20220303Staff 29-43 to IPC - Redacted.pdf

TAYLOR BROOKS
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 11542
Street Address for Express Mail:
I I33I W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE,ID 83714
Attomey for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAIIO 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
REDACTED SECOND
PRODUCTION REQUEST OF
THE COMMISSION STAFF
TO IDAHO POWER COMPANY
STAFF of the Idaho 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
THURSDAY, MARCH 17, 2022.r
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 behalfl 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
I Stuff i, requesting an expedited response. If responding by this date will be problematic, please call Staff s
attorney at [phone].
REDACTED SECOND PRODUCTION
REQUEST TO IDAHO POWER I MARCH 3,2022
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the person preparing the documents. Please also identiff 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 with formula intact and enabled.
REQUEST NO. 29: Please provide the basis for and explain the derivation of the I
used to discount the Aurora Mid-Columbia ("Mid-C") prices in order to determine non-firm
Mid-C prices. Please provide workpapers in Excel format with all formula enabled.
REQUEST NO. 30: Can the I used as an adjustment to determine the Mid-C non-
firm price be modified during the term of the contract? If so, how frequently can it be modified?
(For example: upon acknowledgment future IRPs). If modification is allowed, please identifr
the specific language in the contract that allows such modifications.
REQUEST NO. 31: Can the method for determining the Excess Generation Price be
modified during the term of the contract? If so, please identifu the specific language in the
contract that allows such modifications.
REQUEST NO.32: Please provide the PURPA integration cost for Solar on a $/kWh
basis as determined by the 2019 and2021 IRPs.
REQUEST NO. 33: Please provide the hourly avoided energy cost rates in $/kWh with
and without integration cost over the contract term using the 2019 and202l IRP Incremental
Cost Integrated Resource Plan (ICIRP) avoided cost model. For the generation profile to
determine the rates, please use the amount of hourly Excess Generation (Determined by netting
the Brisbie load from the Renewable Generation forecasts included in the Company's filing).
Please provide all workpapers in Excel format with all formula enabled.
REQUEST NO.34: Are actual hourly Mid-C firm and/or non-firm prices available? If
so, please provide actual 2019,2020 and202l prices in Excel format.
REDACTED SECOND PRODUCTION
REQUEST TO rDAHO POWER 2 MARCH 3,2022
REQUEST NO.35: If no actual hourly Mid-C firm and/or non-firm prices are available,
what actual prices are available? Please provide actual 2019,2020 and202l actual Mid-C prices
with highest time resolution available in Excel format.
REQUEST NO.36: Please provide the following information regarding the renewable
capacity credit:
a. Please explain why the PURPA first capacity deficiency date is not taken into
consideration for determining the renewable capacity credit for generation from
the renewable resource(s).
b. For determining the current PURPA authorized system capacity deficiency date in
the 2019 IRP, was Brisbie's load included in the load forecast? If so, please
provide the Load and Existing Resource Balance with Brisbie's load as a separate
line item.
c. If Brisbie's load was not included, please update the 2019 IRP load and current
resource balance and capacity deficiency date with Brisbie's load included as a
separate line item.
d. For determining the proposed PURPA authorized system capacity deficiency date
in the 2021 IRP, was Brisbie's load included in the load forecast? If so, please
provide the Load and Existing Resource Balance with Brisbie's load as a separate
line item.
e. If Brisbie's load was not included, please update the202l IRP load and current
resource balance and capacity deficiency date with Brisbie's load included as a
separate line item.
f. Regarding future incremental "tranches" of "new" renewable resources, what is
the scope of modifications that can be made to determine the renewable capacity
credit? For example, can the methods used to determine the credit be modified or
is it limited to modifications to the inputs? Please identifu the specific language
that allows such modifications in the contract.
g. Does the contract allow for determining the method andlor amount of the
renewable capacity credit to be reviewed and authorized by the Commission for
future tranches of new renewable resources, especially given the amounts? If so,
REDACTED SECOND PRODUCTION
REQUEST TO IDAHO POWER J MARCH 3,2022
please identifu the specific language in the contract that requires the
Commission' s authori zation.
REQUEST NO.37: Given that each IRP is acknowledged and not authorized, what is
the approval process for values and rates in the Brisbie contract that will be determined and/or
updated after future IRPs are acknowledged? Please identifr the specific language that allows
this approval process in this contract.
REQUEST NO. 38: Please answer the following questions regarding the rates for
demand and supplemental energy (block I and block 2) rates in the contract:
a. Please explain the scope of the modifications that can be made to the contract
rates in the Company's next general rate case. Specifically, can the rate design
and cost-of-service methodologies be modified? Please identifr the specific
language that allows such modifications in the contract.
b. If the rate design for Schedule No. l9T is modified in the Company's general rate
case, will Brisbie's rate design also be modified? If so, please identifr the
specific language that allows such modifications in the contract.
REQUEST NO. 39: Please answer the following questions regarding REC treatment:
a. Please explain whether RECs should be credited to customers based on generation
or consumption.
b. Please explain why Idaho customers who consume the excess generation from
Brisbie's renewable resource(s) should not be allocated the associated RECs.
REQUEST NO. 40: Please provide the daily (by hour) and yearly (by month) load
shape(s) of each Schedule l9T customer within Idaho Power's service territory.
REQUEST NO. 41: What are the specific variables and assumptions included in the no-
harm models and analysis that if actually different than assumed, would lead to a different result?
REDACTED SECOND PRODUCTION
REQUEST TO rDAHO POWER 4 MARCH 3,2022
REQUEST NO. 42: Please provide all price quotes for proposals the Company has
received for new solar resources in the last four years including Jackpot Solar. Please include
the project, the location, the $A{Wh price (over the assumed contract period), and the nameplate
capacity of the solar resource.
REQUEST NO. 43: Please provide the hourly Mid-C price forecast from the
acknowled ged 2019 IRP in Excel format over the 2D-year model period (2019 - 2038)
REQUESTED in Boise, Idaho, Uir34 day of Mar ch2022.
tu Taylor
Deputy Attorney General
i:umisc:prodreq/ipce2l.42tbtncklsme prod req 2
REDACTED SECOND PRODUCTION
REQUEST TO IDAHO POWER 5 MARCH 3,2022
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 3'd DAY OF MARCH 2022,
SERVED THE FOREGOING REDACTED SECOND PRODUCTION REQUEST
oF THE COMMISSTON STAFF TO IDAHO POWER COMPANy, 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
BOrSE ID 83707-0070
E-MAIL: [e-mail]
[e-mail]
MICHAEL HECKLER
COURTNEY WHITE
CLEAN ENERGY OPPORTUNITIES FOR
IDAHO INC
3778 PLANTATION RIVER DR SUITE 102
BOISE,ID 83703
E-MAIL : [e-mail]
courtney@cleanenergvopportunities. com
TIM TATUM
VP REGULATORY AFFAIRS
IDAHO POWER COMPANY
PO BOX 70
BOrSE rD 83707-0070
E-MAIL: [e-mail]
KELSEY JAE
LAW FOR CONSCIOUS LEADERSHIP
920 N. CLOVER DR.
BOISE,ID 83703
E-MAIL: [e-mail]
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CERTIFICATE OF SERVICE