20201204Staff 94-104 to IPC.pdf

EDWARD JEWELL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION ŸM 12·
PO BOX 83720
BOISE,IDAHO 83720-0074
[phone]
IDAHO BAR NO.10446
Street Address for Express Mail:
11331 W CHINDEN BVLD,BLDG 8,SUITE 201-A
BOISE,ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER )COMPANY'S 2019 INTEGRATED RESOURCE )CASE NO.IPC-E-19-19
PLAN )
)FOURTH PRODUCTION
)REQUESTOF 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 AttorneyGeneral,request that Idaho Power Company (IPC or Company)
provide the followingdocuments and information as soon as possible,or by MONDAY,
DECEMBER 28,2020.
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
31.01.01.228.
FOURTH PRODUCTION REQUEST
TO IDAHO POWER 1 DECEMBER 4,2020
In addition to the written copies provided as response to the questions,please provide all
Excel and electronic files on CD with formulas activated.
REQUESTNO.94:In its response to Staffs Production Request No.90,the Company
states,"Combining the WECC-optimized portfolios was done by maintaining similar resource
selections and timing to the portfolios shown in Table 8.5."Please provide an example to illustrate
how this is accomplished and explain how different resource selections are treated for each pair of
portfolios that are combined.Are they excluded so that only similar resource selections are left in
the final combined portfolios?Please explain why or why not.
REQUESTNO.95:In its response to Staffs Production Request No.93,the Company
states,"For baseload resources such as hydro,biomass and cogeneration,the monthlyaverage
megawatts of the generation estimates are used to determine each QF's contribution to capacity."Is
the capacity contribution of non-QF baseload resources determined in the same way?If not,please
explain in detail how it is determined.
REQUESTNO.96:In its response to Staffs Production Request No.93,the Company
states,"For solar and wind resources the total nameplate capacity of each resource type is multiplied
by a peak hour capacity factor to determine the contribution to peak."Please explain whether this
statement applies to both QF and non-QF solar and wind.
REQUESTNO.97:In its response to Staffs Production Request No.93,the Company
states,"For example in the 2019 IntegratedResource Plan the total nameplate capacity of wind QFs
was multiplied by a peak hour capacity factor of 5 percent."Please answer the followingquestions.
a.Please describe how peak hour capacity factors are determined for both QF and non-QF
solar and wind.
b.In the Incremental Cost Integrated Resource Plan (ICIRP)Methodology,the peak hour
capacity factors for wind QFs are listed in the followingtable.Please describe the
relationship between the peak hour capacity factors used in the IRP capacity planning
process and the peak hour capacity factors used in the ICIRP Methodology.
FOURTH PRODUCTION REQUEST
TO IDAHO POWER 2 DECEMBER 4,2020
Peak Hour (July 3-7 PM)Peak Hour (July 3-7 PM)90th Percentile
Benchmark Type Benchmark Average Capacity Factor Capacity Factor
Wind idaho Power Wind (2008-2011)27.4%3.9%
REQUESTNO.98:In its response to Staffs Production Request No.61(b),the Company
states that for the 2021 IRP,the Company developedtools to ensure that the planning margin is
maintained specifically for the Company,versus building and optimizing resources for the WECC,
but not necessarily Idaho Power's system.The Company also states that these tools were used
during the manual optimization process for the 2019 IRP and can be used to check the effectiveness
of the capacity expansion tools selected for the 2021 IRP.Please describe the "tools"used during
the manual optimization process for the 2019 IRP and explain how these tools can ensure the
planning margin is maintained specifically for the Company.
REQUESTNO.99:In its response to Staffs Production Request No.66,the Company
states,"The Long-Term Capacity Expansion (LTCE)ensures that adequate resources are built
throughout the WECC by adhering to strict planning margins by area,as well as other model
constraints.For example,the planning margin for Idaho Power is 15 percent;if the Company's
demand is 3,500 megawatts,AURORA builds enough resources to meet 4,025 MW (4,025 =
3,500*1.15)of demand for the Company's area."If the LTCE ensures that adequate resources are
built throughout the WECC by adhering to strict planning margins by area,please explain why the
"tools"mentioned in the Company's Response to Staff's Production Request No.61 (b)are needed
to ensure the planning margin is maintained specifically for the Company.
REQUESTNO.100:In its response to Staff's Production Request No.89,the Company
states,"According to Energy Exemplar and based on current testing,the newest version of the
AURORA Long-Term Capacity Expansion software is capable of simultaneously modeling the
WECC and Idaho Power,with the concurrent goal of meeting the planning margin for all entities
within the WECC.The planning margin is still the main driver for new resource builds and
retirements,with no priority given to a specific area within the model."Please answer the
followingquestions.
