20210616Staff 1-13 to IPC.pdf

MATT HUNTER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. I0655
; : Fii t- r:i?. I 'i I;l ti' .,1 lJ
Street Address for Express Mail:
I 133I 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 A
DETERMINATION ACKNOWLEDGING ITS
NORTH VALMY POWER PLANT EXIT DATE
CASE NO. IPC-E-21-12
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 WEDNESDAY, JULY 7,2021.
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
3t.01.01.228.
FIRST PRODUCTION REQUEST
TO IDAHO POWER
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I JUNE 16,2021
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: In the Application, the Company is requesting Commission
acknowledgement that "the appropriate exit date from Valmy Unit 2 is December 31, 2025",
while the full analysis is "based on information known today." Please answer the following:
a. How could conditions change from what is known today that would make it
feasible for an earlier Valmy Unit 2 exit date than December 3l ,2025,if the
Commission conditionally approves the Company's proposed exit date in this
case?
b. Please identif, and explain any constraints or limitations in the agreement with
NV Energy that would be a barrier for an exit date before December 31,2025,but
after December 31, 2022 if conditions were to change that would make it feasible,
both from an economic and reliability standpoint?
REQUEST NO. 2: Please provide all workpapers used to justifu the Company's
proposal to exit Valmy Unit 2 in December 31, 2025 when compared to the other options
considered by the Company.
REQUEST NO. 3: Please explain the criteria used to determine the options used for
comparison in the Company's analysis.
REQUEST NO. 4: Are there any other feasible resource options that the Company
could have considered for comparison? If so, please explain what they are and why they were
not considered.
REQUEST NO. 5: Please provide all workpapers and analysis used by the Company to
determine the risk to adequate reliability if the Company were to exit Valmy Unit2 prior to
December 31,2025.
FIRST PRODUCTION REQUEST
TO IDAHO POWER 2 JI.INE 16,2O2I
REQUEST NO. 6: Please provide all workpapers supporting the amounts shown in the
table labeled "Economic Analysis Results" on page 7 of the Application.
REQUEST NO. 7: Please provide an area map that shows: (1) Company owned
transmission; (2) surrounding area transmission used for interconnection; (3) transmission line
segments; (4) transmission line segment rated voltages; (5) transmission line segment rated
capacity considering the flow direction of the energy; (6) transmission line segment capacity
owned by the Company including energy flow direction; (7) other transmission line capacity
segments reserved by the Company identiffing any contractual limitations); (8) transmission
substations; and (9) all Company sourced generation resources. Please provide this map in PDF
format with a resolution that clearly provides the detail necessary for a comprehensive review
and with appropriate labels for each of the above. As appropriate provide a table of the
requested information which can easily correspond to the transmission segment identified on the
area map.
REQUEST NO. 8: Please define the term "net dependable capability" and explain the
meaning as it relates to the North Valmy Power Plant. ,See Ellsworth, DI, p. 3.
REQUEST NO. 9: Please provide a copy of the North Valmy Power Plant "Existing
North Valmy Agreements." See Ellsworth, DI, p. 4.
REQUEST NO. 10: Please provide a copy of the North Valmy Power Plant
"Framework Agreement." See Ellsworth, DI, p. 4.
REQUEST NO. 11: Please provide all Company analysis used for determining the
reduction in transmission availability of 140 MW to 277 MW during the peak load month of July
foryears 2022through2025. See Ellsworth, DI, p.21.
REQUEST NO. 12: Please explain what added resource(s) will provide system
reliability following the proposed exit of the North Valmy Power Plant after the end of 2025
FIRST PRODUCTION REQUEST
TO IDAHO POWER J JUNE 16,202I
REQIIEST NO. 13: Please provide the effect to the Company's tstal load obligation
and Planning Reserve Margin due to the redudion in tansmission availability.
Dated atBoise, Idaho, this I 6'A day ofJune 2021.
Matt Hunter
Deputy Attomey General
i:umisc:prodreq/ipce2l.l2mhrt prod reql
FIRST.PRODUCTION REQUEST
TO IDAHO POWER 4 JUNE 16,2021
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS l6il' DAY OF JUNE 2021, SERVED
THE FOREGOING FIRST PRODUCTION REQUEST OF TIIE COMMISSION STAFF
TO IDAHO POWER COMPAIYY, IN CASE NO. IPC-E-21-I2, BY E-MAILING A
COPY THEREOF, TO THE FOLLOWING:
LISA NORDSTROM
IDAHO POWER COMPANY
PO BOX 70
BOrSE rD 83707-0070
E-MAIL: [e-mail]
[e-mail]
PETER J RICHARDSON
RICHARDSON ADAMS PLLC
515 N 27TH STREET
BOISE ID 83702
E-MAIL: oeter(Erichardsonadams.com
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
7IO N 6TH ST
BOISE ID 83702
E-MAIL: [e-mail]
MATT LARKIN
IDAHO POWER COMPANY
PO BOX 70
BOISE rD 83707-0070
E-MAIL : [e-mail]
DR DON READING
6070 HILL ROAD
BOISE ID 83703
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE