20220406IPC to IdaHydro 3.pdf

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An IDACORP CompanY
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DONOVAN WALKER
Lead Gounsel
[e-mail]
April 6, 2022
VIA ELECTRONIC FILING
Jan Noriyuki, Secretary
ldaho Public Utilities Commission
1 1331 W. Chinden Blvd., Bldg 8,
Suite 201-A(83714)
PO Box 83720
Boise, ldaho 83720-0074
Re Case No. !PC-E-2141
ln The Matter Of ldaho Power Company's Application For Authority to
Proceed with Resource Procurements to Meet ldentified Capacity
Deficiencies in 2023, 2024, and 2025 to Ensure Adequate, Reliable, and
Fair-Priced Service to its Customers
Dear Ms. Noriyuki:
Attached for electronic filing is ldaho Power Company's Response to ldaHydro's
Third Set of lnterrogatories and Second Set of Requests for Production and Requests for
Admission to ldaho Power Company the above entitled matter. lf you have any questions
about the attached document, please do not hesitate to contact me.
Very truly yours,
:..i. !nLl
h*2da!4
Donovan E. Walker
DEW:cd
Enclosures
DONOVAN E. WALKER (lSB No. 5921)
ldaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
[e-mail]
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR
AUTHORITY TO PROCEED WTH
RESOURCE PROCUREMENTS TO MEET
IDENTIFIED CAPACITY DEFIC!ENCIES
IN 2023, 2024, AND 2025 TO ENSURE
ADEQUATE, RELIEABLE, AND FAIR.
PRICED SERVICE TO ITS CUSTOMERS.
CASE NO. |PC-E-2141
IDAHO POWER COMPANY'S
RESPONSE TO IDAHYDRO'S THIRD
SET OF INTERROGATORIES AND
SECOND SET OF REQUESTS FOR
PRODUCTION AND ADMISSION TO
IDAHO POWER COMPANY
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COMES NOW, ldaho Power Company ("ldaho Powe/' or'Company"), and in
response to ldaHydro's Third Set of lnterrogatories and Second Set of Requests for
Production and Requests forAdmission to ldaho Power Company dated March 16,2022,
herewith submits the following information;
IDAHO POWER COMPANY'S RESPONSE TO IDAHYDRO'S THIRD SET
OF INTERROGATORIES, SECOND SET OF REQUESTS FOR PRODUCTION
ANDADMISSION TO IDAHO POWER COMPANY- 1
INTERROGATORY NO. 3: lf any cost as expressed in Request forAdmission No.
2 in the opinion of ldaho Power, please provide ldaho Powe/s opinion of the correct cost.
RESPONSE TO IDAHYDRO'S INTERROGATORY NO. 3: ldaho Power believes
this interrogatory was meant to say: 'lf any cost as expressed in Request for Admission
No. 2 in the opinion of ldaho Power is incorrect, please provide ldaho Power's opinion
of the correct cost." Please see the Company's response to ldaHydro's Admission
Request No.2.
The response to this Request is sponsored by Mark Annis, Regulatory Consultant
of ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO IDAHYDRO'S THIRD SET
OF INTERROGATORIES, SECOND SET OF REQUESTS FOR PRODUCTION
AND ADMISSION TO IDAHO POWER COMPANY - 2
ADMISSION REQUEST NO. 2: Please admit that for each identified source of
electricity that the corresponding initial cost per kWh of electricity is the initia! cost per
kWh of electricity initially approved by the Commission:
Mobile Diesel-diesel:$0.124
Nea! Hot Spr.-qeothermal:$0.117
Lanqley Gulch-gas $0.11 1
Cascade Hydro (new)-hydro:$0.090
Bennett Mt.-gas:$0.078
Danksin, Mt. Home-qas $0.077
Swan Falls Rebuild-hydro:$0.073
Milner Dam Rebuild-hydro $0.063
North Valmv-coal:$0.063
Elkhorn Wind-wind:$0.062
PURPA-different fuels $0.062
Evander Andrews-gas:$0.061
RESPONSE TO IDAHYDRO,S ADMISSION REQUEST NO. 2: EACh Of thc
amounts in the table below represent the levelized cost of energy ('LCOE') of the
resources Iisted, as cited in the order issued by the ldaho Public Utilities Commission in
the associated case, or in other supporting documents, as indicated in the table below.
