20201229IPC to Staff 94-104.pdf

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Ann oonpcotrofiy
LISA D. NORDSTROM
Lead Gounsel
[e-mail]
December 28,2020
VIA ELECTRONIC FILING
Jan Noriyuki, Secretary
ldaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg 8,
Suite 201-A(83714)
PO Box 83720
Boise, ldaho 83720-0074
Re Case No. IPC-E-19-19
201 9 lntegrated Resource Plan
Dear Ms. Noriyuki:
Attached for electronic filing, pursuant to Order No. 34602, is ldaho Power
Company's Response to the Fourth Production Request of the Commission Staff.
lf you have any questions about the aftached documents, please do not hesitate to
contact me.
Very truly yours,
X* !.7(^l-+^-*,
Lisa D. Nordstrom
LDN:slb
Attachment(s)
LISA D. NORDSTROM (lSB No. 5733)
ldaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
I n ord strom @ ida hopower. com
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S 201 9 INTEGRATED
RESOURCE PLAN
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CASE NO. IPC-E-19-19
IDAHO POWER COMPANY'S
RESPONSE TO THE FOURTH
PRODUCTION REQUEST OF
THE COMMISSION STAFF TO
IDAHO POWER COMPANY
COMES NOW, Idaho Power Company ("ldaho Powed' or "Company"), and in
response to the Fourth Production Request of the Commission Staff to ldaho Power
Company dated December 4,2020, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 1
REQUEST NO. 94: ln 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 porffolios 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 fina! combined portfolios?
Please explain why or why not.
RESPONSE TO REQUEST NO. 94: As an example, WECC optimized portfolios
P(1) and P(2) were combined to create the manually-optimized (Planning Gas - Planning
Carbon, or "PGPC") portfolios. This was done by recognizing the similarities among the
two portfolios. Both portfolios selected the same resources in similar quantities. These
resources were selected and the timing and quantity of the resources were selected to
meet the guiding principles listed in the Second Amended 2019 lRP. paqes 1 15-1 16. The
resource selections and quantities of the WECC-optimized portfolios P(1) and P(2) are
compared to the manually-optimized portfolios PGPC below:
NaturalGas Wind Solar Battery
Demand
Response
P(1)933 0 320 90 50
P(2)933 0 320 80 50
PGPC (1)933 0 320 80 50
PGPC (2}933 0 320 80 50
PGPC (3)933 0 320 80 50
PGPC (4)911 0 350 80 50
Four of the six portfolio combinations were similar to the example given above,
containing the same selection of resources in different quantities to meet the guiding
principles.
IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 2
For the high gas, high carbon ("HGHC") portfolio combinations, there were some
variations between the resourcesthe modelselected to meetthe growing system demand
and to replace coal generation. The goal was to determine if portfolios with different
selected resources could be manually optimized to compete with the best performing
portfolio resource mixes identified in the Long-Term Capacity Expansion process. ln
these cases, clean (non-carbon emitting), flexible resources were selected based on the
cost and performance attributes of the available resources. The combination of the
WECC-optimized portfolios P(23) and P(24) are compared to the manually-optimized
portfolios HGHC B2H below:
As listed in the guiding principles, no carbon-emitting resources were added to the
high gas, high carbon portfolios. As shown, the natural gas resources selected in the
WECC-optimized portfolio P(23) were replaced in the manual portfolios with non-carbon
emitting nuclear, biomass, and geothermal generation.
The response to this Request is sponsored by Jared Hansen, Resource Planning
Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 3
Natural
Gas Wind Solar Battery Geothermal Nuclear
Pumped
Storage Biomass
Demand
Response
P(23)500 7200 1050 80 0 0 0 0 t5
P(241 0 1200 1045 80 0 0 s00 30 0
HGHC B2H (1)0 1200 1150 80 60 L20 0 50 50
HGHC B2H (2)0 1200 L150 80 60 L20 0 50 50
HGHC B2H (3)0 1200 1160 80 60 L20 0 60 50
HGHC B2H (4)0 1100 1160 80 30 180 0 30 50
REQUEST NO. 95: ln its response to Staffs Production Request No. 93, the
Company states, "For baseload resources such as hydro, biomass and cogeneration, the
monthly average megawatts of the generation estimates are used to determine each QF's
contribution to capacity." ls the capacity contribution of non-QF baseload resources
detennined in the same wafl lf not, please explain in detail how it is determined.
