
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.
REQUESTNO.8:The table below shows the Henry Hub natural gas price forecasts the
Company provided in the annual natural gas and load update filings in 2019 and 2020.What are
the sources of data used to derive the natural gas forecast for years 2021,2022,and 2023 for both
the 2019 and the 2020 forecast?Please provide the actual data that was used to derive the
forecasts for each forecast and for each of those years.
2020 Forecast ($/MMBtu)2019 Forecast ($/MMBtu)
2021 2.92 2.45
2022 2.62 2.54
2023 2.58 2.88
2024 3.15 3.23
2025 3.66 3.52
2026 3.8 3.69
2027 3.88 3.96
2028 4.1 4.29
2029 4.39 4.57
2030 4.76 4.8
2031 4.89 5.08
2032 4.96 5.36
2033 5.1 5.35
2034 5.26 5.59
2035 5.42 5.8
2036 5.65 5.88
2037 5.68 6.29
2038 5.98 6.58
SECOND PRODUCTIONREQUEST
TO ROCKY MOUNTAIN POWER 2 NOVEMBER 30,2020
DATED at Boise,Idaho,this ay of November 2020.
Edward J.w ll
Deputy AttomeyGeneral
i:umisc prodrcqlpace20.16ejyy prod req 2
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 3 NOVEMBER 30,2020
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 30th DAY OF NOVEMBER 2020,
SERVED THE FOREGOING SECOND PRODUCTION REQUESTOF THE COMMISSION
STAFF TO ROCKY MOUNTAIN POWER,IN CASE NO.PAC-E-20-16,BY E-MAILING
A COPY THEREOF,TO THE FOLLOWING:
TED WESTON EMILY WEGENER
ROCKY MOUNTAIN POWER ROCKY MOUNTAIN POWER
1407 WEST NORTH TEMPLE STE 330 1407 WN TEMPLE STE 320
SALT LAKE CITY UT 84116 SALT LAKE CITY UT 84116
E-MAIL:[e-mail] E-MAIL:[e-mail]
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
[e-mail]
SECRET RY
CERTIFICATE OF SERVICE