20201016IPC to Staff Updated Responses 53 and 55.pdf

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An IDACORP Cornpany
October 16,2020
VIA ELECTRONIC FILING
Jan Noriyuki, Secretary
ldaho Public Utilities Commission
11331 W. Chinden Boulevard
Building 8, Suite 201-A
Boise, ldaho 83714
Re: Case No. IPC-E-19-19
201I lntegrated Resource Plan
Dear Ms. Noriyuki:
Attached for electrcnic filing, pursuant to Order No. 34602, is ldaho power
Company's ('ldahoPowe/) Updated Response to the Second Production Request of the
Commission Staff. Reponsesto Production Request Nos. 53 and 5E update Haho pouer's
responses filed on May 29, 2020 in light of the Company's Second Amended 201glntegrated Resource Plan filed with the commission on october2,2o2o.
lf you have any questions about the attached document, please do not hesitate to
contact me.
Very truly yours,
LISA D. NORDSTROTI
toad Counrel
lnor&trom0ldelroower.com
LDN:slb
Attachment(s)
X*!.7/,a.+,.*,
Lisa D. Nordstrom
LISA D. NORDSTROM (lSB No. 5733)
ldaho Power Gompany
1221 West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
lnordstrom@idahooowe r. com
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POTA'ER
COMPANY'S 201 9 INTEGRATED
RESOURCE PLAN
CASE NO. IPC-E-19-19
IDAHO POWER COMPANY'S
UPDATED RESPONSE TO THE
SECOND PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO IDAHO
POI/VER COMPANY
COMES NOW, ldaho Power Company ('ldaho Powe/' or 'Company'), and
updates its response to the Second Produc{ion Request of the Gommission Staff to
ldaho Power Company dated May 8, 2020, herewith submits the following information:
IDAHO POWER COMPANY'S UPDATED RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 1
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REQUEST NO. 53: Response to Staffs 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 lRP.
b. The Company states that the match between the VER study and the
[monthly] approximation results are 'less cleaf for RegDn. Please explain what is
meant by .!ess clea/'and what was done to rectiff 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.
UPDATED RESPONSE TO REQUEST NO. 53:
a. To determine the RegUp and RegDn percentages shown in Tables 8.1
and 8.2 in the Second Amended 2019 lRP, the Company began with the RegUp and
RegDn percentages for load, wind and solar as determined in the July 2018 Variable
Energy Resource (VER) lntegration Analysis ('VER Study"). Section 3.2 - Study
IDAHO POWER COMPANY'S UPDATED RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY.2
Design and specifically Tables 5 and 8 of the VER Study provide additional detail on the
study design and the RegUp and RegDn values.l
To apply these reserves to the full 2O-year IRP modelling prooess, the Company
used an Excel-based optimization model called "What's Best!". The Excel file
accompanying this response contains the analysis. There is a worksheet for each
season:
SON = September, October, November (Fall)
DJF = December, January, February (Winter)
MAM = March, April, May (Spring)
JJA = June, July, August (Summer)
Wthin each seasonal worksheet load, wind and solar are binned according to
specific characteristics: load and solar are binned according to time of day and wind
according to wind level as a percent of nameplate capacity. The bins and resulting
RegUp and RegDn percentages were determined in the VER Study and are provided in
the top left section of each worksheet.
ldaho Power proportionally adjusted the respective load, wind, and solar
regulating reserve levels until compliance with the NERC BAL-001-2 standard was
achieved. This adjustment is shown in cells O2-PS in each of the seasonal worksheets
(SON, DJF, MAM, JJA). This allocation factor represents the estimated reserve Ievels
given the diversity benefit that occurs when load, wind, and solar reserves are netted
together.
