20201029Staff 59-93 to IPC.pdf

EDWARD JEWELL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-007 4
[phone]
IDAHO BAR NO. 10446
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Street Address for Express Mail:
1 1331 W CHINDEN BVLD, BLDG 8, SUITE 2OI-A
BOISE, TD 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S 2019 INTEGRATED RESOURCE
PLAN
CASE NO.IPC.E-I9.Ig
THIRD PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
IDAHO POWER COMPANY
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Edward Jewell, Deputy Attorney General, request that Idaho Power Company (IPC or Company)
provide the following documents and information as soon as possible, or by THURSDAY,
NOVEMBER L9,2020.
This Production Request is continuing, and the Company is requested to provide, by way of
supplementary responses, additional documents that it or any person acting on its behalf may later
obtain that will augment the documents produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations. The Company is reminded that responses pursuant
to Commission Rules of Procedure must include the name and phone number of the person
preparing the document, and the name, location and phone number of the record holder and if
different the witness who can sponsor the answer at hearing if need be. Reference IDAPA
3t.0t.o1.228.
THIRD PRODUCTION REQUEST
TO IDAHO POWER ocroBER 29,2020
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In addition to the written copies provided as response to the questions, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO.59: Please answer the following questions about the Comprehensive 2019
IRP Review Process outlined on pages 2 through 6 of the Company's Second Amended 2019IRP:
a. Does the Company plan to apply this process to the 2021 IRP? Please explain why or
why not.
b. If the Company plans to apply this process to the 2021 IRP, please describe any
modifications to the process contemplated by the Company.
REQUEST NO. 60: Does the Company plan to conduct its 202I IRP analysis using a
capacity expansion methodology that selects portfolios optimized for Idaho Power's service
territory? Please explain why, or why not.
REQUEST NO.61: In the Company's 2019 IRP Review Report the Company states
Subsequent to the initialfiling, Idaho Power discovered that the LTCE model
optimized portfolios for the entire Western Electricity Coordinating Council
(WECC) region, but not necessarily for ldaho Power's system in particular. For
this reason, on July 19, 2019, the company notified the Commissions of the need to
perform supplemental analysis to ensure that the IRP yielded a least-cost, least-
risk solution specific to IPC's service area, and asked that the Commissions
refrainfrom adopting a procedural schedule until an amended IRP could be filed.
Report at 1.
a. Please describe what steps the Company has taken to identify requirements and
specifications for capacity expansion modeling solutions or software to address
and resolve this problem.
b. Additionally, please describe how the Company will eliminate the potential for
reoccurrence of this problem in subsequent capacity expansion modeling and
IRPs.
c. Please explain the criteria that the Company is using to select capacity expansion
software.
d. Please identify all capacity expansion software that either is or was under review.
e. If software has been identified, please provide the name and vendor of that software.
THIRD PRODUCTION REQUEST
TO IDAHO POWER 2 ocroBER 29,2020
REQUEST NO. 62: On page 2 of the Company's Second Amended 2019 IRP, the
Company states that one objective of its 2019 IRP Review process was Validation of Model
Outputs. Please explain how model outputs were validated.
REQUEST NO. 63: On page 3 of the Company's Second Amended 2019 IRP, the
Company states that it reviewed model outputs. Please explain the criteria used by the IRP Review
Team to evaluate the consistency and accuracy of Aurora LTCE outputs.
REQUEST NO. 64: On pages 4 and 5 of the Company's Second Amended 2019IRP, the
Company states that Natural Gas Variable Transport Costs were inadvertently not included in the
model. Please provide workpapers showing the variable transport costs, per Therm, of gas that was
excluded over the life of the model.
REQUEST NO.65: In the summary of the Irrigation Peak Rewards program on page 10 of
Appendix B of the Company's Second Amended 2019IRP (DSM Annual Report), the Company
states: "This maximum realization rate is not always achieved for every program in any given year."
Please provide the following information:
a. What is the maximum coincident peak reduction achieved by the Company's Irrigation
Peak Rewards program since the program's inception, and on what date and time
did this occur?
b. Under the program's current structure, what is the maximum coincident peak reduction
that could be achieved by the Company's Irrigation Peak Rewards program?
c. Under the program's current structure, what is the maximum coincident peak reduction
that could be achieved by the Company's Irigation Peak Rewards over five
consecutive daYs?
