20200304Staff 1-50 to IPC.pdf

EDWARD JEWELL ocrOt\/RDDEPUTYATTORNEYGENERAL
IDAHO PUBLIC UTILITIES COMMISSION p 4 p 9:6POBOX83720
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
Attorneyfor the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER )COMPANY'S 2019 INTEGRATED RESOURCE )CASE NO.IPC-E-19-19
PLAN )
)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 (IPC or Company)
provide the followingdocuments and information as soon as possible,or by WEDNESDAY,
MARCH 25,2020.
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.
FIRST PRODUCTION REQUEST
TO IDAHO POWER 1 MARCH 4,2020
In addition to the written copies provided as response to the questions,please provide all
Excel and electronic files on CD with formulas activated.
REQUESTNO.I:On page 90 of the Amended 2019 IntegratedResource Plan (IRP),the
Company states,"Idaho Power projects that additional natural gas-fired generating capacity beyond
an incremental 600 MW of capacity would require an expansionof Northwest Pipeline from the
Rocky Mountain supply region to Idaho."
a.)Is an expansion of Northwest Pipeline beyond 600MW required due to availabilityof
natural gas from the Rocky Mountain supply region or capacity of the pipeline in the
Company's service area?Please explain.
b.)If an expansion would be required due to the Rocky Mountain supply region,please
explain why that is necessary given that the Northwest Pipeline is a bi-lateral pipeline
served by multiplesupply regions.
c.)If expansion requirements would be a mix of both supply basin and pipeline capacity,
please explain how and to what extent each element contributes to the requirement.
REQUESTNO.2:Please provide a schedule that details all capacity and transportation
contracts and/or reservations the Company has with Northwest Pipeline for the next ten years.
a.)For each year,please provide the volume required,price,and volume under contract or
reserved.
b.)For each year,please provide the available capacity includingprice and source.
REQUESTNO.3:The Aurora Long Term Capacity Expansion model (LTCE)includes
options to use Traditional Long Term logic,a Mixed Integer Program (MIP)method that
Maximizes Value,and a Mixed Integer Program method that Minimizes Costs.For the Company's
24 Western Electricity Coordination Council (WECC)optimized portfolios,please provide the
followinginformation:
a.)The Capacity Expansion Option and method used,and the rationale for using that
Capacity Expansion Option and method.
FIRST PRODUCTION REQUEST
TO IDAHO POWER 2 MARCH 4,2020
b.)The objective function that was used,with a description of all components of that
objective function.Please include specific zones used to determine prices used in the
Net Present Value (NPV)calculation.
c.)The convergence criteria used,and the rationale for selecting that particular convergence
criteria.
d.)The last 10 values of the objective function used to determine convergence.
REQUESTNO.4:Please explain how flexibilityresources were used in the development
of each of the Company's 24 WECC optimized portfolios.For each of these portfolios,please
identify which resources were included as flexibilityresources.
REQUESTNO.5:Please explain the formal process used by the Company to verify each
of the model runs used to develop the Company's 24 WECC optimized portfolios.Please include
any checklists or formal procedures used to ensure that model configuration was consistent with the
assumptions presented to the Integrated Resource Plan Advisory Committee (IRPAC).
REQUESTNO.6:Please confirm that,with the exception of natural gas and carbon
prices,all modeling parameters to develop the Company's 24 WECC optimized portfolios were
identical for the Amended 2019 IRP.If this is not correct,please explain all differences in
modeling configuration,including the inclusion of resources that were either included or removed
in order to stabilize the model.
REQUESTNO.7:Please describe the process and criteria used by the Company to select a
Capacity Expansion Tool.In addition to the Aurora LTCE tool,what other capacity expansion
tools and techniques did the Company consider?Please explain.
REQUESTNO.8:Please confirm that the Aurora LTCE can optimize portfolios for the
WECC,but not for the Company's system.If this is true,please describe the process and criteria
that will be used by the Company to select a Capacity Expansion tool for future IRPs.
FIRST PRODUCTION REQUEST
TO IDAHO POWER 3 MARCH 4,2020
REQUESTNO.9:Please describe the Company's process for validating the Aurora LTCE
tool prior to development of the Company's 24 WECC optimized portfolios for the Amended 2019
IRP.Please include the Company's procedures for determining the following:
a.)The process for validating the particular options and methods used by the Company
(Traditional,MIP Maximize Value,and MIP Minimize Cost).
b.)Correspondence between IRP objectives and modeling outputs.
c.)Model stability.
d.)Please explain how the Company determined that the Aurora Capacity Expansion Option
and method chosen by the Company would produce portfolios with the least cost and
least risk to the Company's ratepayers.
e.)Efforts undertakenby the Company to characterize the model.
f.)Efforts undertakenby the Company to determine input parameter limits that might cause
the model to become unstable or unreliable.
