20200626IPC to Stop B2H 1-30.pdf

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LISA D. NORDSTROi'
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June 26,2020
VIA ELECTRONIC FILING
Diane Hanian, Secretary
ldaho Public Utilities Commission
11331 W. Chinden Boulevard
Building 8, Suite 201-A
Boise, ldaho 83714
Re: Case No. IPC-E-19-19
2019 lntegrated Resource Plan - ldaho Power Company's Response to the
First Production Request of the STOP B2H Coalition to ldaho Power DRs 1-
30
Dear Ms. Hanian
Attached for electronic filing in the above matter is ldaho Power Company's
Response to the First Production Request of the STOP B2H Coalition to ldaho Power.
lf you have any questions aboutthe enclosed documents, please do not hesitate to
contract me.
Very truly yours,
&;!.("*t^-*,
Lisa D. Nordstrom
LDN:sdh
Enclosures
LISA D. NORDSTROM (lSB No. 5733)
ldaho Power Company
1221 West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
lnord strom@idahopower. com
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
!N THE MATTER OF IDAHO POWER
COMPANY'S 201 9 INTEGRATED
RESOURCE PLAN
CASE NO. |PC-E-19-19
IDAHO POWER COMPANY'S
RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
STOP B2H COALITION TO IDAHO
POWER COMPANY
COMES NOW, ldaho Power Company ("ldaho Power" or "Company"), and in
response to the First Production Request of STOP B2H Coalition to ldaho Power
Company dated June 5, 2A20, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF STOP B2H
COALITION TO IDAHO POWER COMPANY. 1
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REQUEST NO. 1:
On Page 86 of the Amended lRP, ldaho Power states the following;
"The Jim Bridger unites provide system reliability benefits,
particularly related to the company's flexible ramping capacity
needs for EIM participation and reliable system operations. The
need for flexible ramping is simulated in the AURORA modeling as
previously described. However, the AURORA modeling indicates
removal of Jim Bridger units needs to be carefully evaluated
because of potential heightened concerns about meeting regulating
reserve requirements following their removal."
Please describe what ldaho Power's AURORA modeling reveals that
indicates "potentia! heightened concerns about meeting rcgulating reserve
requirements following their removal". Please explain why ldaho Power was
unable to carcfully evaluate the regulating reserye requirements associated
with retirement of Jim Bridger units in the 2019 IRP using AURORA's ability to
simulate the need for flexible ramping.
RESPONSE TO REQUEST NO. 1: ldaho Power evaluated regulating reserve
requirements associated with Jim Bridger exits in the !RP. Page 86 of the Amended IRP
is referencing the need to continue to evaluate these needs as units are exited.
As the Bridger coal units are exited the number of regulating reserve shortfalls increases, as
shown in the chart below. This is what was meant by AURORA's modeling revealing "potential
heightened concems about meeting regulating reserve requirements following their removal'.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF STOP B2H
COALITION TO IDAHO POWER COMPANY -2
Portfolio 16 identified 600 MW of wind and 1,165 MW of solar to meet future demand.
The combination of the additional intermittent resources plus the retirement of 1,026
MW of coal through 2030 will require that the Company turther evaluate flexible capacity
to address potential flexibility deficiencies. While extensive analyses on how to mitigate
the shortage of regulating reserves in the outer years of the IRP have not yet been
conducted, ldaho Power is evaluating regulating reserve requirements of the first
Bridger unit exit in the 2D20Yariable Energy Resource lntegration Study. The Company
will continue to review options to meet these requirements as Bridger unit exits are
negotiated to ensure the reliability of the electrical system.
Reserve Shortfalls By Year - Portfolio 15
40,000
35,000
30,000
25,000
20.000
15,000
10,000
s,000
0
zor9 2020 2027 2022 2023 2024 2025
Years
2030
r Regup r RetDown
The response to this Request is sponsored by Jared Hansen, Resource Planning
Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF STOP B2H
COALITION TO IDAHO POWER COMPANY.3
E
==llr
2026 2027 2028 2029
REQUEST NO. 2: At the December IRPAC meeting, ldaho Power explained that
it refined the representation of ldaho loads and resources in the Aurora model by
assigning ldaho Power Company loads into Area 612 IPC (ldaho Power Company) in
AURORA and assigning the ldaho loads of Bonneville Power and PacifiCorp into a
separate Area 615 identified as lDSo (ldaho South). ldaho Power further showed that
ldaho's peak hour in AURORA in 2019 reflected peak loads in Area 612 UOC if
approximately 3,200 MW and peak hour loads in Area 615 lDSo of approximately 550
MW. (The December 2018 presentation is available at this !ink:
https://docsidahopower.comipdfs/AboutUs/PlanninqForFuture/irp/2018/lRPACDec2018.
pdl
Further, in response to OPUC Staff DR 54 (OPUC Staff DR 54 with supporting
files attached), ldaho Power explained that it assigned 3,480 MW of existing generating
resour@s to Area 612 and assigned 780 MW of existing generating resources to Area
615 resulting in the following Area Load/Resource balance in AURORA. (Note that no
existing coal resouroes were assigned to Area 615 so area 615 will not be directly
affected by the retirement of any existing coal plants).
The following table displays the Load/Resource balance established by ldaho
Power in the AURORA model for Areas 612 (ldaho Power) and 615 (BPA and
PacifiCorp).
Further, in response to Staff DR 54, ldaho Power explained that it assigned
3,480 lvlW of existing generating resouroes to Area 612 and assigned 780 MW of
existing generating resour@s to Area 615 resulting in the following Area Load/Resource
balance in Aurora. (Note that no existing coal resources were assigned to Area 615 so
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF STOP B2H
COALITION TO IDAHO POWER COMPANY.4
lArea 612 IPC lArea 615 IPC
13.197 MW 1554 MWPeak Hour Load
480 MWArea Resources
I,f80
r\tt\ /
P
Area Resources without ,161 MW 80 MWr
Surplus Capacity at Peak
after retirement of Valmy and
Boardman
I-36 MW 226 [/rW
ln"r"rr" Margin = 0 ln"t"r" Margin = 41o/o
area 615 will not be directly affected by the retirement of any existing coal plants.)
The following table displays the Load/Resource balance established by ldaho
Power in the Aurora model for Areas 612 (ldaho Power) and 615 (BPA and
PacifiCorp).
It can be seen from the Table that Area 615 has a significant reserve margin
suggesting that Area 615 will not need new resources for many years, yet ldaho
Power's response to Staff DR 52 (tab R16 RMT) shows that under ldaho Power's
preferred Portfolio P16, a 429 MW combined cvcle gas plant is built in Southern ldaho
Area 615 in 2023.
WECC ldahoSourth 615
Please explain why ldaho Power's preferred Portfolio includes the
addition of a new 429 MW combined cycte gas plant in Southern ldaho, in 2023.
On what utility's behalf is this resource added by AURORA. Please also explain
the effect that this thermal resourco addition in ldaho tn 2023 has on ldaho
Power's determination that its period of sufficiency extends through 2025.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF STOP B2H
COALITION TO IDAHO POWER COMPANY - 5
12t31t2039New Resource
3723 from
2584 CCCT
qas/oilAdv
Na 429 NGllDSo 1t1t2023
RESPONSE TO REQUEST NO. 2:Idaho Power would like to clarify that the
peak load values identified in the table included as part of this request are pulled from
the slides representing the July 23, 2019, hour 18 load forecast, which does not
represent peak conditions for ldaho Power. Additionally, the peaks of ldaho Power and
the ldaho South areas are not coincident. Therefore, the conclusions drawn by STOP
B2H about planning margin are incorrect.