REQUEST NO. 66: On page 6 of the Company's Second Amended 2019IRP, the
Company states, "The B2H transmission line continues to be a top performing resource alternative,
providing Idaho Power access to clean and low-cost energy in the Pacific Northwest wholesale
market." Please provide an explanation of all assumptions made by the Company regarding the
availability of power, including the Company's assumptions about how Washington's Clean Energy
THIRD PRODUCTION REQUEST
TO IDAHO POWER ocToBER 29,20203
Transformation Act (CETA) would impact energy available to import through B2H for Idaho Power
customers.
REQUEST NO. 67: On page 8 of the Company's Second Amended 2019IRP, the
Company states that it forecasts load and demand growth of 1.0 and l.2Vo, respectively. The
Company also states that total customers are expected to increase from 550,000 to715,000 between
2018 and 2038, or an annual growth rate of l.7Vo. Please explain why the Company believes that
load and demand growth will be less than the annual population growth rate.
REQUEST NO.68: On page 58 of the Company's Second Amended IRP, the Company
explained that its third-pany contractor provided a}D-year forecast of Idaho Power's energy
efficiency potential from a total resource cost (TRC) perspective. In Final Order No. 34469, the
Commission ordered the Company to use the "UCT perspective for integrated resource planning."
Please explain why the Company's contractor did not conduct its energy efficiency potential study
using the UCT (Utility Cost Test).
REQUEST NO.69: On page 109 of the Company's Second Amended IRP, the Company
explains that it manually adjusted six WECC-optimized Portfolios. Please explain the following:
a. What criteria did the Company use to select these six WECC-optimized Portfolios for
further adjustment?
b. What criteria did the Company use to group portfolios into "buckets" as described on
the same page?
RBQUEST NO.70: According to Figure 10 (page 57) of Appendix D of the Company's
Second Amended IRP, the Pacific North West (PNW) summer surplus decreases from 6,000 MW in
2020 to 2,000 MW in 2029 for an average decrease of 400 MW per year. At this rate, the PNW
would experience a summer capacity deficit in the year 2034. Why does the Company believe that
the region will have sufficient surlmer capacity for Idaho Power's summer peak needs after 2034?
THIRD PRODUCTION REQUEST
TO IDAHO POWER ocToBER 29,20204
REQUEST NO. 71: Figure 10 (page 57) of Appendix D of the Company's Second
Amended IRP was based on an April 2019 BPA adequacy assessment. [n May 2019, the State of
Washington passed its Clean Energy Transformation Act (CETA).
a. Were the effects of the implementation of CETA factored into the April 2019 BPA
adequacy assessment?
b. If not, please explain how the Company believes that CETA would affect the forecasts
displayed in Figure 10.
REQUEST NO.72: On page 59 of Appendix D of the Company's Second Amended IRP,
the Company states, "Under this arrangement, BPA and/or its customers'OATT payments would,
over time, ensure recovery of Idaho Power's revenue requirement associated with BPA's respective
usage of B2H."
a. How will the contemplated transmission service agreement guarantee full recovery of
Idaho Power's revenue requirement?
b. Why does the Company believe it appropriate to include a share of a line that is not used
to serve the needs of Idaho Power Customers in Idaho Power's rate base?
REQUEST NO.73: Please provide an update to Production Request No. 25 with an
assumption that the Company will own 457o of Boardman to Hemingway Transmission Line.
Please provide the update in EXCEL format with formulae and links intact.
REQUEST NO. 74: Please explain why paying higher property taxes in Oregon benefits
current and future Idaho ratepayers? (Amended Application page 19 - listed two benefits)
REQUEST NO.75: Please provide the other additional benefits, not listed, of owning
more than the assumed?I%o of Boardman to Hemingway Transmission Line on page 19 of Second
Amended Application. (Amended Application page 19)
REQUEST NO. 76: With BPA potentially dropping out of owning a portion of B2H,
please provide an updated project cost estimate that includes the additional taxes, such as property,
THIRD PRODUCTION REQUEST
TO IDAHO POWER 5 ocroBER 29,2020
federal, and state, no longer covered by Bonneville Power Administration. (Amended Application
page 19)
REQUEST NO.77: [n its Amended Application, the Company states that there is potential
savings by exiting Valmy Unit2 as early as year-end 2022, and that additional analysis will be
conducted to identify optimal exit timing. Please provide documentation that shows the
considerations that will be used to determine optimal exit timing of Valmy Unit2. Additionally,
please provide the Company's plan for communicating Valmy Unit2 decisions and notifications.