IDAHO POWER COMPANY'S RESPONSE TO IDAHYDRO'S THIRD SET
OF INTERROGATORIES, SECOND SET OF REQUESTS FOR PRODUCTION
AND ADMISSION TO IDAHO POWER COMPANY _ 3
Resource Case Order/Other Source $/kwh
Mobile DieseLdiesel tPC-E-o1-12 28773 (the Danskin case)$0.124
Neal Hot ermal !PC-E-09-34 31087 $0.117
tPC-E-09-03 30892/Staff Comments $0.111
Cascade Hydro t new)-hydro 1006-265 20610 $0.090
Bennett Mt.-gas lPc-E-03-12 29410 One of several Staff
estimates cited in the Order $0.078
Danskin, Mt. Home-qas IPC-E-o1-12 28773 $0.077
Swan Falls Rebuild-hydro IPC-E-90-02 23520 $0.073
m !rPc-E-90-08 23529 $0.063
North Valmy-coal 1006-265 20610 $0.063
Elkhorn Wind-wind rPC-E-06-31 30259 $0.062
PURPA-different fuels nla ldaho Power records $0.065
Evander Andrews-gas tPC-E-06-09 Staff testimony levelized
disoatch cost $0.061
It is unclear what the 'PURPA-different fuels" line refers to. The Commission
approves published avoided cost rates annually for various PURPA resource types. The
average purchase price (inclusive of energy and capacity) paid to all PURPA qualiffing
facilities for their combined 2021 annual generation was $0.066 per kilowatt-hour.
Note that the amounts in the table generally represent an LCOE calculation for the
applicable resource as measured by various parties in the identified case. LCOE
calculations include several assumptions about resource life, capacity factors, discount
rates and other factors that change over time. The LCOE as referenced in the cases in
the table may or may not be "Commission-approved"; may or may not be the current
LCOE for that resource and may or may not be what is reflected in actual rates for that
resource. ldaho Powe/s 2021 lntegrated Resource Plan Appendix C Technical Report,
page 46 provides the Company's current published estimates of the LCOE for a large
selection of resource types expressed in 2021 dollars.
The response to this Request is sponsored by Tim Tatum, Vice President of
Regulatory Affairs of ldaho Power Gompany.
IDAHO POWER COMPANY'S RESPONSE TO IDAHYDRO'S THIRD SET
OF INTERROGATORIES, SECOND SET OF REQUESTS FOR PRODUCTION
ANDADMISSION TO IDAHO POWER COMPANY-4
ADMISSION REQUEST NO. 3: ln the event ldaho Power either fails to provide a
complete answer to Request for Admission No. 2 or Request for Production No. 2 or
objects to the same, please admit that ldaho Power Company does not possess
information allowing a full or complete answer to Request for Admission No. 2 or Request
for Production No. 2.
Please see the
Company's response to Admission Request No. 2.
The response to this Request is sponsored by Mark Annis, Regulatory Consultant
of ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO IDAHYDRO'S THIRD SET
OF INTERROGATORIES, SECOND SET OF REQUESTS FOR PRODUCTION
AND ADMISSION TO IDAHO POWER COMPANY - 5
PRODUCTION REQUEST NO. 2: For any cost identified by ldaho Power differing
from the initial cost set forth in Request for Admission No. 2, please provide all
documentation giving rise to the differing opinion of ldaho Power.
RESPONSE TO IDAHYDRO'S PRODUGTION REQUEST NO. 2: Please see the
Company's response to Admission Request No. 2. That response only changed one item,
the average cost of PURPA from allsour@s, to provide a more current value forthe2021
calendar year.
