20201119Staff 25-39 to IPC.pdf

EDWARD JEWELL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILMIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-007 4
(208) 334-03t4
IDAHO BAR NO. 10446
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Street Address for Express Mail:
11331 W CHINDEN BVLD, BLDG 8, SUITE 2OI-A
BOISE, D 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER'S
PETITION TO ESTABLISH AVOIDED COST
RATES AND TERMS FOR ENERGY
STORAGE QUALIFYING FACILITIES
UNDER PURPA
CASE NO.IPC.E.2O.O2
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 (Company) provide
the following documents and information as soon as possible, or by FRIDAY,
DECEMBER 4, 2020.r
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
I Staff is requesting an expedited response. If responding by this date will be problematic, please call Staffs attorney at
(2O8) 334-03t4.
THIRD PRODUCTION REQUEST
TO IDAHO POWER
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1 NOVEMBER 19,2020
different the witness who can sponsor the answer at hearing if need be. Reference IDApA
31.01.O1.228.
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.25: Page No. 5 of the Compliance Filing states that Table 2 presents the
Company's actual loads, net of generation by solar PURPA projects, for January through September
2020. Please answer the following questions.
a. Please explain why only solar resources are considered and why other resources such
as wind are not considered.
b. Please explain why only PURPA solar projects are considered and why non-pURpA
solar projects are not considered.
REQUEST NO. 26: Please explain whether the Company can measure the level of
variability of the energy output of a solar-powered or wind-powered energy storage eF and apply
solar or wind integration charges based on the level of variability of the type of resource.
REQUEST NO. 27: Please explain why a landfill gas or anaerobic digester baseload
resource is a reasonable benchmark resource for energy storage eF projects.
REQUEST NO.28: Please explain why a Peak Hour Capacity Factor Credit is needed to
calculate the rate when the only hours a QF is paid for capacity is during peak hours designated in
the proposal.
REQUEST NO. 29: Table 9 in the Compliance Filing shows a 30-year levelized capital cost of
$8.641kw-month and a stream of fixed O&M costs of a 170-MW, $g7g/kw Simple Cycle
Combustion Turbine (SCCT). However, Page No. 73 of the 2OI7 Integrated Resource plan (IRp)
Appendix C shows that the economic life of the SCCT is 35 years. Please answer the following
questions.
a. Please provide the workpapers used to derive Table 9 in the Compliance Filing in
Excel format with all links and formulae intact.
THIRD PRODUCTION REQUEST
TO IDAHO POWER 2 NOVEMBER 19,2020
b. Please explain why it is reasonable to use a 30-year levelized capital cost and fixed
O&M for determining the avoided capacity cost for each year instead of using the
35-year economic life of the SCCT surrogate.
c. Please provide the calculations that determined the $8.64lkW-month levelized cost.
Please provide in Excel format with all links and formulae intact.
d. Please provide the calculations (in Excel format with all links and formulae intact)
and explain how the stream of fixed O&M costs in Table 9 are calculated from the
fixed O&M of the SCCT listed on Page No. 73 of the 2017 IRP Appendix Cin2017
dollars.
e. Why does the Company use the capital cost of a SCCT surrogate in2Ol7 dollars to
determine the levelized capital cost instead of the capital investment cost for the
same surrogate resource in 2026 (first deficit year) dollars?
f. What is the levelized capital cost of an SCCT surrogate with a 35-year (economic
life) and the stream of fixed O&M costs based on an investment of the surrogate
resource occurring in the first deficit year? Please provide in Excel format with all
links and formulae intact.
REQUEST NO. 30: Please provide the calculations for the SCCT - Frame F Class (170
MW) cost of capital as shown on Page No. 76, Appendix C,2Ol7 Integrated Resource plan, 30-year
Levelized Cost of Energy in Excel format with all links and formulas intact.