RESPONSE TO REQUEST NO. 95: The capacity contribution of non-Qualifying
Facility ("QF') baseload resources that sell their generation output to Idaho Power under
Power Purchase Agreements is detemined in the same manner as QF baseload
resources. For all non-QF and QF resources under contract with the Company, capacity
is based on historical information adjusted to include additional forecast information
known to ldaho Power.
The response to this Request is sponsored by Jared Hansen, Resource Planning
Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 4
REQUEST NO. 96: ln 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.
RESPONSE TO REQUEST NO. 96: This statement applies to both Qualifying
Facility ('QF') and non-QF solar and wind resources.
The response to this Request is sponsored by Jared Hansen, Resource Planning
Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 5
REQUEST NO. 97: ln its response to Staffs Production Request No. 93, the
Company states, "For example in the 201g lntegrated Resource Plan the tota! "nameplate
capacity of wind QFs was multiplied by a peak hour capacity factor of 5 percent." Please
answer the following questions.
a. Please describe how peak hour capacity factors are determined for both QF and
non-QF solar and wind.
b. !n the lncremental Cost lntegrated Resource Plan (lClRP) Methodology, the peak
hour capacity factors for wind QFs are listed in the following table. 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.
RESPONSE TO REQUEST NO. 97:
a. The peak hour capacity factor of five percent for Qualifying Facility ('QF") and non-
QF wind resources has been a long-standing assumption used in the Company's
lntegrated Resource Plan ("lRP") for determination of a wind resource's
contribution to peak hour capacity. lt is based on industry information and practice,
and the Company believes it has been a reasonable representation of a wind
resource's contribution to peak hour capacity for long-term planning purposes.
However, this capacity factor is being re-evaluated for the 2021 lRP.
IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 6
Benchmark Tvoe Benchmark
Peak Hour (July 3 - 7 PIrl)
Averase Caoacitv Factor
Peak Hour (July 3 - 7 Pll) 90th Percentih
Caoacitv Fador
Wird ldaho Porcr Wind (200&2011)27.40/o 3.9%
The capacity factors applied to QF and non-QF solar are detailed in Table 4.1 of
the Second Amended 2019 IRP and the process for determining the factors is
described in Section 4, under the heading of Solar-Capacitv Value, of the Second
Amended 2019|RP.
b. As described in subpart a. above, ldaho Power has utilized a peak hour capacity
factor of five percent for wind resources in the Company's long-term IRP process
that is applied to al! months of any given year. The Incremental Cost Integrated
Resource Plan Avoided Cost Methodology ("lClRP Methodology") was developed
and approved by the ldaho Public Utilities Commission in Case No. GNR-E-11-03
and is used to calculate resource-specific avoided cost prices. The peak hour
capacityfactor in the ICIRP Methodologyforwind resourceswas established using
actualwind data on the ldaho Power system for July peak hours during the years
2008-2011 . Because the peak hour capacity factor used in the ICIRP Methodology
is used to set an avoided cost of capacity, a more specific capacity factor is applied.
The response to this Request is sponsored by Jared Hansen, Resource Planning
Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 7
REQUEST NO. 98: ln its response to Staffs Production Request No. 61(b), the
Company states that for the 2021 lRP, the Company developed tools to ensure that the
planning margin is maintained specifically for the Company, versus building and
optimizing resources for the WECC, but not necessarily ldaho 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 lRP. Please describe the "tools" used during the manual
optimization process for the 2019 lRP and explain how these tools can ensure the
planning margin is maintained specifically for the Company.
RESPONSE To REQUEST No. 98: The AURORA Long-Term capacity
Expansion model performs a load and resource balance anatysis. The Company created
a tool to replicate the load and resource balance performed by AURORA, to manually
add or remove resources and adjust the timing of the resources that were selected by
AURORA. The planning margin tool and a comparison of a manually optimized and
WECC optimized portfolio is included in the Excel spreadsheet accompanying this
response. As shown in the Excel spreadsheet, holding the planning margin closer to the
15 percent limit reduces the number and size of resource overbuilds and overall portfolio
costs.
The response to this Request is sponsored by Jared Hansen, Resource Planning
Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 8
REQUEST NO. 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 ldaho 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."
lf the LTCE ensures that adequate resources are built throughout the WECC by adhering
to strict planninq marqins bv area, please explain why the "tools" mentioned in the
Company's Response to Staffs Production Request No. 61 (b) are needed to ensure the
planning margin is maintained specifically for the Company.
