20201016IPC to Staff Updated Responses.pdf

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An IOACORP Comtrany
LISA D. NORDSTRO]II
Lead Gounael
lnod:trom&i&hooow.com
October 16,2024
VIA ELECTRONIC FILING
Jan Noriyuki, Secretary
ldaho Public Utilities Commission
11331 W. Chinden Boulevard
Building 8, Suite 20'l-A
Boise, ldaho 83714
Re: Case No. IPC-E-19-19
2019 lntegrated Resource Plan
Dear Ms. Noriyuki:
Attached for electrcnic filing, pursuant to Order No. 34602, is ldaho Power
Company's ('ldaho Powef) Updated Response to the First Prcduction Request of fie
Commission Staff. Reponses to Production Request Nos. 4,5,10-17, and 43.48 update
ldaho Power's responses filed on March 4, 2020 in light of the Company's Second
Amended 2019 lntegrated Resource Plan filed with the Commission on October2,2020.
lf you have any questions about the attached document, please do not hesitate to
contact me.
Very truly yours,
&. !.7(^*+".*,
Lisa D. Nordstrom
LDN:slb
Attachment(s)
LISA D. NORDSTROM (!SB No. 5733)
ldaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
I nord strom @ ida hopower. com
Aftorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POT'VER
COMPANY'S 201 9 INTEGRATED
RESOURCE PLAN
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GASE NO. IPC-E-I9-19
IDAHO POVVER COMPANY'S
UPDATED RESPONSE TO THE
FIRST PRODUCTION REQUEST
OF THE COMMISSION STAFF
COMES NOW, ldaho Power Company ("ldaho Powe/' or 'Company") and
updates its response to the First Production Request of the Commission Staff to ldaho
Power Company dated March 4,2020, as follows:
IDAHO POWER COMPANY'S UPDATED RESPONSE TO THE FTRST
PRODUCTION REQUEST OF THE COMMISSION STAFF . 1
REQUEST NO. 4: Please explain hour flexibility resources werc used in the
development of each of the Company's 24 \ ,ECC optimized portfolios. For each of
these portfolios, please identiff which resouroes were included as flexibility rcsour@s.
UPDATED RESPONSE TO REQUEST NO.4: This request is no longer
applicable based on the Company's Second Amended lRP.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.
IDAHO POWER GOMPANY'S UPDATED RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE GOMMISSION STAFF .2
REQUEST NO. 5: Please explain the formal process used by the Company to
veriff each of the model runs used to develop the Company's 24 WECC optimized
portfolios. Please include any checklists or forma! procedures used to ensure that
mode! configuration was consistent with the assumptions presented to the lntegrated
Resource Plan Advisory Committee (!RPAC).
UPDATED RESPONSE TO REQUEST NO. 5: While the former response
remains applicable, the 2019 lntegruted Resource Plan Review Report (lRP Review
Report), filed along with the Second Amended 2019 lRP, details the comprehensive
review of ldaho Powe/s resource planning practices and modeling associated with the
2019 IRP Cycle. The outcome of this review not only ensures the validity of the 2019
lRP, but also offers valuable lessons and insights that can be applied in future lRPs.
To conduct the review, the Company formed 11 sub-teams, each with the
appropriate subject mafter expert(s) to examine individual categories of AURORA
model inputs. Each of the sub-teams reviewed the key inputs through the following four-
step process:
o Step I included identification of key IRP inputs, sources and input-related
assumptions,
. Step ll involved evaluating the manner in which key inputs were entered into the
AURORA model.
e Step ll! involved a comprehensive review of the system settings applied within
the AURORA model.
. Step lV included validation of the AURORA model outputs to ensure results were
reasonable/expected with respect to each of the key inputs.
IDAHO POWER COMPANY'S UPDATED RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 3
Specific to this request, in review Step M, the sub-teams sought to verifu and
validate the AURORA model ouputs to ensure the model produced logical and
consistent results. The sub-teams evaluated the reasonableness of the output or
performed additionalwork to validate the data as ne@ssary. For identified adjustments
from Steps I through lll, sensitivity runs were completed to determine the impact. These
sensitivities compared the input data used in the Amended 2019 IRP and the
associated results to reruns of the model with the adjustments identified in Steps I - lll.
