20200306Staff 1-2 to IPC.pdf

EDWARD JEWELL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE,IDAHO 83720-0074
[phone] '?E
IDAHO BAR NO.10446
Street Address for Express Mail:
11331 W CHINDEN BVLD,BLDG 8,SUITE 201-A
BOISE,ID 83714
Attorneyfor the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )IDAHO POWER FOR A VALIDATED )CASE NO.IPC-E-19-18
ECONOMIC CLOSURE DATE FOR NORTH )VALMY POWER PLANT UNIT 2 )FIRST PRODUCTION
)REQUESTOF THE
)COMMISSION STAFF TO
)IDAHO POWER COMPANY
The Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Edward Jewell,Deputy AttorneyGeneral,request that Idaho Power Company (Company)provide
the followingdocuments and information as soon as possible,or by FRIDAY,MARCH 27,2020.
This Production Request is continuing,and the Company is requested to provide,by way of
supplementaryresponses,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
31.01.01.228.
FIRST PRODUCTION REQUEST
TO IDAHO POWER 1 MARCH 6,2020
In addition to the written copies provided as response to the questions,please provide all
Excel and electronic files on CD with formulas activated.
The justification provided in the Company's Application for a December 31,2025,Valmy
Unit 2 closure date is no longer valid given that the modeled analysis provided in this filing was
completed prior to:1)Idaho Power determining that the Long Term Capacity Expansion(LTCE)
functionalitywas not a feasible method for ensuring that the portfolios it produced were least-cost,
least-risk portfolios in Idaho Power's system;and 2)because "Idaho Power identified eight
modifications to its modeling inputs to ensure more accurate modeling results."(See Amended
2019 IRP,p.2).Given that the Company no longer has confidence in the LTCE model's results,
which was used to produce Analysis Numbers 1 and 3 described in this filing (See Application,pp.
3-5),Staff requests dispatch model runs and cost comparisons similar in method to the Company's
Number 2 analysis,but using updated input assumptions included in the Amended 2019 IRP,and
the full costs and savings of the Framework Agreement.Each of these comparisons are described
below.
REQUESTNO.1:Please provide the Net Present Value (NPV)difference and an annual
breakdown of the cost and benefit value streams (capital,fixed operation and maintenance,Net
Power Supply Expense,etc.)used to calculate the NPV differences,between the followingamended
IRP portfolios and alternative futures:
a.the IRP "Preferred Portfolio"with a Valmy Unit 2 shutdown date of December 31,
2025 and the same portfolio using a Valmy Unit 2 shutdown date of December 31,
2024 using "planning"natural gas and "planning"CO2 assumptions.
b.the IRP "Preferred Portfolio"with a Valmy Unit 2 shutdown date of December 31,
2025 and the same portfolio using a Valmy Unit 2 shutdown date of December 31,
2023 using "planning"natural gas and "planning"CO2 assumptions.
c.the IRP "Preferred Portfolio"with a Valmy Unit 2 shutdown date of December 31,
2025 and the same portfolio using a Valmy Unit 2 shutdown date of December 31,
2024 using "low"natural gas and "high"CO2 assumptions.
FIRST PRODUCTION REQUEST
TO IDAHO POWER 2 MARCH 6,2020
d.the IRP "Preferred Portfolio"with a Valmy Unit 2 shutdown date of December 31,
2025 and the same portfolio using a Valmy Unit 2 shutdown date of December 31,
2023 using "low"natural gas and "high"CO2 assumptions.
e.the least cost,least risk IRP Portfolio without the Boardman to Hemingway
Transmission Project using a Valmy Unit 2 shutdown date of December 31,2025
and the same portfolio with a Valmy Unit 2 shutdown date of December 31,2024
using "planning"natural gas and "planning"CO2 assumptions.
f.the least cost,least risk IRP Portfolio without the Boardman to Hemingway
Transmission Project using a Valmy Unit 2 shutdown date of December 31,2025
and the same portfolio with a Valmy Unit 2 shutdown date of December 31,2023
using "planning"natural gas and "planning"CO2 assumptions.
g.the least cost,least risk IRP Portfolio without the Boardman to Hemingway
Transmission Project using a Valmy Unit 2 shutdown date of December 31,2025
and the same portfolio with a ValmyUnit 2 shutdown date of December 31,2024
using "low"natural gas and "high"CO2 assumptions.
h.the least cost,least risk IRP Portfolio without the Boardman to Hemingway
Transmission Project"using a Valmy Unit 2 shutdown date of December 31,2025
and the same portfolio with a Valmy Unit 2 shutdown date of December 31,2023
using "low"natural gas and "high"CO2 assumptions.
REQUESTNO.2:Does an earlier shutdown of the Valmy Unit 2 violate any system
reliability constraints in any of the portfolios requested to be modeled above?If reliability
constraints are violated by closing Valmy Unit 2 earlier than December 31,2025,please provide
evidence/justification that operating Unit 2 until the end of 2025 is the least cost alternative.
DATED at Boise,Idaho,this Ú¾day of March 2020.
Edward Jewel
Deputy Atto y General
i:umise:prodreq/ipcel9.18ejrk prod reql
FIRST PRODUCTION REQUEST
TO IDAHO POWER 3 MARCH 6,2020
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 6th DAY OF MARCH 2020,SERVED
THE FOREGOING FIRST PRODUCTION REQUESTOF THE COMMISSION STAFFTOIDAHOPOWERCOMPANY,IN CASE NO.IPC-E-19-18,BY MAILING A COPY
THEREOF,POSTAGE PREPAID,TO THE FOLLOWING:
LISA D NORDSTROM MATT LARKIN
REGULATORY DOCKETS IDAHO POWER COMPANY
IDAHO POWER COMPANY PO BOX 70
PO BOX 70 BOISE ID 83707-0070
BOISE ID 83707-0070 E-mail:[e-mail]
E-mail:[e-mail]
[e-mail]
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
710 N 6TH ST
BOISE ID 83702
E-mail:botto idahoconservation.org
SE0RËTA Y
CERTIFICATE OF SERVICE