20220126IPC to Staff 1-28.pdf

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An loAcoRP compeny
January 26,2022
VIA ELECTRONIC FILING
Jan Noriyuki, Secretary
ldaho Public Utilities Commission
11331 West Chinden Blvd., Building 8
Suite 201-A
Boise, ldaho 83714
Case No. IPC-E-21-32
ln the Matter of ldaho Power Company's Application forApproval to Modify
Its Demand Response Programs
Dear Ms. Noriyuki:
Attached for electronic filing, pursuant to Order No. 35058, is ldaho Power
Company's Response to First Production Request of the Commission Staff in the above
entitled matter.
Due to the voluminous nature of information provided in response to data requests
in this case, the Company is posting the attachments to these requests to the secure FTP
site to allow parties to view the requested information remotely. The login information for
the confidential and non-confidential portions of the FTP site was provided to all parties
on December 2,2021 who have signed the protective agreement.
lf you have any questions about the attached documents, please do not hesitate
to contact me.
Very truly yours,
LISA D. NORDSTROM
Lead Counsel
I [e-mail]
LDN:sg
Attachments
X*!.fl^ur,.*,
Re
Lisa D. Nordstrom
LISA D. NORDSTROM (lSB No. 5733)
ldaho Power Company
1221 West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
! n ord strom@ida h opowe r. com
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR
APPROVAL TO MODIFY ITS DEMAND
RESPONSE PROGRAMS.
CASE NO. tPC-E-2',1-32
IDAHO POWER COMPANY'S
RESPONSE TO FIRST
PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO
POWER COMPANY
COMES NOW, ldaho Power Company ("ldaho Powe/'or "Company'), and in
response to the First Production Request of the Commission Staff ("StafF') dated
January 5,2022, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 1
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REQUEST FOR PRODUCTION NO. 1: Please provide, in electronic format with
allformulae intact, allworkpapers and other documents used in the development of the
Application and Testimonies including, but not limited to, the charts, tables, numbers,
and incentives.
RESPONSE TO REQUEST FOR PRODUCTION NO. 1: Please see the
attachments provided for Responses 1, 6, 7, 8, and 9 to the First Production Request of
lndustrial Customers of ldaho Power.
The response to this Request is sponsored by Stacy Gust, Regulatory
Administrative Assistant, ldaho Power Company.
IDAHO PO\fGR COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY-2
REQUEST FOR PRODUCTION NO. 2: Please provide a five-year historical
comparison (backcast) of the ELCC method to the current capacity planning method.
RESPONSE TO REQUEST FOR PRODUCTION NO. 2: The 2021 lntegrated
Resource Plan ("lRP") is the first cycle where the Effective Load Carrying Capability
('ELCC) has been calculated for the Demand Response (.DR') portfolio, whereas
previous lRPs assumed the full nameplate capacity of the programs.
Table 1 of the Ellsworth DR Testimony illustrates the ELCC for Test Year 1
(2017), Test Year 2 (2018), Test Year 3 (2019) and Test Year 4 (2020), which
represents four of the past five years. For the Table 1 calculations, while it should be
noted that the Company scaled each Test Year load to match a 2023load forecast, the
net load shape will remain very similar using actual load data (backcast), and the
ELCCs for the DR resource will remain approximately the same. Because ELCC's are
determined through a difference equation, the inclusion of retired units such as Valmy
Unit 1, and Boardman, will similarly result in minimal impacts to the calculated ELCC,
therefore, the Company did not make an aftempt to determine revised numbers.
The response to this Request is sponsored by Jared Ellsworth, Transmission,
Distribution & Resource Planning Director, ldaho Power Company.
IDAHO POVVER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY.3
REQUEST FOR PRODUCTION NO. 3: The Company states that it intends to
evaluate conducting a study to evaluate DR potential. "For future lRPs, the Company
intends to evaluate the possibility of conducting an ldaho Power specific potential study
to evaluate the DR potential in its service are." Ellsworth, Dl at24.
a. Please describe how the Company will define requirements of what a DR
potential would include.
b. Please describe when a DR potential study could be initiated.
c. PIease explain if the Company would conduct the study using internal
resources or if a third pafi would be used. !f a third party is used, please
describe selection requirements, and time to complete the study from RFP
to publication.
d. Please describe if and how the currently proposed program changes
would be addressed in a DR potentialstudy.
RESPONSE TO REQUEST FOR PRODUCTION NO. 3:
a. The Company will work with a third-pafi contractor that has completed DR
potentia! studies for other utilities. This will involve relying on the contractor's
expertise when looking at ldaho Power's customer segments and loads to
calculate achievable DR participation from each type of customer and
program. The Company anticipates the contractor will also review ldaho
Power's current programs as well as any potential programs that could be
utilized within ldaho Power's service area. The Company expects a similar
process as to what the Northwest Power and Conservation Council did in
determining the DR potential for the region but with the study being focused
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 4
on ldaho Power's service area.
b. ldaho Power has selected a contractor and is currently negotiating contract
details. The Company anticipates the DR potential study will begin in
February 2022.
c. ldaho Power chose to use the same third-party contractor it is using for the
energy efficiency potential study. The contractor was selected based on their
previous experience completing DR potential studies, their evaluation cost
estimate, their familiarity working with ldaho Power's data, and the overall
efficiency was considered as they will be completing both potential studies.