The long-term capacity expansion ("LTCE") capability of AURORA was used to
produce WECC-optimized portfolios under various future conditions. ln doing so, the
LTCE optimizes resource additions throughout the WECC, including within ldaho
Power's system as well as the ldaho South area. This is a necessary step to reflect
future market conditions. However, the portfolios evaluated through the company's IRP
reflect the addition of supply-side and demand-side resour@s, as well as, exits from
current coal-units for ldaho Power's system only, and therefore, ldaho Power's
preferred portfolio does not include a new 429 MW combined cycle gas plant as a
recommended resource for ldaho South.
Resources identified by the LTCE model to serve loads outside of ldaho Power
are not included in ldaho Power's reserve margin calculations.
The response to this Request is sponsored by Jared Hansen, Resource Planning
Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF STOP B2H
COALITION TO IDAHO POWER COMPANY - 6
REQUEST NO. 3: Please reference the tab titled'AURORA Resouroes Table" in
ldaho Poweds response to Staff DR No. 54. STOP reviewed the resources assigned to
ldaho Power Area 612 and observed that Area 612 does not include any of ldaho
Powe/s existing PURPA resouroes. STOP observes that ldaho Power has instead
established a third "Area" in Idaho labeled Area 613 and it appears to STOP that ldaho
Power has assigned all of ldaho Poweds existing PURPA resouroes into Area 613 and
assigned a zero capacity to all these PURPA resouroes. STOP interpreB this to mean
that ldaho Power has effectively removed its existing PURPA resouroes from the
AURORA resouroe data base.
tMrat folloua is sampling from EXISTING RESOURCE DATA Qualifying Facility
Data (PURPA) Cogeneration and Small Pouver Production Projects Status as of
December 31,2019 from 2019 Amended lntegrated Resource Plan, Appendix C p29-
31 as compared to resources in Staff DR No. 54 Zone 613.
and Small Power Production Status as of December 3't 2019
Staff DR No. 5,4 -Aurora Resources Table tab
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF STOP B2H
COALITION TO IDAHO POWER COMPANY - 7
End DateProiectMWOn-line Date
Barber Dam
Detrich Droo
JettCrsekWind Farm o Mar-Mar
Name Utility Gaoacitv Fuel AreaIII
I I
I
Jett Croek Jett I \,\N)613
STOP observes that removing all existing PURPA Variable Energy Resources
(VER) (wind and solar) and small hydro resouroes from the ldaho Power system in
AURORA by assigning them zero capacity value would significantly reduce the
amount of reg up and reg down required to be held as balancing reserves by ldaho
Power in the AURORA model.
Please explain why ldaho Power has rcmoved all ats existing PURPA
resouncea from Area 612Jdaho Power and reassigned them to Area 613, and then
zeroed out all PURPA resource capacity and energy in the AURORA model Area
613.
Please explain how this effective rcmoval of all existing ldaho Power
PURPA reEources from the AURORA model affects the ability of AURORA to
accurately model the adequacy of Idaho Powe/s flexible capacity reserves. In
particular, explain how AURORA can realistically ensurc ldaho Powe/s
existing flexible capacity tesources are providing adequaE balancing reserves
(i.e., reg up and reg down) when Jackpot Solar is added in 2022 and Jim
Bridger 1 is retired in 2022. if the model cannot see any of ldaho Power's
existing PURPA resourcea and their associabd demands for flexibility
ngserves.
Finally, please explain the effiect of the above removal of ldaho Power's
PURPA reaources from the Aurora model on the determination of ldaho
Power's period of sufficiency.
lf ldaho Power denies that it has excluded ldaho Power's existing PURPA
rcsourcea in the Portfolio modeling in the AURORA model, please provide a table
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF STOP B2H
COALIT]ON TO IDAHO POWER COMPANY - 8
showing the hourly generation for each PURPA resource in Portfolio's P14, P16
and P16-,4, as dispabhed in the Aurora Model for each hour in July over the 20 year
planning period.
RESPONSE TO REQUEST NO. 3: To address this request, ldaho Power is
referencing the "AURORA Resources Table" tab provided as an attachment to the
Company's response to Staffs Request No. 52, not attachment to Staff's Request No.
54 as indicated in the question.
Within the table, note that the following resources are included: PURPA Thermal,
PURPA Biomass, PURPA Cogen, PURPA Wind, PURPA Solar and PURPA Hydro.
These resources are defined as ldaho Power resources and fall under area 612. The
generation associated with all ldaho Power PURPA resources through the 20-year
planning period and the corresponding generation thereof is accounted for under these
combined PURPA resources and not the individual projects as STOP B2H refers to
above.
The hourly July PURPA generation for the requested portfolios can be found in
the Excel spreadsheet accompanying this response.
The response to this Request is sponsored by Jared Hansen, Resource Planning
Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF STOP B2H
COALITiON TO IDAHO POWER COMPANY.9
REQUEST NO. 4: On page 22 of the Amended 2019 lRP, ldaho Power
discusses the 2018 Variable Energy Resource (VER) Study conducted by ldaho
Power available at this link.
https://apps.puc.state.or.us/edockets/edocs.asp?FileTvpe=HAD&FileName=um1793ha
d 1 691 0.pdf&DocketlD=20334&n umSequence=42
ldaho Power states in the Amended 2019 IRP that:
"The 2018 VER Study also identified that, based on the cunent
resources on Idaho Powe/s system, 173 MW of additional VERs could
be integrated before reserve margin violations exceed 10 percent of the
operating hours during the year."
At the time the 2018 VER Study was conducted, ldaho Power stated that it had
1,016 MW of VER resouroes on the ldaho Power system and estimated the maximum
amount of additional VER that couH be added without exhausting ldaho Power's
existing regulating reserves was 173 MW; a total of 1,190 MW.
'The 173 MW of additional VER results in approximately 1,190 MW of
total nameplate VER (727 MW wind + 289 MW solar + 173 MW
additional VER = approximately 1,190 MW of total VER) on a system
with a 3,400 MW peak and average sales of 1,755 MW. Expansion
beyond this level canies concerns that significant reliability issues will
be encountered associated with the system's inability to provide
sufficient regulating reserves." P 35.
The VER Study further suggested that a strong case could be made that no
additionalVER resources should be put on the system:
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF STOP B2H
COALITION TO IDAHO POWER COMPANY.lO
"However, as described in the 2017 Operational lssues section, the
current quantity of variable resources on ldaho Power's system
periodically exhausts the operating reserves available. The modeling
results and number of actual wind curtailments during 2017 suggest a
strong case could be made that no additional VER resources should be
put on the system to avoid periodic reserve deficiencies." P 36
According to the Amended 2019 lRP, VER resources on the ldaho Power
system now total 1044 MW, an increase of 24 MW since the 2018 Study was
completed. The addition of the 120 MW Jackpot Solar in 2022 will increase this total to
1,164, just shy of the maximum amount that could be added without creating
"significant reliability issues", according to the 2018 Study. At the same time, ldaho
Power is on the verge of losing existing regulating reserves due to the impending
retirement of Boardman and Valmy, flexible resources that were available for
balancing in the 2017 operational study but are retired in the first two years of all
Portfolios in the 2019 !RP.
