20200803IPC to Staff 2nd Partial Response.pdf

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LISA D, NOROSTROII
Laad Counr.l
lnordatromaldahomu.r.cottl
August 3, 2020
ELECTROiIIC FILII{G
Jan Noriyuki, Secretary
ldaho Public Utilities Commission
11331 W. Chinden Boulevad
Building 8, Suite 201-A
Boise, ldaho 83714
Re Case No. IPC-E-2(}.15
2019 Demand-Side Management Erpenses - ldaho Power Gompeny's
Second Partial Response to the Third Produclion Request of the
Commission Staff
Dear Ms. Noripki:
Attached for eleclronic filing is ldaho Power Company's Second Partial Response to
the Third Prcduction Request of the Commission Staff, responding to questions 16, 18, 23,
24, 25 and 27. ll you have any questions about the attached document, please do not
hesitate to contact me.
Very truly yours,
,€; PY"t"+".^,
Liea D. Nordetrom
LDN:slb
Attachment
LISA D. NoRDSTROM (lSB No. 5733)
ldaho Power Company
1221 West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: (208) 388S936
lnordstrom@idahopower. com
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR A
DETERMINATION OF 2018 DEMAND-
SIDE MANAGEMENT EXPENSES AS
PRUDENTLY INCURRED
cAsE NO. |PC-E-20-15
IDAHO POWER COMPANY'S
SECOND PARTIAL RESPONSE
TO THE THIRD PRODUCTION
REQUEST OF THE COMMISSION
STAFF
COMES NOW, ldaho Power Company, and in response to the Third Production
Request of the CommisEion Staff to ldaho Power Company ("ldaho Power" or
"Company'') dated June 25, 2020, herewith submits the following information to
Requests 16, 18, 23, 24, 25 and 27.
IDAHO POWER COMPANY'S SECOND PARTIAL RESPONSE TO THE THIRD
PRODUCTION REQUEST OF THE COMMISSION STAFF - I
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REQUEST NO. 16: Does the Value of Demand calculation include the avoided
cost of energy? lf so, is it based on the amount of DR MWh savings for an equivalent
amount of generation from a 170 fuI\ / SCCT? Please explain and show all calculations.
RESPONSE TO REQUEST NO. 16:
The Value of Demand Response determined during the settlement workshops in
Case No. IPC-E-13-14 does not include a value for avoided cost of energy, it instead
includes "the conesponding deferred energy savings"l shifted, which is the differential
value of energy that the demand response programs could shift from an on-peak time to
an off-peak time. The deferred energy savings calculation is based on the capacity of
the demand response programs multiplied by the maximum 60 hours of program use
and then multiplied by 2 cents per kwh, which represents the differential between on-
and off-peak energy values.
The response to this Request is sponsored by Quentin Nesbitt, Customer
Research &Analysis Leader, ldaho Power Gompany.
I Case No. tPC E-13-14 Settlement Agreement p.3
IDAHO POWER COMPANY'S SECOND PARTIAL RESPONSE TO THE THIRO
PRODUCTION REOUEST OF THE COMMISSION STAFF.2
REOUEST NO. 18: Foreach of the Company's SCCT gas plants, please
provide the following:
the hourly dispatch by plant for each of the resour@s during the times that
DR programs were unavailable due to tariff constraints for each year from
2014 through May 2020;
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;
and
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 through May 2O20.
RESPONSE TO REQUEST NO. 18: Please see the confidential attachment
provided for this response.
The response to this Request is sponsored by Perry Kerfoot, Day Ahead
Balancing Operations Leader, ldaho Power Company.
IDAHO POWER COMPANY'S SECOND PARTIAL RESPONSE TO THE THIRD
PROOUCTION REQUEST OF THE COMMISSION STAFF - 3
a
b
c
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.
RESPONSE TO EST NO. 23:While the requested analysis to quantifo
the value of a CRO has not been performed, the Company can readily provide the
amount of Contingency Reserves Obligation CCRO) that could be provided by ldaho
Power's simple cycle combustion turbine ("SCCT") generation plants Bennet Mountain
and Danskin. The total amount of CRO would be a total of 190 MW if all plants were
running. The breakdown of the 190 MW is reflected below.
r Bennett Mountain - Bennett Mountain can ramp at 7 MW per minute and
its maximum CRO contribution would be 70 MW.
. Danskin 1 - Danskin 1 can ramp at 7 MW per minute and its maximum
CRO contribution would be 70 MW.
o Danskin 2 - Danskin 2 can ramp at 2.5 MW per minute and its maximum
CRO contribution would be 25 MW.
. Danskin 3 - Danskin 3 can ramp at 2.5 MW per minute and its maximum
CRO contribution would be 25 MW.