The process to venry and validate the key inputs was unique to each topic and is
described in Section 5 of the IRP Review Report.
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 THE COMMISSION STAFF -4
REQUEST NO. l0: On page 97 of the Company's Amended 2019 lRP, the
Company states that a "...subset of top-performing WECC portfolios was manually
adjusted with the objec'tive of further reducing portfolio costs specific to the ldaho Power
System." Please provide the criteria used by the Company to select this particular
subset of portfolios.
UPDATED RESPONSE TO REQUEST NO. 10: This request is no longer
applicable based on the Gompany's Second Amended lRP.
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 THE COMMISSION STAFF - 5
REQUEST NO. l{: How does the Company knory that a \AlECC-optimized
portfolio, that wasn't part of the subset that was further manually adjusted, could be
manually adjusted to be more optimalthan the final portblio selected? Please explain.
UPDATED RESPONSE TO REQUEST NO. 11: This request is no longer
applicable based on the Company's Second Amended lRP.
The rcsponse to this Request is sponsored by Jared Hansen, Resource Planning
Leader, ldaho Power Company.
IDAHO POVI'ER COMPANY'S UPDATED RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF .6
REQUEST NO. {2: For each of the manually built portfolios shown in Table 9.9,
please explain the adjustments that were made to the parent VI/ECC portfolio.
UPDATED RESPONSE TO REQUEST NO. 12: 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.
TDAHO POWER COMPANY'S UPDATED RESPONSETOTHE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF .7
REQUEST NO. {3: For each of the manually built portfolios shown in Table 9.9,
please provide the objective function that was used to evaluate the model, with a
description of all components of that objective function.
UPDATED RESPONSE TO REQUEST 1{O. 13: This request is no Ionger
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.
IDAHO POVT'ER COMPANY'S UPDATED RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 8
REQUEST NO. {4: Please confirm that, with the exception of resouroes
specified in the lRP, all modeling parameters used to develop the Company's manually
built portfolios were itlentical. lf this is not @rrect, please explain all differences in
modeling configuration, including the inclusion of resources that were either included or
removed in order to stabilize the model.
UPDATED RESPONSE TO REQUEST NO. 14: 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.
IDAHO POVVER COMPANY'S UPDATED RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF .9
REQUEST NO. 15: Which Aurora zones were used to determine prices that
were used to develop the Net Present Values shourn in Table 9.9?
RESPONSE TO REQUEST NO. 15: 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 POVVER COMPANY'S UPDATED RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF. 10
REOUEST NO. 16: Please explain how flexibility resources were used in the
development of each of the Company's manually built portfolios. For each of these
portfolios, please identiff which resouroes were included as flexibility resouroes.
RESPONSE TO REQUEST NO. 16: 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.
IDAHO POWER COMPANY'S UPDATED RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE GOMMISSION STAFF . 11
REQUEST NO. 17: On page 110 of the Amended 2019 lRP, the Company
states that it, "...is confident that its preferred portfolio detailed in Chapter 10 achieves
the lor cost, low risk objective of the lRP." Please explain the basis for this degree of
confidence.
UPDATED RESPONSE TO REQUEST Nglr {7: This request is no longer
applicable based on the Gompany's Second Amended lRP.
The response to this Request is sponsored by Jared Hansen, Resource Planning
Leader, ldaho Power Company.
IDAHO POVI'ER COMPANY'S UPDATEO RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF.12
REQUEST NO. 43: For the 20 manually built portfolios, please provide evidence
that the portfolios meet regulating reserve requirementrs and reliability standards.
UPDATED RESPONSE TO REQUEST NO.- 43: 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.