The current plan is for the DR potential study to be completed by late summer
or early fall of 2022.
d. The expectation is that the potential study willestimate the full potential of the
Company's DR programs with the proposed program changes. The contractor
willtake into account ldaho Power's current program parameters,
participation levels, and incentives in their estimation calculations. The
updated participation levels of the current programs wil! be known in June and
will be incorporated into the study.
The response to this Request is sponsored by Quentin Nesbift, Customer
Research & Analysis Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 5
REQUEST FOR PRODUCTION NO.4: Please provide details of the
circumstances where opt-out fees can be waived. 'The Company is proposing to add a
provision 6 where opt-out fees can be waived in limited circumstances..."(NESBITT, Dl
24).
RESPONSE TO REQUEST FOR PRODUCTION NO. 4: The Company is
proposing to waive opt out fees in limited situations where a customer experiences a
planned or unplanned outage of 3 hours or more occurring within 24 hours of a Load
Control event, or a multiday outage within 72 hours of an event. A planned or
unplanned outage would be caused by an issue with the transmission or distribution
system and not related to demand response program operations. Existing language in
the tariff requires the waiving of opt-out fees in excess of total program season
incentives for a service location. This provision exists to ensure customers do not owe
the Company if opt-opt fees are greater than the total incentive. The incentive will never
be negative or a cost to participants.
The response to this Request is sponsored by Quentin Nesbitt, Customer
Research & Analysis Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY.6
REQUEST FOR PRODUCTION NO. 5: Please provide details of how the
Company intends to evaluate the proposed DR modifications, if approved, including
frequency of evaluations.
RESPONSE TO REQUEST FOR PRODUCTION NO. 5: The Company will
conduct an internal evaluation of load reduction for each of the programs annually and
report the results in the Demand-Side Management Annual Report. ln addition, third-
pafi impact evaluations are planned to be completed every five years, and a process
evaluation is planned to be conducted in2023 to evaluate overall program processes
that may change as result of this filing.
The response to this Request is sponsored by Quentin Nesbitt, Customer
Research & Analysis Leader, ldaho Power Company.
IDAHO PO\A'ER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 7
REQUEST FOR PRODUCTION NO. 6: Please provide all assumptions and
calculations supporting the values presented in Attachment 1, for SCHEDULE 23
IRRIGATION PEAK REWARDS PROGRAM, Eighth Revised Sheet No.23-5, showing
the Fixed lncentive Payment(s) and Variable !ncentive Payment(s).
RESPONSE TO REQUEST FOR PRODUCTION NO. 6: When the Company
established the incentives for Schedule 23, it considered what it might take for
customers to participate, what other utilities were paying for similar programs, and what
level of incentives the program could support to remain cost-effective. Because these
factors have evolved over time, the Company does not have a single analysis that
captures this evolution. However, in the development of the proposed incentive levels,
the Company recognized how the existing fixed and variable components of the total
incentive have worked welltogether to incent customers to participate as well as
providing the Company with the proper price signal on when to utilize the programs.
With this in mind, the analysis performed by the Company to develop the proposed
incentive amounts used the existing incentive structure and amounts as a starting point.
The proposed adjustments are intended to maximize participation while ensuring the
resulting costs will remain below cost-effectiveness limits.
The response to this Request is sponsored by Quentin Nesbitt, Customer
Research & Analysis Leader, ldaho Power Company.
IDAHO POV\IER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY. S
REQUEST FOR PRODUCTION NO. 7: Please provide all assumptions and
calculations supporting the $5.00 per month incentive payment shown in Attachment 1,
for SCHEDULE 81, RESIDENTIAL AIR CONDITIONER CYCLING PROGRAM, Third
Revised Sheet No.81-3.
RESPONSE TO REQUEST FOR PRODUCTION NO. 7: The $5.00 per month
incentive payment for the Residential Air Conditioner Cycling program has been in place
since the 2013 Settlement Agreement, and the Company did not perform a specific
calculation to establish the amount. Prior to the 2013 Settlement Agreement, the
incentive was $7.00 per month. \Mren the Company set the current incentive, it
considered what it might take for customers to participate, what other utilities were
paying for similar programs, and what level of incentive the program could support to
rema in cost-effective.
The response to this Request is sponsored by Quentin Nesbift, Customer
Research & Analysis Leader, ldaho Power Company.
