20161101Staff 30-34 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
REC EIVED
20 Hi m / -I AM 11 : 2 3
: -, . : I ) H.J J L! C
I! .r". 1:~ ,/MISSION
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
SECOND PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
IDAHO POWER COMPANY
The Staff of the Idaho Public Utilities Commission, by and through its attorney ofrecord,
Brandon Karpen, Deputy Attorney General, request that Idaho Power Company (Company;
Idaho Power) provide the following documents and information as soon as possible, by
TUESDAY, NOVEMBER 22, 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. 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. ID APA 31.01.01.228.
SECOND PRODUCTION REQUEST
TO IDAHO POWER 1 NOVEMBER 1, 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. 30: On page 22 of Ms. Anderson's Testimony, she states "revenue
quality meters will be required on generation units that Idaho Power chooses not to be available
for dispatch in the western EIM." Are the full costs of revenue quality meters and transformers
for non-participating generation units included in the Company's total cost estimates? If so,
please explain where they are provided. If not, please explain why the costs were not included
and provide the estimated cost for non-participating generation units. For each item, please
provide a description of the cost, and the basis for the estimates.
REQUEST NO. 31: For both participating and non-participating generation units,
please explain whether the meter requirements for EIM participation are also adequate for
participation in the regional ISO (i.e. -CAISO). If not, please explain the differences (including
costs). Furthermore, please explain how the Company plans to utilize a least cost approach for
meter replacements if the EIM and regional ISO have different requirements. Please provide all
analysis supporting the Company's approach.
REQUEST NO. 32: The Implementation Agreement allows EIM participants to
terminate the agreement, provided participants have first entered into good faith discussion for
thirty days in an effort to resolve any differences. Has Idaho Power or E3 evaluated the possible
impacts to EIM participants if any participants terminate their Implementation Agreement? If so,
please provide the analysis and explain the results. If not, please explain why not.
REQUEST NO. 33: The CAISO derives a rate that allocates total implementation costs
($19 .65 million) to potential EIM participants according to their proportional share of the total
WECC load (excluding CAISO's load), using data reported to WECC. Please explain why
CAISO's load is excluded for cost allocation purposes. Furthermore, please explain how the
data reported to WECC is verified and determined to be reasonably accurate. Also, please
explain the schedule and process for updating the data and EIM cost allocation. Please provide
all the load data currently used to allocate EIM costs to participants.
SECOND PRODUCTION REQUEST
TO IDAHO POWER 2 NOVEMBER 1, 2016
REQUEST NO. 34: Net energy for load is reported to WECC annually by each
balancing authority area, and is used by WECC to allocate its reliability costs to each balancing
authority area. Please explain why CAISO allocates EIM costs based on 2013 load data instead
of using the more recent data used to allocate WECC reliability costs.
Dated at Boise, Idaho, this ~I
l v day of November 2016.
Technical Staff: Matt Elam/30-34
°i:umisc:prodreq/ipce l 6. l 9bkme prod req2
SECOND PRODUCTION REQUEST
TO IDAHO POWER
~r,=~-i: ..... ,cupen
Deputy Attorney General
3 NOVEMBER 1, 2016
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 1sr DAY OF NOVEMBER 2016,
SERVED THE FOREGOING SECOND 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 MADAMS
RICHARDSON ADAMS PLLC
PO BOX 7218
BOISE ID 83702
E-mail: [e-mail]
[e-mail]
KEN MILLER
SNAKE RIVER ALLIANCE
223 N 6TH ST STE 317
PO BOX 1731
BOISE ID 83701
E-mail: [e-mail]
MATT LARKIN
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-mail: [e-mail]
DR DON READING
6070 HILL ROAD
BOISE ID 83703
E-mail: [e-mail]
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
710 N 6TH STREET
BOISE ID 83702
E-mail: [e-mail]
CERTIFICATE OF SERVICE
I