20211116Staff 1-13 to IPC-Redacted.pdf

Street Address for Express Mail:
I133I W CHTNDEN BVLD, BLDG 8, SUITE 201-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
RILEY NEWTON.
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-007 4
[phone]
IDAHO BAR NO. II2O2
IN THE MATTER OF IDAHO POWER
COMPANY'S ANNUAL COMPLIANCE
FILING TO UPDATE THE LOAD AND GAS
FORECASTS IN THE INCREMENTAL COST
INTEGRATED RESOURCE PLAN AVOIDED
COST MODEL
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2:i?i ii*? i6 ?Y, 3:27
CASE NO. IPC-E-21-35
REDACTED FIRST
PRODUCTION REQUEST OF
THE COMMISSION STAFF TO
IDAHO POWER COMPANY
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The Staff of the Idaho Public Utilities Commission, by and through its attorney of
record, Riley Newton, Deputy Attorney General, request that Idaho Power Company
("Company") provide the following documents and information as soon as possible, or by
TUESDAY, DECEMBER 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, and the name, job title, and telephone number of
the person preparing the documents. Please also identifr the name, job title, location, and
telephone number of the record holder.
REDACTED FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY I NOVEMBER 16,2O2I
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: The Application states that there is a slight increase in customer
loads when compared to the October 2020load forecast that was provided to the Commission for
the 2020 update in Case No. IPC-E-20-35. Please explain what drives the load increase.
REQUEST NO.2: Please explain why the natural gas forecast in this proceeding I
f the natural gas forecast in Case No. IPC-E-21-15 over the next three years, but
significantly
REQUEST NO. 3: The footnote of the October 2021natttral gas forecast states that the
forecast is based on the
Please provide the
Sumas basis and transport costs for Idaho City Gate Delivery
REQUEST NO.4: [n reference to Confidential Response to Staff s Production Request
No. 4 in Case No. IPC-E-21-15, please answer the following questions:
a. Please explain if I uses the same method to determine the forecast over the
next five years in this proceeding. If not, please explain the method used in this
proceeding.
b. Please explain whether and how forwards prices are used to determine the forecast
over the next five years in this proceeding.
REQUEST NO. 5: Please explain in detail how the Peak Hours are selected based on the
2022Forecast Average Load data. Please explain whether these hours represent the highest five
percent of the 2022Forecast Average Load data, similar to how the Peak Hours were determined
in Case No. IPC-E-20-02. Please provide the workpapers that illustrate how the Peak Hours are
determined based on the 2022Forecast Average Load data in this case.
REDACTED FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 2 NOVEMBER 16,202I
REQUEST NO. 6: Page 5 of the Compliance Filing in Case No. IPC-E-20-02 stated that
l) Load, Net of Solar,2) Loss of Load Probability, and 3) Locational Marginal Pricing from the
Energy Imbalance Market were the three different metrics to identifo the Premium Peak Hours.
Please explain whether these three different metrics are used to identiff the Premium Peak Hours
in this proceeding.
REQUEST NO. 7: The Locational Marginal Pricing used in the Compliance Filing in
Case No IPC-E-20-02 was derived from the weighted-average hourly price comprised of all
pricing nodes in the Idaho Power Balancing Area Authority from four fifteen-minute market
price intervals and twelve real-time five-minute price intervals. Please explain whether this
methodology is used to determine the Locational Marginal Pricing in this proceeding. If so,
please list all the pricing nodes used and provide the workpapers that derive the Locational
Marginal Pricing.
REQUEST NO. 8: Please answer the following questions regarding theTable202l
Average of Western Energy Imbalance Market Locational Marginal Prices in the Supplement to
Idaho Power Company's Annual Compliance Filing.
a. Please explain what ELAP stands for, what ELAP prices mean, and why it is
appropriate to use ELAP prices for determining the Premium Peak Hours for
Idaho Power's system.
b. Are the red circles intended to highlight the four-hour block hours that represent
the Premium Peak Hours, instead of the hours being highlighted in the Table?
Please explain.
REQUEST NO. 9: The Supplement to Idaho Power Company's Annual Compliance
Filing states that the Company evaluates Loss of Load Probability ("LOLP") data from the 2019
IRP, using AURORA to analyze the likelihood of unique loss-of-load events in the year 2025 for
100 iterations, and the results show that four unique loss-of-load events occur in the late
aftemoon/evening hours in July. Please answer the following questions.
a. Please provide the results in Excel format from the LOLP analysis mentioned
above.
REDACTED FTRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY J NOVEMBER 16,2O2I
b. The LOLP analysis in the Compliance Filing in Case No. IPC-E-20-02 showed
results in percentages, but the Company uses the number of events in this
proceeding. Please explain the reasons for the methodological difference.
c. Is the LOLP analysis intended to support the Peak Hours or the Premium Peak
Hours? Please explain.
d. Please explain why an analysis for year 2025 is a good indicator to support Peak
Hours or the Premium Peak Hours for year 2022.
REQUEST NO. 10: Please explain why it's asserted that the 2021 actual Load, Net of
Solar data and the 2021 acfial Energy Imbalance Market Locational Marginal Prices data are
good indicators for the Premium Peak Hours in2022.
REQUEST NO. 11: Please provide the following information for the Big Sky West
Dairy project: Resource Type, State, and Project Size.
REQUEST NO. 12: Please provide the Contract Termination Date for the Digester (DF-
AP #1, LLC) project.
REQUEST NO. 13: Please confirm that the Big Sky West Dairy project, the Digester
(DF-AP #I,LLC) project, and the Rock Creek Dairy project have been removed from the IRP
model that is used to determine avoided cost rates for IRP-based projects.
DATED at Boise, Idaho, this lL day of November 2021.
Riley Newton
Deputy Attomey General
i:umisc:prodreq/ipce2 l.35m1y prod req I
REDACTED FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 4 NOVEMBER 16,2021
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS I5TH DAY OF NOVEMBER 2021,
SERVED THE FOREGOING REDACTED FIRST PRODUCTION REQUEST OF
THE COMMTSSION STAFF TO IDAHO POWER COMPANY, IN CASE
NO. IPC-E-21.35, BY E.MAILING A COPY THEREOF, TO THE FOLLOWING:
DONOVAN E WALKER
IDAHO POWER COMPANY
PO BOX 70
BOISE rD 83707-0070
E-MAIL: [e-mail]
dockets@idahopower. com
SECRETARY
CERTIFICATE OF SERVICE