20240614Staff 11-22 to IPC Redacted.pdf

RECEIVED
Friday, June 14, 2024 1:49:47 PM
IDAHO PUBLIC
UTILITIES COMMISSION
CHRIS BURDIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334- 0314
IDAHO BAR NO. 9810
Street Address f'or Express Mail:
11331 W CHINDEN BLVD, BLDG 8, SUITE 201-A
BOISE, ID 83714
Attorney f'or the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER )
COMPANY'S APPLICATION FOR A ) CASE NO. IPC-E-24-16
CERTIFICATE OF PUBLIC CONVENIENCE )
AND NECESSITY FOR THE BOISE BENCH )
BATTERY STORAGE FACILITY ) REDACTED SECOND
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
FRIDAY, JULY 5, 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 SECOND PRODUCTION REQUEST TO
IDAHO POWER COMPANY 1 JUNE 14, 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. 11: Please describe any differences in the anticipated operational
dispatch of the Boise Bench Battery Energy Storage System ("BESS")between summer and
winter peak seasons.
REQUEST NO. 12: Please provide the RCAT model results showing the charge and
discharge hours for the winter months used to inform the "Most Valuable Hours" table in
Confidential Attachment 3 to Production Request No. 1. Please note all hours where the battery
is modeled as unable to charge.
** Note: In the response, please highlight confidential infonnation.
REQUEST NO. 13: Please explain if the assumed round trip efficiency accounts for
variations due to weather and associated parasitic loads.
REQUEST NO. 14: In the testimony of Company witness Ellsworth, he describes a
relation between solar photovoltaic("PV")systems and energy storage systems. Ellsworth at 26.
Please provide the ratio of solar to storage resources on the Company's system, the Effective
Load Carrying Capacity("ELCC")of solar resources, and the ELCC of battery resources for the
following cases:
a. Company's current system,
b. With the inclusion of the 150 MW BESS;
c. With the addition of the forecasted 525 MW solar PV resource described in Ellsworth
at 26;
d. With the addition of any other near-tenn resource additions;
e. With all of the above.
REQUEST NO. IS: In response to Production Request No. 1 - Confidential Attachment
3 at 3, the Bid states that the batteries can be recharged in approximately
Please answer the following questions:
REDACTED SECOND PRODUCTION REQUEST TO
IDAHO POWER COMPANY 2 JUNE 14, 2024

a. Please clarify if this is the minimum time needed to recharge.
b. Please explain if dispatch operations assume a different recharge time than the stated
echarge time.
c. Please provide the average duration of the recharging window in each month.
d. Please explain how the charge rate may affect battery degradation, cycle life, and
round-trip efficiency.
** Note: In the response,please highlight confidential information.
REQUEST NO. 16: In response to Production Request No. 1 - Confidential Attachment
3 at 6, the Company dcscribcs that the discharge cycles from months without critical hours can
be shifted to months with both morning and evening sets of valuable hours. Please provide
workpapers quantifying the shoulder month cycles and showing how they are redistributed.
** Note: In the response,please highlight confidential information.
REQUEST NO. 17: In response to Production Request No. 1 - Confidential Attachment
3 at 3, the Bid states, ` Please specify the
amount of the 365 annual discharge cycles anticipated to be used
** Note: In the response, please highlight confidential information.
REQUEST NO. 18: In response to Production Request No. 1 - Confidential Attachment
3 at 6, the"Most Valuable Hours" tablc shows discharge during hours ot�in summer
months. Please explain why the Company Bid selected battery dispatch during a time frame
when renewable resources are still expected to be generating as opposed to hours after sundown.
a. Additionally, please explain how the Company Bid models capacity availability of
the 4-hour Boise Bench BESS resource across
** Note: In the response, please highlight confidential information.
REQUEST NO. 19: In response to Production Request No. I - Confidential Attachment
3 at 6, the"Most Valuable Hours" table shows discharge during the evening most valuable hours
REDACTED SECOND PRODUCTION REQUEST TO
IDAHO POWER COMPANY 3 JUNE 14, 2024

Please explain why the Company Bid prioritized discharge during
the evening period over the morning period.
** Note: In the response, please highlight confidential information.
REQUEST NO. 20: Company witness Hackett describes that the Company received 21
BESS resource bids for the 2026 RFP. Hackett at 27. Please provide a table similar to the one
contained in the Company's response to Production Request No. 4 f'or each of the RFP bids for
BESS resources. Additionally, fbr each bid please also include the proposed operational date,
cost estimates, battery supplier, location and total MW that could have been provided by the
BESS resource.
REQUEST NO. 21: Please provide supporting documentation for the "Civil
Construction, Site Work, Underground Conduit, and Grounding, Fencing, Concrete
Foundations" cost estimate o isted in the table in the Company's response to
Production Request No. 4.
REQUEST NO. 22: As follow up to the Company's response to Production Request
No. 4, please explain why the Electrical Construction and BESS Installation cost estimates are
both
DATED at Boise, Idaho, this _� +day of June 2024.
hric Rnr�in
Deputy Attorney General
I:\Utility\U.MISC\PRDREQ\IPC-E-24-16 PR 42 Redacted.docx
REDACTED SECOND PRODUCTION REQUEST TO
IDAHO POWER COMPANY 4 JUNE 14, 2024

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS A��DAY OF JUKE 2024,
SERVED THE FOREGOING REDACTED SECOND PRODUCTION REQUEST OF
THE COMMISSION STAFF TO IDAHO POWER COMPANY IN CASE NO. IPC-E-24-
16, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
DONOVAN E WALKER
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: dwalker ,idahoMwer.com
PATRICIA JORDA , SECRETARY
CERTIFICATE OF SERVICE