IDAHO PO\A'ER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 9
REQUEST FOR PRODUCTION NO.8: Please provide all assumptions and
calculations supporting the values presented in Attachment 1, for SCHEDULE 82, FLEX
PEAK PROGRAM, Second Revised Sheet No. 82-5, showing the Fixed Capacity
Payment Rate and Variable Energy Payment Rate.
RESPONSE TO REQUEST FOR PRODUCTION NO. 8: The Company does not
have specific calculations for the derivation of the Fixed Capacity Payment Rate and
Variable Energy Payment Rate for the Commercial & lndustrial Flex Peak program.
Prior to 2015, the program was run by a third-party contractor and the existing incentive
of $3.25 per Kilowatts (kW') per week was similar to the incentive provided by the third-
party contractor during that period. For the proposed program, the Company did not
propose to lower the weekly incentive because of the potentia! impact a reduction would
likely have on customer participation. \Mren the Company proposed the incentive, it
considered what it might take for customers to participate, what other utilities were
paying for similar programs, and what level of incentives the program could support to
rema in cost-effective.
The response to this Request is sponsored by Quentin Nesbitt, Customer
Research & Analysis Leader, ldaho Power Company.
IDAHO PO\A'ER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 1O
REQUEST FOR PRODUCTION NO. 9: ln reference to the following in Section l,
Paragraph 2 of the Application, please explain and provide quantification for the
statement'...peak-hour system capaci$ deficits that typically occur during low hydro
generation and high load events..." (APPLICATION-2).
RESPONSE TO REQUEST FOR PRODUCTION NO. 9: The table below shows
a comparison between the Company's 2021 IRP Load and Resource Balance and the
Company's 2021 summer near-term operating plan. The 2021 IRP Load and Resource
Balance is based upon 50th percentile load and 5Oh percentile hydro, while the
methodology behind the 2O21 summer near-term operating plan utilized 95th percentile
load and a critical water year. Looking solely at the Company's assumed available
existing resources for July of 2021 (and excluding the applied planning margin and
reserve requirements to compare the two forecasts on equalgrounds), the forecasted
system deficit increases by over 200 Megawatts ("MW') when utilizing the 95th
percentile load forecast and a criticalwater year.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCT]ON REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 11
2021 IRP Load and
Resource Balance
2021 Summer Operating
Plan
50fi Percentile Load
and Hydro
July 2021
95m Percentile Load and
Critical Hydro
July 2021
Peak-Hour Load with EE
Existing Demand Response
(3,603)
66
(3,724)
66
Peak-Hour Load with EE & DR (3,537)(3,658)
Bridger
Valmy
663
121
663
121
Langley Gulch
Total Gas Peakers
270
370
270
370
Hydro (Hells Canyon Complex)
Hydro (Run of River)
1,060
295
1,060
200
Solar CSPP (PURPA)
Wind CSPP
Other CSPP
197
93
130
197
83
130
Elkhorn
Raft River Geothermal
Neal Hot Springs Geothermal
Clatskanie Exchange
15
I
I
11
14
8
8
11
Existing Resource Subtotal 3,241 3,135
Monthly Surplus/Defi cit (2s6)(523)
The response to this Request is sponsored by Jared Ellsworth, Transmission,
Distribution & Resource Planning Director, ldaho Power Company.
IDAHO POI/VER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 12
REQUEST FOR PRODUCTION NO. 10: ln reference to Section l, Paragraph 2
of the Application for Demand Response, does low hydro generation range over severa!
hours, over several days, or over a season? Please also explain how Demand
Response directly benefits this situation. (APPLICATION-2).
RESPONSE TO REQUEST FOR PRODUCTION NO. 10: The average
hydroelectric generation refers to the annual total hydroelectric Megawatt-hour ("MWh")
net generation as compared to thifi-year median and mean historical data. A below-
average water year will limit hydroelectric plant operations on an hourly, daily, and
seasonal basis due to the fuel (water availability) restrictions that will keep the units
from operating at maximum capacities for long durations. Hydro generation capacity,
especially at the Company's run-or-river plants, can be highly variable year to year and
can result in 100+ MW summer capacity availability swings.
Demand Response can assist in meeting peak demand needs more often when
water is scarce and less often when water is flush. Demand Response will always be
utilized by the Company's grid operators as a valuable backup resource or resource of
last resort.
The response to this Request is sponsored by Jared Ellsworth, Transmission,
Distribution & Resource Planning Director, ldaho Power Company.
]DAHO PO\A'ER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO ]DAHO POWER COMPANY- 13
REQUEST FOR PRODUCTION NO. 11: Please provide the analysis including
calculations showing how the Company's Demand Response (DR) programs represent
approximately 10 percent of ldaho Powe/s system peak (APPLICATION-2).
ldaho Power's a!!time
system peak was most recently set at 3,751 MW on June 30, 2021. Prior to this, the all-
time system peak was 3,422 MW set on July 7 ,2017. ldaho Power's Demand
Response capacity has varied between 366 MW and 393 MW of capacity lrom20'17-
2021. For any one of these years, the DR capacity is 10 to 12 percent of the system
peak.
The response to this Request is sponsored by Quentin Nesbitt, Customer
Research & Analysis Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY. 14
REOUEST FOR PRODUCTION NO. 12: Please explain why the Company's
Commercia!& lndustrial (C&l) Flex Peak Program (FIex Peak) limits participation to
customers only able to offer load reduction of at least 20 kilowatts (APPLICATION - 3).
RESPONSE TO REQUEST FOR PRODUCTION NO. 12: The Commercial &
lndustrial Flex Peak Program has a minimum participation threshold of 20 kilowatts due
to the manual nature of pulling interval metering data and calculating the payments. The
Company believes that going through this effort for customers contributing less than 20
kilowatts would not be cost-effective.
The response to this Request is sponsored by Quentin Nesbitt, Customer
Research & Analysis Leader, ldaho Power Company.
IDAHO PO\A'ER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY.ls
REQUEST FOR PRODUCTION NO. 13: Please explain and provide an
example showing how the Company verifies the amount of load reduction for a
participant in the Commercial& lndustrial (C&l) Flex Peak Program (Flex Peak) where
the participant manually reduces their nominated load when ldaho Power calls an event
(APPLTCATTON-3).
RESPONSE TO REQUEST FOR PRODUCTION NO. 13: ldaho Powe/s load
reduction calculation for Commercial& lndustrial Flex Peak participants is described in
Schedule 82. The calculation utilizes the three highest energy use days during the
event availability window from the 10 previous non-event days to establish a baseline.
Then event reductions are calculated using actual load on the event day with a day of
adjustment factor applied. For examples, please see aftachments 3, 8, and 9 provided
for Responses to Industrial Customers of ldaho Power Production Request No. 6.
The response to this Request is sponsored by Quentin Nesbitt, Customer
Research & Analysis Leader, ldaho Power Company.
IDAHO POVVER COMPANY'S RESPONSE TO F]RST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 16
REQUEST FOR PRODUCTION NO. 14: Please explain and provide an
example showing how the Company verifies the amount of load reduction for a
participant in the lrrigation Peak Rewards Program where the participant in the lrrigation
Peak Rewards Program where the participant manually reduces its nominated load
when ldaho Power calls an event (APPLICATION -3)
RESPONSE TO REQUEST FOR PRODUCTION NO. 14: ldaho Power has
created a sofiware application for the manua! participants of the lrrigation Peak
Rewards Program that tracks customers, tracks participating locations, logs events,
accesses interval metering data, calculates incentives, and helps facilitate payments to
participants. A2021example is provided in the attachment provided for this response,
and customer information has been removed to protect confidentiality.
The response to this Request is sponsored by Quentin Nesbitt, Customer
Research & Analysis Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 17
REQUEST FOR PRODUCTION NO. 15: PIease provide the methodology,
including details of the calculations, that support the Company's claim that each of the
Demand Response programs have been cost-effective over the past five summers
(APPICATION-3). Please also supplement the requested information to show the cost-
effectiveness of the individual Demand Response programs for the prior five-year period
(t.e. 2012 through 201 6).
RESPONSE TO REQUEST FOR PRODUCTION NO. 15: The methodology for
cost-effectiveness over the past five years (2016-2020) was calculated in accordance
with the Settlement Agreement approved by the Commission in Case IPC-E-13-14. ln
Order No. 32923, the Commission approved the Settlement Agreement, which defined
the annua! value of demand response as equal to the levelized annual cost of the
minimum size deferred resource, measured over a period of 20 years, plus the
corresponding deferred energy savings for 60 program hours. At the time, the avoided
cost value was $16.7 million and has been updated with each lRP. A copy of these
analyses for each IRP cycle since 2013 are provided as attachments to this request.
For program year 2013, the A/C Cool Credit and Irrigation Peak Rewards
programs were suspended. Therefore, a cost-effectiveness evaluation was not
completed. Prior to 2013, the cost-effectiveness methodology also used the 20 year
Ievelized cost of a 170 MW simple cycle combustible gas turbine. However, it was
converted to a dollars per kW per year value that the programs needed to stay under to
remain cost effective. A copy of these analyses for each of the programs in 2012 are
provided as attachments to this request.
IDAHO POVVER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 18
Attachments 2, 5, and 7 are labeled confidential because they contain sensitive
business information from the third-parly contractor that managed the Flex Peak
program up until 2015.
The response to this Request is sponsored by Quentin Nesbitt, Customer
Research & Analysis Leader, ldaho Power Company.
IDAHO POYI/ER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POVVER COMPANY. 19
REQUEST FOR PRODUCTION NO. 16: Please expand Table 1: S-Year
Summary of Demand Response Load Reduction, Capacity and Cost by Jurisdiction to
show the individua! quantities for each DR program, since each program's inception
(APPLTCATTON4).
RESPONSE TO REQUEST FOR PRODUCTION NO. 16: PIease see the
attachment provided for this response.