The response to this Request is sponsored by Perry Kerfoot, DayAhead
Balancing Operations Leader, ldaho Power Company.
IDAHO POWER COMPANY'S SECOND PARTIAL RESPONSE TO THE THIRD
PRODUCTION REQUEST OF THE COMMISSION STAFF . 4
REOUEST NO. 24: For Janua ry 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 suppty provided by DR, and,
c. indicate whether there was an expected peak-hour deficit.
RESPONSE TO REQUEST NO. 24: Please see the confidential attachment
provided for this response. ln response to 24c, there have been no instances of deficits
during the timespan reflected above net of market sales and purchases.
The response to this Request is sponsored by Jordan Prassinos Manager Load
Research and Forecasting, ldaho Power Company.
IDAHO POWER COMPANY'S SECOND PARTIAL RESPONSE TO THE THIRD
PRODUCTION REOUEST OF THE COMMISSION STAFF. S
REQUEST NO. 25: Please provide the follorying information based on the
2019 Amended lntegrated Resource Plan
the forecast monthly peak-hour loads;
the forecast monthly peak-hour supply by resource type (excluding
DR);
the forecast monthly peak-hour supply attributed to DR; and
indicate whether there is a peak hour deficit.
REOUEST NO, 25
a. Please see the attiachment provided for this response.
b. The requested information is unavailable. ln order to determine what
resources or market purchases are meeting the peak hour demand for each month, an
hourly output file is required. While ldaho Power performed an hourly Aurora simulation
for each portfolio for the 2019 lRP, the "output format'for each simulation in the 2019
IRP included a monthly and an annual oulput, but not hourly.
c. ldaho Power models a demand response event in June, July and August
that coincide with the peak hour in each month. The forecasted contribution to peak in
the 2019 Amended IRP for June and July was 390 megawatts, and 337 megawatts for
August.
d. The amount of DR specified in response C is equal to the peak hour deficit
for each of the summer months.
The response to this Request is sponsored by Jordan Prassinos, Manager Load
Research and Forecasting, ldaho Power Company.
IDAHO POWER COMPANY'S SECOND PARTIAL RESPONSE TO THE THIRD
PRODUCTION REQUEST OF THE COMMISSION STAFF.6
a
b
c
d
RESPONSE TO
REQUEST NO.27: Foreach ofthe DR programs since 20O4 please
provide
the hourly peak load reductions in MW's by year;
the average hourly load reductions in MWs by year; and
the number of demand response hours implemented.
RESPONSE TO REQUEST NO. 27: Please see the attachment provided for this
response.
The response to this Request is sponsored by Quentin Nesbitt, Customer
Research & Analysis Leader, ldaho Power Company.
DATED at Boise, ldaho, this 3d day of August 2020.
a
b
c
"(* !.Y"*t**-
LISA D. NORDSTROM
Attorney for ldaho Power Company
IDAHO POWER COMPANY'S SECOND PARTIAL RESPONSE TO THE THIRD
PRODUCTION REQUEST OF THE COMMISSION STAFF - 7
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 3d day of August 2020, I sarved a true and
correct copy of IDAHO POWER COMPANY'S SECOND PARTLqL RESPONSE TO
THE THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF upon the
following named parties by the method indicated below, and addressed to the folloring:
Commission Staff
Dayn Hardie
Deputy Attomey General
ldaho Public Utilities Commission
11331 W. Chinden Boulevard
Building 8, Suite 20'l-A
Boise, ldaho 83714
ldaho !rrigalion Pumpere Associaton, lnc.
Eric L. Olsen
ECHO HAWK & OLSEN, PLLC
505 Pershing Avenue, Suite 100
P.O. Box 61't9
Pocatello, ldaho 83205
Anthony Yankel
12700 Lake Avenue, Unit 2505
Lakewood, Ohio 44107
lndustrial Customec of ldaho Power
Peter J. Richardson
RICHARDSON ADAMS, PLLC
515 North 27h Street (83702)
P.O. Box 7218
Boise, ldaho 83707
Dr. Don Reading
6070 Hill Road
Boise, ldaho 83703
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IDAHO POWER COMPANY'S SECOND PARTIAL RESPONSE TO THE THIRD
PRODUCTION REOUEST OF THE COMMISSION STAFF. S
ldeho Conoervation League
Benjamin J. Otto
ldaho Conservation League
710 North 6ft Street
Boise, ldaho 83702
GIty of Bolee
Abigail R. Germaine
Deputy City Attorney
Boise City Attorney's Office
150 North Capitol Boulevard
P.O. Box 500
Boise, ldaho 83701-0500
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Stephanie L. Buckner
Ex6cutive Assistant
IDAHO POWER COMPANY'S SECOND PARTIAL RESPONSE TO THE THIRO
PRODUCTION REQUEST OF THE COMMISSION STAFF . 9