IDAHO POWER COMPANY'S UPDATED RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF.13
REQUEST NO. 44: Page 46 of the Amended 2019 lntegrated Resource Plan
Appendix C compares long-term capacity expansion results between No B2H portfolios
and \Mth B2H portfolios in pairs. Please ansurer the following questions:
a.) \Mry do pairs of Portfolio 6/Portfolio 18, Portfolio 8/Portfolio 20, Portblio
11lPortfolio 23, and Portfolio l2lPortfolio 24have different coalexit
results?
b.) Why do the remaining pairs have the same coal exit results?
UPDATED RESPONSE TO REQUEST NO. tl4: 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.
IDAHO POVI/ER COMPANY'S UPDATED RESPONSE TO THE FIRST
PRODUCTION REOUEST OF THE COMMISSION STAFF - 14
REQUEST NO. t[5: Page 109 of the Amended 2019 lntegrated Resource Plan
describes the six scenarios of Jim Bridger exit. Please explain in detai! why Scenario 5
and Scenario 6 arc not necessary to be tested on Portfolio 4 and Portfolio 16.
UPDATED RESPONSE TO REQUEST NO. tls: This request is no longer
applicable based on the Company's Second Amended IRP.
The response to this Request is sponsored by Jared Hansen, Resource Planning
Leader, ldaho Power Company.
IDAHO POVVER COMPANY'S UPDATED RESPONSE TO THE FIRST
PRODUCT]ON REOUEST OF THE COMMISSION STAFF - 15
REQUEST NO. '16: Table 9.9 of the Amended 2019 lntegrated Resource Plan
shows the NPV of the 20 manually built portfolios under bur natural gas and carbon
scenarios. Please provide the NPV variance for each of these portblios using the same
methods used to derive the NPV variance in Figure 9.1.
UPDATED RESPOilSE TO REQUEST NO. 46: 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.
IDAHO POWER COMPANY'S UPDATED RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF.16
REQUEST NO. 47: Page 124 ol the Amended 2019 lntegrated Resouroe Plan
discusses the preferred portfolio. Please explain why among 24 WECC-optimized
portfolios and 20 manually built portfolios Portfolio 16(4) is the prefened portfolio.
UPDATED RESPONSE TO REQUEST NO. 47: 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.
TDAHO POV1JER COMPANY'S UPDATED RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF.17
FEOUEST Ng. /A: Page '124 ol the Amended 2019 lntegrated Resourm Plan
states the preferred portfolio was further evaluated under an assumption of planning
case natural gas price forecast and planning case carbon cost 6recast, represented by
P14(7). Please answer the following questions:
a. How do these assumptions differ from the assumptions used to brmulate
the preferred portfolio?
b. PIease define P14(7r.
c. Please explain how this evaluation was conduc'ted.
d. Please provide the results of this evaluation.
UPDATED RESPONSE TO REQUEST NO. /A: This request is no longer
applicable based on the Company's Second Amended IRP.
The rcsponse to this Request is sponsored by Jared Hansen, Resource Planning
Leader, ldaho Power Company.
DATED at Boise, ldaho, this 16th day of October 2020.
"(*!.fl',,*t."*,
LISA D. NORDSTROM
Attomey for ldaho Power Company
IDAHO POWER COMPANYS UPDATED RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 18
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 16h day of October 2A20,1 served a true and
correct copy of IDAHO POWER COMPANY'S UPDATED RESPONSES TO THE
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF upon the following
named parties by the method indicated below, and addressed to the following:
Commission Staft
Edward Jewell
Deputy Attorney 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, Idaho 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.bor@arkoosh. com
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IDAHO POWER COMPANY'S UPDATED RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF. 19
Gloria D. Smith, Managing Attorney
2101 Webster Street, Suite 1300
Oakland, California Y1612
Ana Boyd, Research Analyst
2101 Webster Street, Suite 1300
Oakland, California 94612
lndustrial Customep of ldaho Power
Peter J. Richardson
RICHARDSON ADAMS, PLLC
515 North 27th Street (83702)
P.O. Box 7218
Boise, ldaho 83701
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(.com
[e-mail]
q lq a rq a noam a ri@ ho! la ndha rt. com
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Stephanie L. Buckner
Executive Assistant
IDAHO POWER COMPANY'S UPDATED RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF.20