20160930Staff 1-29 to IPC.pdf

BRANDON KARPEN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 7956
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
IDAHO POWER COMPANY FOR DEFERRAL )
AND RECOVERY COSTS ASSOCIATED WITH )
PARTICIPATION IN AN ENERGY )
IMBALANCE MARKET )
)
) __________________ )
CASE NO. IPC-E-16-19
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
IDAHO POWER COMPANY
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Brandon Karpen, Deputy Attorney General, request that Idaho Power Company (Company;
Idaho Power) provide the following documents and information as soon as possible, by
FRIDAY, OCTOBER 21, 2016.
This Production Request is 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 produced.
Please provide answers to each question, 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 if need be. IDAP A
31.01.01.228.
FIRST PRODUCTION REQUEST
TO IDAHO POWER SEPTEMBER 30, 2016
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. 1: Please provide line item detail for the $1.73 M startup cost estimate.
For each item, please provide a description of the cost, the basis for the estimates, and explain
how the Company will ensure that it is least cost. Please provide copies of all contracts and
invoices to date.
REQUEST NO. 2: Please provide line item detail for the $7.88 M software integration
cost estimate. For each item, please provide a description of the cost, the basis for the estimates,
and explain how the Company will ensure that it is least cost. Please provide copies of all
contracts and invoices to date.
REQUEST NO. 3: Please provide line item detail for the $1.48 M metering cost
estimate. For each item, please provide a description of the cost, the basis for the estimates, and
explain how the Company will ensure that it is least cost. Please provide copies of all contracts
and invoices to date.
REQUEST NO. 4: Please provide job descriptions and estimated salaries and overhead
for each of the six employees the Company included as labor necessary to operate as an EIM
participant.
REQUEST NO. 5: Are the six employees included in the Company's proposal
incremental to current headcount? Please explain. Will the Company require six full-time
employees before or upon start-up in April 2018 or will employees be phased into EIM over a
period of time?
REQUEST NO. 6: Please explain if any duties performed by employees currently
operating in a non-EIM environment be eliminated once the Company begins operating in an
EIM environment.
FIRST PRODUCTION REQUEST
TO IDAHO POWER 2 SEPTEMBER 30, 2016
REQUEST NO. 7: Based on Kathleen Anderson's testimony detailing benefits through
the EIM relative to the planning and managing of congestion, please provide a list of curtailed
energy purchases attributable to transmission path congestion over the past year. For each
occurrence, please provide the amount and cost of the energy curtailed, as well as the type of
resource, and the amount and cost of energy from the alternate resource ultimately used to
balance load.
REQUEST NO. 8: For each of the occurrences listed in the previous question, please
explain if and how participating in the EIM would have prevented the use of the higher cost
alternate source.
REQUEST NO. 9: Please provide electronic versions of exhibits included in the
original application. Also, please provide any worksheets used to derive inputs or constants
within the exhibits. Please provide all worksheets with formulas intact.
REQUEST NO. 10: Based on Kathleen Anderson's testimony (p. 5), please provide
data illustrating that "the Company is at its limits of system integration capabilities given the
proliferation of existing intermittent Public Utility Regulatory Policies Act of 1978 wind and
anticipated solar generation beginning in 2016."
REQUEST NO. 11: Based on Kathleen Anderson's testimony (p. 6), please provide
data illustrating the reduction in bilateral market liquidity for up to two hours prior to the next
operating hour due to the expansion of the EIM.
REQUEST NO. 12: Based on Kathleen Anderson's testimony (p. 10), please describe
and define a "determined default energy bid." How is that different than an EIM market bid,
how is it used in the EIM market in place of a conventional EIM bid, and how is the amount
determined for each resource?
REQUEST NO. 13: Please explain how the E3 model was verified and validated to
ensure it reflects how the electricity system operates in reality.
FIRST PRODUCTION REQUEST
TO IDAHO POWER 3 SEPTEMBER 30, 2016
REQUEST NO. 14: Please provide all worksheets (with formulas intact) for any
analysis performed as a result or related to the E3 study. This should include the allocation of
benefits between the Company and other EIM participants for each of the modeled scenarios.
REQUEST NO. 15: Please provide a copy of model inputs, model outputs, and all
reports completed as a result of the E3 study. This should include a comprehensive list of
assumptions ( e.g. IPC participating generation resources bid into the market, gas prices,
electricity prices, costs, bid strategy/values etc.) used for each of the scenarios modeled: base
scenario, no APS or PGE, early coal retirement, and high RPS case.
REQUEST NO. 16: Please provide a breakdown of the net benefits by purchases and
off-system sales for each of the E3 modeled scenarios. For the amount of purchases, please
provide the amount of energy (MWh) and dollar amounts purchased. For the amount of off­
system sales, please provide the amount of energy (MWh) and the dollar amounts sold for each
of the Company's participating generation resources.
REQUEST NO. 17: Based on Tim Tatum's testimony (p. 5), please explain and provide
E3 model output data that quantifies benefits. Specifically, please show model output comparing
model runs with Idaho Power as an EIM participant and as a non-participant demonstrating: (1)
increased surplus sales, (2) improved transmission congestion, and (3) more efficient integration
of renewable resources.
REQUEST NO. 18: In Kathleen Anderson's testimony (p. 16), the estimated cost of
production for the Company's resources was used instead of market-based rates in the E3 model.
Was the cost of production used for all resources across all BA' s modeled and was this applied
to purchases the Company made in balancing its resources? Please explain.
REQUEST NO. 19: Does the E3 model take into account stream flows and water
availability constraints of the Company's hydro resources included as EIM participating
resources? If not, please explain why not? If so, please provide the assumptions used and
explain how the model takes this into account.
FIRST PRODUCTION REQUEST
TO IDAHO POWER 4 SEPTEMBER 30, 2016
REQUEST NO. 20: Please provide levels of natural gas prices, water availability,
market electricity prices, number of balancing area participants, and renewable penetration that
produces a negative net benefit through the E3 production model.
REQUEST NO. 21: In Kathleen Anderson's testimony (p. 12), she describes how added
participation will benefit participants of the western EIM. Did the Company or E3 quantify the
impacts to EIM only participants if some participants, such as PacifiCorp, also joins the regional
ISO (i.e. CAISO)? If so, please provide the results and analysis. If not, please explain why not.
REQUEST NO. 22: Please provide an estimate showing how the Company's
participation in the Western EIM could impact reserve margin and reliability.
REQUEST NO. 23: Please explain why the sub-hourly dispatch cost savings from the
E3 model are not consistent with the sales revenues shown on line 12 of Exhibit No. 1.
REQUEST NO. 24: In Kathleen Anderson's testimony (p. 9), she states that if Idaho
Power does not obtain market based rate authority from FERC, it would not have a material
impact to Idaho Power's customers. Please explain what is meant by a "material impact."
Furthermore, please explain how there would be any impact to customers if a utility is paid the
settled market price for energy bid into the market, regardless of whether it operates under
market-based rate authority or a default energy bid.
REQUEST NO. 25: Please provide a detailed description and the basis for the annual
software fees of $786,000 per year (i.e., is it calculated based on number of meters or customer
count?). Is this an annual contracted rate, and if so, how long is the initial contract and how will
subsequent contract rates be determined? What services are included in this annual fee (updates,
support, etc.)? What would drive increased software fees in the future?
REQUEST NO. 26: Please provide a detailed breakdown of software integration costs
and any documentation to support the amount (stated to be half the expected capital costs in
Kathleen Anderson's'testimony (p. 21, I. 6-9)).
FIRST PRODUCTION REQUEST
TO IDAHO POWER 5 SEPTEMBER 30, 2016
REQUEST NO. 27: Please provide details of consulting expenses for the System
Integrator needed throughout the integration process. Please provide documentation of total
expected costs and timeline for this service. Also, testimony by Kathleen Anderson (p. 21 ,
I. 11-13) states that the System Integrator has already been engaged. Are these costs included in
the $11.09 million of upfront costs? Please explain.
REQUEST NO. 28: What measures are in place to insure the proposed $15.77 million
of costs to join the EIM is not exceeded?
REQUEST NO. 29: What is the future nomination process for EIM Governing Board
Members? What are the length of terms for each Board Member?
Dated at Boise, Idaho, this ~C)~ day of September 2016.
Technical Staff: Mike Louis/1-20
Matt Elam/21-24
Barbara Romano/25-29
i:umisc:prodreq/ipce I 6. I 9bkmlmebr prod req I
FIRST PRODUCTION REQUEST
TO IDAHO POWER 6
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SEPTEMBER 30, 2016
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 30TH DAY OF SEPTEMBER 2016,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY IN CASE NO. IPC-E-16-19,
BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
JULIA A HILTON
REGULATORY DOCKETS
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-mail: [e-mail]
[e-mail]
PETER J RICHARDSON
GREGORY M ADAMS
RICHARDSON ADAMS PLLC
PO BOX 7218
BOISE ID 83702
E-mail: [e-mail]
[e-mail]
MATT LARKIN
IDAHO POWER COMPANY
POBOX70
BOISE ID 83707-0070
E-mail: [e-mail]
DR DON READING
6070 HILL ROAD
BOISE ID 83703
E-mail: [e-mail]
SECRETAR
CERTIFICATE OF SERVICE