20210625IPC to Staff 24-26.pdf

DONOVAN E. WALKER
Lead Counsel
[e-mail]

June 25, 2021

VIA ELECTRONIC MAIL

Jan Noriyuki, Secretary
Idaho Public Utilities Commission
11331 West Chinden Blvd., Building 8
Suite 201-A
Boise, Idaho 83714

Re: Case No. IPC-E-21-09
Idaho Power Company’s Application for Capacity Deficiency To Be Utilized
For Avoided Cost Calculations

Dear Ms. Noriyuki:

Attached for electronic filing is Idaho Power Company’s Response to the Fourth
Production Requests of the Commission Staff in the above entitled matter.

Please handle the confidential information in accordance with the Protective
Agreement executed in this matter.

If you have any questions about the attached documents, please do not hesitate
to contact me.

Very truly yours,
Donovan E. Walker

DEW:cld
Enclosures
RECEIVED
2021June 25, PM 2:15
IDAHO PUBLIC
UTILITIES COMMISSION

IDAHO POWER COMPANY’S RESPONSE TO THE FOURTH PRODUCTION REQUESTS OF THE
COMMISSION STAFF - 1
DONOVAN E. WALKER (ISB No. 5921)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
[e-mail]

Attorney for Idaho Power Company

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.
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CASE NO. IPC-E-21-09

IDAHO POWER COMPANY’S
RESPONSE TO THE FOURTH
PRODUCTION REQUEST OF
THE COMMISSION STAFF

COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), and in
response to the Fourth Production Request of the Commission Staff to Idaho Power
Company dated June 22, 2021, herewith submits the following information:

IDAHO POWER COMPANY’S RESPONSE TO THE FOURTH PRODUCTION REQUESTS OF THE
COMMISSION STAFF - 2
REQUEST NO. 24: Response to Staff’s Request No. 16 contains the proposed
load forecast in the L&R in an annual format. Response to Staff’s Request No. 11
contains the latest forecast in an annual format. Comparing the two forecasts, the table
below shows the latest load forecast is greater than the proposed load forecast in the
Application. However, Response to Staff’s Request No. 16 states that the first deficit date
will change to July 2029 if all variables are held constant except for using the latest load.
Please explain why the updated first deficit date is later than the originally proposed first
deficit date of August 2028, when the new load is greater. Please verify that the forecast
used to determine the July 2029 deficit date in response to Production Request No. 16
uses the latest load forecast using 50th percentile loads.

RESPONSE TO REQUEST NO. 24: The load forecast submitted in response to
Staff Request No. 11 was 90th percentile peak loads. For load and resource balance
calculations to determine the first deficit date, Idaho Power utilizes 50th percentile peak
loads. The load forecast provided in the Company’s response to Staff Request No. 16
and used in the Company’s Application in this case is slightly lower than the 2019 IRP
forecast, resulting in a later (July 2029) deficit date.
The response to this Request is sponsored by Jared Hansen, Resource Planning
Leader, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FOURTH PRODUCTION REQUESTS OF THE
COMMISSION STAFF - 3
REQUEST NO. 25: Please provide both the forecast included in the Application
and the latest forecast using 50th percentile peak loads in annual format from 2021
through 2040 and the resulting first deficit date due to the change in the forecast.
RESPONSE TO REQUEST NO. 25: Please see the CONFIDENTIAL Excel
spreadsheet accompanying this request, which contains the sales and load forecast that
was included in the Application in this case, as well as the most current sales and load
forecast that was produced in March of 2021. Both forecasts are in 50th percentile energy
and peak format and summarized by year. The resulting deficiency date due to a changed
load forecast (and holding all other factors constant) remains July 2029, consistent with
the date given in the Company’s response to Staff Request No. 16.
The response to this Request is sponsored by Jared Hansen, Resource Planning
Leader of Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FOURTH PRODUCTION REQUESTS OF THE
COMMISSION STAFF - 4
REQUEST NO. 26: Response to Staff’s Production Request No. 15 states that
generation from Valmy could be replaced by market purchases from Southern market
hubs. However, the amount of transmission capacity needs to change from 130 MW to
50 MW. Comparing the updated L&R in this response and the proposed L&R in the
Application, Staff identifies that the difference between the two Market Purchase items
in both L&Rs is approximately 310 MW, which is much greater than 80 MW (130 MW
minus 50 MW). See example below. Please explain in detail the additional adjustments
the Company has made to Market Purchases in addition to the 80 MW reduction.
Market Purchases July
2025
August
2025
July
2026
August
2026
Proposed L&R
1054 MW

1079 MW

1054 MW

1078 MW
Response to Production
Request No. 15

744 MW

769 MW

744 MW

768 MW

RESPONSE TO REQUEST NO. 26: The second amended 2019 IRP assumed
that 131 MW of transmission would be made available for each North Valmy unit exit and
that recent upgrades (increased line wavetrap ratings) would increase the Humboldt (NV
Energy) to Midpoint 345 kV capability by 98 MW. The total of these assumptions is the
360 MW south-to-north capability of the Sierra (NV Energy) to Idaho transmission path
following exit of each North Valmy unit (131 MW + 131 MW + 98 MW = 360 MW).
Recently, the Company determined that firm transmission is not available from
southern market hubs to North Valmy through the NV Energy system. Additional firm
south-to-north transmission is also not available on the PacifiCorp East transmission path
through Utah to Idaho.

IDAHO POWER COMPANY’S RESPONSE TO THE FOURTH PRODUCTION REQUESTS OF THE
COMMISSION STAFF - 5
Given the lack of firm and available transmission, the southern transmission
capacity assumption for market purchases was reduced from 360 MW to 50 MW total.
Idaho Power holds the 50 MW from an existing Transmission Service Reservation on the
PacifiCorp East system from Red Butte to Borah. Red Butte is near the Mead trading
hub, and firm transmission is available from Mead to Red Butte. The total southern
transmission assumption has been reduced by 310 MW (360 MW minus 50 MW).
The response to this Request is sponsored by Jared Hansen, Resource Planning
Leader, Idaho Power Company.

Respectfully submitted this 25th day of June 2021.

DONOVAN E. WALKER
Attorney for Idaho Power Company

IDAHO POWER COMPANY’S RESPONSE TO THE FOURTH PRODUCTION REQUESTS OF THE
COMMISSION STAFF - 6
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on this 25th day of June 2021, I served a true and correct
copy of the within and foregoing IDAHO POWER COMPANY’S RESPONSE TO THE
FOURTH PRODUCTION REQUESTS OF THE COMMISSION STAFF upon the following
named parties by the method indicated below, and addressed to the following:

Matt Hunter
Deputy Attorney General
Idaho Public Utilities Commission
Po Box 83720
Boise, Idaho 83720-0074

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