RESPONSE TO EST NO. 99:The LTCE capacity function ensures the
planning margin for each area is met; however, each area can exceed the specified
planning margin. Resource selections within an area may target a need elsewhere in the
WECC, so the model can exceed a planning margin if the resource selection makes
overall economic sense. The Company placed limits to reduce the amount of overbuilds
within its area; however, excess resource builds can still occur if resource costs specific
to the Company are Iower than resource costs elsewhere within the WECC.
Using the tool ensures the selected resources are optimized for ldaho Power's
system.
The response to this Request is sponsored by Jared Hansen, Resource Planning
Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 9
REQUEST NO. 100: ln its response to Staffs Production Request No. 8g, 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 ldaho Power, with the concunent goal of
meeting the planning margin for all entities within the WECC. The ptanning margin is still
the main driverfor new resource builds and retirements, with no priority given to a specific
area within the model." Please answer the following questions.
a. lf the LTCE adheres to strict planning margins by area, as mentioned in the
Company's Response to Staffs Production Request No. 66, has the concurrent
goal of meeting planning margin for each entity within the WECC already been
achieved by optimizing for the WECC only?
b. ls a priority given to ldaho Power's service territory by optimizing the service area?
lf so, please explain how the priority is given in the mode! and what impacts are
expected to be seen for ldaho Power's service territory.
c. Please provide the objective function used to simultaneously optimize for the
WECC and ldaho Power.
d. Does ldaho Power's practice of simultaneously modeling the WECC and ldaho
Power guarantee that the same ldaho Power Portfolio would be obtained as would
be obtained by optimizing for ldaho Power's system only, without attempting to
meet the planning margins of all entities in the WECC?
IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 1O
RESPONSE TO REQUEST NO. 1OO:
a. No. The model has the option to allow areas that are assigned to a pool to share
resources. This option may help meet the overall planning margin for the pool but
may also overbuild local areas to optimize for the system as a whole.
b. No priority is given to a specific area within the model. All areas are treated the
same.
c. The objective function is to meet the planning margins by area or pool level with
the least overall system cost. The detailed optimization function can be found
within the Aurora application by accessing Help > Additional Resources >
Simulation Logic > Modeling Details > Commitment Optimization Logic Details'
d. No. However, the Company is part of the WECC, and the interplay with market
interactions is necessary when designing a portfolio. A WECC buildout needs to
be performed to provide a market future for costing portfolio builds, in order to
determine a least cost Portfolio.
The response to this Request is sponsored by Jared Hansen, Resource Planning
Leader, ldaho Power ComPanY.
IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY. 11
REQUEST NO. 101: ln its response to Staffs Production Request No.88, the
Company describes a hierarchy consisting of a primary objective of meeting hourly
demand, 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 following questions:
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?
Based on this hierarchy, does the LTCE @nsume allthe designated resources to
meet demand before it selects new resources? lf so, do the resulting portfolios still have
any regulation reserve left when new resources in a late stage are added? lf not, to what
degree does the LTCE consume the designated resources to meet demand before they
select new resources? How is that degree determined?
RESPONSE TO REQUEST NO. ToI:
a. The following resources are designated to meet regulation reserve requirements
in the Aurora model:
Brownlee Units 1-5
Hells Canyon Units 1-3
Oxbow Units 1-4
Danskin Units 1-3
Bennett Mountain Unit 1
Langley Gulch Unit 1
Bridger Units 1-4
IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 12
b. For new resource selections, the following are designated to meet regulation
reserve requirements:
Reciprocating Engines
Batteries
Small Modular Nuclear Reactors
Hydro Pumped Storage
Single-Cycle Combustion Turbines
Combined-Cycle Combustion Turbine
New resources are selected through the Long-Term Capacity Expansion ("LTCE")
process. The LTCE process ensures a minimum planning margin of 15 percent is met
for ldaho Power's system; therefore, resources can meet demand. If additional regulation
reserve requirements are imposed on the portfolio through future resource buildouts, the
model identifies and builds resources that are designated to meet regulation
requirements.
The response to this Request is sponsored by Jared Hansen, Resource Planning
Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 13
REQUEST NO. 102: Page 104 of the Company's Second Amended lRP states,
"The AURORA portfolio development process is more precise in using the defined
resource characteristics and established quantitative requirements associated with those
resources. Examples include increasing regulation requirements with solar generation
additions or maintaining a peak hour planning margin and applying hourly regulating
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.
RESPONSE TO REQUEST NO. 102: The design of the Long-Term Capacity
Expansion ('LTCE') buildouts starting on page 46 of the Second Amended 2019 IRP
Technical Appendix illustrate how economics and regulation requirements are applied.
