20220225Staff 29-34 to IPC.pdf

DAYN HARDIE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 9917
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Street Address for Express Mail:
I I331 W CHINDEN BVLD, BLDG 8, SUITE 2OI-A
BOISE, ID 837I4
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-2I-09
SIXTH 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, request that Idaho Power Company
("Company") provide the following documents and information as soon as possible, or by
FRTDAY, MARCH 18,2022.
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
3t.0r.01.228.
SIXTH PRODUCTION REQUEST
TO IDAHO POWER
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I FEBRUARY 25,2022
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. 29: Please provide the electronic version of Attachment 1- Load and
Resource Balance Data contained in the Amended Application filed on February 4,2022.
REQUEST NO. 30: Page 3 of the Company's Motion and Amended Application states
that the Company agreed with and accepted Staff s recommended changes and adjustments
included in Staff s first set of comments. Please explain why the capacity amounts of Valmy
Unit 2 and Bridger are different than Staff s recommended amounts. What other Staff
recommendations are not reflected in the Attachment I Load and Resource Balance Data
contained in the Amended Application filed on February 4,2022?
REQUEST NO.31: Does the Load and Resource Balance Data contained in the
Amended Application reflect the most recent information of contract changes, such as contracts
that have been signed and/or terminated as of the time when the Company answers this request?
If not, what information has not been included?
REQUEST NO. 32: Page 5 of the Company's Motion and Amended Application states
that despite deficits occurring in July 2021 and July 2022, the IRP does not add any new
resources until2023, so that is the basis of the first capacity deficit. Please answer the following
questions.
a. Why doesn'tthe 2021 IRP add resources in2022 when there is a deficit?
b. Are the deficit amounts in202l and2022 determined using the same method as later
years?
c. Please explain why there was a 329-MW deficit in202l, but there was no physical
evidence that a deficit occurred? Did the Company incur any NERC violations for
the amount of reserves it should have carried during this timeframe? Please provide
actual data compared to the L&R modeled data that explains the lack of a physical
manifestation of the deficit.
SIXTH PRODUCTION REQUEST
TO IDAHO POWER 2 FEBRUARY 25,2022
REQUEST NO.33: Please confirm that there are no early coal plant retirements
assumed in the Load and Resource Balance Data contained in the Amended Application filed on
February 4,2022.
REQUEST NO.34: Page 36 of Appendix A of the 2021 IRP states that the performance
of new demand response progftrms is accounted for prior to determining the need for additional
supply-side resources and that all demand response programs are included in the load and
resource balance. However, Attachment I Load and Resource Balance Data contained in the
Amended Application filed on February 4,2022 shows that new demand response progftrms are
listed in the new resource section and are not accounted for prior to determining the need for
additional supply-side resources and that only existing demand response programs are included
in the load and resource balance. Please reconcile the statement in Appendix A and the
treatment in Attachment I Load and Resource Balance Data.
DATED at Boise, Idaho, this ZSba^,ofFebruary 2022.
Deputy Attorney General
i:umisc:prodreq/ipce2l.9mhyy prod req2
SIXTH PRODUCTION REQUEST
TO IDAHO POWER J FEBRUARY 25,2022
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 25TH DAY OF FEBRU AP(Y 2022,
SERVED THE FOREGOING SIXTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY, IN CASE NO. IPC-E-21-09,
BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
DONOVAN E WALKER
IDAHO POWER COMPANY
PO BOX 70
BOrSE rD 83707-0070
E-MAIL: [e-mail]
dockets@idahopower. com
PETER J RICHARDSON
RICHARDSON ADAMS PLLC
5I5 N 27TH ST
BOISE ID 83702
E-MAIL: [e-mail]
C TOM ARKOOSH
ARKOOSH LAW OFFICES
913 RTVER ST STE 450
BOISE TD 83702
E-MAIL: [e-mail]
erin. ceci l@arkoosh. com
CAMTLLE CHRISTEN
ENERGY CONTRACTS
P.O. BOX 70
BOISE, ID 83707
E-MAIL: [e-mail]
energycontracts@idahopower. com
DR DON READINU
6070 HILL ROAD
BOISE ID 83703
E-MAIL: dreadine@.mindsprins.corn
SECRE
CERTIFICATE OF SERVICE