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Home My WebLink About20250115Staff 21-30 to IPC.pdf RECEIVED Wednesday, January 15, 2025 12:02:10 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 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 ) 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 WEDNESDAY,JANUARY 29, 2025.' 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 1 Staff is requesting an expedited response. If responding by this date will be problematic,please call Staff s attorney at(208)334-0314. SECOND PRODUCTION REQUEST TO IDAHO POWER COMPANY 1 JANUARY 15, 2025 the person preparing the documents. Please also identify the name,job title, location, and telephone number 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. REQUEST NO. 21: Please respond to the following regarding Loss of Load Expectation("LOLE") reliability analyses for"Year 2028 before any adjustments" and"Year 2028 with adjustments of two Request for Proposal ("RFP")projects and industrial customers' load ramps". a. Please explain when these two analyses mentioned above were conducted. b. Please explain when the LOLE reliability analysis for the 2023 Integrated Resource Plan ("IRP") was conducted. c. Please provide the application status of the two RFP projects. d. Please explain whether these two RFP projects have been approved by the Commission. If not,please explain why these two RFP projects should be added as an adjustment to Year 2028. e. Please list all the projects that have not been approved by the Commission in the LOLE reliability analysis for Year 2028 and explain why they should be added in the analysis. f. Among all the projects that have not been approved, please specify the projects from previous RFPs. g. Please list all the industrial customers that will have load ramps in 2028. h. Please provide evidence that these industrial customers' load will ramp in 2028. i. Please explain the methodology used to annualize the impact of the industrial load ramp. j. Please provide the workpapers of the annualization process with formulas intact. REQUEST NO. 22: Please explain whether the capacity contribution of 18.44% is determined in the LOLE reliability analysis for Year 2028 with adjustments for the two RFP projects and industrial customers' load ramps. SECOND PRODUCTION REQUEST TO IDAHO POWER COMPANY 2 JANUARY 15, 2025 REQUEST NO. 23: Response to Production Request No. I I(a) states that the identified high Loss of Load Probability("LOLP")hours started with a baseline from the 2023 Integrated Resource Plan("IRP") and expanded hours to capture hours of higher irradiance. Please respond to the following. a. Please explain why the Company used high LOLP hours from the 2023 IRP as a baseline, which was based on the Year 2025. b. Please explain why the Company did not directly determine high LOLP hours based on the LOLP profiles of Year 2028 with adjustments of two RFP projects and industrial customers' load ramps. c. Please provide the identified high LOLP hours based on the LOLP profiles of Year 2028 with adjustments of two RFP projects and industrial customers' load ramps. d. When the Company added expanded hours to the baseline from the 2023 IRP, please explain how the expanded hours were determined. e. What does "irradiance" mean? Does it mean Plane of Array ("POA") Irradiance? f. Please provide the definition of POA and explain whether it represents the expected output of a solar facility. g. Please explain why the identified high LOLP hours should consider the timing of higher irradiance, instead of focusing on the system's high LOLP hours alone. h. Please explain the impact if the timing of higher irradiance is not considered. REQUEST NO. 24: The footnote of Attachment No. 3 of the Application states that the expanded hours were added to reduce the solar generation measurement variability. Please explain why the variability needs to be reduced and provide an example to illustrate how the variability can be reduced by adding the expanded hours. REQUEST NO. 25: Response to Production Request No. I I(a) states that "[h]aving a wider range of hours (more data points) in the performance ratio metric mitigates potential errors when dealing with small generation numbers (late evening hours and winter hours)without impacting the ELCC calculation." Does the statement mean if the expanded hours are not added, the data points for calculated each month's performance ratio will be too limited and thus the result will be inaccurate? If not, please explain in detail what the statement means. SECOND PRODUCTION REQUEST TO IDAHO POWER COMPANY 3 JANUARY 15, 2025 REQUEST NO. 26: Response to Production Request No. 15 (b) stated that"[t]he Interconnection Customer is entitled to a cash repayment, equal to the total amount paid to the Transmission Provider for the Network Upgrades for the non-usage sensitive portion of transmission charges..." Please explain what "the Network Upgrades for the non-usage sensitive portion of transmission charges"means. REQUEST NO. 27: Response to Production Request No. 13 shows a data point of 100% Effective Load Carrying Capability("ELCC") at 1.0 Performance Ratio. Please respond to the following. a. Please explain why the Company assumes ELCC should be 100% at 1.0 Performance Ratio. b. Under what circumstances is an ELCC typically assumed to be greater than 100% at 1.0 Performance Ratio? c. Under what circumstances is an ELCC typically assumed to be less than 100% at 1.0 Performance Ratio? d. The linear trendline equation included in Response No. 13 (a) will result in an ELCC greater than 100% at a 1.0 Performance Ratio. Please explain how it is possible to have an ELCC greater than 100% at a 1.0 Performance Ratio. REQUEST NO. 28: Response to Production Request No. 13 states that"linear interpolation between the data points is utilized, not the equation of the best-fit straight line." Please explain why linear interpolation between the data points is utilized, instead of the best-fit straight line. REQUEST NO. 29: In reference to Response to Production Request No. 13, please compare these three methods below for payment reduction rate calculation and explain the advantages and disadvantages of each method. 1. Using linear interpolation between the data points. 2. Using best-fit straight line. 3. Using best-fit straight line with constraint of 100% ELCC at a 1.0 Performance Ratio. SECOND PRODUCTION REQUEST TO IDAHO POWER COMPANY 4 JANUARY 15, 2025 REQUEST NO. 30: Please explain how to derive payment reduction rate from June through September with an example, when the performance ratio target is at least 0.95. DATED at Boise, Idaho, this 15th day of January 2025. A- A Chris Burdin Deputy Attorney General I:\Utility\UMISC\PRDREQ\IPC-E-24-42 PR#2.docx SECOND PRODUCTION REQUEST TO IDAHO POWER COMPANY 5 JANUARY 15, 2025 CERTIFICATE OF SERVICE I HEREBY CERTIFY THAT I HAVE THIS &DAY OF JANUARY 2025, SERVED THE FOREGOING SECOND 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(cidahopower.com PO BOX 70 dockets ckidahopower.com BOISE ID 83707-0070 energycontractskidahopower.com E-MAIL: ttatum agidahopower.com caschenbrennergidahopower.com gandersongidahopower.com PATRICIA JORDAN, ECRETARY CERTIFICATE OF SERVICE