20190530Staff 1-20 to IPC.pdf

EDWARD JEWELL
DEPUTY ATTORNEYS GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 10446
JACKPOT HOLDINGS, LLC, FOR THE SALE
AND PURCHASE OF UP TO 220 MEGAWATTS
OF RENEWABLE SOLAR GENERATION.
RECEIVED
,.019 ttAY 30 Pl{ hr tr9
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Street Address for Express Mail:
472W. WASHTNGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
rDAHO POWER COMPANY FOR APPROVAL )
OF A POWER PURCHASE AGREEMENT WITH)
CASE NO. IPC-E.I9.I4
)
)
)
)
)
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
IDAHO POWER COMPANY
The Staff of the Idaho Public Utilities Commission, by and through its attomey of record,
Edward Jewell, Deputy Attorney General, request that Idaho Power Company (Company) provide
the following documents and information as soon as possible, or by THURSDAY,
JUNE 20,2019.
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. Reference IDAPA
3t.0t.0t.228.
FIRST PRODUCTION REQUEST
TO IDAHO POWER I MAY 30,2019
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 files containing assumptions, inputs, outputs, and
summary information for all scenarios used in the Company's economic analysis described in
Larkin's direct testimony on page 11. For each scenario, provide a summary of the parameters
changed for each run.
REQUEST NO. 2: For the 24 portfolio simulations analyzed in the long-term capacity
expansion (LTCE), please provide the following:
a. The existing supply-side resources information input into the model. This should
include but not be limited to: nameplate capacity, capital cost, fixed and variable
O&M, etc.
b. The future supply-side resources available for selection in the model. This should
include but not be limited to: nameplate capacity, capital cost, fixed and variable
O&M, annual capacity factor, economic life, etc.
c. A summary of the individual resources selected and retired during the 20-year
planning period for each of the 24 portfolio simulations. This should include but not
be limited to: name/Identification of the individual resource, nameplate capacity
selected or retired, year of selection/retirement, how it was modeled (forced to retire
or allowed to float in the model), etc.
REQUEST NO. 3: In reference to lines l-3 on page 18 of Mr. Larkin's direct testimony,
both the Jackpot Solar and Franklin Solar Facilities were not selected in 10 of the 24 portfolio
simulations. Of those 10 portfolio simulations, 7 of the simulations did not include both the solar
facilities when Boardman-to-Hemingway (B2H) transmission line was included in the portfolio.
Please respond to the following:
a. For the l0 out of 24 portfolio simulations that did not include both Jackpot Solar and
Franklin Solar Facilities, please explain why the solar PPA projects were not selected
for each of the 10 portfolios.
FIRST PRODUCTION REQUEST
TO IDAHO POWER 2 MAY 30,2019
b. If the Company moves forward with the B2H transmission line, does the Company
still believe that the Jackpot Solar and Franklin Solar PPA are cost effective, given
that the 2'd,3'd, and 4th ranked portfolios (based on least cost net present value using
planning gas and planning carbon assumptions) do not include the solar PPA's?
Please explain.
c. If the Company chooses a preferred portfolio that includes B2H and moves forward
with the transmission line, what resource decisions will need to be made and what
future conditions will need to exist in order for the Jackpot Solar and Franklin Solar
Facilities to be cost-effective? Please explain.
REQUEST NO. 4: In reference to Mr. Larkin's direct testimony on page 18 where he
states, "The results of the LTCE modeling show a high correlation of new solar resources in2022
and2023 with a Jim Bridger unit retirement in 2022." In examining published results thus far in the
IRP process, 6 of the portfolios that retire a Bridger unit later than2022 do not include either of the
two solar PPAs (P21,P22,P23) or possibly only includes one of them (P5, P9, P10), suggesting that
a later retirement of a Bridger unit makes the Jackpot Solar and Franklin Solar Facilities less
economically viable. Please respond to the following:
a. If the Company chooses to retire a Bridger unit later than2022, what conditions need
to exist and at what point in time does the first unit need to retire to make the solar
PPAs consistently cost effective?
b. Please provide all Jim Bridger retirement assumptions used as inputs in the LTCE
modeling for each of the 24 scenarios. This should include but not be limited to: the
individual units available for retirement, the date range the units are available for
retirement, the nameplate capacity, and all fixed and variable cost assumptions.
c. Please provide justification why the chosen Jim Bridger retirement assumptions used
in the LTCE modeling are reasonable.
REQUEST NO. 5: In reference to Production Request Nos. 3 and 4 above, if the Company
moves forward with the B2H transmission line and if the retirement of the first Bridger unit happens
in the 2026 timeframe, what conditions would need to exist for the Jackpot Solar and Franklin Solar
Facilities to be consistently cost effective?
FIRST PRODUCTION REQUEST
TO IDAHO POWER aJ MAY 30,2019
REQUEST NO. 6: For the planning gas/planning carbon scenario, portfolios 13, 14,17,
and l8 are the lowest net present value portfolios. Three of these portfolios do not include the
Jackpot Solar PPA projects, please explain why these lowest cost portfolios did not include the
Jackpot Solar PPA.