For each season, the Company optimized the regulating reserve values (RegUp
and RegDn) using the rules from the VER Study and the approximated reserve levels.
t httos://edocs. ouc.state.or. ude6ocs/HAD/um 1 793ha<l 1 691 0. pdf
IDAHO PO\TVER COMPANY'S UPDATED RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 3
The regulating requirements for load, wind, and solar (cells V12-V14 and Y12-Y14 in
each of the seasonal sheets) were optimized by minimizing the difference squarcd
between the RegUp and RegDn regulating reserve calculations. A visualization of each
seasonal best fit is shown on the sheetrs titled, "RegUp fit graphs' and "RegDn fit
graphs."
b. The Company states that the match between the VER Study and the new
monthly approximation results are "!ess clea/'for RegDn. This can be seen on the
RegUp and RegDn fit graphs in the Excelfile accompanying this response. The RegDn
graph shows a lit that is not as close as the RegUp fit graphs. As noted in the IRP and
in the Company's response to Staffs Request No. 40, the risk of RegDn violations was
considered less of a oonoern because oversupply can be mitigated by ramping down
resour@s. RegUp violations, on the other hand, are a larger risk because the
generation undersupply would need to be filled with another resource.
c. Please refer to the Company's response to Staffs Request No. 40 (b) for
the requested information.
d. \Mile imperfect, the quarterly approximation rules allowed the Company
to incorporate results from the VER Study into the Aurora tool, providing a more realistic
estimate of reserve levels needed for the combined load net wind and solar as opposed
to using a reserve level based on the summation of the three.
The Company is currently updating the integration analysis in anticipation of the
2021 IRP and will be investigating how changes to both data granularity (seasonal,
monthly, hourly) and data types (time-based, output-based) of binning impact the results
of the analysis.
IDAHO POWER COMPANY'S UPOATED RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 4
The response to this Request is sponsorcd by Jared Hansen, Resource Planning
Leader, ldaho Porver Company.
IDAI.IO POWER COMPANY'S UPDATED RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY .5
REQUEST NO. 55: Response to Staffs Request No. 48 states in Section b. that
'The timing and selection of additional resources and the timing of coal unit exitrs in
Portfolio 14(7) are identical to Portfolio 16(a). Please answer the following questions.
a. Please explain what Bridger exit scenario "T" represents.
b. Please explain the difference between Portfolio 14(4), Portfolio 14(7), and
Portfolio 16(4).
UPDATED RESPONSE TO REQUEST NO. 55: 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 Ptanning
Leader, ldaho Power Company.
DATED at Boise, ldaho, this 16s day of October 2020.
X* !.7(,a.+..*,
LISA D. NORDSTROM
Attomey for ldaho Power Gompany
IDAHO POVVER COMPANY'S UPDATED RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POVVER COMPANY - 6
CERTIFICATE 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
SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF upon the following
named parties by the method indicated below, and addressed to the following:
Commission Staff
Edward Jewell
Deputy Aftorney General
ldaho Public Utilities Commission
11331 W Chinden Boulevard
Building 8, Suite 201-A
Boise, ldaho 83714
IdaHydro
C. Tom Arkoosh
ARKOOSH I.AW OFFICES
802 West Bannock Street, Suite LP 103
P.O. Box 2900
Boise, ldaho 83701
ldaho Consewation League
Benjamin J. Otto
ldaho Conservation League
710 North 6th Street
Boise, ldaho 83702
STOP B2H Goalition
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 Aftorney
2101 Webster Street, Suite 1300
Oakland, California 94612
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stacie.foor@arkoosh. com
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IDAHO POVVER COMPANY'S UPDATED RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISS]ON STAFF TO IDAHO POV\'ER COMPANY - 7
Gloria D. Smith, Managing Attorney
2101 Webster Street, Suite 1300
Oakland, California 94612
Ana Boyd, Research Analyst
2101 Webster Street, Suite 1300
Oakland, California 94612
Industria! Customerc 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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tnelson @hollandha rt. com
aclee@holla nd hart. com
oloa rganoamari@holland hart. com
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Stephanie L. Buckner
Executive Assistant
IDAHO POWER COMPANY'S UPDATED RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 8
BEFORE THE
IDAHO PUBLIG UTILITIES COMMISSION
cAsE NO. IPC-E-19-19
IDAHO POWER COMPANY
ATTACHMENT TO REQUEST NO. 53
IEXCEL SPREADSHEET ATTACHED TO EMAILI
TO
IDAHO POWER COMPANY'S UPDATED RESPONSE
TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF