20171010IPC to Renewable Energy Coalition 1-2.pdf

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An IDACORP Companv
LISA D. NORDSTROM
Lead Counsel
I [e-mail]
October 9,2017
VIA HAND DELIVERY ON 10-10-17
Diane M. Hanian, Secretary
ldaho Public Utilities Commission
472Wesl Washington
Boise, ldaho 83702
Re Case No. IPC-E-17-11
2017 lntegrated Resource Plan - ldaho Power Company's Response to the
First Production Request of Renewable Energy Coalition
Dear Ms. Hanian:
Enclosed forfiling in the above matter please find an originaland three (3) copies of
ldaho Power Company's Response to the First Production Request of Renewable Energy
Coalition.
Also enclosed are four (4) copies of a non-confidential disk containing information
responsive to Renewable Energy Coalition's production request.
Very truly yours,
U2*-c@
Lisa D. Nordstrom
LDN:csb
Enclosures
1221 W. ldaho St. (83702)
P.O. Box 70
Boise, lD 83707
LISA D. NORDSTROM (lSB No. 5733)
ldaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
I n ord strom @ ida h opower. com
Attorney for ldaho Power Company
BEFORE THE ]DAHO PUBLIC UT!LITIES COMMISSION
!N THE MATTER OF IDAHO POWER
COMPANY'S 201 7 INTEGRATED
RESOURCE PLAN
CASE NO. IPC-E-17-11
IDAHO POWER COMPANY'S
RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
REN EWABLE ENERGY COALITION
COMES NOW, ldaho Power Company ("ldaho Power"), and in response to the
First Production Request of Renewable Energy Coalition to ldaho Power Company
dated September 18,2017, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF RENEWABLE ENERGY COALITION - 1
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REQUEST FOR PRODUCTION NO. 1: Please provide all discovery responses
and other materials produced in discovery in this docket. This is an ongoing request.
RESPONSE TO REQUEST FOR PRODUCTION NO. 1: To date, the only
discovery propounded in this case is Renewable Energy Coalition's ("REC") First
Production Request to ldaho Power. As a matter of course, copies of ldaho Power's
responses to discovery requests in this case will be provided to the parties.
The response to this Request is sponsored by Christa Bearry, Legal Assistant,
ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF RENEWABLE ENERGY COALITION - 2
REQUEST FOR PRODUCTION NO. 2: Please provide all discovery responses
and other materials produced in discovery in docket IPC-E-17-12. This is an ongoing
request.
RESPONSE TO REQUEST FOR PRODUCTION NO. 2: Attached are ldaho
Power Company's Response to the First Production Request of the Commission Staff
and ldaho Power Company's Response to the Second Production Request of the
Commission Staff. These are the entirety of the responses provided in Case No.
lPc-E-17-12.
The response to this Request is sponsored by Christa Bearry, Legal Assistant,
ldaho Power Company.
DATED at Boise, ldaho, this 9th day of October 2017.
X,*p %,,at,-,.,-,
LISA D. NORDSTRONP
Attorney for ldaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REOUEST OF RENEWABLE ENERGY COALITION - 3
CERTIFICATE OF SERVICE
! HEREBY CERTIFY that on this 9th day of October 2017 I served a true and
correct copy of IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF RENEWABLE ENERGY COALITION upon the following
named parties by the method indicated below, and addressed to the following:
Commission Staff
Sean Costello
Deputy Attorney General
ldaho Public Utilities Commission
47 2 W est Washington (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
lndustrial Gustomerc of ldaho Power
Peter J. Richardson
RICHARDSON ADAMS, PLLC
515 North 27th Street (83702)
P.O. Box 7218
Boise, ldaho 83707
Dr. Don Reading
6070 Hill Road
Boise, ldaho 83703
Sierra Club
Gloria D. Smith
Sierra Club
2101 Webster Street, Suite 1300
Oakland, California 94612
ldaho lrrigation Pumpers Association, lnc.
Eric L. Olsen
ECHO HAWK & OLSEN, PLLC
505 Pershing Avenue, Suite 1OO
P.O. Box 6119
Pocatello, ldaho 83205
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Anthony Yankel
12700 Lake Avenue, Unit 2505
Lakewood, Ohio 44107
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IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF RENEWABLE ENERGY COALITION - 4
!dahydro
C. Tom Arkoosh
ARKOOSH LAW OFFICES
802 West Bannock Street, Suite 900
P.O. Box 2900
Boise, ldaho 83701
Micron Technology, lnc.
Thorvald A. Nelson
Emanuel T. Cocian
Kim Stanger
HOLLAND & HART, LLP
6380 South Fiddlers Green Circle, Suite 500
Greenwood Village, Colorado 80111
Pete Bennett
Micron Technology, lnc.
