20220202Staff 1-28 to IPC.pdf

TAYLOR BROOKS
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 11542
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Street Address for Express Mail:
I 1331 W CHINDEN BLVD, BLDG 8, SUITE 201-A
BOISE, ID 83714
Attomey for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR
APPROVAL OF SPECIAL CONTRACT AND
TARIFf,' SCHEDULE 33 TO PROVIDE
ELECTRIC SERVICE TO BRISBIE, LLC'S
DATA CENTER FACILITY
CASE NO.IPC.E.2I-42
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO IDAHO POWER COMPAI\Y
STAFF of the ldaho Public Utilities Commission, ("Staff') by and through its attomey of
record, Taylor Brooks, Deputy Attomey General, hereby requests that Idaho Power Company
provide the following documents and information as soon as possible, but no later than
WEDNESDAY, FEBRUARY 23, 2022.
This Production Request is 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
the person preparing the documents. Please also identify the name, job title, location, and
telephone number of the record holder.
FIRST PRODUCTION REQUEST
TO IDAHO POWER
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1 FEBRUARY 2,2022
In addition to the written copies provided as response to the requests, please provide all
Excel spreadsheets and electronic files with formulas intact and enabled.
REQUEST NO. 1: If Idaho Power customers are to be held harmless, will Brisbie LLC
("Brisbie") pay for all relevant expenses, such as salaries, wages, O&M, A&G, overhead,
finance, legal, commission filings and all unknown expenses, to procure such renewable
resource(s)?
REQUEST NO.2: If Brisbie never develops adatacenter, who will be responsible to
pay all costs incurred developing the special contract and procuring the renewable resource(s)?
REQUEST NO.3: Please provide a list of any resources that are immediately available
for the proposed Clean Energy Your Way Construction, Schedule 33. If no resources are
immediately available for proposed Schedule 33, please provide a timeline of when qualifuing
resources will be determined.
REQUEST NO. 4: If a waiver is granted for the Oregon Public Utilities Commission
Procurement process, please quantify the financial savings to Brisbie and the impact on the
proposed Schedule 33 rates. Please provide workpapers in Excel format to support your answer
REQUEST NO. 5: Please provide the proposed accounting treatment illustrating how
the Company will hold non-participants harmless from the Schedule 33 Special Contract?
REQUEST NO. 6: Please explain if funding a resource that is Company-owned through
a Contribution in Aid of Construction (CIAC) charged to participants is possible. Also please
provide the advantages and disadvantages of funding the capital cost of the resource through a
CIAC versus the Company recovering the capital exclusively through customer rates.
REQUEST NO. 7: In Order No. 33038, the Commission directed the parties to use the
Company's most recent cost-of-service study as the starting point for determining an appropriate
rate. Please provide workpapers and calculations showing the f,rgures extracted from the 2011
FIRST PRODUCTION REQUEST
TO IDAHO POWER 2 FEBRUARY 2,2022
Cost of Service Study, and how they were used in deriving the rates shown in the contract. Also,
please provide workpapers showing how any changes that have occurred since the 2011 Rate
Case were accounted for in deriving the contract rates presented in Schedule 33.
REQUEST NO. 8: Please explain the rationale for not including the second block of
energy in the calculation of the Sales Based Adjustment Rate. Please demonstrate how this holds
other customers harmless.
REQUEST NO. 9: Please explain how treating the second block of energy as it if were
an off-system sale holds other customers harmless? Please describe how energy sales to a retail
customer are off-system sales?
REQUEST NO. 10: Are all Special Contract customers' second block of energy
excluded from the SBAR calculation? If so, why and if not, why not?
REQUEST NO. l1: Please provide Brisbie's load ramp forecasting monthly peak
demand, average demand, and energy requirement discussed on page 3 of Goralski's Direct
Testimony. Please provide information in electronic format with formulas enabled.
REQUEST NO. 12: Please provide Brisbie's alternate load ramp discussed on page 4 of
Goralski's Direct Testimony. Please provide information in electronic format with formulas
enabled.
REQUEST NO. 13: Please provide all workpapers used to derive the two-block pricing
structure discussed on page 5 Goralski's Direct Testimony. Please provide workpapers in
electronic format with formulas enabled.
REQUEST NO. 14: Please provide the cost-of-service study discussed on page 6 of
Goralski's Direct Testimony. Please provide information in electronic format with formulas
enabled.
FIRST PRODUCTION REQUEST
TO IDAHO POWER J FEBRUARY 2,2022
REQUEST NO. 15: Please provide an electronic copy of the workpapers used to create
Confidential Exhibit No. 3, with formulas enabled.
REQUEST NO. 16: Please explain how the results of the no-harm analysis discussed in
Goralski's Direct Testimony would change if the resources selected for the special contract are
different than the model resources.
REQUEST NO. 17: Please explain the rationale for assuming costs are included as if
the Company had a general rate case each year discussed on page 23 of Goralski's Direct
Testimony.