The response to this Request is sponsored by Quentin Nesbitt, Customer
Research & Analysis Leader, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY.20
REQUEST FOR PRODUCTION NO. 17: Please provide the analysis,
calculations, and documentation by DR program showing the lack of potential near-term
peak-hour deficits identified in the load and resource balance prepared for the 2013 IRP
which prompted Case No. IPC-E-12-29. Please provide the comparable analysis for all
years where Demand Response programs were offered (APPLICATION-4,
PARAGRAPH -5).
RESPONSE TO REQUEST FOR PRODUCTION NO. 17: Please see the
attachment provided for this response. See tab by tab details below:
o 12013-20321tab: This includes the'Load and Resource Balance'file from
the 2013 lRP. Row 6 includes reductions to peak related to existing
demand response (from the 2011 !RP). Row 36 includes reductions to
peak from the 2013 IRP identified demand response, which is zero
through 2015, and begins to ramp back up in 2016.
. 12011-2012ltab: This includes the'Load and Resource Balance'file from
the 2011 IRP Update. Row 10 includes reductions to peak related to
existing demand response. Comparing 2012 Row 40 to Row g, demand
response was necessary in 2011, and no longer necessary in 2012
following the addition of Langley Gulch.
o l2010ltab: This includes the'Load and Resource Balance'file from the
2009 lRP. Rows 7-8 include reductions to peak related to existing demand
response. Rows 4648 includes reductions to peak from 2009 IRP
identified demand response. Demand Response was neoessary to meet
peak needs.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 21
. [2009]tab: This includes the'Load and Resource Balance'file from the
2008 IRP Update. At this point, the historical data and methodology
become less clear. DSM was identified as a line item in Row 28 as
necessary to meet peak requirements.
o 12006-20081tab: This includes the'Load and Resource Balance'file from
the 2006 lRP.
o 12004-2005ltab: This includes the'Load and Resource Balance'file from
the 2004 lRP.
o 12002-2003ltab: This includes the'Load and Resource Balance'file from
the 2002 lRP. ln this lRP, the focus was average MW, i.e. energy based
analysis.
The response to this Request is sponsored by Jared Ellsworth, Transmission,
Distribution & Resource Planning Director, ldaho Power Company.
IDAHO PO\A'ER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 22
REQUEST FOR PRODUCTION NO. 18: Please identify all resources used in
calculating the Loss-Of-Load Probability (LOLP). Please explain why resources
available through market purchase are or are not considered in the LOLP.
(APPL!CAT|ON-6, PARAGRAPH -1 0).
RESPONSE TO REQUEST FOR PRODUCTION NO. 18: \ffhen analyzing the
current and proposed DR portfolio parameters, ldaho Power's Loss -of-Load Probability
('LOLP') calculations were based upon the Company's expected 2023 load and
resource balance. \Mth the four test years used for weather shaping, historica! load was
scaled to have the same peak load as the forecasted 2023 system peak. The resource
types included in the LOLP calculations are listed below:
o Existing Solar, \Mnd, CSPP
o Jackpot Solar Project
o Demand Response
o Geothermal (Raft River, Neal Hot Springs)
. Hells Canyon Complex (Hells Canyon Dam, Brownlee, Oxbow)
. Run of River Hydroelectric Plants
o Natural Gas (Langley Gulch, Bennett Mountain, Danskin)
o Coa! (Bridger, Valmy)
To obtain a resource's ELCC, the perfect generation of the system with the
resource is subtracted from the perfect generation of the system without the resource
and then divided by the evaluated resource's nameplate capacity. Because a resource's
ELCC is dependent on a difference calculation (one of which both variables would
include market purchases, and thus cancel out), the addition of market purchases to the
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 23
LOLP modeling would not have a significant impact on the ELCC determination
calculation and corresponding results. Therefore, for the purpose of determining DR
ELCC, market purchases were not included in the Company's LOLP calculations.
To reiterate, the calculation of LOLP in this DR case was simply a first step in
determining DR's ELCC. For the 2021 lRP, and for the purposes of determining whether
the Company is resource sufficient (i.e. the L&R balance), the Company includes
market purchases into its LOLP calculations.
The response to this Request is sponsored by Jared Ellsworth, Transmission,
Distribution & Resource Planning Director, ldaho Power Company.
IDAHO PO\A'ER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POVVER COMPANY.24
REQUEST FOR PRODUCTION NO. 19: Please identify all resources and
values used in calculating the Loss-Of-Load Expectation (LOLE). Please explain why
market purchases are not considered within LOLE (APPLICATION-6, PARAGRAPH -
121.
RESPONSE TO REQUEST FOR PRODUCTION NO. 19: Please refer to
Response to Request for Production No. 18.
