20210707Staff 1-14 to IPC.pdf

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DAYN HARDIE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-007 4
[phone]
IDAHO BAR NO. 9917
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Street Address for Express Mail:
I I33I W CHINDEN BLVD, BLDG 8, SUITE 2OI-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 ITS LOAD CURTAILMENT
AND INTERRUPTION PLAN
CASE NO. IPC.E.2I.13
FIRST 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, requests that Idaho Power Company provide the
following documents and information as soon as possible, but no later than WEDNESDAY,
JULY 28,2021.
This Production Request is to be considered as continuing, and Idaho Power 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 or information
produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name, job title, and telephone number of
FIRST PRODUCTION REQUEST
TO IDAHO POWER
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JULY 7,2021
the person preparing the documents. Please also identifu the name, job title, location, and
telephone number of the record holder.
In addition to the written copies provided as response to the requests, please provide all
Excel spreadsheets and electronic files on CD with formulas intact and enabled.
R-EQUEST NO. 1: Company Witness Anderson's direct testimony states that the
Company's current reliability coordinator is operated by the California Independent System
Operator ("CAISO"). Anderson DI at 4.
a. Please provide current copies of CAISO curtailment procedures and requirements the
Company is expected to comply with.
b. Please explain how the Load Curtailment and Intemrption Plan ("LCIP") and
modified Rule J align with and support CAISO curtailment procedures and
requirements.
c. Please explain if CAISO has requested the Company to curtail since becoming the
Company's reliability coordinator in 2018. If so, please provide dates, size, duration,
and reason for each curtailment.
REQUEST NO. 2: Please describe how the Company provides notification of
curtailment or intemrption to state regulatory and reliability authorities. Please provide
supporting documentation and examples.
REQUEST NO.3: Please explain how customers were notified of the proposed LCIP
and Rule J modifications and provide supporting documentation.
REQUEST NO. 4: Please describe how the Company provides notification of
curtailment or interruption to customers and the public. Please provide supporting
documentation and examples.
REQUEST NO. 5: Please explain how legacy stakeholders and contractual customers
were notified of the proposed LCIP and Rule J modifications. Please provide supporting
documentation.
FIRST PRODUCTION REQUEST
TO IDAHO POWER 2 JULY 7,2021
REQUEST NO. 6: Please explain how Demand Response participants were notified of
the proposed LCIP and Rule J modifications. Please provide supporting documentation.
REQUEST NO. 7: Company Witness Anderson's direct testimony states
'oOver time, changes in technology, modifications to industry practices, and changes in
generation capacity have served to make the existing Modified Regional Plan obsolete."
Anderson DI at 3.
a. If the Modified Regional Plan is obsolete at the regional level, please explain how
regional partners and stakeholders are addressing curtailment planning and
notification.
b. Please provide copies of Company, regional partner, and stakeholder correspondence
regarding current regional curtailment planning activities and status of the Modified
Regional Plan.
c. Please provide current copies of any documents that place the Modified Regional
Plan document in an "obsolete" status.
REQUEST NO.8: Regarding page9 of Kathleen Anderson's direct testimony, how are
"facilities essential to the public welfare" determined, tracked, and notified?
REQUEST NO. 9: Table 1 on page 2 of the LCIP states "as required by NERC
Standards." What are the NERC standards that are referenced in the LCIP?
REQUEST NO. 10: Page 4 of the Application states that the LCIP applies to
emergencies declared by state entities, and when directed by the North American Electric
Reliability Corporation ("NERC") or the Western Electricity Coordinating Council ("WECC"),
and by the Company at its own discretion.
a. Please describe the process for resolution if one entity's declaration conflicts with the
decisions of another entity.
b. Please describe the scope and provide examples for the types of emergencies that can
be declared by the various entities mentioned above.
FIRST PRODUCTION REQUEST
TO IDAHO POWER J JULY 7,2021
REQUEST NO. 11: Please describe how the Company notifies customers and the
public of return to service. Please provide supporting documentation and examples.
REQUEST NO. 12: Page 5 of the Application states the Modified Regional Plan has
addressed only long-term regional energy shortages, while the Rule J procedures cover short-
term emergencies. In contrast, the 2021 LCIP contains both short- and long-term operational
activities the Company can initiate during emergencies to minimize adverse impacts to
customers and restore system stability. Please answer the following questions:
a. Which long-term components of the LCIP are coilrmon with the Modified Regional
Plan?
b. Which short-term components of the LCIP are covered by the Rule J Procedures?
REQUEST NO. 13: Page 5 of the Application states that the 2021LCIP addresses the
Company's operational approach to Initiation of Load Curtailment; Automatic, Remote and
Manual Actions; Curtailment Stages; Intemrptible Loads; Block Rotation; Emergency Load
Shed Groups; and Return to Service. Please answer the following questions:
a. Is each item listed above implemented differently under a short-term emergency
versus a long-term emergency? If so, please describe the difference.
b. Does the Modified Regional Plan address each item? If so, how does the Modified
Regional Plan address each item? Are there any differences between the Modified
Regional Plan and the LCIP for each item?
c. Do the Rule J Procedures address each item listed above? If so, how do the Rule J
procedures address each item? Is there any difference between the Rule J procedures
and the LCIP on each item?
REQUEST NO. 14: If the LCIP is approved, is the Company still going to implement
the Modified Regional Plan? Does the LCIP replace the Modified Regional Plan? Please
explain.
FIRST PRODUCTION REQUEST
TO IDAHO POWER 4 JULY 7,2027
'7b
DATED at Boise, Idaho, this day of July 2021.
\
Deputy Attorney General
i:umisc:prodreq/ipce2l. l3dhkskprod req I
FIRST PRODUCTION REQUEST
TO IDAHO POWER 5 ruLY 7,202r
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 7TH DAY OF JULY 2021, SERVED
THE FOREGOING FIRST PRODUCTION REQUEST OF TITE COMIVIISSION
STAFF TO IDAHO POWER COMPATYY, IN CASE NO. IPC-E-21-13, BY
E.MAILING A COPY THEREOF, TO THE FOLLOWING:
LISA NORDSTROM
IDAHO POWER COMPANY
PO BOX 70
BOrSE ID 83707-0070
E-MAIL : [e-mail]
dockets@idahopower. com
CONNIE ASCHENBRENNER
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: [e-mail]
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SECRETA*'f
CERTIFICATE OF SERVICE