20241204Staff 1-20 to IPC Redacted.pdf

RECEIVED
Wednesday, December 4, 2024 3:50:23 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 OF IDAHO POWER )
COMPANY'S APPLICATION FOR ) CASE NO. IPC-E-24-42
APPROVAL OF A POWER PURCHASE )
AGREEMENT WITH BLACKS CREEK )
ENERGY CENTER, LLC ) 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
THURSDAY, DECEMBER 26, 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.
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 1 DECEMBER 4, 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: In Attachment No. 3 of the Application, the Company states that
different historical years would be used to calculate an average Loss of Load Expectation
("LOLE") for each month. Please explain what historical years are used and why those historical
years are used. In addition, please explain how the average monthly LOLE is calculated.
REQUEST NO. 2: In Attachment No. 3 of the Application, the Company states "[i]f a
significant resource stack change is expected in the near future, an adjusted case would be used
to guide the monthly weighted average calculations." Is the Company referring to how a Load&
Resource ("L&R") year is selected? If so,please explain in detail how a L&R year is selected in
the context of a significant resource stack change. If not, please explain what an adjusted case
means and how it would be used to guide the calculations.
REQUEST NO. 3: In this case, Blacks Creek project is expected to come online in
December 31, 2027, and thus Year 2028 (the year after the online date) is used to determine the
months of capacity need. In Case No. IPC-E-24-01, the Pleasant Valley Solar 2 project was
expected to come online in December 31, 2026, but the Company used Year 2026 (the year
before the online date) to determine the months of capacity needs. Please explain why the
Company changed the method in this case.
REQUEST NO. 4: In Attachment No. 3 of the Application, the Company states that
"[i]n review of the projected near-term load and resource buildout, Idaho Power adjusted the
2028 monthly LOLE weighted averages to better reflect the expected LOLE distribution of
future years." Please respond to the following:
a. Please explain in detail how adjustments were made;
b. Please explain how the projected near-term load and resource buildout affected the
adjustments;
c. Please define "future years"; and
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 2 DECEMBER 4, 2024

d. Please explain how the adjusted 2028 monthly LOLE in Table 2 of Attachment No. 3
of the Application better reflected the expected LOLE distribution of future years.
REQUEST NO. 5: In Attachment No. 3 of the Application, the Company states that
"[t]he twelve months of the calendar year are grouped into three different periods given their
Loss of Load Probability("LOLP")profiles. Please respond to the following:
a. Please provide the LOLP profiles;
b. Please explain how the LOLP profiles are generated;
c. Please explain whether the LOLP profiles are based on L&R Year of 2028;
d. Please explain the relationship between the LOLP profiles and the original 2028
monthly LOLE in Table 1 of Attachment No. 3 of the Application;
e. Please explain the relationship between the LOLP profiles and the adjusted 2028
monthly LOLE in Table 2 of Attachment No. 3 of the Application; and
f. Please explain how the LOLP profiles guided the grouping into three different periods
(i.e. Summer, Winter, and Off-Season).
REQUEST NO. 6: In Attachment No. 3 of the Application, the Company states that
"[b]ecause the summer total is set to equal the approximate 68%, the high LOLP hours weekly
weighting can be used to smooth the summer period spread." Please explain the relationship
between the LOLP profiles used in this step and the LOLP profiles used in the grouping step that
generated the adjusted 2028 monthly LOLE in Table 2 of Attachment No. 3 of the Application.
REQUEST NO. 7: In Attachment No. 3 of the Application, the Company states that the
capacity contribution of the Blacks Creek project is 18.44%. Please explain what capacity
contribution represents, how this value is determined, and why it is significantly lower than the
capacity contributions of the Pleasant Valley Solar project(31.21%) and Pleasant Valley Solar 2
project(31.54%).
REQUEST NO. 8: According to Table 5 of Attachment No. 3 of the Application, the
annual payment is distributed to each month based on 2028 seasonal monthly LOLE, regardless
of Black Creek's generation capabilities. Please respond to the following:
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 3 DECEMBER 4, 2024

a. Under normal circumstances, how well does the project's generation capabilities
align with the Company's 2028 seasonal monthly LOLE?
b. Under normal circumstances, how well does the project's generation capabilities
align with the capacity contribution of 18.44%?
c. The total annual payment is based on the capacity contribution of 18.44%, which will
be further reduced if the measured output does not match the expected output based
on Performance Ratio metric. Please explain how well the capacity contribution of
18.44% aligns with the expected output based on Performance Ratio metric.
REQUEST NO. 9: Please explain why the Performance Ratio Target for summer
months is lower than that for non-summer months.
REQUEST NO. 10: What are the advantages of using the 2028 Seasonal Monthly
LOLE in Table 4 overusing the adjusted 2028 Monthly LOLE in Table 2 or the original 2028
Monthly LOLE in Table 1?
REQUEST NO. 11: Attachment No. 3 of the Application states that the Performance
Ratio metric will be calculated based on the high LOLP hours from the timing of highest risk
analysis published in the 2023 IRP. Please respond to the following:
a. Please provide the LOLP profiles that contain the high LOLP hours and explain
whether they are based on Year 2028;
b. Please explain the relationship between the LOLP profiles in this request and the
LOLP profiles used to smooth the summer period spread in Table 4 of Attachment
No. 3 of the Application; and
c. Please explain the relationship between the LOLP profiles in this request and the
LOLP profiles used in the grouping step that generated the adjusted 2028 monthly
LOLE in Table 2 of Attachment No. 3 of the Application.
REQUEST NO. 12: Attachment No. 3 of the Application states that"[t]he hours where
capacity is needed are the hours which have high LOLP values. To provide compensation for
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 4 DECEMBER 4, 2024

