20240423Staff 1-19 REDACTED to IPC.pdf

RECEIVED
Tuesday,April 23,2024 1:07 PM
IDAHO PUBLIC
UTILITIES COMMISSION
CHRIS BURDIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 9810
Street Address for Express Mail:
11331 W CHINDEN BLVD, BLDG 8, SUITE 201-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER IDAHO POWER )
COMPANY'S APPLICATION FOR ) CASE NO. IPC-E-24-12
APPROVAL OF A MARKET PURCHASE )
AGREEMENT )
REDACTED FIRST
PRODUCTION REQUEST OF
THE COMMISSION STAFF TO
IDAHO POWER COMPANY
Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Chris Burdin, Deputy Attorney General, requests that Idaho Power Company ("Company")
provide the following documents and information as soon as possible, but no later than
TUESDAY,MAY 14, 2024.
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 identify the name,job title, location, and
telephone number of the record holder.
REDACTED FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY 1 APRIL 23, 2024

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.
REQUEST NO. 1: Please provide supporting workpapers of the load and resource
balance that details the 236 MW deficit in 2026 as mentioned m Company Witness Ellsworth's
Testimony at 14. If not included,please include the expected capacity of contracted projects
through 2025.
REQUEST NO. 2: Please explain how the Company modeled the Oxbow Hydro
maintenance in 2026 in the recent capacity update, mcluding the expected MWs that will be
expected to be reduced as a result. Ellsworth at 17. Additionally,please explain when the
Company expects the Oxbow Hydro mauitenance to be completed.
REQUEST NO. 3: Please explain why the Agreement does
Confidential Exhibit No. 9 at 1. In the response, please specify who will own the
_ for each transaction i.e., Seller or Purchaser.
** Note: In the response, please highlight confidential information.
REQUEST NO. 4: Please explain why the term requires the
-. Confidential Exhibit No. 9 at 2.
** Note: In the response, please highlight confidential information.
REQUEST NO. 5: In the event the Company elects to receive Firm Energy,please
explain the requirement to have ' ". Confidential Exhibit
No. 9 at 4.
a. Additionally, please explain if the Company will have to
** Note: In the response, please highlight confidential information.
REDACTED FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY 2 APRIL 23, 2024

REQUEST NO. 6: The Company may request to increase capacity during the Fixed
Term of for a total of_ Confidential Exhibit No. 9 at 4. Please answer
the following:
a. Please provide the total estimated costs of increasing capacity to-
b. If the Company increases to�, please explain how this will be the least cost
resource in terms of the 2026 RFP shortlist;
c. Please explain if the Company will need to renegotiate the Agreement if it chooses to
increase the capacity to a total of_;
d. Ellsworth stated in his testimony, "Once B2H is completed, the Powerex contract will
be treated as 200 MW of fully incremental capacity." Ellsworth at 25. Please explain
if the Company requests to increase to_ that contract will be treated=
. of fully incremental capacity; and
e. If the Company increases the capacity to_ and 13211 is not energized by June
1, 2026,please provide a table that details the alternative delivery points the
Company will use during the Bridge Term.
** Note: In the response, please highlight confidential information.
REQUEST NO. 7: Section 12 in Confidential Exhibit No. 9 describes how the
Company may
Confidential Exhibit No. 9 at 16. Please explain the impacts of
converting to this service and answer the following:
a. If this option was chosen,please explain how that would impact this Agreement as a
cost-effective resource; and
b. If this option was chosen,please provide supporting workpapers that detail what the
estimated expenses by year of both (a) Bridge Term and(b) Fixed Term.
** Note: In the response, please highlight confidential information.
REQUEST NO. 8: Please provide workpapers that were used to determine the Fixed
Capacity price. Confidential Exhibit No. 9 at 6.
** Note: In the response, please highlight confidential information.
REDACTED FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 3 APRIL 23, 2024