On top of these increases in VER resources and loss of flexible capacity
resources (Boardman and Valmy), the 2019 Amended IRP Preferred Portfolio
proposes the early retirement ol 177 MW of Bridger capacity, which would further
reduce the balancing reserves available to ldaho Power. !n summary despite an 148
MW increase of VER resour@s since the 2018 Study, and the loss of regulating
reserves associated with the retirements of Boardman, Valmy and the further
retirement of a Bridger unit in 2022,ldaho Power claims in the 2019 IRP that it has
sufficient regulating reserves and no new flexibility resources are needed under the
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PROOUCTION REQUEST OF STOP B2H
COALITION TO IDAHO POWER COMPANY. .I1
preferred Portfolio, even with the retirement of a Bridger unit in 2022.
"The results of the 2019 lRP portfolio development show that additional
VERs are selected in a majority of LTCE portfolios, and many of the
portfolios show new solar resources selected and coal units being
retired. This indicates the model has sufficient regulating reserves to
economically retire a reserve-contributing coal unit while adding new
solar resources." (Amended IRP Page 23)
Please explain this conflicUdisconnect between the AURORA modeling
results showing that the ldaho Power system has plenty of existing flexible
capacity reaources to integrate Jackpot Solar and retire a Bridger unit and the
detailed analytic results presented in the 2018 VER Study showing that ldaho
Power is close to exhausting ib flexible capacity reserye margin today, evon
without the addition of new VER resources or coal plant retirements (i.e.,
Valmy, Boardman and Bridger).
RESPONSE TO REQUEST NO. 4: The VER study conducted in 2018 was
focused on identifying the costs of VER integration. While a VER limit was identified
(173 MW), the limit does not indicate an absolute limit, especially given the different
attributes of wind and solar generation. lt indicates a point at which a more detailed
analysis will be required.
The analysis of the preferred portfolio in the 2019 IRP was conducted under a
different set of conditions and over a different timeframe that included an updated load
forecast, the addition of Jackpot Solar, Bridger unit exits, access to markets, and the
addition of the Boardman to Hemingway line, among other resource additions and exits.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF STOP B2H
COALITION TO IDAHO POWER COMPANY - 12
The regulation reserye requirement results of this analysis are presented in the
Company's response to STOP B2H's Request No, 1.
Because the purpose, resource types, conditions, and timeframe of each
analysis are different, the results vary.
ldaho Power is continuing to analyze the integration costs and benefits
associated with VER integration in the 2020 VER Study, currently in progress. The 2020
VER Study assumptions will include Jackpot Solar and the first Bridger unit exit
The response to this Request is sponsored by Jared Hansen, Resource Planning
Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF STOP B2H
COALITION TO IDAHO POWER COMPANY - 13
REQUEST NO. 5: Referencing page l1 of the Reply Comments of ldaho
Power (see STOP Request No. 5 support file - attached), E. Emergency Transmission
Capacity Does Not Offset the Need for B2H, please explain how ldaho Power defines
the term "Emergency Transmission".
RESPONSE TO REQUEST NO. 5: The "Emergency Transmission" term on
Page 11 of the reply comments references the definition of CBM. According to the
NERC Glossary of Terms, CBM is defined as:
Capacity Benefit Margin ("CBM") - The amount of ftrm fransmrssrbn capability
preserued by the lransmrssion Provider for Load-Seruing Entities (LSEs), whose
loads are located on that Tansmission Prcvider's sysfem, to enable access by
the LSEs to generation from interconnecfed sysfems to meet generation
reliability requiremenfs. Preseruation of CBM for an ISE a//ols that entity to
rcduce its installed generating capacity below that which may otherwise have
been necessary without interconnecflons to meet ,ts generation rcliability
requiremenfs. Ihe fransmissrbn transfer capability prcserued as CBM is intended
to be used by fhe ISE only in times of emergency generation deficiencies.
CBM is intended to be used only in times ol emergency (emphasis added) generation
deficiencies, i.e. CBM is emergency transmission capacity.
The response to this Request is sponsored by Jared Ellsworth, Transmission,
Distribution & Resource Planning Director, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF STOP B2H
COALITION TO IDAHO POWER COMPANY.14
REQUEST NO. 6: PIease provide a copy (listing) of ldaho Power's
Designabd Network Resources, as currently posted on ldaho Power's Open
acceas Same Time lnformation System (OASIS).
RESPONSE TO REOUEST NO. 6:Please see the Excel spreadsheet
accompanying this response which contains the list of ldaho Povyer's designated
Network Resources.
The response to this Request is sponsored by Joshua Harris, System Operations
Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF STOP B2H
COALITION TO IDAHO POWER COMPANY.l5
REOUEST No. 7: Please Refer to the FERC Audit Report dated June 11,2018,
"Audit of ldaho Power Company's Open Access Same-Time lnformation Systems,
Business Practice Standards and Communication Protocols for Public Utilities,
Transparency Rule, and lnformation Posting Requirements Contained Within ldaho
Power's Open Access Transmission Tariff" (FERC Docket No. PA17-7-000)
available on the FERC website at
https://elibrarv.ferc. gov/idmws/common/OpenNat.asp?filel D= 1 4943440 .
Pertaining to CBM, FERC noted the following Pertinent Guidance p 38
Peftinent Guidance
18 c.F.R. S s7.6(b)(s)(iiil6) sfafes:
The Transmr'ssrbn Prcvider must reevaluafe ifs CBM needs at least every
year'
18 c.F.R. S 37.6(b)(3)(iiil@) sfafes;
The Transmission Prcvider musf post its pnctices for reevaluating its
CBM needs.
18 C.F.R. S 37.7(b) sfafes, in paft:
The audit data are to be retained and made available upon requestfor
download for five yearc from the date when they are first posted in the
same electronic form as used when they originally werc posted on the
oAs/s.
The audit found that ldaho Power was not in compliance with the above:
"ldaho Power's data responses demonstrated that it established
its current CBM value (330 MW) in2O15 and had not changed in
the last three years. ldaho Power admitted that it does not have
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF STOP B2H
COALITION TO IDAHO POWER COMPANY. 16
the documentation for reevaluating its CBM needs as an internal
documented procedure to inform its practices, nor does it post
such information on its OASIS. This does not comply with the
requirement described under 18 C.F.R. S 37.6(bX3XiiiXB), which
requires a transmission provider like ldaho Power to post its
practices for reevaluating its CBM needs."
FERC recommended that ldaho Power:
. lmplement a procedure to maintain documentation adequate to
show ldaho Power reevaluated its annual CBM needs on a going-
forward basis.
r Enhance controls to ensure the planning department provides timely
notification to OASIS personnelthat they reevaluated CBM needs.
. Revise CBM Procedures to include a description of practices for the
annual reevaluation of CBM needs or post a separate document
describing the practices for annual reevaluation of CBM needs.
The report indicated that ldaho Power accepted and implemented each of these
recommendations.
Conective Actions Taken
As of June 2, 2017 ,ldaho Power had developed two procedures to ensure its
transmission planner and OASIS staff coordinate with each other on evaluating
and posting CBM needs. ldaho Power also developed a Capacity Benefit
Margin Procedure that summarizes its current process for establishing a CBM
value. Based upon its review of the actions undertaken by ldaho Power during
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF STOP B2H
COALITION TO IDAHO POWER COMPANY - 17
the audit, audit staff determined that ldaho Power has fully completed
Recommendation 17-19. to reevaluate its capacity benefit margin (CBM) needs
at least annually, and post its practices for reevaluating its CBM needs.
Pease provide a copy of each of the two procedures referenced in the
FERC Audit Report that ldaho Power developed to ensure its transmission
planner and OASIS staff coordinate with each other on evaluating and posting
CBM needs.
