20140205IPC to Simplot 1-6.pdf

Stffi*.
An IDACORP Companv
"r'1' .l'IIr
DONOVAN E. WALKER
Lead Counsel
February 5,2014
VIA HAND DELIVERY
Jean D. Jewell, Secretary
ldaho Public Utilities Commission
472 W est Washington Street
Boise, ldaho 83702
Re: Case No. IPC-E-13-21
ldaho Power Company's SAR Capacity Sufficiency ldaho Power
Company's Responses to the First Production Requests of the J. R. Simplot
Company
Dear Ms. Jewel!:
Enclosed for filing in the above matter are an original and three (3) copies of ldaho
Power Company's Responses to the First Production Requests of the J. R. Simplot
Company to ldaho Power Company. Also enclosed are four (4) copies of a non-
confidential disk containing information responsive to these production requests.
Donovan E. Walker
DEW:csb
Enclosures
'1221 W. ldaho St. (83702)
PO. Box 70
Boise, lD 83707
DONOVAN E. WALKER (lSB No. 5921)
ldaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
dwal ker@ id ahopower. com
Attorney for ldaho Power Company
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR
APPROVAL OF ITS CAPACITY
DEFIC]ENCY PERIOD TO BE UTILIZED IN
THE COMPANY'S SAR METHODOLOGY.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-13-21
IDAHO POWER COMPANY'S
RESPONSES TO THE FIRST
PRODUCTION REQUESTS OF
THE J. R. SIMPLOT COMPANY
TO IDAHO POWER COMPANY
COMES NOW, ldaho Power Company ("ldaho Powe/' or "Company"), and in
response to the First Production Requests of the J. R. Simplot Company to ldaho Power
Company dated January 15,2014, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSES TO THE FIRST PRODUCTION
REQUESTS OF THE J. R. SIMPLOT COMPANY TO IDAHO POWER COMPANY - ,I
REQUEST FOR PRODUCTION NO. 1: Please provide, in electronic format
where possible with formulas intact the models and spreadsheets that were used to
produce Table 2, page 3 of the Application in this docket (!PC-E-13-21).
RESPONSE TO REQUEST FOR PRODUCTION NO. 1: Please see the Excel
file provided on the enclosed CD.
The response to this Request is sponsored by Phil DeVol, Resource Planning
Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO THE FIRST PRODUCTION
REQUESTS OF THE J. R. SIMPLOT COMPANY TO IDAHO POWER COMPANY - 2
REQUEST FOR PRODUCTION NO. 2: Please provide, ln electronic format
where possible and with formulas intact, the models and spreadsheets that were used
to produce Table 3, page 4 of the Application in this docket (lPC-E-13-21).
RESPONSE TO REQUEST FOR PRODUCTION NO. 2: Please see the Excel
file provided on the enclosed CD.
The response to this Request is sponsored by Phil DeVol, Resource Planning
Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO THE FIRST PRODUCTION
REOUESTS OF THE J. R. SIMPLOT COMPANY TO IDAHO POWER COMPANY - 3
REQUEST FOR PRODUCTION NO. 3: Please provide on an annual basis for
the years 2013 through 2020, the expected MW reduction in peak and projected cost of
each of the Company's demand response programs (A/C Cool Credit, lrrigation Peak
Rewards, FlexPeak Management) used to find the peak-hour surpluses displayed in
Table 3, page 4 of the Application in this docket (IPC-E-13-21). Please display the
projections for each program separately.
RESPONSE TO REQUEST FOR PRODUCTION NO. 3: Table 3 in ldaho
Power's Application reflects up to 440 megawatts ("MW") of peak hour reduction
resulting from the Company's three demand response programs. ln 2013, ldaho Power
achieved approximately 48 MW of peak load reduction from its FlexPeak Management
program. The Company is confident that it can satisfy the deficits as shown on Table 2
in its Application with its existing demand response programs if necessary. Through its
recent Demand Response Settlement Agreement, ldaho Power is required to offer all
existing participants the opportunity to participate, which could add up to 440 MW of
peak reduction. The settlement agreement requires the Company allow 2012levels of
participation. ln 2012, the Company had a demand response capacity of 438 MW from
its demand response programs, as noted on page 143 of ldaho Poweds Demand-Side
Management 2012 Annual Report, which was filed with the Idaho Public Utilities
Commission ("Commission") on March 15,2012, and can viewed via the following link:
https:/iwww.idahopower.com/pdfs/AboutUs/RatesRequlatorv/Reports/S5.pdf.
The response to this Request is sponsored by Pete Pengilly, Customer Research
and Analysis Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO THE FIRST PRODUCTION
REQUESTS OF THE J. R. SIMPLOT COMPANY TO IDAHO POWER COMPANY.4
REQUEST FOR PRODUCTION NO. 4: Refer to ldaho Power's 2013 IRP at p.
40, stating:
Figure 4.3 shows the annual demand response program
capacity between 2OO4 and 2012. The large jump in
demand response capacity from 61 MW in 2008 to 218 MW
in 2009 was a result of transitioning the majority of the
lrrigation Peak Rewards program to a dispatch program.
The demand response capacity in 2011 and 2012 included
320 and 340 MW of capacity from the lrrigation Peak
Rewards program, respectively, which was not used based
on the lack of need and the cost to dispatch.
a. Please provide the percentage of overall demand response capacity and
the amount in MW reduction in peak that "was not used based on the lack of need and
the cost to dispatch," as noted in the above passage from the lRP.
b. Please provide the annual demand response capacity (MW) of ldaho
Power's lrrigation Peak Rewards program that was assumed to derive the peak-hour
surpluses displayed in Table 3, page 4 of the Application in this docket (IPC-E-13-21).
c. For the figures supplied in subpart b. regarding the Irrigation Peak
Rewards for the years 2013 through 2033, does the Company expect there will be any
change in the demand response capacity (MW) that will not be use based on "the lack
of need and the cost to dispatch"? lf so, please provide the change in percentage for
each year for the years 2013 through 2033.