8000 South FederalWay
Boise, ldaho 83707
STOP B2H
Brad M. Purdy
Attorney at Law
2019 North 17th Street
Boise, ldaho 83702
Renewable Energy Coalition
Gregory M. Adams
RICHARDSON ADAMS, PLLC
515 North 27th Street (83702)
P.O. Box 7218
Boise, Idaho 83707
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erin. ceci l@arkoosh. com
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etcocian@ holland hart. com
kcsta nqer@ hol land ha rt. com
kl ha I l@ hol land ha rt. com
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, Legaln
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF RENEWABLE ENERGY COALITION - 5
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BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
GASE NO. IPC-E-17-11
IDAHO POWER COMPANY
RESPONSE TO REC'S
REQUEST FOR PRODUCTION NO.2
DONOVAN E. WALKER (lSB No. 5921)
ldaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
dwalker@ ida hopower. com
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Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
APPROVAL OF THE CAPACIry
DEFICIENCY TO BE UTILIZED FOR
AVOI DED COST CALCULATIONS.
CASE NO. IPC-E-17-12
IDAHO POWER COMPANY'S
RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
THE COMMISSION STAFF
COMES NOW, ldaho Power Company, and in response to the First Production
Request of the Commission Staff to ldaho Power dated August 10, 2017, herewith
submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 1
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REQUEST NO. 1: Please provide the peak-hour monthly deficits with existing
DSM and existing resource data (that support Table 1 in the Application) in Excel
format.
RESPONSE TO REQUEST NO. 1: Please see the Excel file on the enclosed
CD which contains the peak-hour load and resource balance data from the 2017
lntegrated Resource Plan, Appendix C: Technical Report.
The response to this Request is sponsored by Michael Darrington, Energy
Contracts Leader, ldaho Power Company.
DATED at Boise, ldaho, this 1sth day of August 2017 .
d*r
DONOVAN E. WALKER
Attorney for ldaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 2
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 15th day of August 2017 I served a true and
correct copy of IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF upon the following named
parties by the method indicated below, and addressed to the following:
Commission Staff
Camille Christen
Deputy Attorney General
ldaho Public Utilities Commission
472 West Washington (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
X Hand Delivered
_U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
1
Christa Bearry,Assistant
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF.3
I
DONOVAN E. WALKER (lSB No. 5921)
ldaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: (208) 3886936
dwalker@ idahopower. com
r.:i
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
APPROVAL OF THE CAPACITY
DEFICIENCY TO BE UTILIZED FOR
AVOIDED COST CALCULATTONS
CASE NO. tPC-E-17-12
IDAHO POWER COMPANY'S
RESPONSE TO THE SECOND
PRODUCTION REQUEST OF
THE COMMISSION STAFF
COMES NOW, ldaho Power Company ("ldaho Power" or "Company"), and in
response to the Second Production Request of the Commission Staff to ldaho Power
dated August 31,2017, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF - 1
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REQUEST NO. 2: Please provide and explain the major drivers causing the first
capacity deficiency date to move from the currently authorized date of July 2024 to July
2026 as proposed by the Company. Specifically, but not limited to:
a. Please explain why "Adjustments for EE Potential Study Forecast" in the
load resource balance is reduced from an average 161 MW for July peak months from
2024 through 2026 in the 2015 IRP as compared to an average 1 I MW in the 2017 lRP.
b. Please explain the drivers causing the difference in Market Purchase
availability/transmission import capacity in the load resource balance between the 2015
IRP and 2017 IRP for months July 2024, July 2025, and July 2026. As part of the
explanation, please describe the specific rationale for each driver and/or any changes in
assumptions between the 2015lRP and the 2017 lRP.
RESPONSE TO REQUEST NO. 2:
a. Prior to each lntegrated Resource Plan ("lRP"), ldaho Power contracts
with a third-party consultant to produce an Energy Efficiency Potential Study,
sometimes called a Conservation Potential Study ("CPA"). ln 2014 and 2016, the
Company contracted with Applied Energy Group ('AEG'). AEG's CPA analysis begins
by estimating loads by end use assuming no energy efficiency programs are offered by
ldaho Power. Each study is "re-based" at the beginning year of the study. lt is
assumed that energy efficiency's cumulative demand reduction (and cumulative energy
reduction) from previous years is embedded in the Company's load forecast. Because
of the re-basing of each study and the fact that the demand reduction is cumulative, the
load reduction from one study's calendar year to another study's calendar year is not
comparable. Additionally, the total energy efficiency peak reduction potential by month
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF - 2
is the sum of the Load Forecast-included EE (line 2\ and the Adlustment for EE
Potential Study Forecast (line 4) from the 2017 IRP Peak-Hour Load and Resource
Balance analysis.
To compare the magnitude of estimated peak reduclion from one CPA study to
another, planning years must be considered. For instance, July 2024-2026 (planning
years 8-10) in the 2017 study would be analogous to July 2022-2024 (planning years 8-
10) in the 2015 lRP. As shown in the table below, this comparison yields an average of
220 megawatts ("MW') of estimated cumulative peak load reduction from energy
efficiency in the 2015 IRP compared to an average of 192 MWof estimated peak load
reduction from energy efficiency in the 2017 lRP, a decrease of 28 MW.
