20190822Staff 2-9 to IPC.pdf

EDWARD JEWELL
DEPUTY ATTORNEYS GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 10446
RECEIVED
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Street Address for Express Mail
412W, WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR
APPROVAL OF THE CAPACITY
DEFICIENCY TO BE UTILIZED FOR
AVOIDED COST CALCULATIONS.
CASE NO. IPC-E-19-20
SECOND 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 (Company) provide
the following documents and information as soon as possible, or by THURSDAY,
SEPTEMBER 12, 2019.
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.
SECOND PRODUCTION REQUEST
TO IDAHO POWER
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1 AUGUST 22,2019
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. 2: Please list and describe major causes (e.g. a change from 95th percentile
to 50th percentile, a l5 percent peak-hour planning margin, load growth, etc.) for the difference in
load used to develop the capacity deficiency period between the IPC-E-17-12 and the current filing.
Please quantify each cause.
REQUEST NO.3: Page 90 of the 2019 IRP states "... Idaho Power compared the2017
IRP's 95th percentile peak-hour capacity, including the addition of 330 MW of capacity benefit
margin (CBM) to the 50th percentile peak-hour forecast with a 15 percent planning margin being
used in the 2019 IRP...the two methods do not result in significant differences." Please provide the
following:
a. Please define and explain "capacity benefit margin." What is the source of this
capacity, and how was it determined/calculated?
b. Please explain why adding 330 MW of CBM to the 50th percentile 2017 IRP forecast
is a good comparison to the 2019 IRP 50th percentile forecast plus a l5% planning
margin.
REQUEST NO. 4: Staff calculated the average of Cogeneration and Small Power
Production (CSPP) capacity for 2026,2027,2028, and2029, using 2017 IRP data and 2019 IRP
data, respectively. The 2019 IRP average is about 108 MW higher. Please identify major causes
for the increase and quantify each cause.
REQUEST NO. 5: Referring to the electronic workpapers provided by Idaho Power to
calculate capacity deficiency in Case No. IPC-E-17-12, the Company included "Transmission
Capacity Available for Market Purchases" to determine peak capacity. This was changed to
"Market Purchases" in this year's filing. Please answer the following questions:
a. How are these terms defined and are they equivalent? Please explain.
b. Staff calculated the average of Transmission Capacity Available for Market
Purchases for 2026,2027 ,2028, and 2029 using the 2017 IRP data and the 2019 IRP
SECOND PRODUCTION REQUEST
TO IDAHO POWER AUGUST 22,20192
data, respectively. The 2019 IRP average is about 356 MW higher. Please identify
major causes for the increase and quantify each cause.
REQUEST NO. 6: Please explain why the month with the largest deficit shifted to August
in the current filing from July in Case No. IPC-E-17-12.
REQUEST NO. 7: What is the justification and specific criteria Idaho Power uses to
decide whether or not to include future changes to the set of existing resources, such as early
retirements and additions of new resources, in the load and resource balance used to calculate the
deficiency period? In addition, how are these decisions made and who is responsible for making
these decisions?
REQUEST NO. 8: What specific resources are included in the ooNew Resource-Solar"
category in Attachment 1 of the Company's Application? How are they determined/calculated?
Please explain why there is zero-peak contribution during winter months from these solar
resources?
REQUEST NO. 9: Please explain why Total Coal in year 2029 changed from 527 MW in
Case No. IPC-E-I7-12 to 703 MW in the current filing?
,aDATED at Boise, Idaho, this day of August 2019.
Edward J
Deputy
i :umisc:prodreq/ipce I 9.20ejyy prod req2
SECOND PRODUCTION REQUEST
TO IDAHO POWER J AUGUST 22,2019
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 22"d DAY OF AUGUST
2019, SERVED THE FOREGOING SECOND PRODUCTTON REQUEST OF
THE COMMISSION STAFF TO IDAHO POWER COMPANY, IN CASE
NO. IPC.E-19-20, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO
THE FOLLOWNG:
DONOVAN WALKER
REGULATORY DOCKETS
IDAHO POWER COMPANY
PO BOX 70
BOrSE rD 83707-0070
E-mail : dwalker@idahopower. com
[e-mail]
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
710 N 6TH ST
BOISE ID 83702
E-mail: [e-mail]
C TOM ARKOOSH
ARKOOSH LAW OFFICES
PO BOX 2900
BOISE ID 83701
E-mail : [e-mail]
erin. cecil@arkoo sh. com
S AR
CERTIFICATE OF SERVICE
MICHAEL DARRINGTON
ENERGY CONTRACTS LEADER
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-mail: [e-mail]
ener gycontracts@ idahopower. com