Please provide a copy of ldaho Power's Capacity Benefit Margin
Procedure referenced above as currently posted on OASIS, that summarizes
its current process for establishing a GBM value, and
Please provide documentation of ldaho Power's three most recent annual re-
evaluations of CBM needs.
RESPONSE TO REQUEST NO. 7: The two procedures ldaho Power developed
accompany this response and are titled "Capacity Benefit Margin Procedure" and
"MOD-004-1 - Transmission Planner."
The Company developed the "Capacity Benefit Margin Procedure" in 2017 lo
ensure the evaluation of CBM takes place. The procedure was created to enhance
controls in the way the Company's Load Serving Operations communicates with System
Planning at least annually regarding the evaluation of CBM. The "MOD-004-1
Transmission Planne/'procedure is utilized by System Planning to evaluate CBM and it
describes the roles and responsibilities for compliance with NER Reliability Standard
Mod-004-1.
Lastly, the record indicating the ldaho Power's annual evaluation of CBM is
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF STOP B2H
COALITION TO IDAHO POWER COMPANY. 18
included in the figure below. As mentioned in the procedures, System Planning reviews
the ldaho Power system to determine if ldaho Power's Most Severe Single Contingency
('MSSC') has changed from 330 MW for a RemedialAction Scheme 1'FIAS") 2-unit trip
of Jim Bridger Power PIant. To this date it has remained the same.
The response to this Request is sponsored by Joshua Hanis, System Operations
Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF STOP B2H
COALITION TO IDAHO POWER COMPANY - 19
REQUEST NO. 8:
Reference Compliance with EV Guideline 1 (Amended 2019 lntegrated Resource
Plan - Appendix C page 85) reprinted below.
Guideline 1: Forecast the Demand for Flexible Capacity
Forecast the Demand for Flexible Capacity: The electric utilities shall forecast the
balancing reserves needed at different time intervals (e.g. ramping needed within
5 minutes) to respond to variation in load and intermittent renewable generation
over the Z0-year planning period.
Please provide ldaho Power's forecast of balancing reserves needed at
different time intervals to respond to variation in load and inbrmittent renewable
generation over the 20-year planning period for Portfolios P4, P-16 and P164.
RESPONSE TO REQUEST NO.8: The requested forecasts are provided in the
attachment accompanying this response. The amount of reserves needed or required
are Iisted by year in column F. Column G shows the resources that meet those reserve
requirements.
The response to this Request is sponsored by Jared Hansen, Resource Planning
Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF STOP B2H
COALITION TO IDAHO POWER COMPANY.20
REQUEST NO. 9: Reference Compliance with EV Guideline 2 (Amended 2019
lntegrated Resource Plan - Appendix C page 85) reprinted below.
Guideline 2: Forecast the Supply for Flexible Capacity
Forecast the Supply of Flexible Capacity: The electric utilities shall forecast
balancing reserves available at different time intervals (e.9. ramping available within 5
minutes) from existing generating resources over the 20-year planning period.
Please provide ldaho Power's forecast of balancing reserves available for
existing generating resources over the 20-year planning period for Portfolios P4,
P16 and P{64.
RESPONSE TO REQUEST NO. 9: For every portfolio tested, the nameplate
capacity of the existing resources listed below were designated in Aurora as resources
available for providing balancing reserves. Plant capacities can be found in Table 3.2 ot
the Amended 2019 lRP. However, if a unit is retired in a portfolio, that capacity is no
longer available.
o Brownlee
o Oxbow
o Langley Gulch
. Danskin
o Bennett Mountain
o Jim Bridger
. Valmy
ln addition to ldaho Power's existing resources, new natural gas and storage
resouroes identified in the portfolios also provide balancing reserves. Please refer to
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF STOP B2H
COALITION TO IDAHO POWER COMPANY - 21
the Amended Appendix C Long-Term Capital Expansion Results (pages 49 and 67) for
a listing of the resources added for Portfolios 4, 16, and 164.
The response to this Request is sponsored by Jared Hansen, Resource Planning
Leader, ldaho Pourer Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REOUEST OF STOP B2H
COALITION TO IDAHO POWER COMPANY.22
REQUEST NO. 10: I OPUC staff data request #33 (STOP REQUEST NO. 00
staff asks about resource adequacy concerns in the Pacific northwest and the type of
resources that the company is assuming is available to generate power and
subsequently buy at mid -c to expert across B2H. the company's reply is reassuring.
However, the ldaho PUC in Case No. IPC-E-19-14, ln the matter of the
application of ldaho Power for the approval of a power purchase agreement with
Jackpot holding LLC for the sale and purchase of up to 22O megawatts of renewable
solar generation, IPUC staff felt that the inclusion of Jackpot Solar was a prudent
investment as the PPA rates were more competitive over the PPA period than market
purchased from the mid -c.
Please show alt market research done on the cost of market purchases
from the mid+ for the 20 year planning period. lf no market research was done
please show al! mid - c cost dah from AURORA for the 20 year planning period.
CASE NO. IPC-E-19-14, ln the matter of the application of ldaho power for
the approval of a power purchase agreement with Jackpot Holdings, LLC for
the sa/e and purchase of up to 220 megawafts of renewable solar generation,
IPUC sfaffsfafe on p 5.
To supplement the 2019 /RP analysis, Slaff compared contract prices to
expected market prices at Mid-C. ld. at 10. Staff selected Mid-C for
comparison because ldaho Power fransacfs most of its ma*et purchases
through the Mid-C hub. ld. at 11. Sfaff found a $145,000 savings in thts
comparison during the first year, $492,000 in savings in the second year,
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF STOP B2H
COALITION TO IDAHO POWER COMPANY.23
and increased savings thereafter because the forecasfed Mid-C prices
increase at a faster rate than the contract rate. ld. at 10-12.
RESPONSE TO REQUEST NO. 10: Section 9 "Regional Resource Adequacy"
on page 12O of ldaho Power's Amended IRP discussed the Company's research into
regional resource adequacy to better understand the liquidity of the regional wholesale
electric markets, ln addition, the Excel spreadsheet accompanying this response
provides the Aurora output of annual market purchase and sales prices for each
portfolio over the 20-year planning period.
The response to this Request is sponsored by Jared Hansen, Resource Planning
Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF STOP B2H
COAL]TION TO IDAHO POWER COMPANY.24
REQUEST NO. {{: ln the Amended 2019 lntegrated Resource Plan - Appendix
D on p 9 in the Section "Mid-C and ldaho Powet'', the company states:
"ldaho Power customers benefit from these surplus energy sales as offsets to net
power supply costs through the power cost adjustment (PCA)."
Please provide the last 10 yearB of data showlng how ldaho Power
customers benefited financially form these surplus energy sales as offiEets to net
power supply costs through the power cost adjustment (PCA).
Please provide the last 10 years of data for power cost adjustment (PCA) by
categories and schedules. lnclude the Base Power Cost Proiected Power Gost
estimate, the true up and true up of the true up, earnings sharing by schedule,
and the power cost adjustment by cchedule.
httos://docs.idahopower.com/pdfslaboutus/ratesreoulatory/tarifE/48.pdf
RESPONSE TO REQUEST NO. 11: Please see the Excel file accompanying
this response. The first tab of the Excel file titled 'Actual Net Power Supply Expense"
provides historical net power supply expense ('NPSE') for the last 10 years, including
surplus sales revenue, which serves as an ofbet to total NPSE and a benefit to
customers, The remaining tabs in the Excel file support the determination of PCA rates
by class for the last 10 years, including the Base Power Costs and Projected Power
Costs for Category 1, Category 2 and Category 3, the true up and true up of the true up,
and earnings sharing.
]DAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF STOP B2H
COALITION TO IDAHO POWER COMPANY .25
The response to this Request is sponsored by Matt Larkin, Revenue
Requirement Senior Manager, Idaho Power Gompany.
IDAHO POWER COMPANTS RESPONSE TO THE FIRST PRODUCTION REQUEST OF STOP B2H
COALITION TO IDAHO POWER COMPANY.26
REQUEST NO. 12: ln OPUC staff DR 33 the company provides in
attachment 2, "2025 Northwest Gen" which is a summary from a 2025 heavy
summer load Western Electricity Coordinating Council ("WECC') power flow case
that lists all the dispatchable resources expected to be available in 2025 in the
Northwest and Canada.
Please show the cost of market purchases from the mid-c for this time
period. Howe do the market purchases from the mid-c during this period
compare to the PPA for Jackpot Solar for the same time period?
RESPONSE TO REQUEST NO. 12: For the preferred portfolio, the average
purchase price for the year 2025 is $39.49/MWh compared to Jackpot Solar's purchase
ag reemen t in 2025 ot $22.7 ilMwh.
The response to this Request is sponsored by Jared Hansen, Resource Planning
Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF STOP B2H
COALITION TO IDAHO POWER COMPANY.2T
REQUEST NO. t3: Based on the anticipated coal retirements in the mid -c,
Table 9.10 Coal retirement forecast p 121, how will this rcduce the congestion on
Pat {4 W-E?
How many MW travel along Path 14 W-E from these units on a
monthlyldailylhourly schedule for the past 10 years?
RESPONSE TO REQUEST NO. 13: ldaho Power does not expect the listed
coal retirements to have a significant impact on Path 14. The Path 14 transmission
utilized to transmit ldaho PoweCs share of Boardman will be repurposed for Northwest
market purchases. Any non-Boardman coal power transfers were simply market
purchases, and ldaho Power will transact with a different seller in the future post coal
unit retirement.
ldaho Power was only able to readily access data back to December 2013 out of
our existing system. Please see the Excel spreadsheet accompanying this response for
the hourly data from December 2013 to present related to Boardman and Centralia
schedules across Path 14. Please note that the data in the spreadsheet for Centralia is
total plant data (two units both identified in Table 9.10).
The Company did not provide information related to Colstrip because ldaho
Power was not able to differentiate the Colstrip data between Units 1 and 2, which were
identified in Table 9.10 to be retired and the much larger Units 3 and 4 which are
continuing operation.
Valmy is in Nevada and does not cross Path 14.
The response to this Request is sponsored by Jared Ellsworth, Transmission,
Distribution & Resource Planning Director, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF STOP B2H
COALITION TO IDAHO POWER COMPANY - 28
REQUEST NO. 14: On pdf p 303 of the 2019 Amended lntegrated
Resource Plan, "Data Point 2. Pacilic Northwest Power Supply Adequacy
Assessment for 2023-Northwest Power Conservation Council Report" the
company discusses the increased resource inadequacy as expressed as a
loss-of-load probability (LOLP). This LOLP will exceed and grow beyond the
5 percent threshold for years. Under normal market conditions as supply
decreases the price increases.
Please describe the analysis the company did to factor in the price
increase in the mid - c due to this reaource inadequacy. Show the price
increases the company input into AURORA. lf AURORA supplied the prices
please show those. lf both occurrcd show these too.
RESPONSE TO REQUEST NO. 14: Prices are not an input to the Aurora
model. Rather, the Aurora software applies economic principles and dispatch
simulations to model the relationships between generation, transmission, and demand
across a modeled WECC to forecast market prices.
The Loss-of-Load Probability ("LOLP) is a statistical analysis concerned with
evaluating the preferred portfolio's probability of losing load using a threshold of one day
per 10 years. A market price analysis is not performed for this evaluation.
ldaho Power performed a stochastic risk analysis assessing the effect of portfolio
costs when outcomes of variables differ from the planning case. ln this analysis, market
prices are impacted by the changes in natural gas prices, load, and hydro generation.
This analysis can be found in Chapter 9 of the 2019 Amended lRP, pages 111-115.
Please refer to the Excel spreadsheet accompanying the Company's Response
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF STOP B2H
COALITION TO IDAHO POWER COMPANY - 29
to STOP B2H Request No. 10 for the Aurora output of annual average sales and
purchase prices for each portfolio over the 20-yeat planning period.
The reeponse to this Request is sponsored by Jared Hansen, Resource Planning
Leader, ldaho PovYer Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF STOP B2H
COALITION TO IDAHO POWER COMPANY - 30
REQUEST NO. 15: The com pany states, "ldaho Power assumed two 100
MW BPA long-term point-to-point reservations will not continue starting July
2026. BPA agreed to this arrangement with ldaho Power while awaiting BzH,
and the service is only conditionally firm.
How is this annual revenue credit loss calculated in the portfolios? What are
the effects of the annual revonue credit loss to the cost ultimately borne by
customers/ratepayers per the B2H Cost Treatment in the IRP section?
RESPONSE TO REQUEST NO. 15: The two 100 MW BPA long-term point-to-
point reservations are a bridge to a longer-term solution for BPA, and ldaho Power
assumed these reservations would terminate in July 2026 tndependent of the IRP
portfolios. This assumption is consistent throughout all portfolios and independent of
any costs related to B2H; therefore, there are no effects of the annual revenue credit
loss on relative portfolio cost.
The response to this Request is sponsored by Jared Ellsworth, Transmission,
Distribution & Resource Planning Director, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF STOP B2H
COALITION TO IDAHO POWER COMPANY - 31
REQUEST NO. 16: ln OPUC staff DR 33 the company states that, "lt is
worth noting that intermittent renewable resources can be purchased as a firm
product if the selling party takes steps to "firm" up the product. For example,
ldaho Power had over 13,000 MWh of firm purchases from Avangrid Renewables
from 2017-20'19."
How many contracts of this nature has the company considered,
purchased, are in negotiation to purchase, and furned down? lf some were turned
down please explain why. What is the MW value of each?
RESPONSE TO BEQUEST NO. 16: ldaho Power's purchases from Avangrid
Renewables were market transactions. ldaho Power is continuously negotiating energy
purchases and sales through the market, either bilaterally or through trading platforms
such as lCE, on timeframes of months, days, and hours ahead of real time to provide
the most cost-effective energy to its customers. months, days, and hours ahead of real
time to provide the most cost-effective and reliable energy to our customers. Further,
the depth and availability of market products is significant, and for practical purposes
the Company does not retain information on all possible contract options that are not
ultimately pursued.
Market transactions are very fluid and available products are voluminous,
therefore, it is not possible to provide contracts of this nature that ldaho Power
considered, is in negotiation to purchase, or turned down as indicated in the request.
ldaho Powe/s annual energy purchases are summarized within the annual FERC Form
1 filing on Pages 326 and 327.The 2019 data is attached for convenience.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF STOP B2H
COALITION TO IDAHO POWER COMPANY.32
The rcsponse to this Request is sponsored by Jared Ellsworth, Transmission,
Distribution & Resource Planning Director, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF STOP B2H
COALITION TO IDAI{O POWER COMPANY - 33
REQUEST NO. 17: The 2018 Variable Ene rgy Resource (VER) Study (2019
Amended lntegrated Resource Plan pdf p 37) used an approximation method to
convert hourly rules imposed on a one-year historical test year to monthly rules
imposed on a twenty year forecast period with changing resources.
