20200625Staff 13-28 to IPC.pdf

DAYN HARDIE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720.007 4
(208) 334-03t2
IDAHO BAR NO. 99I7
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Street Address fbr Express Mail:
1I33I W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, ID 83714
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF TDAHO POWER
COMPANY'S APPLICATION FOR A
DETERMINATION OF 2OT9 DEMAND-SIDE
MANAGEMENT EXPENSES AS PRUDENTLY
INCURRED
CASE NO. IPC-E-20-15
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,
Dayn Hardie, Deputy Attorney General, requests that Idaho Power Company provide the
follor,r,ing documents and information as soon as possible. but no later than THURSDAY,
JULY 16,2020.
This Production Request is to be considered as continuing, and Idaho Power 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 or inlbrmation
produced.
Please provide answers to each question, supporting workpapcrs that provide dctail or are
the source of information used in calculations, and the name, job title. and telephone number of
THIRD PRODUCTION REQUEST'
TO IDAHO POWER
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JLINE 25,2020
the person preparing the documents. Please also identify the name, job title, location, and
telephone number of the record holder.
In addition to the written copies provided as response to the requests, please provide all
Excel spreadsheets and electronic files on CD with formulas intact and enabled.
REQUEST NO. 13: Please provide the Company's calculations supporting the $1 1.5
million Program Cost with a breakdown by Demand Response (DR) progranr.
REQUEST NO. 14: Please explain the methodology and provide workpapers by DR
program fbr the Company's calculations suppo(ing the $19.8 million Value of Demand amounts
based on the fuI|60-hour dispatch relbrenced in paragraph l6 on page 8 of the Application. In
addition, please provide:
a. the calculation of the Value ol'Demand based on the 2019 Amended Integrated
Resource Plan; and
b. the calculation based on actual hours of avoided demand and energy savings seen in
2019 for each of the three DR programs.
REQUEST NO. 15: Does the Value of Demand amount consider the differences in how
DR programs are implemented compared to the capacity factor of a 170 MW Simple-Cycle
Combustion Turbine (SCCT) assumed in the 2019 Amended Integrated Resource Plan? If so,
please explain how. If not, pleasc explain why not.
REQUEST NO. l6: Does the Value of Demand calculation include the avoided cost of
energy? If so, is it based on the amount of DR MWh savings fbr an equivalent amount of
generation fiom a 170 MW SCCT? Please explain and show all calculations.
REQUEST NO. 17: For 2019. please provide the following by event when implemented
for each DR program:
a. the date and time the event was initiated:
b. the amount ofenergy saved in each event hour;
c. the value ofenergy saved in each event hour: and
d. the corresponding market price ofenergy for each event hour
THIRD PRODUCTION REQUEST
TO TDAHO POWER 2 .TIJNE 25,2020
REQUEST No. 18: For each of the company's sccr gas plants, please provide the
following:
a. the hourly dispatch by plant for each of the resources during the times that DR
programs were unavailable due to tariff constraints for each year from 2014 through
May 2020;
b. the hourly dispatch by plant for each of the resources during the times that DR
programs were available for each year from 2014 through May 2020; andc. the hourly dispatch by plant for each of the Company's SCCT resources during the
times that DR programs were utilized for each year from 2014 throughMay 2020.
REQUEST NO. l9: Substituting an eight-hour Li-lon battery included as a potential
resource for selection in the Amended 2019 IRP for the 170 MW SCCT, please provide the
Company's Value of Demand amount based on the full 60-hour dispatch referenced in paragraph
l6 on page 8 of the Application for each DR program. Please provide all calculations in Excel
format with fonnulas intact and enabled.
REQUEST NO.20: Please explain why the Company does not use DR programs to its
fullest extent, compared to just implementing the three events for each program in 2019 as
required by Commission Order No. 32923.
REQUEST NO. 21: Please provide the number of daily DR events dispatched by DR
program for each year from 2012 through 2018.
