20140724Staff 1-4 to IPC.pdf

KRISTINE A. SASSER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03s7
BAR NO. 6618
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION TO UPDATE ITS
WIND INTEGRATION RATES AND
CHARGES.
Dtrr-tr l\/Fnl\t-l/L
20lr{ JUL 2t+ PH 3: l5
IflL!"lr'! :i:ll ] l:.
r ri tiliit s-i; ii,l *t t ss lr:il
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC.E.I3-22
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
IDAHO POWER COMPAI\"Y
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Kristine A. Sasser, Deputy Attorney General, requests that Idaho Power Company (Company)
provide the following documents and information on or before THURSDAY, AUGUST 14, 201.4.
This Production Request is to be considered as continuing, and Idaho Power 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 produced.
Please provide answers to each question and any supporting workpapers that provide detail or
are the source of information used in calculations. The Company is reminded that responses pursuant
to Commission Rules of Procedure must include the name and phone number of the person preparing
the document, and the name, location and phone number of the record holder and, if different, the
witness who can sponsor the answer at hearing. Reference IDAPA 3I.01.01.228.
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic files on CD with formulas activated.
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY I JULY 24,2014
REQUEST NO. 1: Please provide a copy of the spreadsheet used to derive the levelized and
non-levelized wind integration charges shown on the proposed Schedule 87. Please state the
escalation rate used to derive the non-levelized rates and discuss why that rate was chosen. Please
also state the discount rates used in the calculations and discuss why that rate was chosen.
REQUEST NO. 2: Idaho Power discusses in its Reply Comments its decision to base its
analysis of integration costs on day-ahead rather than hour-ahead forecasts. Does Idaho Power
believe there could be integration costs associated with both hour-ahead and day-ahead forecasting
errors? Does Idaho Power believe the method it used in its 2013 Wind Integration Study captures
integration costs associated with hour-ahead forecasting errors?
REQUEST NO.3: On page 9 of AWEA and Renewable Northwest's comments it states "As
the wind comes up, a utility will back off more expensive generation previously made available in the
day-ahead time frame to meet load, which saves the utility operating costs. As the wind drops off, a
utility will increase the use of its more expensive generation, hour-by-hour, adjusting for the wind's
output and mindful to not use any more higher-cost generation than necessary." If both the utility's
day-ahead and hour-ahead wind forecasts were perfectly accurate, but the utility still had to back
down more expensive generation resources in order to receive wind generation (or alternatively, less
expensive resources), would Idaho Power consider these to be integration costs? How would these
costs be captured by the utility if they are not considered integration costs? Does Idaho Power
believe these costs would be captured by a wind integration study performed using Idaho Power's
method or the method recommended by AWEA and Renewable Northwest? Does Idaho Power
believe these costs are captured in either the SAR or IRP methodologies employed by the
Commission for calculating avoided cost rates?
REQUEST NO. 4: Under the proposal described in Idaho Power's Reply Comments, how
would wind integration charges be assigned in instances in which the proposed project's capacity
straddled a penetration level in the tariff? For example, what would be the integration charge for a
proposed 40 MW project if the current wind penetration level on Idaho Power's system is 678 MW?
Would the project be assigned the integration charge for the 601-700 penetration level, the 701-800
level, or a prorated amount?
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY JULY 24,2014
Dated at Boise,Idaho, fin ?luday of Juty 2014.
Technical Staff: Rick Sterling
i:umisc:prodreq/ipcel3.22ksrps prod req I
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY
Deputy Attorney General
ruLY 24,2014
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 24th DAY OF JULY 2014,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY, IN CASE NO. IPC-E-I3-
22, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
DONOVAN E WALKER MICHAEL J YOUNGBLOOD
REGULATORY DOCKETS GREG SAID
IDAHO POWER COMPANY IDAHO POWER COMPANY
PO BOX 70 PO BOX 70
BOISE ID 83707-0070 BOISE ID 83707-0070
E-MAIL: dwalker@,idahopower.com E-MAIL: [e-mail]@idahopower,com [e-mail]
DEAN J MILLER RICK KOEBBE PRESIDENT
McDEVITT & MILLER LLP IDAHO WINDS LLC
420 W BANNOCK ST 5420 W WICHER RD
BOISE ID 83702 GLENNS FERRY ID 83623
E-MAIL: [e-mail] E-MAIL: [e-mail]
KEN MILLER PETER J RICHARDSON
SNAKE RIVER ALLIANCE RICHARDSON ADAMS PLLC
PO BOX 1731 515 N 27TH STREET
BOISE ID 8370I BOISE ID 83702
E-MAIL: [e-mail] E-MAIL: [e-mail]
BENJAMIN G HUANG MGR GREGORY M ADAMS
c/o MOUNTAIN AIR PROJECT RICHARDSON ADAMS PLLC
6000 N FOXTAIL WAY 515 N 27TH STREET
GLENNS FERRY ID 86623 BOISE ID 83702
E-MAIL: [e-mail] E-MAIL: [e-mail]
PAUL ACKERMAN TERESA A HILL
ASST GENERAL COUNSEL K&L GATES LLP
EXELON BUSINESS SER CORP ONE SW COLUMBIA ST
IOO CONSTELLATION WAY STE I9OO
BALTIMORE MD 21202 PORTLAND OR 97258
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE
DINA M DUBSON
RENEWABLE NW PROJECT
421 sw 6ffi AvE srE l r25
PORTLA}'{D OP.972O4
E-MAIL: dina@nrp,org
DEBORAH E NELSON
PRESTON N CARTER
GTVENS PURSLEY LLP
POBOX2720
BOISE ID 8370t-2t20
E-MAIL: [e-mail]
prestoncarter@ givenspursley. com
CERTIFICATE OF SERVICE