The LOLE is calculated by adding the maximum LOLP from each day for a time
period (typically over the course of a year). The LOLP identifies high and low-risk hours
regarding system load exceeding generation capacity, and the maximum LOLP from
each day over the course of 365 days are summed together to calculate the LOLE. As
part of the analysis, the Company adds perfect resource capacity until the system
reaches the 0.05 days per year LOLE target. Ultimately, for IRP purposes, this perfect
resource requirement is compared and then offset (at least partially - depending on its
size) by market purchases via available transmission capacity to market hubs. Any
amount of perfect resource requirement that is not offset by market purchases, or new
resource acquisitions, results in an L&R balance deficit.
The response to this Request is sponsored by Jared Ellsworth, Transmission,
Distribution & Resource Planning Director, ldaho Power Company.
IDAHO PO\A'ER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 25
REQUEST FOR PRODUCTION NO.20: Please provide all Company reasoning,
methodology, and analysis supporting the decision to use a LOLE of 0.05 days per year
(APPL|CAT|ON-7, PARAGRAPH -12).
RESPONSE TO REQUEST FOR PRODUCTION NO. 20: ldaho Power utilized a
reliability threshold (LOLE) of 0.1 days per year in the 2019 !RP. For the 2021 lRP,
ldaho Power is adopting a reliability threshold of 0.05 days per year calculated based on
historical averages. The 0.05 (1-in-20) reliability threshold was chosen to: 1) account for
the extreme weather events that are becoming more frequent in the Northwest, and 2)
factor in water availability uncertainty year to year.
Regarding extreme weather, the Company is utilizing historical data to forecast
average load and average hydro conditions. Therefore, utilizing historical data to plan
for a 1 in 20 event will be comparable to planning for a 1 in 10 event in the future with
more extremes. For example, the response to Staffs Request for Production No. 9
illustrates that a peak demand year coupled with a poor water year, resulting in reduced
hydro generation, can result in a 200+ MW change in resource requirements. The poor
water year alone is equivalent to a season-long resource outage of about 100 MW.
A part of the Company's Load & Resource balance is Emergency Transmission
Capacity Benefit Margin ("CBM') totaling 330 MW. Another way of assessing whether
the Company has sufficient resources is considering the chances the Company must go
into an Energy Emergency and call on CBM and ask for assistance from the region to
meet demand requirements. lnspecting July of 2023, the Company's load forecast is
3,724 MW with a 15.5o/o planning margin of 577 MW. This 577 MW must encompass
operating reserves, extreme weather, and unplanned outages, and the 577 MW already
IDAHO POVVER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 26
includes 330 MW of CBM. The 247 MW of remaining non-CBM planning margin
capacity (577-330=247) is barely sufficient to meet the extremes discussed above
(200+ MW) before factoring in any amount for operating reserves and unplanned
outages. !f the reliability threshold were 1 in 10 instead of 1 in 20, the 247 MW of
remaining non-CBM planning margin capacity would become 174 MW, which would be
insufficient to meet the extremes discussed in the prior paragraph. This simply
represents a spot check of reasonableness associated with the reliability threshold.
Finally, the 0.05 days per year threshold aligns with the reliability threshold used
by the Northwest Power & Conservation Council. The Company will continue to
evaluate the 0.05 reliability threshold to appropriately balance cost and risk. Given
forecasted load growth and pending coal generation retirements, there is little risk that
the Company will be in a prolonged position with a material amount of excess
resources.
The chart below shows the individual and average Test Year resource needs
under the 0.05 and 0.1 reliability thresholds. Test Year 3 and onwards increasingly
exceed the LOLE reliability thresholds. Please note that 2021 is newly obtained data
and is not included in the average calculation (shown in the figure and table below);
2021 data is shown for comparison only because it was not available at the time the
study was performed.
IDAHO POVVER COMPANY'S RESPONSE TO FIRST PRODUCTION REOUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 27
2023 Rcource ileed
TestYear 1 TestYear2 TeatYear3 TestY6er4 2Ul1'
The table below includes the actualvalues represented in the chart above
The response to this Request is sponsored by Jared Ellsworth, Transmission,
Distribution & Resource Planning Director, ldaho Power Company.
IDAHO PO\A'ER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 28
600
5@
400
300
200
100
==!,oozoefooot
0
Resource tleed @ 0.1 LOLE
Resourco t{eed 0.(ELOLE
ry AVG Resourc€ Ne6d @ 0.05 LOLE
TY AVG Resoure N6d @ 0.1 LOLE
1-in-10 LOLE Resource Need 295 MW 346 MW 406 MW 422MW 367 MW
367 MW 420 MW 477 MW 499 MW 441 MW1jn-20 LOLE Resource Need
Test
Year 1
Test
Year 2
Test
Year 3
Test
Year 4 AverageDescriptions
REQUEST FOR PRODUCTION NO. 21: Please provide the calculations
showing how the individual DR programs have been cost-effective each year since the
Settlement Agreement in 2013.
Please see
aftachments 7-11 for Staffs Request for Production No. 15.
The response to this Request is sponsored by Quentin Nesbitt, Customer
Research & Analysis Leader, ldaho Power Company.