REQUEST NO. 9: Confidential Exhibit No. 9 Additional Provisions 3(a) at 9 states,.
Please explain how
the Company will notify the Commission if this occurs. Additionally,please explain how
changing the will impact the cost of
this Agreement.
** Note: In the response,please highlight confidential information.
REQUEST NO. 10: In Confidential Exhibit No. 9 -Additional Provisions 3(c)(i), it
states,
Please
explain what the estimated fee to export out of the Markets Plus footprint will be and how it is
calculated.
**Note: In the response,please highlight confidential information.
REQUEST NO. 11: The Agreement states
)7
Confidential Exhibit No. 9 at 19. Please clarify if Idaho Power Film Energy purchases from
Powerex would be subject to CCA costs.
a. Additionally,please explain how Powerex will calculate the"amount". Please
provide supporting workpapers;
b. Please explain if this"amount"is different than actual CCA costs; and
c. If the Company is subject to CCA costs,please explain if the Company plans to pass
those costs on to Idaho customers.
**Note: In the response,please highlight confidential information.
REQUEST NO. 12: As part of the Company's All-Source Request for Proposals
("RFP'), the Company identified tables of eligible products. Table 3.2 identified"Gas-fired
REDACTED FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY 4 APRIL 23,2024

Convertible to Hydrogen (G2H)" as an eligible product. Please answer the following questions
about this product:
a. Please describe how this product would materially differ from a conventional gas-
fired plant;
b. Please explain the Company's reasons for requesting this product, but not a
conventional gas-fired plant;
c. Please provide examples of other utilities or energy companies that implemented this
product; and
d. Please provide the Company's cost estimate data regarding the extra costs that would
be typical between this product and a conventional gas-fired plant.
REQUEST NO. 13: Please provide the following information from the Gas-fired
Convertible to Hydrogen ("G21­1")proposal submitted as part of the RFP:
a. Please provide the proposed location of the resource and its natural gas supply plan;
b. Please provide the proposed electrical interconnection or delivery path;
c. Please provide the proposed nameplate capacity;
d. Please provide the proposed price; and
e. Please provide the proposed plan to provide convertibility to hydrogen.
REQUEST NO. 44: The RFP requested proposals that would alleviate capacity deficits
in 2026 and 2027. Because the Company did not determine the final short list of competitive
proposals until March of 2023, proposers will now have under three years to finish a 2026
project.
a. Please list all potential resource types with typical acquisition lead times that exceed
three years;
b. Please provide the typical acquisition lead time for those resource types; and
c. Please describe roadblocks and solutions the Company can pursue to enable longer
lead-time projects.
REQUEST NO. 15: Staff believes that the Company constructed Langley Gulch gas
plant("Langley") with the capability to expand its capacity.
REDACTED FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY 5 APRIL 23, 2024

a. Please describe the capacity-expansion features currently in place at Langley;
b. Please describe the requirements to expand the capacity of the plant, and the
additional amount of capacity that could be reasonably achieved; and
c. Please explain why the Company did not submit a Langley expansion project as a
benchmark project.
REQUEST NO. 16: Please provide the worksheets (with formulas enabled) determining
the life-cycle calculations for the top three 2026 proposals.
REQUEST NO. 17: Please answer the following questions about AURORA modeling
of the Powerex Market Purchase Agreement ("MPA"):
a. Please describe how the Company modeled the MPA in Aurora;
b. Please confirm that the model accounts for the cost of 16 hours of energy at the Day-
Ahead Mid-C Peak Index price if a delivery order is placed; and
c. Please provide an appropriate range of AURORA hourly data that shows an MPA
delivery order being executed during a 2027 summer peak.
REQUEST NO. 18: Please answer the following questions about AURORA modeling
of Battery Energy Storage Systems ("BESS"):
a. Please describe how the Company models BESS in AURORA;
b. Please describe the factors that AURORA uses to determine how and when to
recharge the BESS;
c. Please clarify if the cost of BESS-recharging energy is accounted for in the portfolio;
and
d. Please provide appropriate AURORA hourly data from a run that shows a BESS
resource discharging and recharging during a peak winter month.
REDACTED FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY 6 APRIL 23, 2024

REQUEST NO. 19: Please describe any steps the Company is considering to shorten
the next RFP timeline.
DATED at Boise, Idaho, this 23`d day of April 2024.
kvA
Chris Burdin
Deputy Attorney General
1:\Utility\UMISC\PRDREQ\IPC-E-24-12 PR#I Redwted.docx
REDACTED FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY 7 APRIL 23,2024

CERTIFICATE OF SERVICE
c l-
I HEREBY CERTIFY THAT I HAVE THIS;; DAB' OF APRIL 2024,
SERVED THE FOREGOING REDACTED FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY, IN CASE NO. IPC-E-24-12,
BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
DONOVAN E WALKER
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: dwalkerOidahopower.com
PATRICIA JORD , SECRETARY
CERTIFICATE OF SERVICE