REQUEST NO.31: Please describe the process and schedule that QFs and rhe Company
will follow for QFs to submit their annual revised generation profile and for the Company to update
their peak hours and capacity payment adjustments. In the description, please include the
following.
a. The time frame to update the Company's peak hours and premium peak hours for
QFs. For example, will it occur at the QF's first anniversary of the online date, the
Commission acknowledgement date of the October 15 filing, or some other date?
b. The time frame for the QF to update its generation profile.
c. The time frame for new rates to take effect.
THIRD PRODUCTION REQUEST
TO IDAHO POWER 3 NOVEMBER 19,2020
d. The specific provisions needed in future Energy Sales Agreements using the
Company's proposed method and schedules.
REQUEST NO.32: Page No. 3 of the Compliance Filing states that the month/hours
representing the highest five percent of estimated average load are highlighted in the two boxes in
Table 1. Is the highest five percent identified by sorting all the numbers in Table 1 from highest to
lowest. If not, please describe the method. Please provide workpapers in Excel format with
formulas intact demonstrating the method used.
REQUEST NO. 33: Page No. 6 of the Compliance Filing states that the data in Table 3
suggests a moderate correlation between LOLP and peak load hours. Please quantify the correlation
and explain why a moderate level is acceptable.
REQUEST NO. 34: Similar to the format of Table 2 inthe Compliance Filing, please
provide the total actual load, the amount of actual solar generation, and the amount of actual wind
generation as separate tables for each year from 2017 through2O2O in Excel format with all
formulas intact.
REQUEST NO.35: Please provide the average Idaho Power Locational Marginal pricing
(LMP) for years 2018 and 2019, similar to that provided in Table 3 of the Compliance Filing in
Excel format with all formulas intact.
REQUEST NO.36: On page No. 4 of the Application, the Company identified three
metrics to identify hours that are most important for output from a battery storage unit to be
deployed: load net of solar, loss of load probability and locational marginal pricing from the energy
imbalance market. Please provide detail on how the differing results (i.e., identification of most
important hours) from these metrics were combined to yield a single proposed set of peak hours and
premium peak hours.
REQUEST NO.37: In determining the peak hours based on load data shown in Table 1 of
the Compliance Filing, did the Company consider the variance of the actual hourly loads over the
THIRD PRODUCTION REQUEST
TO IDAHO POWER NOVEMBER 19,20204
days of each month? For example, when the Company put a box around hours 14 tfuough 22 in
July to designate core peak hours, did it consider the load variance over the 31 days of the month
for each of those hours inside of the box (peak hours) compared to the load variance for hours
outside of the box (non-peak hours). Please explain.
REQUEST NO.38: Please explain how the Company determined the proposed rate
differential of l2o7o between core peak hours and the premium peak hours. Please provide all
workpapers used to justify the premium in Excel format with all formula intact.
REQUEST NO.39: Please provide a rate proof comparing expected total capacity
payments to QF's. The rate proof should include expected MWh by time-of-day period, using
proposed peak period definitions for July and August, and the payment rate per IVMh. please
provide this rate proof for each of the following in Excel format with all formula intact:
a. under the current payment structure (with capacity payments over all hours), and
b. under the proposed structure with a l20Vo differential between core peak hours and
premium peak hours (with no capacity payments in the off-peak hours).
DATED at Boise,Idaho, this lvaalof Novemb er 2020.
\
[rr Edward J
Deputy Attorney General
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THIRD PRODUCTION REQUEST
TO IDAHO POWER 5 NOVEMBER 19,2020
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS lgth DAY oF NOVEMBER 2020,
SERVED THE FOREGOING THIRD PRODUCTION REQUEST OF THE
COMMISSTON STAFF TO IDAHO POWER COMPANY, rN CASE NO. IPC-E-20-02,BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
DONOVAN E WALKER
REGULATORY DOCKETS
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: dwalker@ .com
dockets @ idahopower.com
Y
CERTIFICATE OF SERVICE