20211110Staff 1-4 to PAC.pdf

JOHN R. HAMMOND, JR.
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-007 4
(208) 334-03s7
IDAHO BAR NO. 5470
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Street Address for Express Mail:
I I331 W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, ID 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-2I.20
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO ROCKY MOI]NTAIN
POWER
The Staff of the Idaho Public Utilities Commission, by and through its attomey of
record, John R. Hammond, Jr., Deputy Attorney General, requests that Rocky Mountain Power
("Company") provide the following documents and information as soon as possible, but no later
than WEDNESDAY, DECEMBER 1, 2021.
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
the person preparing the documents. Please also identi$ the name, job title, location, and
telephone number of the record holder.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER
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I NOVEMBER IO, 2021
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 explain why the load forecast in Case No. PAC-E-21-20 is
higher than the load forecast in Case No. PAC-E-20-16 over the entire period from202l through
2040. Please also provide a detailed explanation for the differences over the next three years.
REQUEST NO.2: Please explain why this year's natural gas forecast at Henry Hub is
higher than last year's forecast over the next three years, and then lower than last year's forecast
thereafter.
REQUEST NO.3: Please confirm that Sunny Bar Ranch is counted twice in Table 3 of
the Application. If confirmed, please provide a corrected Table 3 in the Application.
REQUEST NO.4: Please confirm that Sunny Bar Ranch is not double counted in the
Company's IRP model used to determine IRP-based avoided cost rates.
DATED at Boise, Idaho, tni*lo%uyof Novemb er 2021
R.Jr
Deputy Attorney General
i:umisc:prodreq lpace2l.Z0jhyy prod req I
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 NOVEMBER 10,2021
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS loth DAY OF NOVEMBER 2021,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION
STAFF TO ROCKY MOUNTAIN POWER, N CASE NO. PAC-E-21-20, BY
E-MAILING A COPY THEREOF, TO THE FOLLOWING:
TED WESTON
ROCKY MOUNTAIN POWER
I4O7 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84I 16
E-MAIL: ted.weston@oacifi corp.com
DATA REQUEST RESPONSE CENTER
E.MAIL ONLY:
datareq uest@pacifi com. com
EMILY WEGENER
ROCKY MOUNTAIN POWER
1407 WN TEMPLE STE 320
SALT LAKE CITY UT 84116
E-MAIL: ernily.wegener@oacifi com.com
SECRETARY
CERTIFICATE OF SERVICE