20231109Staff 5-6 to IPC.pdf

ADAM TRIPLETT
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION 9 PM 2:34
PO BOX 83720
BOISE,IDAHO 83720-0074 MM!SSION
[phone]
IDAHO BAR NO.10221
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 IDAHO POWER )COMPANY'S ANNUAL COMPLIANCE )CASE NO.IPC-E-23-25
FILING TO UPDATE THE LOAD AND GAS )FORECASTS IN THE INCREMENTAL COST )INTEGRATED RESOURCE PLAN AVOIDED )SECOND PRODUCTION
COST MODEL.)REQUESTOF THE
)COMMISSION STAFF
)TO IDAHO POWER COMPANY
Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Adam Triplett,Deputy Attorney General,requests that Idaho Power Company ("Company")
provide the followingdocuments and information as soon as possible,but no later than
THURSDAY,NOVEMBER 16,2023.
This Production Request is to be considered as continuing,and the Company 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.
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
Staffis requesting an expedited response.If responding by this date will be problematic,please call Staff's
attorney at [phone].
SECOND PRODUCTION REQUEST
TO IDAHO POWER COMPANY 1 NOVEMBER 9,2023
the person preparing the documents.Please also identify the name,job title,location,and
telephonenumber of the record holder.
In addition to the written copies provided as response to the requests,please provide all
Excel spreadsheets and electronic files with formulas intact and enabled.
REQUESTNO.5:Please respond to the followingregarding the proposed load.
a.When was the proposed load created?
b.Please confirm that the proposed load is based on 70th perCenÍile Of load;
c.Please explain why and how the Company determined that the 70th percentile
energy load forecast was the right level to use for its planning case.Please provide
evidence and any workpapers to explain the answer;
d.Please provide the timeframe of load data used to develop the load forecast;
e.Please explain how the load data was collected;and
f.Please explain what "70th percentile"means.
REQUESTNO.6:Please explain what percentile of load was used in Case No.IPC-E-22-
26.If the percentile was different than the percentile proposed in this case,please quantifythe
difference between the two load forecasts due to the different percentiles.
DATED at Boise,Idaho,this '7 day of November 2023.
Adam Triplett
Deputy AttorneyGeneral
i:umisc:prodreq/IPC-E-23-25 PR#2
SECOND PRODUCTION REQUEST
TO IDAHO POWER COMPANY 2 NOVEMBER 9,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 9th DAY OF NOVEMBER 2023,
SERVED THE FOREGOING SECOND PRODUCTION REQUESTOF THE
COMMISSION STAFF TO IDAHO POWER COMPANY,IN CASE NO.IPC-E-23-25,
BY E-MAILING A COPY THEREOF,TO THE FOLLOWING:
MEGAN GOICOECHEA ALLEN
DONOVAN E WALKER
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL:mgoicoecheaallen idahopower.com
[e-mail]
[e-mail]
SECRETARY
CERTIFICATE OF SERVICE