20220315IPC to Staff 29-34-Redacted.pdf

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Donovan E. Walker
AnD CORPComFny
DONOVAN E. WALKER
Lead Gounsel
dwalker@ida hooower.com
March 15,2022
VIA ELECTRONIC MAIL
Jan Noriyuki, Secretary
ldaho Public Utilities Commission
11331 West Chinden BIvd., Building 8
Suite 201-A
Boise, ldaho 83714
Re: Case No. IPC-E-21-09
ldaho Power Company's Application for Capacity Deficiency To Be Utilized
For Avoided Cost Calculations
Dear Ms. Noriyuki:
Attached for electronic filing is ldaho Power Company's Redacted Response to the
Sixth Production Requests of the Commission Staff in the above entitled matter.
!f you have any questions about the attached documents, please do not
hesitate to contact me.
Very truly yours,
2dotl<-
DEW:cld
Enclosures
DONOVAN E. WALKER (lSB No. 5921)
ldaho Power Company
1221 West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
dwa [e-mail]
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
!N THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR
APPROVAL OF THE CAPACIW
DEFICIENCY TO BE UTILIZED FOR
AVOI DED COST CALCULATIONS.
cAsE NO. !PC-E-21-09
IDAHO POWER COMPANY'S
REDACTED RESPONSE TO
THE SIXTH PRODUCTION
REQUEST OF THE
COMMISSION STAFF
COMES NOW ldaho Power Company ('ldaho Powe/' or "Company'), and in
response to the Sixth Production Request of the Commission Staff to Idaho Power
Company dated February 25,2022, herewith submits the following information:
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE SIXTH PRODUCTION REQUESTS OF
THE COMMISSION STAFF - 1
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REQUEST NO. 29: Please provide the electronic version of Aftachment 1- Load
and Resource Balance Data contained in the Amended Application filed on February 4,
2022.
RESPONSE TO REQUEST NO. 29: The Load and Resource Balance workbook
from the 2021 IRP analysis is attached.
The response to this Request is sponsored by Jared Hansen, Resource Planning
Leader of ldaho Power Company.
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE SIXTH PRODUCTION REQUESTS OF
THE COMMISSION STAFF - 2
REQUEST NO. 30: Page 3 of the Company's Motion and Amended Application
states that the Company agreed with and accepted Staffs recommended changes and
adjustments included in Staffs first set of comments. Please explain why the capacity
amounts of Valmy Unit 2 and Bridger are different than Staffs recommended amounts.
What other Staff recommendations are not reflected in the Attachment 1 Load and
Resource Balance Data contained in the Amended Application filed on February 4,2022?
RESPONSE TO REQUEST NO. 30: The Load and Resource Balance workbook
from the 2021 IRP analysis is attached to Staff Request No. 29. The Aftachment 1 table
in the amended application shows Valmy Unit 2 and Bridger peak capacity after
reductions to account for the Effective Forced Outage Rates (EFOR) for the plants. The
Valmy Unit 2 and Bridger capacities prior to applying the EFORs are 133.5 MW (rounds
to 134 MW) and 708 MW respectively. These capacity levels match StafPs recommended
changes and the 2021 IRP analysis. The other Staff recommendations are also included
within the Load and Resource Balance data.
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE SIXTH PRODUCTION REQUESTS OF
THE COMMISSION STAFF - 3
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? lf not, what information has not been included?
GONFIDENTIAL RESPONSE TO REQUEST NO. 31:
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE SIXTH PRODUCTION REQUESTS OF
THE COMMISSION STAFF - 4
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 until 2023, so that is the basis of the first capacity deficit. Please
answer the following questions.
a. Why doesn't the 2021 IRP add resources in 2022when there is a deficit?
b. Are the deficit amounts in 2021 and 2022 determined using the same
method as later years?
c. Please explain why there was a 329-MW deficit in 2021, 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.
RESPONSE TO REQUEST NO. 32:
a. The lRP doesn't add resources in 2021 or2022 because the Aurora model
was prevented from selecting resources in those modelyears due to the inability of ldaho
Power to procure resources in that timeframe. The mode! started selecting resources to
achieve a 15.5o/o planning reserve margin in 2023.
b. Yes, the deficit amounts in2021 and2022 were determined using the same
method as the later analysis years in the !RP.
c. First, it should be noted that a load and resource (L&R) deficit in a year does
not mean that the Company will have to curtail load in actual operations. The larger the
deficit, the larger the risk of potential shortfalls that will lead to load curtailments. lt is
therefore the Company's goalto meet or exceed its reliability thresholds.
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE SIXTH PRODUCTION REQUESTS OF
THE COMMISSION STAFF - 5
The 329 MW deficit identified in the 2021 year of the 2021 IRP L&R balance is
primarily caused by a transitional capacity accounting issue in the L&R balance related
to 3rd party transmission reservations. This issue fully resolves by the 2023 year.