Two primary drivers in the reduction of the achievable energy efficiency potential
from the 2015 study to the 2017 study were the lower demand-side management
alternate costs, primarily caused by a lower gas price forecast, and the impact of the
Energy lndependence and Security Act ("E!SA") on lighting standards affecting lighting
potential. EISA essentially removes most savings potential from energy efficiency
lighting in 2020 as efficient lighting becomes the standard. However, it should be noted
that while these may be drivers in the decrease in the estimated peak load reduction for
the years 2024-2026, AEG estimates the cumulative on-peak load reduction from the
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF - 3
ldaho Power's 2017lRP tdaho Power's 2015lRP
Planning Juty IRPyear Year
8 2024s 202510 2026
Load Forecast-
included EE
{tlW)
149
172
199
Total
Total
(Mw)
168
197
215
575
192
for EE
Potential
Study
Forecast
{rdw)
19
2A
16
Total
(lvfw)
16S
235
251
659
220
Non- Existing
Forecasted DSM
Planning July IRP trended EE (EE)year Year (MW) (M\ l)
8 2A22 86 83
c 2023 125 11410 2024 134 117
Total
Average
energy efficiency achievable potential will increase over the IRP 2O-year planning period
from 473 MW in the 2015 lRPl to 483 MW in the 2017 lRP.2
b. The peak-hour load and resource balance for the 2015 and 2017 lRPs
contains the following values for the referenced line item:
2015 tRP 2017 tRP
239 MW July 2024 487 MW
261 MW July 2025 486 MW
257 MW July 2026 616 MW
Although the magnitude of the transmission capacity values appears to have
increased between the 2015 IRP and 2017 lRP, that is not the case. The apparent
differences are primarily a result in the assumptions included in each of the two lRPs
and the way the numbers are presented in the tables. Apart from these reasons, which
are discussed in detail below, the transmission capacity values are relatively
comparable.
For the 2017 lRP, the values shown on the line labeled "Transmission Capacity
Available for Market Purchases" include all the transmission capacity available for peak-
hour market purchases associated with the ldaho-Nevada path, the ldaho-Montana
path, and the ldaho-Northwest path. For the 2015 lRP, the values contained only the
amount of transmission capacity available and needed to eliminate or reduce the pre-
market-purchase deficit. For example, the transmission value for July 2024 shown in
the table in the 2015 IRP reflects only the amount of available transmission capacity
which was needed to eliminate the pre-market-purchase deficit, while the transmission
I IRP 2015, Appendix C, page 79.
2lRP 2017, Appendix C, page 67.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF - 4
value for July 2024 in the 2017 IRP reflects all of the transmission capacity available at
the time.
Another significant component of the apparent variation between the numbers in
the two lRPs is that for the 2017 IRP analysis, the Company assumed that the
transmission capacity on the ldaho-Nevada path would be available for peak-hour
market purchases following ldaho Power's exit from coal-fired operations at North
Valmy Unit 1 year-end 2019 and North Valmy Unit 2 year-end 2025. The assumed
peak-hour generating capacity of North Valmy is 263 MW, split evenly between the two
units; thus, for the 2017 lRP, the exit from each North Valmy coal unit is assumed to
make available for peak-hour market purchases half of the 263 MW of transmission
capacity (approximately 131 MW for July 2024 and July 2025 and 263 MW in July
2026). Discussion of the assumed peak-hour market purchases on the ldaho-Nevada
path is found on pages 68-69 of the 2017 lRP.
While the 2015 IRP preferred portfolio reflected ldaho Power's exit from coal-
fired operations at North Valmy year-end 2025, the Company's analysis did not include
an assumption that capacity on the ldaho-Nevada path would be available for peak-hour
market purchases in 2026.
Another component of the apparent variation between the transmission values
reflected in the 2015 and 2017 lRPs is that in ldaho Power's assessment of the regional
transmission interconnections for the 2017 lRP, the Company determined that an
additional 77 MW of transmission capacity on the ldaho-Montana path could be
assumed available for peak-hour market purchases in July 2024-2026. For the 2015
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF - 5
lRP, no transmission capacity on the ldaho-Montana path was included in the load and
resource balance.
The response to this Request is sponsored by Pete Pengilly, Customer Research
and Analysis Leader, ldaho Power Company, and Phil DeVol, Lead Planning Analyst,
ldaho Power Company.
DATED at Boise, ldaho, this 11th day of September 2017.
E. WALKER
Attorney for ldaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF - 6
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 11th day of September 2017 I served a true and
correct copy of IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF upon the following named
parties by the method indicated below, and addressed to the following:
Commission Staff
Camille Christen
Deputy Attorney General
ldaho Public Utilities Commission
472 West Washington (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
ldahydro
C. Tom Arkoosh
ARKOOSH LAW OFFICES
802 West Bannock Street, Suite 900
P.O. Box 2900
Boise, ldaho 83701
X Hand Delivered
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_FAXX Email [e-mail]
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erin. cecil@arkoosh. com
Christa Bea rry,Legal
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF - 7
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