20200429Staff 3-8 to IPC.pdf

SECOND PRODUCTION REQUEST
TO IDAHO POWER 1 APRIL 29, 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 THE APPLICATION OF
IDAHO POWER FOR A VALIDATED
ECONOMIC CLOSURE DATE FOR NORTH
VALMY POWER PLANT UNIT 2
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CASE NO. IPC-E-19-18

SECOND 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 WEDNESDAY,
MAY 20, 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 April 29,PM3:09
IDAHO PUBLIC
UTILITIES COMMISSION

SECOND PRODUCTION REQUEST
TO IDAHO POWER 2 APRIL 29, 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. 3: Please describe and quantify the risk to system reliability associated
with a Planning Margin of 14.90 percent in 2024, and 13.43 percent in 2025 shown in response to
PR1, tabs A through H of file Attachment - Response to Staff's Request No. 1
(00269972xBCD5C).XLSX, versus the Company’s 15 percent Planning Margin.

REQUEST NO. 4: What is the difference to the Loss of Load Probability (LOLP) between
a 15 percent Reserve Margin compared to the stated 13.43 percent deficient Reserve Margin?

REQUEST NO. 5: What is the difference to the LOLP between a 15 percent Reserve
Margin compared to the stated 14.9 percent deficient Reserve Margin?

REQUEST NO. 6: The Company delayed exiting a Bridger coal unit to address the
Reserve Margin shortfall in PR2. Please provide evidence demonstrating that the Company
analyzed a range of other resources that could meet that Reserve Margin shortfall, and that shows
that extending the life of the Bridger unit is the least cost resource to meet that need.

REQUEST NO. 7: Was additional demand response considered a feasible alternative to
offset reliability constraints attributed to early closure of Valmy Unit 2 and the Reserve Margin
shortfall?
a. Please explain why, or why not, demand response could satisfy the noted reliability
constraints attributed to the early exit of Valmy Unit 2 prior to 2025. Please provide
justification and evidence supporting the Company’s assertions and analysis.

SECOND PRODUCTION REQUEST
TO IDAHO POWER 3 APRIL 29, 2020
REQUEST NO. 8: Please provide the Net Present Value (NPV) difference and the annual
breakdown of cost and benefit value streams (capital, fixed operation and maintenance, exit fees,
Net Power Supply Expense, etc.) used to calculate the NPV difference considering the IRP
Preferred Portfolio with a Valmy Unit 2 shutdown date of December 31, 2025 versus:
a. The same portfolio using increased demand response to satisfy the reliability
constraint considering a Valmy Unit 2 shutdown date of December 31, 2024 using
“planning” natural gas and “planning” CO2 assumptions;
b. The same portfolio using increased demand response to satisfy the reliability
constraint considering a Valmy Unit 2 shutdown date of December 31, 2023 using
“planning” natural gas and “planning” CO2 assumptions;
c. The same portfolio using increased demand response to satisfy the reliability
constraint considering a Valmy Unit 2 shutdown date of December 31, 2024 using
“planning” natural gas and “high” CO2 assumptions; and
d. The same portfolio using increased demand response to satisfy the reliability
constraint considering a Valmy Unit 2 shutdown date of December 31, 2023 using
“planning” natural gas and “high” CO2 assumptions.

DATED at Boise, Idaho, this 29th day of April 2020.

_______________________________________
Edward Jewell
Deputy Attorney General

i:umisc:prodreq/ipce19.18ejrk prod req2
CERTIFICATE OF SERVICE
CERTIFICATE OF SERVICE

I HEREBY CERTIFY THAT I HAVE THIS 29th DAY OF APRIL 2020, SERVED
THE FOREGOING SECOND PRODUCTION REQUEST OF THE COMMISSION
STAFF TO IDAHO POWER COMPANY, IN CASE NO. IPC-E-19-18, BY E-MAILING
A COPY THEREOF, TO THE FOLLOWING:

LISA D NORDSTROM
REGULATORY DOCKETS
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-mail: [e-mail]
[e-mail]

MATT LARKIN
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-mail: [e-mail]

BENJAMIN J OTTO
ID CONSERVATION LEAGUE
710 N 6TH ST
BOISE ID 83702
E-mail: [e-mail]

PETER J RICHARDSON
RICHARDSON ADAMS PLLC
515 N 27TH STREET
PO BOX 7218
BOISE ID 83702
E-mail: [e-mail]

DR DON READING
6070 HILL ROAD
BOISE ID 83703
E-mail: [e-mail]

/s/ Reyna Quintero __
SECRETARY