REQUEST NO.78: On page 7 of the 2019 IRP Review Report, the Company states that
Valmy lJnit2 cannot provide regulation reseryes. Please explain if the unit's operating
characteristics changed or if it was incorrectly identified in previous iterations of the IRP as a
regulation reserve resource.
REQUEST NO. 79: On page 6 of 2019IRP Review Report, the Company describes a
change in the way demand response is treated in modeling from a last-resort resource to a resource
to offset peak load. Please provide the analysis and justification used to support this change, and
documentation demonstrating that actual deployment of demand response meets this purpose.
REQUEST NO.80: On page 6 of the 2019 IRP Review Report, the Company describes a
change in ramp rate from 100 percent to 60 percent for Langley Gulch. Please define the term
"percent ramp rate," and explain the impact that this change will have to the Company's IRP.
REQUEST NO. 81: Please provide evidence, based on actual operation, that the ramp rates
for Danskin and Bennett Mountain plants are accurate in the model.
REQUEST NO.82: Please explain the process the Company performed to validate, not
only the input assumption for all of its resources, but all inputs into the model to ensure it represents
actual operation.
THIRD PRODUCTION REQUEST
TO IDAHO POWER ocToBER 29,20206
REQUEST NO. 83: On page 64 of 2019IRP Review Report, natural gas peaker plant
startup costs are described. The Company included the following results:
Results - The adjustment to the startup costs of the peaker plants resulted in the
largest impact to the results of all the adjustments across the tested portfolios.
The Preferred Portfolio increased by 0.93 percent, with increases among the
tested portfolios ranging from 0.79 percent to 1.07 percent.
Please provide workpapers with formulas intact for all peaker plant startup cost adjustments
REQUEST NO. 84: Please provide a detailed explanation for the IRP impact of
transmission input adjustments made to transmission line loss and wheeling rates, transmission
capacity input corrections (53 MW, 85 MW, and 200 MW), and for the transmission capacity
update for ownership share at Bridger West. 2019 IRP Report at 7.
REQUEST NO. 85: On page 28 of 2Ol9IRP Review Report (Forecast Generation), the
Company states that all PURPA contracts are forecast to be replaced upon expiration of the existing
contract, except for wind contracts, because the Company is unable to accurately predict whether
wind Qualifying Facilities (QFs) will choose to invest in repowering due to several factors. Please
identify and explain the factors.
REQUEST NO.86: On page 28 of 2019IRP Review Report (Forecast Generation), the
Company discusses PURPA Inputs in AURORA and states that "average estimated generation is
allocated to Heavy Load at 56 percent, unless it is determined a different proportion should be used.
Average estimated generation for solar has been calculated to be 84 percent."
a. Please describe "ayerage estimated generation" and explain how it is determined. In the
explanation, please include: The source of the data used, if it is based on historic data, and if
it is calculated specific to each month or as an annual average.
b. Please explain how the 56 percent is determined.
c. Please explain how the 84 percent is determined.
d. Please list and explain all purposes making it necessary to allocate estimated generation to
Heavy Load hours and Light Load hours in the modeling process. Is one purpose to
determine a QF's generation amount at the hourly level?
THIRD PRODUCTION REQUEST
TO IDAHO POWER ocroBER 29,20201
e. Please explain how the QFs' generation amounts are used in the dispatch process. Does
AURORA subtract the hourly generation amount of QFs from the load first, due to must-
purchase provisions, and then dispatch other resources to meet the remaining load?
REQUEST NO.87: On page 50 of the20Ig IRP Review Report (Long Term Capacity
Expansion Results), the Company states that "equal or fewer natural gas resources were selected by
the model in the planning gas scenario than the resource stacks built under high-gas conditions
when comparing the same carbon conditions." Does the Company mean "more" natural gas
resources, instead of "fewer"? Please explain.
REQUEST NO. 88: On page 6l of 2019IRP Review Report (Reserve Shortfall), in its
discussion of the reserve shortfall for P16(4), the preferred portfolio identified in the First Amended
2019 IRP, the Company states, "There was a projected reserve shortfall of just 54 NIWh out of
119,000,000 NtWh of total load."
a. Please explain why a reserve shortfall exists. Does the Company's implementation of
AURORA relax reserve requirements to achieve a solution? Is there a hierarchy between
least cost and reliability in reaching its optimization results?
b. Please report the total load in MWh identified in the Second Amended 2019IRP.
c. Please report the amount of reserve shortfall in MWh for the preferred portfolio PGPC
B2H(1) identified in the Second Amended 2019 IRP.
d. Please discuss whether the reserve shortfall provided above is acceptable and why.
e. Generally, how many loss of load hours per year due to regulation reserve shortfall is
appropriate for planning purposes? Does the reserve shortfall provided above meet this
standard?
