20220203IPC to Staff Attachment 1 - UM 2210 - Attachment to Response to 37.PDF

DAYN HARDIE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE,IDAHO 83720-0074
[phone]
IDAHO BAR NO.9917
Street Address for Express Mail:
11331 W CHINDEN BLVD,BLDG 8,SUITE 201-A
BOISE,ID 83714
Attorneyfor the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER )COMPANY'S APPLICATION FOR )CASE NO.IPC-E-21-41AUTHORITYTOPROCEEDWITHRESOURCE)PROCUREMENTS TO MEET IDENTIFIED )CAPACITY DEFICIENCIES IN 2023,2024,AND )FIRST PRODUCTION
2025 TO ENSURE ADEQUATE,RELIABLE,)REQUESTOF THE IDAHO
AND FAIR-PRICED SERVICE TO ITS )COMMISSION STAFF
CUSTOMERS )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 ("Company"or
"Idaho Power")provide the followingdocuments 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 1 JANUARY 13,2022
the person preparing the documents.Please also identify the name,job title,location,and
telephonenumber 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.
REQUESTNO.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 Application for Waiver 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.
REQUESTNO.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.
REQUESTNO.3:Please explain why the Company is limitingthe current 80 MW
Request for Proposal to company-owned resources to meet the 2023 capacity deficit.
REQUESTNO.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.
REQUESTNO.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.
REQUESTNO.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
REQUESTNO.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.
REQUESTNO.8:Table 1:Peak-Hour Load and Resource Balance shows a deficit of
101 MW in July of2023.Please explain why the current Request for Proposal for 80 MW of
capacity will reliably serve customer demand in 2023.
REQUESTNO.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.
REQUESTNO.10:Please identify and explain any issues or limitations to bringing
Valmy Unit 1 back into service to meet the system reliability issues followingthe reliability and
economic impact analyses completed in May 2021.
REQUESTNO.11:Please provide the specific documents from the Northwest Power
and ConservationCouncil 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.
REQUESTNO.12:Please fully explain and provide specific examples supporting the
Company's statement regarding the OPUC Resource Procurement Rules where the rules "...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."
REQUESTNO.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 viabilityof the utility,economic dispatch,environmental
FIRST PRODUCTION REQUEST
TO IDAHO POWER 3 JANUARY 13,2022
policies,real-time needs and load growth,and other attributes,is one that benefits customers,
developers,and the utility."
REQUESTNO.14:Please provide a schedule illustratingthe 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.
REQUESTNO.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,this day of January 2022.
Dayn Ha e
Deputy Attorney General
i:umise:prodreq/ipce21.43dhjt req l
FIRST PRODUCTION REQUEST
TO IDAHO POWER 4 JANUARY 13,2022
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 13TH DAY OF JANUARY 2022,
SERVED THE FOREGOING FIRST PRODUCTION REQUESTOF THE
COMMISSION STAFF TO IDAHO POWER COMPANY,IN CASE NO.
IPC-E-21-41,BY E-MAILING A COPY THEREOF,TO THE FOLLOWING:
DONOVAN E WALKER TIM TATUM
IDAHO POWER COMPANY VP REGULATORY AFFAIRS
PO BOX 70 IDAHO POWER COMPANY
BOISE ID 83707-0070 PO BOX 70
E-MAIL:dwalkerŒilidahopower.com BOISE ID 83707-0070
dockets idahopower.com E-MAIL:
TOM ARKOSH BENJAMIN J OTTO
AMBER DRESSLAR EMMA E SPERRY
ARKOOSH LAW OFFICES ID CONSERVATION LEAGUE
PO BOX 2900 710 N 6TH ST
BOISE ID 83701 BOISE ID 83702
E-MAIL:tom.arkoosh arkoosh.com E-MAIL:botto aidahoconservation.org
[e-mail] esperrvaidahoconservationsorg
efin.ceelaarkoosh.com
PETER J RICHARDSON DON READING
RICHARDSON ADAMS PLLC 6070 HILL ROAD
515 N 27TH ST BOISE ID 83703
PO BOX 7218 E-MAIL:dreadin amindspring.com
BOISE ID 83702
E-MAIL:peter richardsonadams.com
SECRE Y
CERTIFICATE OF SERVICE