REQUEST NO. 18: Please provide the workpapers used to determine the imputed debt
discussed on page 25 of Goralski's Direct Testimony. Please provide workpapers in electronic
format with formulas enabled.
REQUEST NO. 19: Please explain the rationale for the methods used to determine the
value of the Renewable Capacity and Excess Generation credits for renewable generation above
Brisbie's load as discussed in Goralski's Direct Testimony. In addition, please explain why the
Company's methods used to determine the value of these credits will ensure all other customers
will pay no more than the Company's avoided cost (i.e. the cost they would have to pay, if
Brisbie load and the renewable generation did not exist).
REQUEST NO. 20: Please explain the rationale for the schedule to update the excess
generation credit as proposed on page 17 of Goralski's Direct Testimony. Did the Company
explore altemative schedules? If so, what were they and what are the advantages and
disadvantages of each.
REQUEST NO. 21: Please explain the rationale for the block 2 hybrid pricing structure
consisting of embedded and marginal costs discussed in Goralski's Direct Testimony. In
addition, please explain why this rate design will ensure that Brisbie will pay their fair allocation
of cost based on the benefits they will receive from the system.
FIRST PRODUCTION REQUEST
TO IDAHO POWER 4 FEBRUARY 2,2022
REQUEST NO. 22: In the Application, page 4,the Company states, "Because Brisbie
will pay the costs associated with new renewable resources under the ESA, and provide security
as described in Tatum Direct, p l0-11, Idaho Power requests authority to procure the necessary
resources contemplated within the ESA without seeking Commission approval of each such
procurement." Please respond to the following:
a. Please provide a list of all costs and benefits associated with the renewable
resources including, but not limited to, the costs and benefits associated with the
Energy Services Agreement (ESA) and the Construction Agreement.
b. Please identiff who will be responsible for each of the identified costs and
benefits identified above (part a.).
c. Please explain how each of the identified costs and benefits identified above (part
a.) are and will be modeled in the Integrated Resource Plan (IRP) and the No-
Harm analyses. Please explain the rationale for any differences between the IRP
and No-Harm analysis modeling.
d. Please explain why not seeking Commission approval for procurement of new
renewable resources for Brisbie is appropriate.
REQUEST NO. 23: Please answer the following for the No-Harm Analysis included in
Goralski's Direct Testimony.
a. Please identifu any differences between the preferred portfolio in the 2021 IRP
and the portfolio derived for the base case in the No-harm Analysis.
b. Please identiff any differences in the assumptions used to derive the preferred
portfolio in the 2021 IRP and the assumptions used to derive the portfolio for the
base case in the No-harm Analysis.
c. Please veriff that the resources selected for Brisbie's renewable resources was
chosen by the capacity expansion model and was not forced into the portfolio. If
not, please explain.
REQUEST NO.24: Please identift any differences in the method and input
assumptions used for the base case portfolio and the base low portfolio in the No-Harm analysis
discussed in Goralski's Direct Testimony.
FIRST PRODUCTION REQUEST
TO IDAHO POWER 5 FEBRUARY 2,2022
REQUEST NO. 25: Please explain how: (1) the Special Contract between ldaho Power
and Brisbie; (2) the rates and charges set out in Schedule 33; and (3) the regulatory framework
for the ongoing implementation and administration of the Special Contract ensure that other
Company customers are held harmless.
REQUEST NO. 26: Please identifu and explain the potential risks that could cause any
renewable resource(s) costs to shift to other customers. In the response, please include answers
to the following:
a. What are the specific risk variables and assumptions included in the No-Harm
analysis and included in the rate design framework proposed by the Company that
could cause costs to shift to other Company customers?
b. For each identified risk variable/assumption above, please explain the potential or
likelihood for each to change causing the rate design proposal to impact other
customers.
c. For each risk variable/assumption identified above, please identifu and explain
how the risk can be effectively mitigated (or is mitigated in the Company's
proposal).
REQUEST NO.27: Please identiff and explain any other contractual and/or rate design
frameworks that would meet the objectives outlined in Goralski's direct testimony, Page 2, line
24 through Page 3, line 1 l.
REQUEST NO.28: Please explain the specific firm requirements needed by Brisbie
regarding its clean energy goals. For example, could retirement of RECs for Brisbie's share of
load serve Brisbie's clean energy goals?
FIRST PRODUCTION REQUEST
TO IDAHO POWER 6 FEBRUARY 2,2022
REQIJESTED in Boise, Idaho, ,hi, L*day of February 2022.
({i Taylor
Deputy Attomey Geireral
i:umiscprodre{ipce2l.42ttrrcHsme prod req I
FIRST PRODUCTION REQUEST
TO IDAHO POWER 7 FEBRUARY 2,2022
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 2Nd DAY OF FEBRUARY 2022,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION
STAFF TO IDAHO POWER COMPAIIY, N CASE NO. IPC-E-21-42, 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
TIM TATUM
VP REGULATORY AFFAIRS
IDAHO POWER COMPANY
PO BOX 70
BOrSE rD 83707-0070
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE