20200327Staff 1-5 to IPC.pdf

FIRST PRODUCTION REQUEST
TO IDAHO POWER 1 MARCH 27, 2020
EDWARD JEWELL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 10446

Street Address for Express Mail:
11331 W CHINDEN BVLD, BLDG 8, SUITE 201-A
BOISE, ID 83714

Attorney for the Commission Staff

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF IDAHO POWER’S
PETITION TO ESTABLISH AVOIDED COST
RATES AND TERMS FOR ENERGY
STORAGE QUALIFYING FACILITIES
UNDER PURPA
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CASE NO. IPC-E-20-02

FIRST PRODUCTION
REQUEST OF 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 Attorney General, request that Idaho Power Company (Company) provide
the following documents and information as soon as possible, or by FRIDAY,
APRIL 17, 2020.
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
31.01.01.228.
RECEIVED
2020 March 27,PM1:16
IDAHO PUBLIC
UTILITIES COMMISSION

FIRST PRODUCTION REQUEST
TO IDAHO POWER 2 MARCH 27, 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.

REQUEST NO. 1: If an energy storage facility is used to time shift generation output from
a dedicated renewable generation source, and if both the generator and the storage facility are
operationally controlled and dispatched by the QF, please explain the feasibility of a configuration
requiring two separate QFs: one QF, contract, and avoided cost rate for energy taken directly to load
from the generation facility; and another QF, contract, and avoided cost rate for the energy taken
directly to load from the storage facility. In addition, please answer the following for this
configuration:
a. Please explain the technical feasibility to separately measure/meter the amount of
energy from the generation QF that is taken directly to load (total generated energy
minus generated energy that is stored in the energy storage QF to be dispatched
later), from the amount of energy from the energy storage QF taken directly to load
(generated energy that was stored in the energy storage QF minus storage efficiency
losses).
b. If technically feasible, please describe the facilities and equipment required and
provide a diagram showing how the facilities, meters, and equipment would need to
be configured for both QFs.
c. Please identify and describe the types of cost that would be avoided for output taken
to load from the generation QF.
d. For each type of cost identified above for the generation QF, please describe the
Company’s preferred method for deriving an accurate avoided cost rate for published
rates and for negotiated rates.
e. Please identify and describe the types of cost that would be avoided for output taken
to load from the energy storage QF.
f. For each type of cost identified above for the energy storage QF, please describe the
Company’s preferred method for deriving an accurate avoided cost rate for published
rates and for negotiated rates.
g. For this particular configuration, please describe the responsibilities of the QFs and
of the Company for all aspects of operation.

FIRST PRODUCTION REQUEST
TO IDAHO POWER 3 MARCH 27, 2020
h. Currently, all QF’s are required to adhere to 90/110 firmness requirements. Would
the 90/110 firmness requirements be feasible in its current form for both the
generation QF and the energy QF? If not, how would it need to change?
i. For this particular configuration and the Company’s preferred method of deriving
avoided cost, please identify and describe any contract terms and conditions that may
be necessary for either QF.

REQUEST NO. 2: If an energy storage facility is used to time shift generation output from
a dedicated renewable generation source, and if both the generator and the storage facility are
operationally controlled and dispatched by the QF, please explain the feasibility of a combined QF
having different rates depending on the type of generation that is combined with an energy storage
facility (storage + wind, storage + solar, storage + hydro, storage + biomass, etc.). In addition,
please answer the following for this configuration.
a. Please explain the technical feasibility to measure/meter the amount of energy taken
directly to load from the combined QF and describe the facilities and equipment that
would be needed.
b. Please identify and describe the types of cost that would be avoided for output taken
to load from a combined QF.
c. For each type of avoided cost identified above for the combined QF, please describe
the Company’s preferred method for deriving an accurate avoided cost rate for
published rates and for negotiated rates.
d. For this particular configuration, please describe the responsibilities of the QF and of
the Company for all aspects of operation.
e. Currently, all QF’s are required to adhere to 90/110 firmness requirements. Would
the 90/110 firmness requirements be feasible in its current form for a combined
renewable generation facility and energy storage facility QF? If not, how would it
need to change?
f. For this particular configuration and the Company’s preferred method of deriving
avoided cost, please identify and describe any contract terms and conditions that may
be necessary.

FIRST PRODUCTION REQUEST
TO IDAHO POWER 4 MARCH 27, 2020
REQUEST NO. 3: Please compare the separate generation and energy storage QF
configuration described in Request No. 1 with the combined QF configuration described in Request
No. 2, by providing the advantages and disadvantages of each.

REQUEST NO. 4: In its Application, the Company states that “the potential benefits and
possible promise of economically viable, utility-scale energy storage facilities is in the unique
operational characteristics to, for example: provide ancillary grid services such as reserve capacity,
surge capacity, load-balancing, or voltage support; firming of variable generation; or time-shifting
generation to match load. However, to realize these benefits, it would first of all be necessary for
the project to be configured and operated in such a manner, and secondly it would be necessary for
operational control and dispatchability of the facility to be with the utility charged with serving
load.” Please answer the following:
a. Please describe in detail how the QF would need to be “configured and operated,” in
order to capture the benefits of a utility-scale energy storage facility, as described
above.
b. Would this QF necessarily need to be configured as a “stand-alone” storage QF
facility? Please explain why or why not.
c. Please describe the responsibilities of the QF and of the Company for the Company’s
described configuration. Please include the responsibilities for obtaining/procuring
the energy, scheduling delivery of energy to the QF to be stored, and dispatching the
energy out of the storage facility.
d. Please identify and describe in detail, the specific types of cost that the utility would
avoid if operated as the Company has described.
e. For each of the types of cost that the utility would avoid for this configuration, please
describe the cost drivers and rate designs that would accurately compensate the QF.
f. If an energy storage facility gives operational control and dispatchability to Idaho
Power, how can the facility ensure Idaho Power will operate and dispatch the facility
in a way that can generate a fair and reasonable amount of revenue to the QF?
g. For the configuration and operation as described by the Company, please discuss the
feasibility of a fixed avoided cost rate based on the energy storage facility’s
capabilities (e.g. the QF could be paid a fixed amount each month based on the

FIRST PRODUCTION REQUEST
TO IDAHO POWER 5 MARCH 27, 2020
facility’s discharge rate, energy storage capacity, or other combinations of
capabilities), and why it may or may not be appropriate.
h. Please explain if it is cost-effective for Idaho Power to manage the operation and
dispatch of storage facilities that are less than 100 kilowatts. If not, what would the
size of the storage facility have to be to make it cost effective?
i. Currently, all QF’s are required to adhere to 90/110 firmness requirements. Would
the 90/110 firmness requirements be feasible in its current form for the operation and
configuration as described by the Company? If not, how would it need to change?
j. How would the Company ensure that energy input into the battery facility does not
exceed Federal Energy Regulatory Commission’s 25 percent fossil fuel limitation
(See Luz, 51 FERC P 61,172)?
k. For this configuration as described by the Company, please identify and describe any
contract terms and conditions that may be necessary.

REQUEST NO. 5: Currently, generation QFs are paid different avoided energy cost rates
depending on whether the generation is delivered during high or low load hours because the value
of energy is different depending on the time that it is delivered. Are two levels of rates (high or low
load hours) sufficient to differentiate the value of energy from an energy storage facility to the
Company’s system? Please explain.

DATED at Boise, Idaho, this 27th day of March 2020.

_______________________________________
Edward Jewell
Deputy Attorney General

i:umisc:prodreq/ipce20.2ejyyml prod req1

CERTIFICATE OF SERVICE

I HEREBY CERTIFY THAT I HAVE THIS 27th DAY OF MARCH 2020, SERVED
THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO
IDAHO POWER COMPANY, IN CASE NO. IPC-E-20-02, BY E-MAILING A COPY
THEREOF, TO THE FOLLOWING:

DONOVAN E WALKER
REGULATORY DOCKETS
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: [e-mail]
[e-mail]

/s/ Reyna Quintero __
SECRETARY