IDAHO PO\A'ER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY.29
REQUEST FOR PRODUCTION NO.22: Please provide the calculations
showing the cost-effectiveness of each of the DR programs over the past 10 years
based on the "current method" as wellas the'proposed method".
RESPONSE TO REQUEST FOR PRODUCTION NO. 22: For the "current
method", please see Attachments 1-11 provided for Staffs Request for Production No.
15. For the 'proposed method', ldaho Power does not possess the requested analysis,
and therefore, cannot produce it. The Commission has already made determinations on
the cost-effectiveness of the DR programs operated from 2011-2020. The Company
believes the merits of the proposed economic valuation method can, and should, be
assessed based on current and forward-looking information.
The response to this Request is sponsored by Quentin Nesbitt, Customer
Research & Analysis Leader, ldaho Power Company.
IDAHO POVVER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 30
REQUEST FOR PRODUCTION NO. 23: Please provide allcalculations and
assumptions used to support the $131.60 per kW per year value presented as the 2022
levelized fixed cost value for the Simple-Cycle Combustion Turbine (ELLSWORTH, Dl
21).
RESPONSE TO REQUEST FOR PRODUCTION NO. 23: From page 51 of the
2021 IRP filed in Case No. IPC-E-2143, 'The primary source of cost information for the
2021 IRP is the 2020 AnnualTechnology Baseline report released by the National
Renewable Energy Laboratory (NREL) in July 2020." ldaho Power also consulted the
2020 EIA and Lazard reports as wel! as historic Simple-Cycle Combustion Turbine
('SCCT") costs for its existing units. For more information and assumptions on future
supply-side generation and storage resources, please see Chapter 5 of the 2021 IRP
Report and the 'Supply-Side Resource Data' section of the 2021 IRP Technical
Appendix C,
Please see Attachment 4 to Request No.9 from the First Production Request of
lndustrial Customers of ldaho Power which includes the calculations supporting the
2022levelized fixed cost of a SCCT as $131 .60 per kW per year.
The response to this Request is sponsored by Jared Ellsworth, Transmission,
Distribution & Resource Planning Director, ldaho Power Company.
IDAHO PO\A'ER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY.3l
REQUEST FOR PRODUCTION NO. 24: Please explain the Company's
reasoning for using a20-year levelized cost for the Simple-Cycle Combustion Turbine.
RESPONSE TO REQUEST FOR PRODUCTION NO. 24: ldaho Power
determined the SCCT continues to represent a reasonable proxy for an avoided supply-
side capacity resource for demand response program analysis, as applied in this case.
!|Vhile the 2021 IRP relies primarily on battery storage and transmission to meet peak
future capacity needs, an SCCT still represents a viable supply-side alternative to
demand response under the method proposed in this case. Further, the Company, Staff
and other parties have experience with this calculation and changing to storage or
transmission as a proxy avoided cost would bring additional complexity to an already
complex set of issues without a commensurate increase in analytical precision. The
Company will continue to assess the reasonableness of this method going forward but
believes that this more familiar method is appropriately applied in this case.
The response to this Request is sponsored by Quentin Nesbitt, Customer
Research & Analysis Leader, ldaho Power Company.
IDAHO PO\A'ER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY.32
REQUEST FOR PRODUCTION NO.25: Please provide allcalculations and
assumptions used to support the $38.11 per kW per year value presented as additional
system benefits of a Simple-Cycle Combustion Turbine over an equally effective 492
MW DR portfolio (ELLSWORTH, Dl 21).
Please see
Attachments 1-4 to Request No. 9 from the First Production Request of lndustrial
Customers of ldaho Power.
The response to this Request is sponsored by Jared Ellsworth, Transmission,
Distribution & Resource Planning Director, ldaho Power Company.
IDAHO POVVER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMM]SSION STAFF TO IDAHO POWER COMPANY- 33
REQUEST FOR PRODUCTION NO. 26: Please explain why, in Table 3 -
Proposed Demand Response Portfolio ELCC (300 MW Capacity), the Proposed
Demand Response ELCCo/o dropped in Test Year 3 to 62.00% versus Test Year 2 of
64.000/o. Please also explain the contributors affecting the change in values from Test
Year 1 through Test Year 4 (ELLSWORTH, Dl 25).
RESPONSE TO REQUEST FOR PRODUCTION NO. 26: Because the
Company's "LOLE MATLAB@ algorithm utilizes four years of historical hourly output
data to provide actual weather shapes for non-controllable resources (or resources for
which ldaho Power does not have direct operational control over such as wind, solar,
dairy digestors, non-wind and non-solar PURPA projects, run-of-river hydroelectric
plants, and geothermal generation), the net load shape varies by test year.
Energy-limited resources such as battery storage and DR are created based on
the net Ioad, meaning DR dispatch shapes and effectiveness also vary by test year.