REQUESTNO.10:On page 97 of the Company's Amended 2019 IRP,the Company
states that a "...subset of top-performing WECC portfolios was manually adjusted with the objective
of further reducing portfolio costs specific to the Idaho Power System."Please provide the criteria
used by the Company to select this particular subset of portfolios.
REQUESTNO.11:How does the Company know that a WECC-optimized portfolio,that
wasn't part of the subset that was further manually adjusted,could be manuallyadjusted to be more
optimal than the final portfolio selected?Please explain.
REQUESTNO.12:For each of the manuallybuilt portfolios shown in Table 9.9,please
explain the adjustments that were made to the parent WECC portfolio.
REQUESTNO.13:For each of the manuallybuilt portfolios shown in Table 9.9,please
provide the objective function that was used to evaluate the model,with a description of all
components of that objective function.
FIRST PRODUCTION REQUEST
TO IDAHO POWER 4 MARCH 4,2020
REQUESTNO.14:Please confirm that,with the exception of resources specified in the
IRP,all modeling parameters used to develop the Company's manuallybuilt portfolios were
identical.If this is not correct,please explain all differences in modeling configuration,including
the inclusion of resources that were either included or removed in order to stabilize the model.
REQUESTNO.15:Which Aurora zones were used to determine prices that were used to
develop the Net Present Values shown in Table 9.9?
REQUESTNO.16:Please explain how flexibilityresources were used in the development
of each of the Company's manuallybuilt portfolios.For each of these portfolios,please identify
which resources were included as flexibilityresources.
REQUESTNO.17:On page l10 of the Amended 2019 IRP,the Company states that it,
"...is confident that its preferred portfolio detailed in Chapter 10 achieves the low cost,low risk
objective of the IRP."Please explain the basis for this degree of confidence.
REQUESTNO.18:Please include all analysis performed for Boardman-To-Hemingway
(B2H)related rate base estimates at the hypothetical 42%ownership ($648 million)that was
conducted to support the November 5,2019 Form 8-K submission to the Security Exchange
Commission.
REQUESTNO.19:Page 37 of Appendix D states that B2H will provide a range of
benefits,includingachieving the Company's clean energy goals,meeting Oregon and Washington
Renewable Portfolio Standards and legislation,and providing benefits toward achieving regional
balancing area operating efficiencies,reliability and resiliency,and resource adequacy.Please
explain why it is reasonable for Idaho Power customers to fund such a large portion of a resource
that may benefit the region more than it benefits them.
REQUESTNO.20:Idaho Power assumed that B2H will have constant transmission usage
that produces the additional transmission revenue included in the Amended 2019 IRP filing.
FIRST PRODUCTION REQUEST
TO IDAHO POWER 5 MARCH 4,2020
Appendix D at 42.Please describe where constant transmission capacity usage will come from and
include forecasts,contracts,and/or relevant documents to support these assumptions.
REQUESTNO.21:On pages 4 and 5 of its Amended 2019 IRP,the Company states that it
reduced the discount rate from 9.59 to 7.12 percent.Please provide all workpapers,in EXCEL
format with formulae and links intact,for the calculation of the new discount rate and include the
derivation of the (.74%)tax deduction rate reflected on page 6 of the Company's December 6,2019
IRPAC PowerPoint presentation.
REQUESTNO.22:Please provide the signed B2H Joint Permit funding agreement
described on page 69 of the Company's Amended 2019 IRP.
REQUESTNO.23:On page 72 of its Amended 2019 IRP,the Company states that
"Portfolios involvingB2H result in a higher FERC transmission rate than portfolios without B2H."
Please provide all FERC transmission rates for all Transmission lines used by Idaho Power,
includingB2H and Gateway West.
REQUESTNO.24:On page 72 of its Amended 2019 IRP,the Company states that it
included costs for local interconnection upgrades totaling $21 million in its B2H cost analysis.
a.)Please provide a list,with description,costs,and schedule of all projects included in this
estimate.
b.)Please provide a list,with costs,of any interconnection upgrades related to B2H that
were not included in this estimate.
c.)Was the cost of these upgrades used in the calculation to determine capital costs for all
resource types considered in Table 1 on page 6 of Appendix D?Please explain.