REQUEST NO. 89: Page 67 of 2019IRP Review Report: Process and Findings states that
"Energy Exemplar, the developers of AURORA, regularly releases updated versions of the
software. One of the latest updates enables co-optimization of results, which would allow co-
optimization of the portfolio specific to Idaho Power and the WECC. This development could
greatly increase the efficiency of the IRP process." Does the Company plan to co-optimize
THIRD PRODUCTION REQUEST
TO IDAHO POWER ocToBER 29,20208
portfolios for Idaho Power's system and for the WECC in the future? If so, please explain why the
Company seeks to co-optimize,rather than optimizefor Idaho Power's system alone.
REQUEST NO. 90: Table 8.5 on page 119 of the Second Amended 2019 IRP shows how
the new portfolios are created in the second amended IRP. For example, Portfolio PGPC combines
the original P(13) and P(14), and Portfolio PGPC B2H combines the original P(1) and P(2). Please
provide and explain the individual steps used to determine how the new portfolios were created.
REQUEST NO. 91: Page27 of Appendix C lists resource additions and removals from the
preferred portfolio for PURPA reference purposes. Please explain the purpose of this table and
provide an example of how it is intended to be used.
REQUEST NO.92: Please provide the workpapers used to determine the deficiency period
start date of July 2029 andthe 42 MW deficit as shown on page 28 of Appendix C.
REQUEST NO. 93: Please describe the QF historic generation data used for determining
the QF contribution of capacity in the IRP. Specifically, what time periods (how many years of
data, which months, which hours) of historic data are used? If the types of data are different for
different QF technologies, please explain the differences of each.
DATED at Boise, Idaho, this 29rH day of October 2020
&> &*L{
Edward lefeU\
Deputy Attoldy General
i:umisc:prodreq/ipcel9.l9ejmm prod req3
THIRD PRODUCTION REQUEST
TO IDAHO POWER 9 ocroBER 29,2020
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 29th DAY OF OCTOBER 2020,
SERVED THE FOREGOING THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY, IN CASE NO.
IPC-E-19-19, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
LISA D NORDSTROM
REGULATORY DOCKETS
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-mail : lnordstrom @ idahopower.com
dockets @ idahopower.com
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
710 N 6TH ST
BOISE D 83702
E-mail: botto@ idahoconservation.org
PETER J RICHARDSON
RICHARDSON ADAMS PLLC
515 N 27TH STREET
PO BOX 7218
BOISE ID 83702
E-mail : [e-mail]
JACK VAN VALKENBURGH
VAN VALKENBURGH LAW PLLC
PO BOX 531
BOISE ID 83701
E-mail: jack@ vanvalkenburghlaw.com
AUSTIN RUESCHHOFF
THORVALD A NELSON
HOLLAND & HART LLP
555 17TH ST STE 32OO
DENVER CO 80202
E-mail: darueschhoff@ hollandhart.com
tnelson @ hollandhart.com
aclee @ hollandhart.com
gl garanomari @ hollandhart.com
TIM TATUM
MATT LARKIN
IDAHO POWER COMPANY
PO BOX 70
BOrSE rD 83707-0070
E-mail: [e-mail]
mlarkin @ idahopower.com
C TOM ARKOOSH
ARKOOSH LAW OFFICES
PO BOX 2900
BOISE ID 8370I
E-mail: [e-mail]
erin.cecil @ arkoosh.com
DR DON READING
6070 HILL ROAD
BOISE ID 83703
E-mail: dreading @mindsprin g.com
JIM KREIDER
STOP B2H COALITION
60366 MARVIN RD
LA GRANDE OR 97850
E-mail: [e-mail]
JIM SWIER
MICRON TECHNOLOGY INC
8OO SOUTH FEDERAL WAY
BOISE ID 83707
E-mail: [e-mail]
CERTIFICATE OF SERVICE
JTJLIAN ARIS
SIERRA CLUB
2101 WEBSTER ST STE 13OO
OAKLAND CA94612
E-mail: [e-mail]
GLORIA D SMMH
SIERRA CLUB
2101 WEBSTER ST STE 13OO
OAKLAND CA946I2
E-mail: [e-mail]
_l-/fu
SECRETART
CERTIFICATE OF SERVICE