Secondly, per part (b) above, the 2021 deficit is also partially caused by an increase to
the Company's planning margin to meet a 1 day in 20 years loss of load expectation
(LOLE), as discussed in other Production Requests.
Regarding the transitional capacity accounting issue, in the 2021 lRP, the
Company only counted transmission that had secured third-party firm transmission to a
market hub toward meeting its L&R capacity needs. During 2021 operations, the
Company had 200 MW of secured third-party transmission rights. These firm third-party
reservations will increase from 200 MW to 380 MW by 2023, reducing the deficit by 180
MW. ln 2021 operations, the Company was not able to secure the 180 MW of third-party
transmission capacity long-term, however, this capacity was used, when available, and
the Company relied considerably on the 180 MWand other non-firm transmission imports
over existing transmission to serve load. The 180 MW accounts for a large portion of the
329 MW deficit and is fully secured by 2023, coincident with the year the Company will
be bringing on new resources.
The other Iarge transitionalcapacity item in the2O21 IRP L&R is the Effective Load
Carrying Capability (ELCC) of the Company's Demand Response (DR) programs. Due to
the timing of actual 2021 peak Ioad needs landing squarely in the late-June / early-July
timeframe, it is likely that the DR programs provided a higher ELCC than 66 MW.
Approved modifications to the DR programs are expected to increase their effectiveness
to 176 MW in 2022, reducing future deficits.
IDAHO POVVER COMPANY'S REDACTED RESPONSE TO THE SIXTH PRODUCTION REQUESTS OF
THE COMMISSION STAFF.6
The Company did not incur any NERC violations related to reserves during
Summer 2021.
The response to this Request is sponsored by Jared Hansen, Resource Planning
Leader of ldaho Power Company.
IDAHO POVT,ERCOMPANY,S REDACTED RESPONSE TO THE SIXTH PRODUCTION REQUESTS OF
THE COMMISSION STAFF - 7
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.
RESPONSE TO REQUEST NO. 33: No early coalexits are assumed in the portion
of the Load and Resource Balance Data prior to (above) the 2021 IRP Resources rows.
The table does include the planned exit of Valmy Unit 2 at the end of year 2025.
The conversion of Bridger units 1 and2to natural gas operation in 2024is included
in the 2021 IRP Resource section. The2021lRP Resource rows also include the Bridger
unit 3 early exit year-end 2025 and the Bridger unit 4 early exit year-end 2028.
The response to this Request is sponsored by Jared Hansen, Resource Planning
Leader of ldaho Power Company.
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE SIXTH PRODUCTION REQUESTS OF
THE COMMISSION STAFF - 8
REQUEST NO. 34: Page 36 of Appendix A of the 2021 IRP states that the
performance of new demand response programs 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 1 Load and Resource
Balance Data contained in the Amended Application filed on February 4,2022 shows that
new demand response programs are listed in the new resource section and are not
accounted for prior to determining the need for additiona! 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 1 Load
and Resource Balance Data.
RESPONSE TO REQUEST NO. 34: Staff correctly notes that the statement in
Appendix A of the 2021 IRP does not describe where the new demand response
programs were applied in the Load and Resource Balance Data. The new demand
response programs are listed in the new resource section of the Load and Resource
Balance to reflect program additions selected through the IRP analysis among other
resource options on equal basis. However, whether the new demand response programs
are applied prior to or within the new resources section, the Company is still anticipating
a July 2023 first capacity deficit.
The response to this Request is sponsored by Jared Hansen, Resource Planning
Leader of ldaho Power Company.
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE SIXTH PRODUCTION REQUESTS OF
THE COMMISSION STAFF - 9
Respectftrtly submitbd this 15h day of March 2022
&*Zilettn-
DONOVAN E. WALKER
Attromey for ldaho Power Gompany
IDA}IO POWERCOMPANY'S REDACTED RESPONSETOME SXTH PRODUCTION REQUESTS OF
THE COMMISSION STAFF . 10
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 1$h day of March 2022, I served a true and
correct copy of the within and foregoing IDAHO POWER COMPANY'S REDACTED
RESPONSE TO THE SIXTH PRODUCTION REQUESTS OF THE COMMISSION
STAFF upon the following named parties by the method indicated below, and addressed
to the following:
Dayn Hardie
Deputy Aftorney General
!daho Public Utilities Commission
Po Box 83720
Boise, Idaho 83720-0074
Peter J. Richardson ISB # 3195
RICHARDSON ADAMS, PLLC
515 N.27th Street
Boise, Idaho 83702
!daHydro
C. Tom Arkoosh
ARKOOSH LAW OFFICES
802 W. Bannock Street
Suite LP 103
Boise, lD 83701
Emailed to:
davn.hardie@puc. idaho.oov
Emailed to:
[e-mail]
Emailed to:
[e-mail]
Erin.ceci!@arkoosh.com
Christy Davenport, Legal Assistant
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE SIXTH PRODUCT]ON REQUESTS OF
THE COMMISS]ON STAFF - 11