20210503Staff 1-12 to IPC.pdf

MATT HUNTER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 10655
Street Address for Express Mail:
1 133I W CHINDEN BVLD, BLDG 8, SUITE 201-A
BOISE, ID 83714
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-21.09
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
IDAHO POWER COMPANY
The Staff of the Idaho Public Utilities Commission requests that Idaho Power Company
(Idaho Power; Company) provide the following documents and information as soon as possible,
by MONDAY, MAY 24,2021.
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
31.0r.01.228.
FIRST PRODUCTION REQUEST
TO IDAHO POWER
)
)
)
)
)
)
)
)
I MAY 3,2021
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. 1: Please provide Attachment 1 in Excel format with all formulae
intact.
REQUEST NO.2: Please describe what is included in "Existing EE" in the Load and
Resource Balance and whether it includes all cost-effective EE yet to be implemented or if it
only includes EE already implemented. Please provide the source of the data.
REQUEST NO.3: Please define "non-forecasted trended EE" and explain why its value
is zero throughout the IRP planning horizon. Please provide the source of the data.
REQUEST NO. 4: Please provide the exit dates assumed for each unit of the Bridger
coal plant and for Valmy Unit #2 and explain the basis that was used for determining the dates
REQUEST NO. 5: Please provide the amount of market purchases that are assumed
from the Southwest Transmission Pathway associated with the retirement of the Valmy coal
plant? Please provide rationale for the assumptions and explain how the assumptions are
reflected in the Load and Resource Balance.
REQUEST NO. 6: Please explain how the amount of deficit or surplus is determined in
the Load and Resource Balance, especially with respect to the resolution of time. In addition,
please answer the following:
a. Are all hours examined or are there set times of the day that are examined for each
month? Please explain.
b. If all hours are examined, how is the information converted to monthly data?
c. Does the contribution at peak for different resources use the same time periods as
above? Please explain.
d. What data is used to determine the contribution of peak for wind and solar in the
Load and Resource Balance?
FIRST PRODUCTION REQUEST
TO IDAHO POWER 2 MAY 3,2027
Please explain why PURPA solar capacity is zero in winter months (December,
January, and February).
REQUEST NO. 7: Have there been any updates to PURPA contracts, such as
terminations or additions since the development of this Load and Resource Balance in the 2019
IRP? Please list all the updates.
REQUEST NO. 8: Have there been any updates to power purchase agreements, such as
terminations or additions since the development of this Load and Resource Balance in the 2019
IRP? Please list all the updates.
REQUEST NO. 9: Please explain how Market Purchases' contribution to peak is
determined. In the explanation, please include whether market availability and transmission
capacity were considered. Also, please provide a breakdown of market availability by market
hub, if available, in Excel format with formulae intact.
REQUEST NO. l0: Does the Company have interruptible load contracts included in the
Load and Resource Balance? If so, please describe each contract. Also, please provide the
following:
a. Explain how interruptible load contracts are included in the Load and Resource
Balance.
b. Provide the amount of capacity contribution in each year.
c. Explain if intenuptible load contracts are assumed to be renewed in the Load and
Resource Balance after contract expiration.
d. Please explain whether their values were considered for load when calculating the
planning margin.
REQUEST NO. 11: Is the load forecast included in the Application the latest
information available? If not, please provide the latest load forecast and explain causes for any
difference from the amounts included in the Application. In the explanation, please include how
the latest load forecast reflects impacts of the pandemic.
FIRST PRODUCTION REQUEST
TO IDAHO POWER
e
J MAY 3,2021
REQUEST NO. 12: Please explain how net-metering generation is considered in the
Load and Resource Balance and answer the following questions.
a. How is the capacity contribution of net-metering generation determined? Please
provide workpapers that calculate the capacity contribution with formulae intact.
b. Please explain if the capacity contribution comes from both existing net-metering
customers and/or forecasted net-metering customers.
c. Are existing net-metering customers assumed to continue throughout the IRP
planning horizon once included in the Load and Resource Balance, and are the levels
of their capacity contribution expected to change over time? Please explain.
(J
DATED at Boise, Idaho, this 3 day of May 2021.
Matt Hunter
Deputy Attomey General
i:umisc:prodreq/ipce2l.9mhyy prod reql
FIRST PRODUCTION REQUEST
TO IDAHO POWER 4 MAY 3,2021
CERTIFICATE OF SERYICE
I HEREBY CERTIFY THAT I HAVE THIS 3'd DAY OF MAY 2021, SERVED
THE FOREGOING FIRST PRODUCTION REQUEST OF TIIE COMMISSION STAFF
TO IDAHO POWER COMPANIY, IN CASE NO. IPC-E-21-09, BY E-MAILING A
COPY THEREOF, TO TIIE FOLLOWING:
DONOVAN E WALKER
IDAHO POWER COMPANY
PO BOX 70
BOrSE ID 83707-0070
E-MAIL: [e-mail]
[e-mail]
MICHAEL DARRINGTON
ENERGY CONTRACTS
P.O. BOX 70
BOISE, LDAHO 83707
E-MAIL : [e-mail]
energy contracts@ idahopower. com
SECRETAR
CERTIFICATE OF SERVICE