FOURTH PRODUCTION REQUEST
TO IDAHO POWER 3 DECEMBER 4,2020
a.If the LTCE adheres to strict planning margins by area,as mentioned in the Company's
Response to Staff's Production Request No.66,has the concurrent goal of meeting
planning margin for each entitywithin the WECC already been achieved by optimizing
for the WECC only?
b.Is a priority given to Idaho Power's service territoryby optimizing the service area?If so,
please explain how the priority is given in the model and what impacts are expected to be
seen for Idaho Power's service territory.
c.Please provide the objective function used to simultaneously optimize for the WECC and
Idaho Power.
d.Does Idaho Power's practice of simultaneously modeling the WECC and Idaho Power
guarantee that the same Idaho Power Portfolio would be obtained as would be obtained
by optimizing for Idaho Power's system only,without attempting to meet the planning
margins of all entities in the WECC?
REQUESTNO.101:In its response to Staffs Production Request No.88,the Company
describes a hierarchy consisting of a primary objective of meeting hourlydemand,and a secondary
objective of meeting regulation reserve requirements.The regulation reserves are input into
AURORA,and designated to be served by a select set of Company resources.Please answer the
followingquestions:
a.What resources are designated to meet regulation reserve requirements.
b.Will any of the new resources selected be designated to meet regulation reserve
requirements?
c.Based on this hierarchy,does the LTCE consume all the designated resources to meet
demand before it selects new resources?If so,do the resulting portfolios still have any
regulation reserve left when new resources in a late stage are added?If not,to what degree
does the LTCE consume the designated resources to meet demand before they select new
resources?How is that degree determined?
REQUESTNO.102:Page 104 of the Company's Second Amended IRP states,"The
AURORA portfolio development process is more precise in using the defined resource
characteristics and established quantitative requirements associated with those resources.Examples
FOURTH PRODUCTION REQUEST
TO IDAHO POWER 4 DECEMBER 4,2020
include increasing regulation requirements with solar generation additions or maintaining a peak
hour planning margin and applying hourlyregulating reserve requirements in the economic
selection and timing of resource additions and retirements."Please provide examples that illustrate
how regulating reserve requirements are applied in the economic selection and timing of resource
additions and retirements while maintaining a peak hour planning margin.
REQUESTNO.103:Please explain if a regulation reserve shortfall can cause loss of load.
If so,please explain if there is a way to quantifyloss of load caused by regulation reserve shortfall.
REQUESTNO.104:In its response to Staffs Production Request No.62,the Company
states,"The Overarching goal of Step IV was to verify and validate the AURORA model outputs to
ensure that the model produced logical and consistent results."Please provide the following
information:
1.A list of the specific functions that the Company validated for both models.
2.For each function validated,please provide the specific tests that were conducted,the
results that the Company expected from each test,whether or not the actual results
matched expectations,and if results and expectations did not match,provide an
explanation and a conclusion for the discrepancy.
DATED at Boise,Idaho,this 4th day of December 2020.
Edward Jew 11
Deputy Attorne eneral
i:umise:prodreq/ipcel9.19ejmm prod req4
FOURTH PRODUCTION REQUEST
TO IDAHO POWER 5 DECEMBER 4,2020
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 4'"DAY OF DECEMBER 2020,
SERVED THE FOREGOING FOURTH PRODUCTION REQUESTOF 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 TIM TATUM
REGULATORY DOCKETS MATT LARKIN
IDAHO POWER COMPANY IDAHO POWER COMPANY
PO BOX 70 PO BOX 70
BOISE ID 83707-0070 BOISE ID 83707-0070
E-mail:[e-mail] E-mail:[e-mail]
[e-mail] [e-mail]
BENJAMIN J OTTO C TOM ARKOOSH
ID CONSERVATION LEAGUE ARKOOSH LAW OFFICES
710 N 6TH ST PO BOX 2900
BOISE ID 83702 BOISE ID 83701
E-mail:botto idahoconservation.ore E-mail:[e-mail]
[e-mail]
PETER J RICHARDSON DR DON READING
RICHARDSON ADAMS PLLC 6070 HILL ROAD
515 N 27TH STREET BOISE ID 83703
PO BOX 7218 E-mail:[e-mail]
BOISE ID 83702
E-mail:[e-mail]
JACK VAN VALKENBURGH JIM KREIDER
VAN VALKENBURGH LAW PLLC STOP B2H COALITION
PO BOX 531 60366 MARVIN RD
BOISE ID 83701 LA GRANDE OR 97850
E-mail:[e-mail] E-mail:[e-mail]
AUSTIN RUESCHHOFF JIM SWIER
THORVALD A NELSON MICRON TECHNOLOGY INC
HOLLAND &HART LLP 800 SOUTH FEDERAL WAY
555 17TH ST STE 3200 BOISE ID 83707
DENVER CO 80202 E-mail:[e-mail]
E-mail:[e-mail]
[e-mail]
[e-mail]
[e-mail]
CERTIFICATE OF SERVICE
JULIAN ARIS GLORIA D SMITH
SIERRA CLUB SIERRA CLUB
2101 WEBSTER ST STE 1300 2101 WEBSTER ST STE 1300
OAKLAND CA 94612 OAKLAND CA 94612
E-mail:[e-mail] E-mail:[e-mail]
SECRE RY
CERTIFICATE OF SERVICE