REQUESTNO.25:Please provide,in EXCEL format with formulae and links intact,the
Company's estimate of the costs of B2H to Idaho ratepayers,including,but not limited to:
a.)Rate Base Total
b.)Allowance for Funds Used During Construction (AFUDC)
c.)Permitting Costs and Permits Received and Filed
FIRST PRODUCTION REQUEST
TO IDAHO POWER 6 MARCH 4,2020
d.)Pre-Construction Cost
e.)Construction Cost
f.)Unforeseen expenses
g.)Expected Cost Overrun
h.)Warranty Cost
REQUESTNO.26:On page 63 of its Amended 2019 IRP,the Company states that,
"Historically,Idaho Power experiences its peak load at different times of the year than most Pacific
Northwest utilities;as a result,Idaho Power can purchase energy from the Mid-Columbia energy
trading market during its peak load and sell excess energy to Pacific Northwest utilities during their
peak."Please provide the followinginformation:
a.)The date,time,and magnitude (MW)of the Company's 100 highest peaking events
during the calendar year,2019.
b.)The date,time,and magnitude (MW)of the peaking events of "most Pacific Northwest"
utilities referred to in its statement.
REQUESTNO.27:Please provide all studies and forecasts of firm,dispatchable
generationcapacity that would be available to the Company through the proposed B2H transmission
line at the time of Company system peaking events during calendar years 2019 through 2038.
REQUESTNO.28:Please provide,in EXCEL format with formulae and links intact,the
Company's estimate of the costs of Gateway West to Idaho customers,including,but not limited to:
a.)Rate Base Total
b.)AFUDC
c.)Permitting Costs and Permits Received and Filed
d.)Pre-Construction Cost
e.)Construction Cost
f.)Unforeseen Expenses
g.)Expected Cost Overrun
h.)Warranty Cost
FIRST PRODUCTION REQUEST
TO IDAHO POWER 7 MARCH 4,2020
REQUESTNO.29:Regarding Idaho Power's segment of the proposed Gateway West
transmission line:
a.)What is the capacity of Idaho Power's current transmission resources into territory that
would be served by these segments of Gateway West?
b.)Please provide load studies for the years 2019 through 2038 for the territorythat would
be served by these segments of Gateway West.
REQUESTNO.30:Please provide the workpapers for the calculations of capital costs for
all resource types considered in Table 1 on page 6 of Appendix D.Please include:Total capital
$/kW,Total Capital $/kW-Peak,and Depreciable Life.
REQUESTNO.31:From Figure 7.5 on page 92 of the Amended 2019 IRP,please provide
all workpapers and calculations for the resources presented.
REQUESTNO.32:From Figure 7.6 on page 94 of the Amended 2019 IRP,please provide
all workpapers and calculations for the resources presented.Please include the assumed level of
annual energy outputs for each resource and the inputs/assumptions used to calculate the annual
cost of energy over the life of the resource.
REQUESTNO.33:With the 2017 Bonneville Power Administration (BPA)decision to
cancel the I-5 Corridor Reinforcement transmission project,which was based on BPA policy
change toward non-wires solutions to "embrace a more flexible,scalable,and economically and
operationally efficient approach to managing BPA transmission needs[,]"'please describe the
current status of the IPC-BPA B2H partnership and funding position.As of February 26,2020,
Bonneville Power states "Bonneville has not yet made a decision about joint ownership of the B2H
Project."2 Please include the most current documentation available to support the Company's
response.
'May 17,2017.Elliot Mainzer of Bonneville Power Administration.Letter to Region I-5 Corridor ReinforcementProjectdecision.https://www.bpa.gov/Projects/Projects/l-5/Documents/letter I-5 _decision final web.pdf2BOnneVillePowerAdministration.Boardman to Hemingway Transmission Line Project (DOE/EIS -507).
https://www.bpa.gov/efw/Analysis/NEPADocuments/Pages/Boardman-to-Hemingway.aspx
FIRST PRODUCTION REQUEST
TO IDAHO POWER 8 MARCH 4,2020
REQUESTNO.34:B2H was not selected as part of the 2019 PacifiCorp/Rocky Mountain
Power preferred resource portfolio.Please describe the current status of the IPC/PacifiCorp B2H
partnership and fundingposition.Please include the most current documentation available to
support the Company's response.