REQUEST NO. 7: Has the Company performed any analysis similar to the "with and
without" Jackpot Solar analysis described in Mr. Larkin's direct testimony on pages l4-15 based on
the 2019 IRP assumptions? For example, selecting top ranking 2019 IRP portfolios, and running
the portfolios "with Jackpot Solar" forced into the model and "without Jackpot Solar" forced out of
the model, over a range of gas/carbon to compare how Jackpot Solar impacts the portfolio
simulations. If any analysis like this has been performed, please provide the work papers and
results of the analysis.
REQUEST NO. 8: For portfolio simulations nos. 5, 9, and 10, the results reflect 100 MW
of solar in year 2023. Does this represent the Franklin Solar facility, or something else? Please
explain.
REQUEST NO. 9: Please provide the financial and operating characteristics of the Jackpot
Solar PPA that were included in the AURORA New Resource Table mentioned in Mr. Larkin's
direct testimony on lines 24-25 on page 16.
REQUEST NO. 10: The Application on page 6 reads "the PPA allows the Seller an
adjustment of Estimated Monthly Net Output Amounts by the 25th day of the preceding month."
With the potential for a larger impact to load and resource balance than the PURPA contracts that
have been approved with a 5-day notice to adjust monthly generation estimates (Order No. 34263),
and with no historic power production data, please explain the potential costs and risks of replacing
the shortfall that could occur between projected monthly output and delivered energy.
REQUEST NO. 11: Please provide a copy of the executed Generator Interconnection
Agreement for the 120 MW Jackpot Solar Facility mentioned on pageT of the Application.
FIRST PRODUCTION REQUEST
TO IDAHO POWER 4 MAY 30,2019
REQUEST NO. 12: Please provide the estimated annual hourly production data for the
Jackpot Solar and Franklin Solar Facilities. If an estimated peak hour capacity value has been
calculated for either facility, please provide the value, along with how the value was calculated.
REQUEST NO. 13: Please explain iflhow Idaho Power intends to pass costs and/or
benefits of Liquidated Damages for Output Shortfall on to customers. Agreement, Section 7.12,
page 40.
REQUEST NO. 14: Lines 16-17 of Mr. Larkin's direct testimony on page 10 discuss the
additional 100 MW of Franklin Solar being "contingent upon the Generator Interconnection
Agreement (GIA) process for the additional 100 MW and the outcome of additional analyses."
Please provide an update on the status of the GIA process. Also provide any additional analyses the
Company has completed on the Franklin Solar option and include an explanation of the new
analyses.
REQUEST NO. 15: Mr. Larkin's direct testimony lines 24-25 on page l0 states the option
to purchase the additional 100 MW of the Franklin Solar facility expires on September 1, 2019,
unless otherwise agreed.
a. Has an agreement been made to differ from the September 1,2019 date?
b. When does the Company plan on making a decision on exercising this option?
c. What factors and analysis are pending to evaluate this option? Please explain and
provide any analysis completed.
REQUEST NO. 16: Has the Company calculated an estimated value for the sale of
Renewable Energy Certificates (RECs) mentioned in Mr. Larkin's direct testimony lines 6-7 on
page 16? If so, please provide the value and work papers used to calculate the RECs value.
REQUEST NO. 17: Please provide all workpapers and spreadsheets (with calculations and
links enabled) used to develop Exhibits 4 and 5, any cost-benefit analysis to customers, and all other
analyses performed.
FIRST PRODUCTION REQUEST
TO IDAHO POWER 5 MAY 30,2019
REQUEST NO. 18: Please provide the economic analysis, with supporting workpapers,
which is stated in Larkin's Direct Testimony page l9 Line 9.
REQUEST NO. 19: Please provide the net power cost change expected in the PCA from
the Jackpot Holdings PPA. What other cost changes are expected in the PCA once Jackpot
Holdings is included?
REQUEST NO.20: Please explain how the liquidated damages, when appropriate, will be
recorded, as mentioned in Section7.l2.2 of the Power Purchase Agreement.
DATED at Boise, Idaho, this g onauyof May 2019
>d
Edward J
Deputy
i:umisc:prodreq/ipcel9. l4ejmerftnc prod reql
FIRST PRODUCTION REQUEST
TO IDAHO POWER 6 MAY 30,2079
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 30th DAY OF MAY 2019, SERVED
THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION
STAFF TO IDAHO POWER COMPANY, IN CASE NO. IPC-E-19-14, BY MAILING
A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
DONOVAN WALKER
REGULATORY DOCKETS
IDAHO POWER COMPANY
PO BOX 70
BOISE rD 83707-0070
E-mail : dwalker@idahopower. com
dockets@idahopower. com
MATT LARKIN
IDAHO POWER COMPANY
PO BOX 70
BOISE rD 83707-0070
E-mail: [e-mail]
Y
CERTIFICATE OF SERVICE