How does the margin of error derived from a one-year historical test year to
monthly rules imposed on a twenty year forecast period with changing resources
associated with tables 8.1 and 8.2 change over the 20 year period? Please provide
this data in an excel format.
RESPONSE TO REQUEST NO. 17: The RegUp and RegDn approximations
presented in Tables 8.1 and 8.2 are applied to hourly load, hourly wind generation, and
hourly solar generation throughout the 20-year planning period. These approximations
represent the regulating reserves rules necessary to balance variations in load, wind
and solar generation. For example, as customer load increases throughout the 20-year
planning period, as shown in Figure 7.1 and Table 7.1 of the 2019 Amended lRP, the
regulating reserve requirement necessary to integrate the variation due to the increase
in load would increase proportionally to additional load in any given future hour
throughout the 20-year planning period. The same is true for portfolios with increased
wind and/or solar capacity over the 2}-year planning period. The requested
information is provided in the Excel spreadsheet accompanying this response.
The response to this Request is sponsored by Jared Hansen, Resource Planning
Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF STOP B2H
COALITION TO IDAHO POWER COMPANY - 34
REQUEST NO. 18: ln LC 70 Pacifi Corp's (PAC) 2019 lRP, a 540/o partner in
the B2H, they are having trouble modeling the B2H topology in the lRP. ln that
docket it appears that the topography of B2H cannot be analyzed because an
additional transmission path, Hemingway to South-Central Oregon / Northern
California, is needed to link the "bubbles".
How does this topography issue and the need to analyze a Hemingway to
South-Central Oregon I Northern California transmission proiect impact the
company? lf PAC decides to build the Hemingway to South-Gentra! Oregon I
Northern California transmission project how will that impact transmission loads
and revenue on the B2H? Will the company be a party to the Hemingway to
South-Gentral Oregon I Northern California transmission project? (PAC response
to OPUC staff data request 91; see also OPUC staff opening comments p 49-50;
and PAC's final commenE p 37)
RESPONSE TO REQUEST NO. t8: Questions about PacifiCorp's IRP modeling
topography and modeling needs should be directed to PacifiCorp. However, because
the upgrades would be associated with PacifiCorp's interest in B2H and its load-service
needs, ldaho Power believes the impacts on ldaho Power's system would likely be
negligible. ldaho Power does not currently have plans to be a party to upgrades
between Longhorn and South-Central Oregon/Northern California.
The response to this Request is sponsored by Mitch Colburn, Engineering &
Construction Director, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REOUEST OF STOP B2H
COALITION TO IDAHO POWER COMPANY.3S
REQUEST NO. 19: The Amended and Restated Joint Permitting Agreement
was to have ended on March 15,2020. However, it was extended to July 15,202A.
Please provide the original and the 12O day extension to the
Amended and Restated Joint Permitting Agreemen(s).
RESPONSE TO REQUEST NO. ,l9: Please see the Protected lnformation
attachments accompanying this response.
1) Amended and Restated Join Permit Funding Agreement
2l First Amendment to Amended and Restated Joint Permitting Agreement
3) Negotiation period extension notice
The response to this Request is sponsored by Mitch Colburn, Engineering &
Construction Director, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF STOP B2H
COALITION TO IDAHO POWER COMPANY.36
REQUEST NO. 20: What is the amount allocated to the Amended and
Restated Joint permitting Agreement? How much has been spent to date? How
much is this underlover budget. Are ratepayers paying for any of these expenses
currently?
RESPONSE TO REQUEST NO. 20: The amount allocated to the Amended and
Restated Joint Permit Funding Agreement is approximately $136 million,
The total project expenditure to-date is roughly $108 million.
ldaho Power budgets annually. For the 2020 budget year, the project is
forecasted to spend roughly $10 million under the 2020 budget. The overall project
estimate is still in-line with the cost assumed in the 2019 lRP.
ldaho Power customers are not currently paying for any of the project expenses
to-date.
The response to this Request is sponsored by Mitch Colburn, Engineering &
Construction Director, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF STOP B2H
COALITION TO IDAHO POWER COMPANY - 37
REQUEST NO. 21: During the company's 2017 !RP it stated that it will not
receive special ratemaking treatment by FERC in the form of a 20O basis point
incentive Return on Equity (lncentive ROE) pursuant to FERC Order No. 6791
and FERC Order on Petition for Declaratory Order issued by FERC on October
21,2009.2
Please reaffirm that the company will not receive special ratemaking
treatment by FERC in the form of a 200 basis point incentive Return on Equity
(lncentive ROE).
RESPONSE TO REQUEST NO.21: The Company is reaffirming that it will not
receive special ratemaking treatment by FERC in the form of a 200-basis point incentive
return on equity
The response to this Request is sponsored by Mitch Colburn, Engineering &
Construction Director, ldaho Power Company
1 FERC Order No. 679, Promoting Transmission lnvestment through Pricing Reform, July 20, 2006. The
order is available at httos://wrvw.ferc.gov/whats-nedcomm+neeU072006/E-3.pdf
2 ORDER ON PETITION FOR DECLARATORY ORDER, October 21,2008 in Docket EL08-75-000. The
Order is available at STOP B2H Coalition Production Requests 1-30 in IPC-E-19-19.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCT]ON REQUEST OF STOP B2H
COALITION TO IDAHO POWER COMPANY - 38
REQUEST NO. 22: ln the audio for the OPUC S pecial Public Meeting LC4 ldaho
Power IRP Commission Workshop on 412'1120 the retirements of the Bridger units were
discussed. ln discussing exit strategies and alignment with PacifiCorp IRP (40:50) the
company said that they had a framework in terms of a process that they used with the
Valmy plant.
ln the company's final comments in the Oregon docket on Vlamy of the 2017 IRP
on pdf p 42the company states:
lnitialdiscussions yielded an executed Term Sheef signed on December 29,
2017, laying out initial provisions.l04 ldaho Power and NV Energy are now in the
process of determining the fixed and variable cosf responsibilities and finalizing a
Definitive Agreement providing for ldaho Power's conclusive exit from both Valmy
units. ldaho Power's discussions with law firms that have experience with
dissolving partnerships and power plant c/osures suggesf that the industry
average is approximately two-years to reach an agreement between partners.
As stated above, the industry average for dissolving partnerships is approximately 2
years. The first closure for unit 1 is slated tor 2022 in the lRP. The company is less
than 2 years out from this date. There should be a draft term sheet and Definitive
Agreement.
ls there a proxy built into the lRP to express these costs? lf yes please
explain the development of the proxy and cost to the IRP. What is the estimated
impact to rate payers. Please share all material the company has on the Term
sheet and the Definitive Agreement. lf a proxy is not built into the IRP to express
these costs why?
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF STOP B2H
COALITION TO IDAHO POWER COMPANY.39
RESPONSE TO REQUEST NO. 22: To date, the Company has only entered
into initial, high-level discussions with PacifiCorp on the Bridger unit retirement. The
Term Sheet and Definitive Agreement for Bridger units have not yet been formed.
As part of the portfolio costs, the Company has included the net book value of
the Bridger investments at the time of its retirement. An additiona! $130.57 million was
added to the Preferred Portfolio to reflect the acceleration of all four Bridger unit's end-
of-life. lt is likely that, similar to the Definitive Agreement with Valmy, there will also be
fixed costs that represent ongoing Bridger-related costs that exist under the current
Bridger agreements and shared costs that are ongoing Bridger-related costs that exist
regardless of a decision to exit a unit.