This means the ELCC of DR is also directly related to the system's net load, which can
vary significantly from year-to-year due to load variability and the shape of the
Company's non-controllable resources.
The minor differences in the described ELCC values from test year to test year
are attributed to load variation and variable energy resources' output; the variables in
the modeldo not change. For example, Test Year 1 reflected a historically expected
year, with high load conditions in early July complimented by high renewable output.
Test Year 2 was a historically mild year, with no significant extremes. Test Year 3
depicted a historically unique year, with high load conditions occurring in the month of
September when solar output was limited as compared to its generation capability in the
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCT]ON REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 34
earlier summer months. Test Year 4 had two days in August where wind and solar
ouput were low while load was high, causing two higher risk days in that specific
month.
The response to this Request is sponsored by Jarcd Ellsworth, Transmission,
Distribution & Resource Planning Director, ldaho Power Company.
IDAHO PO\,\JER COMPAI.IY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 35
REQUEST FOR PRODUCTION NO. 27: Please provide the data showing the
statistically derived resource capacity probability distribution for all hours over the past 4
years referenced in Ellsworth Direct Testimony (ELLSWORTH, D! 4). Please provide
any other data or other information used to support the values. This information would
include, but is not limited to, resource capacities, historical resource availability, and
statistical forced outage rates.
RESPONSE TO REQUEST FOR PRODUCTION NO. 27: Please see the
attachments provided for this response.
The response to this Request is sponsored by Jared Ellsworth, Transmission,
Distribution & Resource Planning Director, Idaho Power Company.
IDAHO POVVER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POVVER COMPANY- 36
REQUEST FOR PRODUCTION NO. 28: Please provide the data showing the
hourly system 'net load" and 'total system load" over the past 4 years referenced in
Ellsworth Direct Testimony (ELLSWORTH, D! 4). Please provide hourly information by
resource showing the resource and how it was utilized to meet the load and or system
reliability.
RESPONSE TO REQUEST FOR PRODUCTION NO. 28: Please see the
aftachment provided for this response showing the hourly system load and net load data
for the four historical test years used in the analysis. The LOLE MATLAB@ algorithm is
a capacity modelwhere the generation available is modeled regardless of whether it
was used to meet load.
The response to this Request is sponsored by Jared Ellsworth, Transmission,
Distribution & Resource Planning Director, ldaho Power Company.
IDAHO POVVER COMPAiIY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POVVER COMPANY- 37
DATED at Boise, ldaho, this 26ffl day of January 2022
&'-fr.ff^*t*.*,
LISA D. NORDSTROM
Attomey for ldaho Power Company
IDAHO POWER COMPAI.IYS RESPONSE TO FIRST PRODUCTTON REQUESTOF THE
COMMISSION STAFF TO IDAHO POVVER COMPAT.IY.38
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 26th day of January 2022, ! served a true and
correct copy of ldaho Power Company's Response to First Production Request of the
Commission Staff to ldaho Power Company upon the following named parties by the
method indicated below, and addressed to the following:
Commission Staff
Riley Newton
Deputy Attorney General
ldaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg No.8,
Suite 201-A (83714)
PO Box 83720
Boise, lD 83720-0074
ldaho lrrigation Pumpers Association, lnc.
Eric L. Olsen
Echo Hawk & Olsen, PLLC
505 Pershing Ave., Ste. 100
P.O. Box 6119
Pocatello, ldaho 83205
Lance Kaufman
Aegis lnsight
4801 W. Yale Ave.
Denver, CO 80219
ldaho Conservation League
Benjamin J. Otto
Emma E. Sperry
ldaho Conservation League
710 N. 6th Street
Boise, ldaho 83702
lndustrial Customers of ldaho Power
Peter J. Richardson
Richardson Adams, PLLC
515 N.27th Street
P.O. Box 7218
Boise, ldaho 83702
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IDAHO POWER COMPANY'S RESPONSE TO THE FIRST SET OF PRODUCTION REQUEST OF THE
COMMISSION STAFF -39
Dr. Don Reading
6070 Hill Road
Boise, ldaho 83703
Micron Technology, lnc.
Austin Rueschhoff
Thorvald A. Nelson
Austin W. Jensen
Holland & Hart LLP
555 17th Street, Suite 3200
Denver, CO 80202
Jim Swier
Micron Technology, lnc.
8000 South FederalWay
Boise, lD 83707
Boise Gity
Ed Jewe!!
Deputy City Attorney
Boise City Attorney's Office
150 N. Capitol Blvd. P.O. Box 500
Boise, lD 83701-0500
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tnelson@holland hart. com
awiensen@holland ha rt.com
aclee@holla nd hart. com
o loaroanoamari@holland hart.com
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bo isecitvatto rnev@citvofboise. o ro
&-.sJ=
Stacy Gust, Regulatory Administrative
Assistant
IDAHO PO\'\'ER COMPANY'S RESPONSE TO THE FIRST SET OF PRODUCTION REQUEST OF THE
COMMISSION STAFF .40