20191030Staff 26-36 to IPC.pdf

IN THE MATTER OF THE APPLICATION OF
IDAHO POWER COMPANY FOR APPROVAL
OF A POWER PURCHASE AGREEMENT WITH
JACKPOT HOLDINGS, LLC, FOR THE SALE
AND PURCHASE OF UP TO 220 MEGAWATTS
OF RENEWABLE SOLAR GENERATION.
RECEIVED
,ll9 CCT 30 Pl{ 12: h9
CASE NO. IPC.E.I9.Id
THIRD PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
IDAHO POWE,R COMPANY
, tjiLlc
c0hil,{lssloN
Street Address for Express Mai[:
I1331 W CHINDEN BVLD, BLDG 8, SUITE 2OI.A
BOISE, ID 837I4
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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I Staffis requesting an expedited response. lfresponding by this date will be problcmatic, please call Staffs attorney at
(208) 334-03 r 4.
ocToBER 30,2019
EDWARD JEWELL
DEPUTY A'TTORNEYS GENERAL
IDAHO PUBLIC U]ILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 8}720-OO'74
(208) 334-03 | 4
IDAHO BARNO. 10446
Attomey for the Commission Staff
The Staffof the Idaho Public Utilities Commission, by and through its attorney of record,
Edward Jewell, Deputy Attomey General, request that Idaho Power Company ("Company")
provide the following documents and information as soon as possible, or by WEDNESDAY,
NOVEMBER 6,2019.'
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 ofthe record holder and if
THIRD PRODUCTION REQUEST
TO IDAHO POWER l
different the w'itness who can sponsor the answer at hearing if need be. Rel'erence IDAPA
31.01.0 r .228.
In addition to the written copies provided as response to the qucstions, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO, 26: Please provide and dcscribe the input assumptions and functionality
tbr the AURORA LTCE that are different betwecn thc 24 WECC-optimized portlblios in the initial
application and the latest 24 WECC-optimized portfolios. Differenccs to include (but not limitcd
to): (l) REC values lbr.Iackpot Solar, (2) transmission interconnection costs for Jackpot Solar, (3)
removal ofFranklin Solar, (4) corect online date fbr Jackpot Solar, (6) allowing the model to
correct the peak credil for new solar ifJackpot Solar is not selected. and (7) change in the amount of'
excess overbuilds beyond the planning reserve target.
REQUEST NO. 27: Please provide a supplemental response to Stall' Production Request
No. 2 that includes the information for the latcst 24 WECC-optimized portlblios.
REQUEST NO. 28: Please provide a NPV summary of the latest 24 WECC-optimized
portfolios similar to the "Po(folio Summaries" provided at the April I l, 2019 IRPAC meeting.
REQUEST NO. 29: Please identily all WECC-optimized portfolios that have been
manually modified lbr this analysis, and provide: (l) atl the manual modifications made to the
WECC-optimized porttblios, and (2) a NPV summary of the modifled portlblios similar to the
"Portfolio Summaries" provided at the April I I , 201 9 IRPAC meeting.
REQUEST NO,30: Please provide the average monthly Mid-C electricity price forecast
for each hour ofeach day over a ten-year period (Dec. 2022-Dec.2032) generated by Aurora in
Excel format for the following alternative futures:
a. Zero CO2; planning gas; and
b. Planning CO2; planning gas.
'l'HIRD PRODUCI'lON RITQUEST.I'O IDAHO POWER ocToBER 30. 20192
REQUEST NO.31: Please provide the workpapers used to create Exhibit No. 2 from
Larkin's Direct Testimony.
REQUEST NO.32: Please provide the monthly averagc Mid-C electricity price forecast
over a 20-year period (Dec. 2022-Nov. 2023) generated by Aurora in Excel fbrmat for the following
altemative futures:
a. Zero CO2: planning gas;
b. Planning CO2; planning gas;
c. High CO2: planning gas:
d. Planning CO2; mid gas; and
e. Planning CO2; high gas.
REQUEST NO. 33: Please provide a supplemental response to Staff Production Request
No. 16 that includes the REC values included in thc updated analysis along with workpapers for thc
calculation. In addition, please address the following:
a. What inlormation or data was used to determine the REC lbrecast used in the
analysis? Please provide the information and data.
b. What type of RECs are assumed? (Example: Bundled, Unbundled, etc.)
c. What market are the RECs assumed to be sold in?
d. Please provide the dollar valuc and type (Bundled, Unbundled, etc.) ofactual RECs
the Company has sold over the last 3 ycars.
REQUEST NO. 34: Please provide the following information:
a. Describe the new interconnection costs related to the Jackpot Solar PPA that are
included in the updated modeling inputs.
b. Why were they added?
c. Please explain why these costs arc not the responsibility ofthe developer/project
d. Please provide the workpapers used to produce the interconnection inputs in the
model.
THIRD PRODUCTION REQUEST
TO IDAHO POWER -)OC'fOlllrR 30.2019
owner.
REQUEST NO. 35: Please provide the requested inlbrmation in Attachment A, which was
discussed on October 28th, 2019, between Idaho Power and Commission Staffas a supplement to
Staff Production Request No. 25.
REQUEST NO.36: Please identify and explain the cause(s) driving the difference between
the results ofProduction Request No. 25 provided to Staff in the September 17,2019 meeting and
the results provided in the October 21,2019 meeting between Staff and Idaho Power.
DATED at Boise, Idaho, this 9oe Auy of October 2019.
Edward J
Deputy A
i:umisc r prodrcqlipce 19. l,lej merlinc prod req3
THIRD PRODUCTION REQUEST
TO IDAHO POWER 4 ocroBER 30,2019
Attachment A
Case No. IPC-E- I 9- l 4
Third Production Requestl0l31ll9 Page I ofl
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CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 3O'I' DAY OF OCTOBER 2019,
SERVED THE FOREGOING THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY, IN CASE NO. IPC-8.I9.14,
BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
DONOVAN WALKER
REGULATORY DOCKETS
IDAHO POWER COMPANY
PO BOX 70
BOrSE ID 83707-0070
E-mail: [e-mail]
[e-mail]
MATT LARKIN
IDAHO POWERCOMPANY
PO BOX 70
BOISE ID 83707-0070
E-mail : [e-mail]
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CERTIFICATE OF SERVICE