However, due to the negotiated nature of the agreement the terms reached as
ldaho Power negotiates with PacifiCorp for the Bridger units may be different from the
arrangements reached during the course of negotiations with NV Energy as related to
Valmy.
The response to this Request is sponsored by Tom Harvey, VP of Power Supply,
ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF STOP B2H
COALITION TO IDAHO POWER COMPANY - 40
REQUEST NO. 23: On the 4121120 call with the Commission there was a
discussion about WECC vs the company's optimized portfolios. The company
discussed how they removed some WECC resources from of the company's
portfolios because they were not in the best interest of the company's rate payer.
This pushed most renewable actualizations out to 2030. However, it was unclear
if B2H was a WECC resource or a company resource.
Please clarify if the B2H is a WECC or company resource. What nesources
urere removed from the WECC optimized portfolios that did not benefit the
company's ratepayers. Please list the resources removed, the proposed in
service date, MW nameplate capacity, and capacity value.
RESPONSE TO REQUEST NO. 23: B2H is a Company resource.
The basis of this request mischaracterizes the Company's discussion with regard
to WECC resources and ldaho Power resources. The manually optimized portfolios
modified ldaho Power's resource portfolio to determine if a more optimal solution could
be reached for ldaho Power's customers. This was performed to address the concern
that the Long-Term Capacity Expansion (.'LTCE") mode! was making decisions with
regard to ldaho Power's resource portfolio that benefited the entire WECC region (of
which ldaho Power is part) while not necessarily benefiting ldaho Power and its
customers. Therefore, manual adjustments were made to the timing of certain
resources within ldaho Power's portfolio to determine if a more optimal solution could be
reached. This process did not involve manual adjustments to resources located in the
WECC outside of ldaho Power's resource portfolio.
The manual portfolios-including in-service dates and MW capacity values- can
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF STOP B2H
COALITION TO IDAHO POWER COMPANY - 41
be viewed in the Amended IRP Appendix C - Technical Report, pages 46-A7.
The response to this Request is sponsored by Jared Hansen, Resource Planning
Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF STOP B2H
COALITION TO IDAHO POI/I'ER COMPANY.42
REQUEST NO. 24: This is a restatement of IPUC Staff Request No 25 with
different language in bold.
Please provide, in EXCEL format with formulae and links intact, the Company's
estimate of the costs of B2H to ldaho
ratepayers broken down by ldaho and Oregon customer rate schedules,
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
d. Pre-Construction Cost
e. Construction Cost
r. Unforeseen expenses
s. Expected Cost Ovenun
Warranty Cost
RESPONSE TO REQUEST NO. 24: ldaho Power does not budget projects on a
jurisdictional basis. The jurisdictional allocation is determined at the time the Company
requests recovery of the costs. ln general, transmission plant is allocated to each
jurisdiction based on system peak demands. Based on ldaho Power's 2019 Oregon
Results of Operation, the transmission allocation factor was 4.14 percent.
The protected information Excel spreadsheet accompanying this response
contains the B2H cost estimate as provided in response to IPUC Staff Request No. 25.
The response to this Request is sponsored by Mitch Colburn, Engineering &
Construction Director, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF STOP BzH
COALITION TO IDAHO POWER COMPANY.43
REQUEST NO. 25: The Company states that it included costs for local
interconnection upgrades totaling $21 million in its B2H cost analysis.
ln the B2H lntegration Breakdown it shows overheads of 10o/o.
ls this l0% overhead included in the 20% contingency or is it in addition
to? !f in addition to the 20% contingency why?
RESPONSE TO REQUEST NO. 25: The overhead costs are in addition to the
B2H project 20 percent contingency. The 20 percent contingency is not applied to
local interconnection upgrades.
General overheads are costs that are incurred in direct support of the Company's
construction process but would be very difficult to directly associate to a particular
construction job. These costs are accumulated and allocated back to construction jobs
based on a cost allocation methodology. lt is ldaho Power Company's policy, per 18
CFR Part 101 Electric Plant lnstructions (4) (2019), to apply overheads to construction
work orders.
When applicable, the 20 percent contingency is used only for estimating prolect
costs. The overhead cost is only applied to actual construction costs as they are
incurred.
The response to this Request is sponsored by Mitch Colburn, Engineering &
Construction Director, ldaho Power Company,
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF STOP B2H
COALITION TO IDAHO POWER COMPANY - 44
REQUEST NO. 26: ln the OPUCs 2013 Plan acknowledqement in Order No. 14
253 at pdf p 6 it states, "ldaho Power does not request acknowledgment of Gateway
West as a supply side resource. Instead, the company asserts that Gateway West is
reasonable to address transmission system constraints and provide for future least cost
resource development.
What is the future least cost resource development the company
envisioned in 2013?
RESPONSE TO REQUEST NO. 26: The Gateway West project was not
developed to provide access to a specific least cost resource, but rather gives ldaho
Power access to resources east of ldaho Power's service territory. This access will
provide low cost and low risk resource options that are not available without the
Gateway West project.
The 2013 IRP identified the Boardman to Hemingway transmission line with
associated market purchases as the major resource addition identified in the preferred
resource portfolio.3
The response to this Request is sponsored by Jared Hansen, Resource Planning
Leader, ldaho Power Company.
3 See page I of the 2013 IRP - httos://edocs.puc.state.or.us/efdocs/HAtulc58haa15512.pdt
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF STOP BzH
COALITION TO IDAHO POWER COMPANY.45
REOUEST NO. 27: !n response to IPUC staff request 49a the company's
answer is very confusing. The question and answer are:
Question: Page 28 ol the Amended 2019 lntegrated 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.9. approva! of Jackpot
Solar). Please answer the following questions:
a. Please list any other changes that have occurred since the original lRP
was filed and that should be included in deficit calculations for the Amended 2019
lntegration Resource Plan Appendix C.
Answer:
The capacity deficit did not change in the Amended 2019 IRP because
no resource changes occurred that would require adjusting the calculation.
Capacity deficit is determined using ldaho Power's current load and resource
balance, as well as committed generation additions and retirements. ln
contrast, potential resource additions or retirements do not factor into the
calculation. As such, Jackpot Solar was not considered because it was not a
definitive addition at the time of analysis. Additionally, the retirement of Bridger
was not a factor because the plant's retirement dates are uncertain.
How would adding Jackpots 100 MW of capacity reduce the import flow
from the PNW on B2H? How will thig in turn reduce overall revenue and the
annual revenue credit loss to customers/ratepayerc per the B2H Cost Treatment
in the IRP section?
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF STOP B2H
COALITION TO IDAHO POWER COMPANY.46
RESPONSE TO REQUEST NO. 27: Adding a new resource, such as Jackpot
Solar, may reduce the need to import power, time-shift the need to import power,
reduce the dispatch of other internal resouroes, and/or time-shift the dispatch of other
internal resouroes. Each of these actions are considered within the AURORA mode!.
B2H and Jackpot Solar are complimentary as both were included in the preferred
portfolio.
During times when transmission capacity is not being utilized to serve ldaho
Power's native load customers, unutilized transmission capacity is made available via
ldaho Powe/s Open Access Same-Time lnformation System (OASIS) and the capacity
is sold to third-parties. Revenues associated with these transmission capacity sales
flows back to ldaho Power's customers and offsets transmission costs.
