20201016IPC to B2H Coalition Updated Responses.pdf

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LISA D. NORDSTROXI
Lead Gouneel
[e-mail]
October 16,2020
VIA ELECTRONIC FILING
Jan Noriyuki, Secretiary
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
Dear Ms. Noriyuki
Attached for electronic filing, pursuant to Order No. 34602, is ldaho Power
Company's ("ldaho Powe/') Updated Response to the First Production Request of STOP
B2HCoalltion. ReponsestoProduc'tionRequestNos.2,8,9, 10, 12,13,17and23update
ldaho Power's responses filed on June 26, 2020 in light of the Company's Second
Amended 2019lntegrated Resource Plan filed with the Gommission on October 2,2020.
lf you have any questions about the attached document, please do not hesitate to
contact me.
Very truly yours,
X*!.7/^1.t,-*,
Lisa D. Nordstrom
LDN:slb
Attachment(s)
LISA D. NORDSTROM (lSB No. 5733)
ldaho Power Company
1221 West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: (208) 388€936
lnordstrom@idahooower. com
Attorney for Idaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POVVER
COMPANY'S 201 9 INTEGRATED
RESOURCE PLAN
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CASE NO. IPC-E-19-19
IDAHO POWER COMPANY'S
UPDATED RESPONSE TO THE FIRST
PRODUCTION REQUEST OF STOP
B2H COALITION TO IDAHO PO\TVER
COMPANY
COMES NOW, ldaho Power Company ("ldaho Powe/' or 'Company'), and
updates its response to the First Production Request of STOP B2H Coalition to ldaho
Power Company dated June 5, 2020, herewith subrnits the following information:
IDAHO POVVER COMPANY'S UPDATED RESPONSE TO THE FIRST PRODUCTION REQUEST OF
STOP B2H COALITION TO IDAHO POWER COMPANY - 1
REQUEST NO. 2: At the December IRPAC meeting, Idaho 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 turther showed that
ldaho's peak hour in AURORA in 2019 reflected peak loads in Area 612 UOG if
approximately 3,200 MW and peak hour loads in Area 615 lDSo of approximately 550
MW. (The December 2418 presentation is available at this !ink:
https://docsidahopower.comiodfu/AboutUs/PlanninqForFuture/irp/2O18/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
resources to Area 612 and assigned 780 MW of existing generating resouroes 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/Resouroe 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 MW of existing generating resources 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 resources were assigned to Area 615 so
]DAHO POWER COMPANY'S UPDATED RESPONSE TO THE FIRST PRODUCTION REQUEST OF
STOP B2H COALITION TO IDAHO POVI/ER COMPANY - 2
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).
[Area 612 IPC [Area 615lPC
Peak Hour Load 13.197 MW lss+ nttw
Area Resources
13,480
MW
r8o
MW
Area Resources without
13,161
MW
r8o
MW
Surplus Capacity at Peak
rfter retirement of Valmy and
Boardman
136 MW
ln"r"r"Margin = 0
Dzo uw
In"r"*"Margin = 41Yo
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
Powe/s response to Staff DR 52 (tab R16 RMT) shows that under ldaho Powe/s
preferred Portfolio P16, a 429 MW combined cvcle oas plant is built in Southern ldaho
Area 615 in 2023.
Please explain why ldaho Power's prefemed Portfolio includes the additon
of a new 429 ilw combined cycle gas plant in Southern ldaho, in 2023. On what
utility's behalf is this resource added by AURORA. Please also explain the effiect
that this thermal resource addition in ldaho in 2023 has on ldaho Power's
determination that its period of sufficiency extends through 2025.
IDAHO POWER COMPANY'S UPDATED RESPONSE TO THE FIRST PRODUCTION REQUEST OF
STOP B2H COALITION TO IDAHO PO\TI'ER COMPANY.3
WECC ldahoSourth 615 New Resource
3723 from
2584 CCCT
sas/oilAdv
NA 429 NGIIDSo 111t2023 1Uyn039
UPDATED RESPONSE TO REQUEST NO.2: This request is no longer
applicable based on the Company's Second Amended lRP.
The response to this Request is sponsored by Jared Hansen, Resource Planning
Leader, ldaho Power Gompany.
IDAHO POWER COMPANY'S UPDATED RESPONSE TO THE FIRST PRODUCTION REQUEST OF
STOP B2H COALITION TO IDAHO POWER COMPANY -4
REQUEST t{O. 8: Reference Compliance with EV Guideline 1 (Amended 2019
lntegrated Resource Plan - Appendix C page 85) reprinted below.