capacity when it is needed, the PR metric will be calculated based on the high LOLP hours... ."
Please respond to the following:
a. Please explain how the Performance Ratio metric is calculated based on the high
LOLP hours;
b. Please illustrate the calculation mathematically;
c. Please explain how monthly Performance Ratios are calculated, which will be used to
calculate payment reductions;
d. Please provide detailed justifications for why non-risk hours (3pm-5pm for summer
and 3pm-4pm for winter) are added to the risk-hour timeframes; and
e. Please explain whether ratepayers are harmed when capacity payment is paid when
capacity is not needed by the Company.
REQUEST NO. 13: Please respond to the following regarding Figure 2 of Attachment
No. 3 of the Application:
a. Please provide the linear regression curve formula behind the relationship between
Performance Ratio and Effective Load Carrying Capability used to calculate payment
reduction rate;
b. Please explain how the relationship is determined;
c. Please explain what input data is used to determine the relationship; and
d. Please explain what the dots in Figure 2 represent.
REQUEST NO. 14: Given Section 4.3.2,please confirm that the final nameplate
capacity of the Facility cannot be below■ MW or above■ MW.
REQUEST NO. 15: Exhibit 3 of the Power Purchase Agreement ("PPA") states that.
Please
respond to the following:
a. What is the cost of the-?
b. Who pays for the cost of the-?
c. Who pays for the cost of Operations and Maintenance ("O&M") of the-?
d. What is the O&M rate?
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 5 DECEMBER 4, 2024

e. How is the O&M rate determined?
f. Please provide a copy of the Generator Interconnection Agreement.
REQUEST NO. 16: Section 1.126 stated the Scheduled Commercial Operation Date is
; however, the Parties shall work in good faith to move such date to_
-, if the Generator Interconnection Agreement back feed power milestone and limited
operation study indicate that—, is feasible. Please explain whether the LOLE values
used in determining avoided cost of capacity will be affected if the Commercial Operation Date
is changed. Specifically, will the LOLE values of the period from June 1, 2027, through May 31,
2028,be used, instead of the period from January 1, 2028, through December 31, 2028? Or will
the LOLE values for the period from January 1, 2028, through December 31, 2028, be locked in
when the PPA is executed?
REQUEST NO. 17: Please describe the competitive procurement process used to
procure the PPA and provide all other proposals considered in the procurement process. In your
response, please explain whether the procurement process was conducted by Brisbie or the
Company. If it was conducted by the Company, please explain how the process for selecting
resources for Brisbie will not hurt the Company's opportunities of selecting resources to meet
system needs.
REQUEST NO. 18: The Contract between Brisbie and the Company required that
Special Contract at 25. Please
explain whether this requirement has been met for the Blacks Creek.
REQUEST NO. 19: In Case Nos. IPC-E-22-29 (Pleasant Valley Solar) and IPC-E-24-
01 (Pleasant Valley Solar 2), the definition of Market Price Index referenced a price for energy
that is not delivered to a final point of delivery in a balancing authority area located entirely in
Washington, to avoid potential impacts of Washington's Climate Commitment Act("CCA").
Please respond to the following:
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 6 DECEMBER 4, 2024

a. Please explain why such references are removed in the definition of Market Price
Index in this case; and
b. Please explain whether and how Washington's CCA affects this PPA.
REQUEST NO. 20: Please explain whether Order No. 36383 in Case No. IPC-E-24-23
affects this case.
DATED at Boise, Idaho, this 4th day of December.
��A "
Chris Burdin
Deputy Attorney General
Technical Staff: Yao Yin
I:\Utility\UMISC\PRDREQ\IPC-E-24-42 PR#1 Redacted.docx
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 7 DECEMBER 4, 2024

CERTIFICATE OF SERVICE
t�h
I HEREBY CERTIFY THAT I HAVE THIS DAY OF DECEMBER 2024,
SERVED THE FOREGOING REDACTED FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY, IN CASE NO. IPC-E-24-42,
BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
DONOVAN E. WALKER TIM TATUM
IDAHO POWER COMPANY CONNIE ASCHENBRENNER
PO BOX 70 GRANT ANDERSON
BOISE ID 83707-0070 IDAHO POWER COMPANY
E-MAIL: dwalker awidahopower.com PO BOX 70
dockets c�idahopower.com BOISE ID 83707-0070
energycontracts(«idahopower.com E-MAIL: ttatumC&idahopower.com
c asc henbrenneraw id ahopo wer.com
ganderson0midahopower.com
PATRICIA JORDAN, SE,ZRETARY
CERTIFICATE OF SERVICE