20220113Staff 1-15 to IPC.pdf

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:
11331 W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
1q
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR
AUTHORITY TO PROCEED WITH RESOURCE
PROCUREMENTS TO MEET IDENTIFIED
CAPACITY DEFICIENCIES IN 2023, 2024, AND
2025 TO ENSURE ADEQUATE, RELIABLE,
AND FAIR-PRICED SERVICE TO ITS
CUSTOMERS
CASE NO. IPC.E-2I.4I
FIRST PRODUCTION
REQUEST OF THE IDAHO
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,
Dayn Hardie, Deputy Attomey General, requests that Idaho Power Company ("Company" or
"Idaho Power") provide the following documents and information as soon as possible, but no
later than THURSDAY, FEBRUARY 3,2022.
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 I JANUARY 13,2022
the person preparing the documents. Please also identify 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.
REQUEST NO. 1: Please provide copies of all past and future data requests and
responses between the Company and the Oregon Public Utility Commission ("OPUC") for the
Docket No. UM 2210: Idaho Power Applicationfor l(aiver of Competitive Bidding Rules.
Please include both formal and informal responses. This response should include public and
confidential data responses. Please provide all future responses at, or shortly after, the time
when the Company files its responses to the request.
REQUEST NO.2: Please explain why the Company limited the current 80 MW
Request for Proposal to wind, solar, energy storage, or some combination of these resources
REQUEST NO.3: Please explain why the Company is limiting the current 80 MW
Request for Proposal to company-owned resources to meet the 2023 capacity deficit.
REQUEST NO. 4: Please explain the difference in the Company's request for an
exemption in this case versus the request for a waiver of Oregon's Resource Procurement Rules
filed with the OPUC.
R-EQUEST NO. 5: Has the Company requested a waiver from the OPUC Resource
Procurement Rules for the current 80 MW Request for Proposal? Please explain why or why
not.
REQUEST NO. 6: Please provide a markup to the OPUC Resource Procurement Rules
that would allow the Company to meet its time requirements to secure needed resources to meet
reliability requirements that are least cost while maintaining a fair and transparent process.
FIRST PRODUCTION REQUEST
TO IDAHO POWER 2 JANUARY 13,2022
REQUEST NO. 7: Please provide a detailed explanation of why it would be extremely
detrimental to the Company if the Company was required to comply with the OPUC Resource
Procurement Rules.
REQUEST NO. 8: Table l: Peak-Hour Load and Resource Balance shows a deficit of
101 MW in July of 2023. Please explain why the current Request for Proposal for 80 MW of
capacity will reliably serve customer demand in2023.
REQUEST NO. 9: If the 120 MW Jackpot Solar project is not in service by summer
2023, please explain why only approximately 40 MW of additional summer peak capacity will
be needed to meet projected customer demand.
R-EQUEST NO. 10: Please identifu and explain any issues or limitations to bringing
Valmy Unit I back into service to meet the system reliability issues following the reliability and
economic impact analyses completed in May 2021.
REQUEST NO. 11: Please provide the specific documents from the Northwest Power
and Conservation Council showing where it has moved to a LOLE of 0.05 days per year, or no
more than one loss of load event per 20 years.
REQUEST NO. 12: Please fully explain and provide specific examples supporting the
Company's statement regarding the OPUC Resource Procurement Rules where the rules 00... are
designed to favor least cost PPA resources that are not the optimal resources operationally or for
a utility such as Idaho Power that already holds a proportionately large amount of PPAs."
REQUEST NO. 13: Please fully explain and provide specific detail showing how the
OPUC Resource Procurement Rules differs from the Idaho Power's Request for Proposal process
given the Company's statement: "By contrast, a procurement process for resources that takes into
account not only price, but also reliability, system operation, long-term operation and
maintenance of facilities, financial viability of the utility, economic dispatch, environmental
FIRST PRODUCTION REQUEST
TO IDAHO POWER J JANUARY 13,2022
policies, real-time needs and load growth, and other attributes, is one that benefits customers,
developers, and the utility."
REQUEST NO. 14: Please provide a schedule illustrating the specific changes to the
Company's assumptions and modeling from the 2019 second amended IRP and the 2021 IRP.
Please include the effects of each change on the Company's capacity deficiency date.
REQUEST NO. 15: Does the Company plan to file CPCN case(s) with the Idaho
Commission after it completes its resource selections? If not, please explain.
DATED at Boise,Idaho, thi, l3$day of Janu ary 2022.
Deputy A General
i:umisc:prodreq/ipce2l.43dhjt req I
FIRST PRODUCTION REQUEST
TO IDAHO POWER 4 JANUARY 1.3,2022
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS I3TH DAY OF JANUARY 2022,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
CoMMISSION STAFF TO IDAHO POWER COMPANY, IN CASE NO.
TPC.E-21-4I, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
DONOVAN E WALKER
IDAHO POWER COMPANY
PO BOX 70
BOISE rD 83707-0070
E-MAIL: dwalker(Oidahopower.com
dockets(dt idahopower. c om
TOM ARKOSH
AMBER DRESSLAR
ARKOOSH LAW OFFICES
PO BOX 2900
BOISE ID 8370I
E-MAIL: [e-mail]
amber. dressl [e-mail]
eri n. cec i l(a-l.ark oo sh. c om
PETER J RICHARDSON
RICHARDSON ADAMS PLLC
515 N 27TH ST
PO BOX 721 8
BOISE ID 83702
E-MAIL : peter(drichardsonadarns.com
TIM TATUM
VP REGULATORY AFFAIRS
IDAHO POWER COMPANY
PO BOX 70
BOrSE rD 83707-0070
E-MAIL : ttatum(ZDic{ahopower.com
BENJAMIN J OTTO
EMMA E SPERRY
ID CONSERVATION LEAGUE
710 N 6TH ST
BOISE ID 83702
E-MAIL : botto(E)idahoc onservation.orq
esperr.v' (01.i d ahoconservati on. ors
DON READING
6070 HILL ROAD
BOISE ID 83703
E-MAIL : dreadin g(d.mindsorin g. com
SECRETAR
CERTIFICATE OF SERVICE