RESPONSE TO REQUEST FOR PRODUCTION NO. 4:
a. ln 2011 and 2012, ldaho Power had 320 MW and 340 MW of capacity
available from the Irrigation Peak Rewards program, respectively, which represents 79
and 78 percent of total available remand respond capacity for 2011 and 2012.
IDAHO POWER COMPANY'S RESPONSES TO THE FIRST PRODUCTION
REQUESTS OF THE J. R. SIMPLOT COMPANY TO IDAHO POWER COMPANY - 5
b. Please see the Company's response to J. R. Simplot Company's Request
for Production No. 3.
c. Yes. The Irrigation Peak Rewards program ("Program") was temporarily
suspended in 2013 per Commission Order No. 32776, so it was not available. The
Program was redesigned per Commission Order No. 32923. The redesign of the
Program includes three dispatches of the Program under the fixed incentive; thus, the
Company anticipates that it will use the Program at least three times each season and
utilize all programs up to their maximum capacity.
The response to this Request is sponsored by Pete Pengilly, Customer Research
and Analysis Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO THE FIRST PRODUCTION
REQUESTS OF THE J. R. SIMPLOT COMPANY TO IDAHO POWER COMPANY - 6
REQUEST FOR PRODUCTION NO. 5: Refer to Table 3, page 4 of the
Application in this docket (lPC-E-13-21).
a. Please provide the assumed on-line date for the Boardman to Hemingway
transmission line for purposes of producing this table.
b. Please provide the current expected on-line date of the Boardman to
Hemingway transmission line and identify the source of the current projection.
c. lf the on-line date Boardman to Hemingway transmission line is delayed
beyond current expected on-line date, how does the Company expect to meet the peak-
hour deficits that would occur due to the delay?
RESPONSE TO REQUEST FOR PRODUGTION NO. 5:
a. The assumed on-line date for the Boardman to Hemingway transmission
line for purposes of producing this table is the year 2018 (per Table 1.1 Action Plan,
page 9 of ldaho Powe/s 2Ol3lntegrated Resource Plan).
b. The IDACORP, lnc., third quarter 2013 10-Q (page 58, first paragraph,
last sentence) indentifies the current expected on-line date of the Boardman to
Hemingway transmission line as "2020 or beyond."
c. lf the on-line date of the Boardman to Hemingway transmission line is
delayed beyond the current expected on-line date, ldaho Power's 2013 lntegrated
Resource Plan (page 114, second paragraph, last sentence) states that "ldaho Power
intends to use demand response programs to adapt to schedule variations that may
occur on the Boardman to Hemingway project."
The response to this Request is sponsored by Phi! DeVol, Resource Planning
Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO THE FIRST PRODUCTION
REQUESTS OF THE J. R. SIMPLOT COMPANY TO IDAHO POWER COMPANY - 7
REQUEST FOR PRODUCTION NO. 6: Assuming the Commission accepts the
peak-hour deficits filed by ldaho Power in this docket and using the currently approved
inputs for all other variables, please provide the levelized and non-levelized avoided
costs rates for contract lengths 1 through 20 years for:
Wind projects (100 kW or smaller),
Solar projects (100 kW or smaller),
Non-Seasonal Hydro projects (smallerthan 10 aMW),
Seasonal Hydro projects (smaller than 10 aMW),
e. Other projects (smallerthan 10 aMW)
RESPONSE TO REQUEST FOR PRODUCTION NO. 6: ldaho Power is unable
to respond to this Request as the surrogate avoided resource published avoided cost
model used to calculate the rates requested above is operated and maintained by
Commission Staff.
The response to this Request is sponsored by Randy C. Allphin, Energy
Contracts Leader, ldaho Power Company.
DATED at Boise, ldaho, this 5th day of February 2014.
IDAHO POWER COMPANY'S RESPONSES TO THE FIRST PRODUCTION
REQUESTS OF THE J. R. SIMPLOT COMPANY TO IDAHO POWER COMPANY. S
a.
b.
AN E. WALKER
Attorney for ldaho Power Company
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 56 day of February 2014 I served a true and
correct copy of IDAHO POWER COMPANY'S RESPONSES TO THE FIRST
PRODUCTION REQUESTS OF THE J. R. SIMPLOT COMPANY TO IDAHO POWER
COMPANY upon the following named parties by the method indicated below, and
addressed to the following:
Commission Staff
Kristine A. Sasser
Deputy Attorney General
ldaho Public Utilities Commission
472 West Washington (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
J. R. Simplot Company
Peter J. Richardson
Gregory M. Adams
RICHARDSON ADAMS, PLLC
515 North 27th Street
Boise, ldaho 83702
Dr. Don Reading
6070 Hi!! Road
Boise, ldaho 83703
X Hand Delivered
U.S. Mail
Overnight Mail
FAXX Email [e-mail]
Hand Delivered
U.S. Mai!
Overnight Mail
FAXX Email peter@ richard sonadams. com
o req@richard sonadams. com
X
Hand Delivered
U.S. Mail
Overnight Mail
FAXX Email [e-mail]
IDAHO POWER COMPANY'S RESPONSES TO THE FIRST PRODUCTION
REQUESTS OF THE J. R. SIMPLOT COMPANY TO ]DAHO POWER COMPANY - 9