REQUEST NO. 22: Is the SCCT avoided cost value adjusted for the inability of DR to
provide Contingent Reserve Obligations (CRO) identified in the study "Demand Response as
Operating Reserves Feasibility Report" dated 09/30i l4? Please explain.
REQUEST NO. 23: Please provide an estimate for the value of CRO that can be
provided by an SCCT. Please include the basis used to provide the estimate and all calculations
in Excel format with formula intact and enabled.
THIRD PRODUCTION REQUEST
TO IDAHO POWER J JLINE 25,2020
REQUEST NO. 24: For January 2012 through May 2020, please provide the actual
monthly peak-hour loads. For each peak hour, please provide:
a. the actual peak-hour supply by resource type (excluding DR),
b. the actual monthly peak-hour supply provided by DR, and,c. indicate whether there was an expected peak-hour deficit.
REQUEST NO. 25: Please provide the following information based on the 2019
Amended Integrated Resource Plan:
a. the forecast monthly peak-hour loads;
b. the forecast monthly peak-hour supply by resource type (excluding DR);
c. the forecast monthly peak-hour supply attributed to DR; and
d. indicate whether there is a peak hour deficit.
REQUEST NO. 26: Does the Value of Demand based on the 170 MW SCCT identified
in the Settlement Agreement in IPC-E-13-14 still represent the most appropriate resource to
determine the avoided cost for the Company's DR programs? Order No. 32923 at 4. If so,
please explain why; if not, please explain why not.
REQUEST NO. 27: For each of the DR programs since 2004 please provide
a. the hourly peak Ioad reductions in MW's by year;
b. the average hourly load reductions in MW's by year; and
c. the number of demand response hours implemented.
REQUEST NO. 28: For each DR event over the past 5 years, how many MW of load
reduction were requested from the participants and how many of megawatts of load were
actually curtailed? Please provide a breakdown by DR program.
THIRD PRODUCTION REQUEST
TO IDAHO POWER 4 JUNE 25,2020
IlstADATED at Boise,Idaho, this day of Jrme 2020.
Hardie
Deputy
i:umisc:prodreq/ipcc20.l5dhrk prcd rcq 2
THIRD PRODUCTION REQUEST
TO IDAHO POWER 5 JUNE 25,2020
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 25TH DAY OF JLINE 2020, SERVED
THE FOREGOING THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF
TO IDAHO POWER COMPANY, IN CASE NO. IPC-E-20-15, BY E.MAILING A COPY
THEREOF, TO THE FOLLOWTNG:
LISA D NORDSTROM
IDAHO POWER COMPANY
PO BOX 70
BOrSE ID 83707-0070
E-mail : [e-mail]
[e-mail]
ERIC L OLSEN
ECHO HAWK & OLSEN PLLC
505 PERSHING AVE, SUITE IOO
PO BOX 6l 19
POCATELLO ID 83205
E-rnai I : elo(rDechohawk. corn
PETER J zuCIIARDSON
RICHARDSON ADAMS PI.LC
5I5 N 27T}{ STREET
PO BOX 721 8
BOISE ID 83702
E-mail: peter:(Erichardsonadams.com
BENJAMIN J OTTO
IDAHO CONSERVATION LEAGUE
TION6THSTREET
BOISE ID 83702
E-mail: [e-mail]
CONNIE ASCHENBRENNER
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-mail : [e-mail]
ANTHONY YANKEL
I27AO LAKE AVE, LINIT 2505
LAKEWOOD OH 44107
E-mail: tony(riyankel.net
DR DON READING
6070 HILL ROAD
BOISE ID 83703
E-mail: [e-mail]
ABIGAIL R GERMAINE
DEPUTY CITY ATTORNEY
BOISE CITY ATTORNEY'S OFFICE
I05 N CAPITAL BLVD
PO BOX 500
BOISE ID 83701-0500
E-mail : [e-mail]
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SECRETARV-
CERTIFICATE OF SERVICE