REQUESTNO.35:Please describe the Company's plan if a funding partner declines to
fund its currentlyassumed share of the B2H project.
REQUESTNO.36:Page 71 of the Amended 2019 Integrated Resource Plan states that
transmission wheeling revenues are not included in AURORA calculations and the Company
modeled incremental transmission wheeling revenue from non-native load customers as an annual
revenue credit for B2H portfolios as in the 2017 IRP.Please answer the followingquestions:
a.)Please explain why AURORA is not able to capture transmission wheeling revenues.
b.)How much is the annual revenue credit for B2H portfolios?How is the value
determined?
REQUESTNO.37:Page 72 of the Amended 2019 IntegratedResource Plan states that
Idaho Power's transmission assets are funded by native load customers,network customers,and
point-to-pointtransmission wheeling customers based on a ratio of each party's usage of the
transmission system.
a.)To which of these categories are Public Utility Regulatory Policy Act (PURPA)
QualifyingFacilities (QFs)classified?
b.)Please explain how network customers fund Idaho Power's transmission assets.
REQUESTNO.38:Page 42 of the Amended 20 19 Integrated Resource Plan Appendix D
describes the formula for calculating transmission rates and states Idaho Power's existing
transmission wheeling customers will pay this higher transmission rate.Idaho Power assumed
constant transmission usage by third parties from 2018 levels.Please answer the following
questions:
a.)Please explain why only existing transmission wheeling customers will pay this higher
transmission rate,not native-load customers and network customers.
FIRST PRODUCTION REQUEST
TO IDAHO POWER 9 MARCH 4,2020
b.)Please discuss whether constant transmission usage is assumed for all three categories of
customers:Native-load customers,network customers,and transmission wheeling
customers.If so,why.If not,why not.
REQUESTNO.39:Page 21 of the Amended 2019 IntegratedResource Plan states that the
2018 Variable Energy Resource (VER)Study expressed these regulating reserve requirements as
the dynamicallyvaryingfunction of several factors:season,load-base schedule,time of day,wind-
base schedule,and solar-base schedule.Please answer the followingquestions:
a.)Please discuss whether these factors are captured in the LTCE model and in the portfolio
analysis of the Amended 2019 IRP on an hourly basis.
b.)Please discuss whether all the selected portfolios (both WECC-optimized and manually
adjusted)meet the regulation reserve requirements.
c.)Please discuss whether the models define categories of regulation reserves (Load Up,
Load Down,Solar Up,Solar Down,Wind Up,Wind Down)each reserve-providing
resource can provide.
d.)Please discuss whether the models set constraints on how much capacity reserve-
providing resources (such as dispatchable thermal and hydro resources)can provide to
meet regulation reserve requirements.
e.)Please explain if the effects of the Energy Imbalance Market (EIM)are considered in
terms of providing regulating reserve in the Amended 2019 IRP.
REQUESTNO.40:Page 100 of the Amended 2019 Integrated Resource Plan states that
given the substantial variations in VER generating capacity between portfolios,and temporally (i.e.
year-to-year)within portfolios,it was impractical to approximate the Regulation Down regulating
reserve for wind and solar production,except for the winter season for solar.Please answer the
followingquestions:
a.)Please use specific examples to further explain how "the substantial variations in VER
generatingcapacity between portfolios,and temporally within portfolios"made it
impractical to approximate Regulation Down regulating reserve for wind and solar
production.
b.)Please explain why the winter season for solar is an exception.
FIRST PRODUCTION REQUEST
TO IDAHO POWER 10 MARCH 4,2020
REQUESTNO.41:Page 22 of the Amended 2019 Integrated Resource Plan states that
integration charges for VERs are not used as an input into the AURORA model because portfolio
development for the Amended 2019 IRP is being performed through LTCE modeling.Please
answer the followingquestions:
a.)Please describe the impacts of not including integration charges for VERs on the
Amended 2019 IRP results,on the Company,on the PURPA QFs,and on the ratepayers.
b.)How is the Company planning to mitigate the issue?
REQUESTNO.42:Page 23 of the Amended 2019 Integrated Resource Plan states that
when additional incremental VERs are added to the system outside,or between,IRP cycles,there is
still a need to identify the incremental cost of maintaining adequate reserves for reliable operations.
Please answer the followingquestions:
a.)Please explain if the modeling in the Amended 2019 IRP has built in extra regulation
reserves to cope with additional incremental VERs that could be potentiallyadded to the
system outside or between IRP cycles.
b.)If not,what is Idaho Power's plan to address these additional incremental VERs.