The response to this Request is sponsored by Jared Ellsworth, Transmission,
Distribution & Resource Planning Director, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF STOP B2H
COALITION TO IDAHO POWER COMPANY - 47
REQUEST NO. 28: ln CUB's opening comments in the OPUC docket they state,
..from the Company's Distribution System Planning presentation (OPUC Docket UM
2005), that ldaho Power currently has a 92% AMI deployment in Oregon and targeting
for a 99% deployment by the end of 2020.
What are IPC's plan to utilize the AMI? Please tell us what features are
activated and what new features will be activated to assist ratepayers. When will
these time based rate designs be deployed and how many MW of demand
response do you anticipate by category:
1) critical peak pricing (CPP),
2l variable peak pricing (VPP),
3) time-of-use (TOU) pricing,
4l and critical peak rebates (CPR)? Pdf p47
RESPONSE TO REQUEST NO. 28: ldaho Power is currently utilizing its
advanced metering infrastructure (AMl) technology in the following ways:
o Billing Data: ldaho Power utilizes the AMI system in lieu of truck rolls to obtain
billing meter reads for all customers where AMI is installed. ln addition to the
monthly meter reads, the AMI system also enables ldaho Power to obtain meter
reads necessary because of customer movement. That is, ldaho Power utilizes
the AMI system to get a meter read to end service for one customer and begin
service for the next customer when a customer moves out and a new customer
moves in, eliminating the cost of a truck roll to obtain the final meter read.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF STOP B2H
COAL]TION TO IDAHO POWER COMPANY - 48
. Customer access to data: The AMI technology enables customers to view their
usage information to better evaluate, manage, and understand how and when
they use energy.
e Automated GonnecUDisconnect Capability: The Company utilizes AMI to
remotely control service reconnecUdisconnect switches across its ldaho service
area, and currently utilizes the reconnect functionality in Oregon.
o Outage Scoping and Restoration Confirmation Functionality: The Company
has integrated the AMI and Outage Management System (OMS) systems to
allow OMS operators to manually query AMI meters in the area of a sustained
Smart Grid Management (SGM) outage event. This allows OMS operators to
quickly and accurately locate outages on the distribution system and initiate
outage restoration efforts without depending on customer calls.
. Time Based Rate Designs: The deployment of AMI has enabled the company
to achieve more precise usage measurement which will ultimately facilitate more
sophisticated and cost-based rate designs. ldaho Power implemented a Time of
Day ("TOD") Pilot Plan for Oregon residential customers in June 2019 and offers
an optional TOD plan for its ldaho residential customers. ldaho Power also has
experience with running a Critical Peak Pricing pilot in 2005-2006; however, in its
most recently acknowledged lRP, no deficiency period is identified until 2026.
ldaho Power currently relies on its existing Demand Response programs, which
have a total capacity of approximately 390 MW, to manage peak if necessary.
The response to this Request is sponsored by Connie Aschenbrenner, Rate
Design Senior Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF STOP B2H
COALITION TO IDAHO POWER COMPANY .49
REQUEST NO. 29: What technique or techniques does ldaho Power
incorporate into their modeling, in Appendix A: Sales and Load Forecast, to
account for forecast errorc in past IRPS?
RESPONSE TO REQUEST NO. 29: The Company's service area remains at the top of
the list of fastest growing areas in the US. With most-recent residential customers
growth at 2.8 percent and commercial customers at 1.8 percent, the Company feels it is
prudent to continually monitor the drivers of growth to properly reflect the impact on the
system load forecast. This includes monthly comparisons of the sales forecast to actual
and weather-adjusted sales.
Outside of the review noted above, the specifications for the Company's sales
regression models, including the Company's specialcontract customers, are evaluated
at least once a year and updated to provide a robust forecast within this dynamic
growth environment. As such, the Company evaluates the structural assumptions and
the specifications of the models to ensure they reflect the constantly changing economic
environment.
During this process, the Company evaluates and tests alternatives, particularly
as guided by significant variances, and the assumptions that serve as inputs to the
regression models. Aside from this analysis, the Company continually evaluates the
accuracy of third-party data that serves as input to the models. The framework for
analysis is to evaluate the model assumptions regarding the independent variables as
they compare to actual behavior. Significant deviations from predictions result in root
cause analysis to ensure that the models are properly specified,
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF STOP B2H
COALITION TO IDAHO POWER COMPANY. sO
The response to this Request is sponsored by Jordan Prassinos, Load Research
and Forecasting Manager, ldaho Porer Company.
IDAHO POWER COMPANY'S RESPONSE TOTHE FIRST PRODUCTION REQUEST OF STOP B2H
COAL]TION TO IDAHO POWER COMPANY.5l
REQUEST NO. 30: Please refer to STOP Request No. 20
When the B2H is not built what will be the mte payer responsibility for all
permitting expenses incurred?
RESPONSE TO REQUEST NO. 30: This request is based on the definitive
statement that the B2H line will not be built. Given the results of the Company's analysis
in this docket, as well as the Commission's recognition in ldaho Porer's last five IRP's
that continued development of the project is reasonable, ldaho Power disagrees with
the premise of this question. Notwithstanding, all costs to-date related to the B2H
project were prudently incurred and will be subject to review by the Commission in a
future ratemaking proceeding.
The response to this Request is sponsored by Matt Larkin, Revenue
Requirement Senior Manager, ldaho Power Company.
DATED at Boise, ldaho, this 26s day of June 2020.
X* !-(^1.t..*,
LISA D. NORDSTROM
Attorney for ldaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF STOP B2H
COALITION TO IDAHO POWER COMPANY. 52
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 26th day of June 2020 I served a true and
conect copy of IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF STOP B2H COATION TO IDAHO POWER COMPANY
upon the following named parties by the method indicated below, and addressed to the
following:
Commission Stafr
Edward Jewell
Deputy Attorney General
ldaho Public Utilities Commission
1 1331 W. Chinden Boulevard
Building 8, Suite 201-A
Boise, ldaho 83714
ldaHydro
C. Tom Arkoosh
ARKOOSH LAW OFFICES
802 West Bannock Street, Suite LP 103
P.O. Box 2900
Boise, ldaho 83701
ldaho Conservation League
Benjamin J. Otto
ldaho Conservation League
710 North 6th Street
Boise, ldaho 83702
STOP B2H Coalition
Jack Van Valkenburgh
Van Valkenburg Law, PLLC
P.O. Box 531
Boise, ldaho 83701
Jim Kreider
60366 Marvin Road
La Grande, Oregon 97850
ldaho Sierra Club
Julian Aris, Associate Attorney
2101 Webster Street, Suite 1300
Oakland, California {A612
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IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF STOP B2H
COALITION TO IDAHO POWER COMPANY. s3
Gloria D. Smith, Managing Attomey
2101 Webster Street, Suite 1300
Oakland, California 94612
Ana Boyd, Research Analyst
2101 Webster Street, Suite 1300
Oakland, California 94612
lndustrial Customee of ldaho Power
Peter J. Richardson
RICHARDSON ADAMS, PLLC
515 North 27th Street (83702)
P.O. Box 7218
Boise, ldaho 83707
Dr. Don Reading
6070 Hill Road
Boise, ldaho 83703
Micron Technology, lnc.
Austin Rueschhoff
Thorvald A. Nelson
Holland & Hart, LLP
555 Seventeenth Street, Suite 3200
Denver, Colorado 80202
Jim Swier
Micron Technology, lnc.
8000 South FederalWay
Boise, ldaho 83707
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z1:_&-.:iddl^-
Sandra D. Holmes
Legal Ad min istrative Assistant
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF STOP B2H
COALITION TO IDAHO POWER COMPANY - 54