Guideline {: Forpcast the Demand for Flexlble Capacity
Forecast the Demand for Flexible Capacity: The electric utilities shall forecast the
balancing reserves needed at different time intervals (e.9. ramping needed within
5 minutes) to rcspond to variation in load and intermittent renewable generation
over the 20-year planning period.
Please provide ldaho Powsr's forrcast of balancing rcserves needed at
different time intervals to respond to variation in load and intermitbnt rcnewable
generation over the 20-year planning period for Portfiolios P4, P-16 and P164.
UPDATED RESPONSE TO REQUEST NO. 8: This request is no longer
applicable based on the Company's Second Amended lRP.
The response to this Request is sponsored by Jared Hansen, Resource Planning
Leader, ldaho Porer Company.
IDAHO POWER COMPANY'S UPDATED RESPONSE TO THE FIRST PRODUCTION REQUEST OF
STOP B2H COALITION TO IDAHO POVI'ER COMPANY. s
REQUEST NO. 9: Reference Compliance with EV Guideline 2 (Amended 2019
lntegrated Resource Plan - Appendix G page 85) reprinted below.
Guideline 2: Forecast the Supply for Flexible Capacity
Forecast the Supply of Flexible Capacity: The electric utilities shalt forecast
balancing reserves available at different time intervals (e.9. ramping available within 5
minutes) from existing generating resources over the 2O-year planning period.
Please provide ldaho Powe/s brecast of balanclng rcserues available for
existing generafing tuoulcet oyer the 20-year planning period for Portfiolios P4,
P16 and P164.
UPDATED RESPONSE TO REQUEST NO. 9: This request is no longer
applicable based on the Company's Second Amended lRP.
The response to this Request is sponsored by Jared Hansen, Resoure Planning
Leader, ldaho Power Company.
IDAHO POWER COMPANY'S UPDATED RESPONSE TO THE FIRST PRODUCTION REQUEST OF
STOP B2H COALITION TO IDAHO POV1JER COMPANY.6
REQUEST NO. 10: ln OPUC staff data request #33 (STOP REQUEST NO. 10)
staff asks about resouroe adequacy conoerns in the Pacific northwest and the type of
resouroes 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. IPG-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 sale and purchase of up to 220 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 all market'rcsearch done on the cost of market purchaS:es
from the mid+ for the 2O year planning period. lf no market rcsearch was done
please show all mid - c cost data 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 agrcement with Jackpot Holdings, LLC for
fhe sate and purchase of up to 220 megawaffs of renewable solar generation,
IPUC sfaffsfafe on p 5.
To supplement the 2019 IRP analysrs, Sfaff compared contract prices to
expected market prices at Mid-C. ld. at 10. Sfaff selected Mid-C for
comparison because ldaho Power fransacfs mosf of its market purchases
through the Mid-C hub. ld. at 11. Staff found a $145,000 savings in fhis
comparison during the first year, $492,0A0 in savrngs in the second year,
and incrcased savings thereafter because the forecasfed Mid-C prices
increase at a faster rate than the contmct rate. ld. at 10-12.
UPDATED RESPONSE TO REOUEST NO. 10: Section 9 "Regiona! Resource
Adequacy' on page 127 of ldaho Powe/s Second Amended IRP discussed the
Company's research into regional resource adequacy to better understand the liquidity
IDAHO POWER COMPANY'S UPDATED RESPONSE TO THE FIRST PRODUCTION REQUEST OF
STOP B2H COALITION TO IDAHO POI/\'ER COMPANY - 7
of the regional wholesale electric markets. In addition, the Excel spreadsheet
accompanying this response provides the Aurora output of annual market purchase and
sales prices fur each portfolio overthe 2hyear planning period.
The response to this Request is sponsored by Jared Hansen, Resource Planning
Laader, ldaho Power Company.
IDAHO POVVER COMPANYS UPDATED RESPONSE TO THE FIRST PRODUCTION REQUEST OF
STOP B2H COALITION TO IDAHO POV'/ER COMPANY - 8
REQUEST NO. t2: 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. How do the market purchasec from the mid-c durlng this period
compare to the PPA for Jackpot Solar for the rame time period?
UPDATED RESPONSE TO REQUEST NO. 12: For the preferred portfolio, the
average purchase price for the year 2025 is $39.84/MWh compared to Jackpot Solads
purchase agreement in 2025 of $22.751M\ Jh.
The response to this Request is sponsored by Jared Hansen, Resource Planning
Leader, ldaho Power Company.
