20221102Staff 1-6 to PAC.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:
I I33I W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, ID 83714
Attomey for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF ROCKY MOTII\TAIN POWER TO
T]PDATE LOAD AND GAS FORECASTS
USED IN THE INTEGRATED RESOURCE
PLAN AVOIDED COST MODEL
CASE NO. PAC-8.22-I6
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO ROCKY MOUNTAIN
POWER
Staff of the ldaho Public Utilities Commission, by and through its attomey of record,
Michael Duval, Deputy Attomey General, requests that Rocky Mountain Power ("Company")
provide the following documents and information as soon as possible, but no later than
WEDNESDAY, NOVEMBER 16, 2022.1
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 Stuffit requesting an expedited response. If responding by this date will be problematic, please call Staff s
attorney at [phone].
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER
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I NOVEMBERZ,2022
the person preparing the documents. Please also identi$ 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 explain what the'.FERC" column represents in Table No. I
in the Application, how its values are determined, and why the values should be part of the
Company's load forecast.
REQUEST NO. 2: Please confirm whether the years are misaligned with the load data
in the "Load Forecast - May 2021" section of Table No. I in the Application. For example,
should the total load for 2022have been 60,810 GWh?
REQUEST NO. 3: The following graph compares the202l load forecast and the2022
load forecast.
Rocky Mountain Power Load Forecast
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER
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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 the2022 forecast for each
customer class.
2 NOVEMBER2,2022
c. Please explain why the 2022 energy forecast is higher than the 2021 forecast. In
the explanation, please identifu the major drivers or causes for each customer
class affecting the change.
REQUEST NO. 4: Table No. 3 lists the start and end date for the Georgetown Irrigation
Company contract being April l, 2022, and March 31,2042, respectively. Please explain why
the contract has a 2l-year term, while the maximum published rate contract term of PURPA
contracts is 20 years.
REQUEST NO. 5: 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 Rocky Mountain Power's queue.
Specifically, which of the following are included:
o PURPA projects with contracts 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 Rocky Mountain 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 Rocky Mountain 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. 6: 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 IRP-based contract is signed, which do not include
"projects in negotiation" or "projects with a signed contract but not yet Commission approved."
FIRST PRODUCTION REQUEST
TO ROCKY MOLTNTAIN POWER J NOVEMBER2,2022
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DATED at Boise, Idaho, this day ofNovember 2022.
Michael Duval
Deputy Attorney General
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FIRST PRODUCTION REQUEST
TO ROCKY MOI,JNTAIN POVIER 4 NOVEMBERZ,2A22
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 2Nd DAY OF NOVEMBER 2022,
SERVED THE FOREGOING rIRST PRODUCTION REQUEST OF TIIE COMMISSION
STAFF TO ROCKY MOUNTATN POWER, IN CASE NO. pAC-E-22-t6, 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: [e-mail]
DATA REQUEST RESPONSE CENTER
E.MAIL OIILY:
datarequest@pac ifi corp.com
JOE DALLAS
ROCKY MOUNTAIN POWER
825 NE MULTNOMAH ST, SUITE 2OOO
PORTLAND OR 97232
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE