20210602Staff 1-4 to IPC.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 133I W CHINDEN BVLD, BLDG 8, SUITE 20 I -A
BOISE, ID 837I4
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IDAHO POWER COMPANY'S APPLICATION
TO UPDATE THE GAS FORECAST IN THE
INCREMENTAL COST INTEGRATED
RESOURCE PI.AN AVOIDED COST MODEL
CASE NO.IPC.E-21.15
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
IDAHO POWER COMPANY
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
John R. Hammond Jr., Deputy Attorney General, request that Idaho Power Company ("Company")
provide the following documents and information as soon as possible, or by WEDNESDAY
JUNE 23,2021.
This Production Request is 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 produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations. The Company is reminded that responses pursuant
to Commission Rules of Procedure must include the name and phone number of the person
preparing the document, and the name, location and phone number of the record holder and if
different the witness who can sponsor the answer at hearing if need be. Reference IDAPA
31.01.01.228.
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY
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1 JI.INE 2,2021
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. 1: The 2017 Integrated Resource Plan ("IRP") used the U.S. Energy
Information Administration's ("EIA") Henry Hub High Oil and Gas Resource and Technology
forecast. The 2019 IRP used the gas forecast from S&P Global Platts ("Platts"). Please describe
the key difference between the two methods and explain the advantages of the Platts forecast over
the EIA forecast.
REQUEST NO. 2: The Application states that the 2021Platts forecast is approximately
30lo lower overall than the 2018 Platts forecast, except for the periods of 2021-2023 and2039-2040
Please explain what causes the 2021 Platts forecast tobe3Yo lower and why the periods of 2021-
2023 and2039-2040 are exceptions.
REQUEST NO. 3: Please provide Table No. I in Confidential Attachment No. 1 in Excel
format and include the202l EIA Henry Hub High Oil and Gas Resource and Technology forecast
for comparison.
REQUEST NO. 4: Please explain how Platts determines the first five years of the natural
gas forecasts and how forward market prices are used during this period of the forecast.
DATED at Boise,Idaho, this 2 day ofJune 2021
Hammond
Attorney General
i:umisc:prodreq/ipce2 l. I 5hyy prod req I
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 2 JUNE2,2O21
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAvE THIS 2ND DAY oF JUNE 2021,
SERVED TTIE FOREGOING FIRST PRODUCTION REQUEST OF TIIE
coMMrssroN sTArF To rDAHo PowER coMpANy, IN CASE NO.
IPC-E.2I.IS, BY E.MAILING A COPY TI{EREOF, TO THE FOLLOWING:
DONOVAN E WALKER
IDAHO POWER COMPANY
PO BOX 70
BOrSE ID 83707-0070
E-MAIL: [e-mail]
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sscRETARt'//
CERTIFICATE OF SERVICE