The response to this Request is sponsored by Ma* Annis, Regulatory Consultant
of ldaho Power Company.
Respectfully submitted this 6h day of April 2022.
h,,*Zdat4-
DONOVAN E. WALKER
Aftorney for ldaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO IDAHYDRO'S THIRD SET
OF INTERROGATORIES, SECOND SET OF REQUESTS FOR PRODUCTION
AND ADMISSION TO IDAHO POWER COMPANY - 6
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 6th day of April2022, I served a true and correct
copy of the within and foregoing IDAHO POWER COMPANY'S RESPONSE TO
IDAHYDRO'S THIRD SET OF INTERROGATORIES AND SECOND SET OF
REQUESTS FOR PRODUCTION AND ADMISSION TO IDAHOPOWER COMPANY
upon the following named parties by the method indicated below, and addressed to the
following:
Dayn Hardie
ldaho Public Utilities Commission
Po Box 83720
Boise, ldaho 83720-0074
Peter J. Richardson
RICHARDSON ADAMS, PLLC
515 N.27th Street
Boise, ldaho 83702
Dr. Don Reading
6070 Hill Road
Boise, lD 83703
!daHydro
C. Tom Arkoosh
Amber Dresslar
ARKOOSH LAW OFFICES
913 w. River Street, Suite 450
P.O. Box 2900
Boise, lD 83701
ldaho Conservation League
Benjamin J. Otto
Emma E. Sperry
710 North 6th Street
Boise, lD 83701
Greg M. Adams
RICHARDSON ADAMS, PLLC
515 N.27th Street
Boise, ldaho 83702
Spencer Gray
NIPPC
P.O. Box 504
Mercer lsland, WA 98040
Emailed to:
davn.hard ie@ouc. idaho.oov
Emailed to:
peter@ richa rdsonadams.com
Emailed to:
dread [e-mail]
Emailed to:
tom. a rkoosh @arkoosh. com
amber.d ressla r@a rkoosh. com
[e-mail]
Emailed to:
botto@ida hoconservation.orq
esperrv@ ida hoconservation.orq
Emailed to:
q reo @richa rdsonadams.com
Emailed to:
[e-mail]
IDAHO POWER COMPANY'S RESPONSE TO IDAHYDRO'S THIRD SET
OF INTERROGATORIES, SECOND SET OF REQUESTS FOR PRODUCTION
AND ADMISSION TO IDAHO POWER COMPANY - 7
Abigail R. Germaine
Elam & Burke, P.A.
251 E. Front St., Suite 300
P.O. Box 1539
Boise, lD 83701
Scott Miller
Western Power Trading Forum
1540 River Park Dr., Suite 211
Sacramento, CA 95815
Max Greene
Renewable Northwest
421 SW6th Ave., Suite 1400
Portland, OR 97204
Jim Kreider
STOP BB2H Coalition
60366 Marvin Road
La Grande, OR 97850
Jack Van Valkenburgh
Van Valkenburgh Law, PLLC
P.O. Box 531
Boise, lD 83701
Ed Jewell
Boise City Aftorneys Office
P.O. Box 500
Boise, lD 83701
VUilGehl
Boise Gity Dept. of Public Works
P.O. Box 500
Boise, lD 83701
Emailed to:
[e-mail]
Emailed to:
[e-mail]
Emailed to:
[e-mail]
Emailed to:
[e-mail]
Emailed to:
iack@va nva lkenbu rq h law.com
Emailed to:
[e-mail]
bo isecitvatto rnev@citvofbo ise. o rq
Emailed to:
wqeh [e-mail]
Christy Davenport, Legal Assistant
IDAHO POWER COMPANY'S RESPONSE TO IDAHYDRO'S THIRD SET
OF INTERROGATORIES, SECOND SET OF REQUESTS FOR PRODUCTION
AND ADMISSION TO IDAHO POWER COMPANY - 8