For example, on paoe 47, Portfolio 14 (Planning Gas - Planning Carbon) buildout
includes: 600 megawatts of gas, 320 megawatts of solar, 80 megawatts of batteries and
45 megawatts of demand response to meet the planning margin, as well as the regulation
requirements for that scenario. When the scenario is adjusted as shown on paqe 57,
Portfolio 2a (High Gas - High Carbon) buildout includes: 1,200 megawatts of wind, 1,045
megawatts of solar, 80 megawatts of batteries, 500 megawatts of pumped storage and
30 megawatts of biomass. Both portfolios build resources to meet the planning margin,
as well as resources that are designated to meet regulation reserye requirements;
however, Portfolio 24 selected pumped storage which is better suited to the High Gas -
High Carbon scenario. lt is also worth mentioning that the first Combined-Cycle
Combustion Turbine ("CCCT") and the pumped hydro storage are built when the final
IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION
REOUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 14
Bridger unit is exited, for which the timing is different between the two portfolios. This
demonstrates that a capacity resource was needed, as well as a resource that can provide
regulation reserye requirements. Other examples are available throughout the LTCE
buildouts.
The response to this Request is sponsored by Jared Hansen, Resource Planning
Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY. 15
REQUEST NO. 103: Please explain if a regulation reserve shortfall can cause
loss of load. lf so, please explain if there is a way to quantiff loss of Ioad caused by
regulation reserye shortfal!.
RESPONSE TO REQUEST NO. 103: A regulation reserve shortfall cannot cause
a loss of load event. A loss of load event occurs when demand exceeds supply.
The response to this Request is sponsored by Jared Hansen, Resource Planning
Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 16
REQUEST NO. 104: !n its response to Staffs Production Request No. 62, the
Company states, "The Overarching goa! of Step lV 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.
RESPONSE TO REQUEST NO. 104:
1. The specific functions validated during the 2019 IRP Review are listed as the
subheadinqs to Section 5 in the 2019 IRP Review Report.
2. Detailing the specific tests conducted and the results and conclusions are the
primary purpose of Section 5 and Section 6 of the 2019 IRP Review Report.
The response to this Request is sponsored by Jared Hansen, Resource Planning
Leader, ldaho Power Company.
DATED at Boise, ldaho, this 28th day of December 2020.
X*!.(,,*+r-*,
LISA D. NORDSTROM
Attorney for ldaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 17
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 28th day of December 2020,1 served a true and
correct copy of IDAHO POWER COMPANY'S RESPONSE To THE FOURTH
PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER
COMPANY 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 Blvd., Bldg. No. 8,
Suite 201-A(83714)
PO Box 83720
Boise, lD 83720-0074
ldaHydro
C. Tom Arkoosh
ARKOOSH LAW OFFICES
802 W. Bannock Street, Suite LP 103
P.O. Box 2900
Boise, lD 83701
ldaho Conservation League
Benjamin J. Otto
ldaho Conservation League
710 N. 6th Street
Boise, lD 83702
STOP B2H Coalition
Jack Van Valkenburgh
Van Valkenburg Law, PLLC
P.O. Box 531
Boise, lD 83701
Jim Kreider
STOP B2H Coalition
60366 Marvin Road
La Grande, OR 97850
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stacie rkoosh.com
erin.ceci l@a rkoosh.com
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IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 18
ldaho Sierra Club
Julian Aris, Associate Attorney
Gloria D. Smith
Sierra Club
2101 Webster Street, Suite 1300
Oakland, CA 94612
lndustrial Customers of ldaho Power
Peter J. Richardson
RICHARDSON ADAMS, PLLC
515 N.27th Street
P.O. Box 7218
Boise, lD 83702
Dr. Don Reading
6070 Hill Road
Boise, lD 83703
Micron Technology, lnc.
Austin Rueschhoff
Thorvald A. Nelson
Holland & Hart, LLP
555 17th Street, Suite 3200
Denver, CO 80202
Jim Swier
Micron Technology, lnc.
8000 South Federal Way
Boise, lD 83707
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tnelson@hol dhart.com
aclee@ holland hart.com
oloaroa noamari @ hol land hart. com
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Stephanie L. Buckner
IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY. 19
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
GASE NO. IPC-E-I9-19
IDAHO POWER COMPANY
ATTACHMENT TO REQUEST NO. 98
(EXCEL SPREADSHEET ATTACHED TO EMA|LI
ro
IDAHO POWER COMPANY'S RESPONSE TO THE
FOURTH PRODUCTION REQUEST OF THE
COMMISSION STAFF