20200508Staff 51-58 to IPC.pdf

SECOND PRODUCTION REQUEST
TO IDAHO POWER 1 MAY 8, 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
COMPANY'S 2019 INTEGRATED RESOURCE
PLAN
)
)
)
)
)
)
)
)

CASE NO. IPC-E-19-19

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 (IPC or Company)
provide the following documents and information as soon as possible, or by FRIDAY,
MAY 29, 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 May 8AM11:27
IDAHO PUBLIC
UTILITIES COMMISSION

SECOND PRODUCTION REQUEST
TO IDAHO POWER 2 MAY 8, 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. 51: In its response to Staff’s Production Request No. 21 the Company lists
the capital weighting of long-term debt and the capital weighting of common equity as 50.10% and
49.90%, respectively. The Company also states that the cost of long-term debt and the cost of
common equity are 5.73% and 10.00%, respectively. According to footnote No. 1 of the document,
these percentages are interpreted by Idaho Power, because in the General Rate Case of IPC-E-11-08
the Commission only approved an overall rate of return of 7.86% without specifying the capital
weightings and the costs. Please show and provide documentation supporting the capital weighting
percentages and the cost percentages used for long-term debt and common equity.

REQUEST NO. 52: Response to Staff’s Request No. 39 provides the number of megawatt
hours where regulation requirements are not met in each portfolio. The highest unmet rate is
0.076% in Portfolio 24. Please answer the following questions.
a. Please provide the Company’s threshold for unmet rates and/or criteria that the
Company used to determine that a portfolio was not acceptable.
b. When the Company found a portfolio that was unacceptable based on the Company’s
thresholds or criteria, please explain how the Company adjusted the portfolio to meet
the Company’s acceptance thresholds/criteria.
c. Please explain how the Company verified that the portfolios will meet the NERC
BAL-001-2 Standard that the development of regulation requirements is based on.

REQUEST NO. 53: Response to Staff’s Production Request No. 40 discusses the
approximation results for Regulation Up (RegUp) and Regulation Down (RegDn). Please answer
the following questions.
a. Please provide and explain each step in the monthly approximation process used to
develop the RegUp and RegDn percentages shown in Tables 8.1 and 8.2 in the
Amended 2019 IRP.

SECOND PRODUCTION REQUEST
TO IDAHO POWER 3 MAY 8, 2020
b. The Company states that the match between the VER study and the [monthly]
approximation results are “less clear” for RegDn. Please explain what is meant by
“less clear” and what was done to rectify the situation.
c. Please provide the data and an explanation (using examples if necessary) that
illustrates why the Company included a RegDn requirement for Solar during the
winter season, but did not include a RegDn requirement for solar during the
remaining seasons or for wind across all four seasons.
d. By using monthly approximation rules, is there a loss of accuracy due to the loss in
hourly resolution that could affect the amount of regulation resources held in
reserve? Please explain.

REQUEST NO. 54: In the Company’s 2018 VER Study (p.30), the Company states that
“AURORA does not include a cost for reserve violations in the total portfolio cost.” Please explain
how the costs of these violations were included in the cost of each portfolio in the IRP. If included,
please provide these costs for each portfolio.

REQUEST NO. 55: Response to Staff’s Request No. 48 states in Section b. that “The
timing and selection of additional resources and the timing of coal unit exits in Portfolio 14(7) are
identical to Portfolio 16(4). Please answer the following questions.
a. Please explain what Bridger exit scenario “7” represents.
b. Please explain the difference between Portfolio 14(4), Portfolio 14(7), and Portfolio
16(4).

REQUEST NO. 56: Please describe the Company's requirements and specifications for
capacity expansion modeling software. Please provide relevant supporting documentation that uses
common system and software engineering industry standards such as ISO/IEC/IEEE 12207:2017 or
similar. If industry standards are not used, please explain why not. Please provide the Company's
current requirements and specifications for capacity expansion modeling software. Please provide
any changes being considered for the 2021 IRP.

SECOND PRODUCTION REQUEST
TO IDAHO POWER 4 MAY 8, 2020
REQUEST NO. 57: Please confirm that the modeling tool used by the Company for its
2021 IRP will be configured to optimize portfolio selection for the Company's service territory.
Please explain your answer.

REQUEST NO. 58: Please explain how energy efficiency will be modeled in the 2021
IRP. Please include answers to the following questions:
a. Will energy efficiency be modeled as a supply-side resource?
b. Will measures be modeled individually, or bundled?
b. If measures are bundled, please explain how measures will be selected for inclusion
in each bundle.

DATED at Boise, Idaho, this 8th day of May 2020.

__________________________________
Edward Jewell
Deputy Attorney General

i:umisc:prodreq/ipce19.19ejmm prod req2
CERTIFICATE OF SERVICE
CERTIFICATE OF SERVICE

I HEREBY CERTIFY THAT I HAVE THIS 8th DAY OF MAY 2020, SERVED
THE FOREGOING SECOND PRODUCTION REQUEST OF THE COMMISSION
STAFF TO IDAHO POWER COMPANY, IN CASE NO. IPC-E-19-19, 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]

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

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

C TOM ARKOOSH
ARKOOSH LAW OFFICES
PO BOX 2900
BOISE ID 83701
E-mail: [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]

JACK VAN VALKENBURGH
VAN VALKENBURGH LAW PLLC
PO BOX 531
BOISE ID 83701
E-mail: [e-mail]

JIM KREIDER
STOP B2H COALITION
60366 MARVIN RD
LA GRANDE OR 97850
E-mail: [e-mail]

AUSTIN RUESCHHOFF
THORVALD A NELSON
HOLLAND & HART LLP
555 17TH ST STE 3200
DENVER CO 80202
E-mail: [e-mail]
[e-mail]
[e-mail]
[e-mail]
JIM SWIER
MICRON TECHNOLOGY INC
800 SOUTH FEDERAL WAY
BOISE ID 83707
E-mail: [e-mail]

CERTIFICATE OF SERVICE

JULIAN ARIS
SIERRA CLUB
2101 WEBSTER ST STE 1300
OAKLAND CA 94612
E-mail: [e-mail]

GLORIA D SMITH
SIERRA CLUB
2101 WEBSTER ST STE 1300
OAKLAND CA 94612
E-mail: [e-mail]

/s/ Reyna Quintero __
SECRETARY