REQUESTNO.43:For the 20 manuallybuilt portfolios,please provide evidence that the
portfolios meet regulating reserve requirements and reliability standards.
REQUESTNO.44:Page 46 of the Amended 2019 IntegratedResource Plan Appendix C
compares long-term capacity expansion results between No B2H portfolios and With B2H
portfolios in pairs.Please answer the followingquestions:
a.)Why do pairs of Portfolio 6/Portfolio 18,Portfolio 8/Portfolio 20,Portfolio 11/Portfolio
23,and Portfolio 12/Portfolio 24 have different coal exit results?
b.)Why do the remaining pairs have the same coal exit results?
REQUESTNO.45:Page 109 of the Amended 2019 IntegratedResource Plan describes
the six scenarios of Jim Bridger exit.Please explain in detail why Scenario 5 and Scenario 6 are not
necessary to be tested on Portfolio 4 and Portfolio 16.
FIRST PRODUCTION REQUEST
TO IDAHO POWER 11 MARCH 4,2020
REQUESTNO.46:Table 9.9 of the Amended 2019 IntegratedResource Plan shows the
NPV of the 20 manuallybuilt portfolios under four natural gas and carbon scenarios.Please
provide the NPV variance for each of these portfolios using the same methods used to derive the
NPV variance in Figure 9.1.
REQUESTNO.47:Page 124 of the Amended 2019 Integrated Resource Plan discusses
the preferred portfolio.Please explain why among 24 WECC-optimized portfolios and 20 manually
built portfolios Portfolio 16(4)is the preferred portfolio.
REQUESTNO.48:Page 124 of the Amended 2019 Integrated Resource Plan states the
preferred portfolio was further evaluated under an assumption of planning case natural gas price
forecast and planning case carbon cost forecast,represented by Pl4(7).Please answer the following
questions:
a.)How do these assumptions differ from the assumptions used to formulate the preferred
portfolio?
b.)Please define Pl4(7).
c.)Please explain how this evaluation was conducted.
d.)Please provide the results of this evaluation.
REQUESTNO.49:Page 28 of the Amended 2019 Integrated Resource Plan Appendix C
states the first capacity deficit is 42 MW in July 2029,which has not changed from the first capacity
deficit in the original 2019 Integrated Resource Plan Appendix C.Since the Company's original
filing,several changes have occurred (e.g.approval of Jackpot Solar).Please answer the following
questions:
a.)Please list any other changes that have occurred since the original IRP was filed and that
should be included in deficit calculations for the Amended 2019 Integration Resource
Plan Appendix C.
b.)Please discuss whether these changes have been taken into account in the capacity deficit
in the Amended 2019 Integration Resource Plan Appendix C.
c.)If so,please explain why the first capacity deficit has not changed.
FIRST PRODUCTION REQUEST
TO IDAHO POWER 12 MARCH 4,2020
REQUESTNO.50:Page 28 of the Amended 2019 Integrated Resource Plan mentions
Schedule 87,Intermittent Generation Integration Charges.Is the Company planning to file updates
to integration charges based on the 2018 VER Study?
DATED at Boise,Idaho,this day of March 2020.
Edward Jew
Deputy Atto ey General
i:umise:prodreq/ipcel9.19ejmm prod reql
FIRST PRODUCTION REQUEST
TO IDAHO POWER 13 MARCH 4,2020
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 4TH DAY OF MARCH 2019,SERVED THE FOREGOING FIRST PRODUCTION REQUESTOF THECOMMISSIONSTAFFTOIDAHOPOWERCOMPANY,IN CASE NO.IPC-E-19-19,BY MAILING A COPY THEREOF,POSTAGE PREPAID,TO THEFOLLOWING:
LISA D NORDSTROM TIM TATUM
REGULATORY DOCKETS MATT LARKINIDAHOPOWERCOMPANYIDAHOPOWER COMPANY
PO BOX 70 PO BOX 70BOISEID83707-0070 BOISE ID 83707-0070
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BENJAMIN J OTTO C TOM ARKOOSHIDCONSERVATIONLEAGUEARKOOSHLAWOFFICES
710 N 6TH ST PO BOX 2900
BOISE ID 83702 BOISE ID 83701
E-mail:botto idahoconservation.org E-mail:[e-mail]
erin.cecil arkoosh.com
SECRETARY
CERTIFICATE OF SERVICE