IDAHO POWER COMPANY'S UPDATED RESPONSE TO THE FIRST PRODUCTION REQUEST OF
STOP BzH COALITION TO IDAHO POVI/ER COMPANY.9
REQUEST NO. t3: Baged on the anticipabd coal mtlrcments ln the mid +,
Table 9.{0 Coal rutirement forecast p 121, how wlll this rcduce the congestion on
Pat {4 W-E?
How many [iW travel along Path 14 W-E from these unlts on a
monthlyldallylhourly schedule for tfie past l0 yearc?
UPDATED RESPONSE TO REQUEST NO. {3: This request is no longer
applicable based on the Company's Second Amended lRP.
The response to this Request is sponsored by Jared Hansen, Resouroe Planning
Leader, ldaho Power Company.
IDAHO PO\TI'ER COMPANY'S UPDATED RESPONSE TO THE FIRST PRODUCTION REQUEST OF
STOP B2H COALITION TO IDAHO POI/',ER COMPANY - 10
BEQUEST NO. t7: The 2018 Variable Energy 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-yoar historical test year to
monthly rules imposed on a twenty-year forccast period with changing resourcoa
associated with tables 8.1 and 8.2 change oyer the 20 year period? Please provide
this data in an excel format.
UPDATED RESPONSE TO REQUEST NO. t7: 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 2&.year planning period. These
approximations represent the regulating reserves rules necessary to balance variations
in load, wind and solar generation. For example, as customer Ioad increases throughout
the 2O-year planning period, as shown in Figure 7.1 and Table 7.1 of the 2019 Second
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 20-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 UPDATED RESPONSE TO THE FIRST PROOUCTION REOUEST OF
STOP B2H COALITION TO IDAHO POWER COMPANY - 11
REQUEST NO. 23: On the 4121120 call with the Gommission 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 resouroe.
Please clarify if the B2H is a WEGC or company resource. What nosources
were removed from the WECC optimized portfolios that did not benefit the
company's rabpayers. Please list the resources removed, the proposed in
service date, MW nameplate capacity, and capacity value.
UPDATED RESPONSE TO REQUEST NO.23: This request is no longer
applicable based on the Company's Second Amended lRP.
The response to this Request is sponsored by Jared Hansen, Resource Planning
Leader, ldaho Power Company.
DATED at Boise, ldaho, this 16th day of October 2020.
X*!.fl^*+r-*,
LISA D. NORDSTROM
Attorney for ldaho Power Company
IDAHO POVVER COMPANY'S UPDATED RESPONSE TO THE FIRST PRODUCTION REQUEST OF
STOP B2H COALITION TO IDAHO POTA/ER COMPANY. 12
CERTIFIGATE OF SERVICE
I HEREBY CERTIFY that on this 16th day of October 2020,1 served a true and
correct copy of IDAHO POWER COMPANY'S UPDATED RESPONSES TO THE
FIRST PRODUCTION REQUEST OF STOP B2H COALITION upon the following
named parties by the method indicated below, and addressed to the following:
Commission Staff
Edward Jewell
Deputy Attomey General
ldaho Public Utilities Commission
11331 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 Conseruation 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 94612
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stacie.foor@arkoosh. com
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IDAHO POWER COMPANY'S UPDATED RESPONSE TO THE FIRST PRODUCTION REQUEST OF
STOP B2H COALITION TO IDAHO POWER COMPANY. 13
Gloria D. Smith, Managing Aftorney
2101 Webster Street, Suite 1300
Oakland, California 94612
Ana Boyd, Research Analyst
2101 Webster Street, Suite 1300
Oakland, California 94612
lndustria! Customett 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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aclee@ holla nd hart.com
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Stephanie L. Buckner
Executive Assistant
IDAHO POIA'ER COMPANY'S UPDATED RESPONSE TO THE FIRST PRODUCT]ON REQUEST OF
STOP B2H COALITION TO IDAHO POWER COMPANY.14
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
GASE NO. IPC-E-19-19
IDAHO POWER COMPANY
ATTACHMENT TO REQUEST NO. 10
(EXCEL SPREA DSHEET ATTACHED TO EMAILI
TO
IDAHO POWER COMPANY'S UPDATED RESPONSE
TO THE FIRST PRODUCTION REOUEST OF STOP B2H
COALITION
BEFORE THE
IDAHO PUBLIC UTILITIES GOMMISSION
CASE NO. IPC-E-{9-19
IDAHO POWER COMPANY
ATTAGHMENT TO REQUEST NO. 17
(EXCEL SPREADSHEET ATTACHED TO EMAILI
TO
IDAHO POWER GOMPANY'S UPDATED RESPONSE
TO THE FIRST PRODUCTION REQUEST OF STOP B2H
COALITION