20220211Staff 1-37 to IPC.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:
I I33I W CHINDEN BVLD, BLDG 8, SUITE 2OI-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAIIO PUBLIC UTILITIES COMMISSION
IN TTIT' MATTER OF IDAHO POWER
COMPAI\TY'S 2021 INTEGRATED RESOTJRCE
PLAI\t
CASE NO.IPC-E-2I43
FIRST PRODUCTION
REQUEST OF THE
COMI/ilSSION STAFF TO
IDAHO POWER COMPAIIY
The Staffof the Idaho Public Utilities Commissio4 by and through its affomey of
record, Dayn Hardie, Deputy Attomey General, request that Idaho Power Company ("Company"
or "Idaho Power") provide the following documents and information as soon as possible, or by
TRIDAY, MARCH 4,2022.
This Production Request is continuing, and the Company is requested to provide, by way
of supplementary responses, additional documents rhat it or any person acting on its behalf may
later obtain that witl augment the documents produced.
Please provide answers to each question, supporting workpapers that provide detail or iue
the source of information used in calculations. The Company is reminded that responses
pursuant to Commission Rules of Procedure must include the name and phone number of the
person preparing the document, and the naille, location, and phone number of the record holder
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY
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I FEBRUARY II,2O22
and if different the witness who can sponsor the enswer at hearing if need be. See IDAPA
31.01.01.228.
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic files on CD with forrnulas activated.
REQIfEST NO. 1: Page 38 of the 2021 Integrated Resource Plan ("IRP") states that
Idaho Power operates 17 hydroelectric projects with a total nameplate capacity of 1,773 MW.
However, Table 4.2 shows l8 hydroelectric projects with a total nameplate capacity of 1,798.8
MW. Please reconcile the two amounts.
REQLTEST NO. 2: Page 88 of the 2021 IRP states that, given the lack of long-term firm
transmission availability south of NV Energy, the transmission path capacity into tlre Idaho
Power system is not included within Idatro Power's capacity planning margiry however, the path
is expected to continue to be heavily used for real-time transactions by the Energy Imbalance
Market (*EIM"). Please confirm that the transmission path still has non-firm availability for the
EIM, despite the lack of long-term firm ransmission availability.
RBQUEST NO.3: The Second Amended 2019IRP used different gas forecast levels
and different carbon cost levels to develop portfolio buildouts. See Chapter 8 of the Second
Amended 2019 IRP. However, the202l IRP only used the planning gas forecast and the
planning carbon cost to develop portfolio buildouts; different gas forecast levels and different
carbon cost levels are used in the Portfolio Cost Analysis. Please explain why different gas
forecast levels and different carbon cost levels are not used to develop portfolio buildouts in the
2021 rRP.
REQLIEST NO. 4: Table 9.2 tnthe202l IRP shows regulation reserve requirements.
Please answer the following questions.
a. How are the regulation resenre requirements determined? Please provide the
supporting workpapers.
b. Why is Wind RegDn 0%:mthe 2019IRP, but it is not 0%tnthe 2021 IRP?
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPAI.IY 2 FEBRUARY II,2O22
c. Why is Solar RegDn 0olo (except for winter) in the 2019 IRP, but it is not 0% in
the 2021 IRP?
d. Why are regulation reserve deterrnined at the seasonal level in the
2019 IRP, but they are determined at the monthly level in the 2021 IRP?
e. What is the "approximation" process in the 2021 IRP that exrapolates a single
year of regulation reserve requirements to the Z0-year planning horizon? Please
provide the supporting with all formulas intact.
f, Staffexpressed its concenrs regarding the impacts of regulation reserve shortfalls
from a reliability perspective and a cost perspective in Staffs comments in Case
No. IPC-E-19-19. Please explain whether and how the Company addresses these
issues in the 2021 IRP. (Please note the distinction between regulation reserve
requirements and planning reserve margins in answering this question)
g. Page 6 of the Second Amended 2019IRP states that Valmy Unit 2 was modeled
with the ability to provide regulation reserves, but an adjustment is made that the
unit cannot provide regulation reserves. Please explain why Vabny Unit 2 cannot
provide regulation reserves and whether Vahny Untt2 is modeled to not provide
regulation reserves in the 2021 IRP.
REQUEST NO.5: Page 99 of Appendix C of the 2021 IRP lists the average Electric
Load Carrying Capacity (*ELCC") sf sxi5ring resources and the average ELCC of future
resources. Please respond to the following.
a. Please describe how the average ELCC of existing resources and the average
ELCC of futtne resources are determined.
b. Please explain why Jackpot Solar is separated from Solar PV in detemrining
ELCC of future resources.
c. Page 138 of the 2021 IRP states that the Company utilized static ELCC values for
each resource type modeled, even though resource ELCC can vary depending on
the total resource makeup of aportfolio. Please explain why the Company
believes that static ELCC values are appropriate.
REQLIEST NO.6: Page 145 of the 2021 IRP states that the offsetting cost of selling
wheeling service using the Boardman-to-Hemingway ("B2H") capacity is not factored into the
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPAI.IY 3 FEBRUARY II,2O22
portfolio Net Present Value ('NPV"). Did the Company include wheeling revenue from its
hansmission system in any of its modeled NPV results? Please explain why it did or did not
include wheeling revenue and which scenarios/portfolios would be affected by not including it.
REQUEST NO. 7: Page 162 of the 2021 IRP states that the planning forecast for CSPP
wind includes a renewal rate of 25Yo for contracts that will expire during the IRP timeframe.
Please respond to the following.
a. Please explain why 25o/o is used in the planning forecast and how it is detennined.
b. Is25Yo assumption used in Table 10.7: July peak hour load and resource balance
table?
c. How does the Company determine which wind expiring contracts fall in the25Yo
of contracts that are renewed to include in the AURORA model and in the existing
load and resource balance, respectively?
REQUEST NO.8: Page 170 of the 2021 IRP states that "the developers of Jackpot Solar
informed the Company that the global supply chain disruptions have raised conceilrs regarding
Jackpot Solar's ability to achieve commercial operation by the dates identified in the approved
agreement." Please provide an update on the status of the project.
REQTIEST NO.9: Please provide answers and explanations to the following questions
regarding Table 10.7: July peak hour load and rcsource balance.
a- Does each year's largest deficit always occur in July?
b. Does the peak load reflect the highest load arnount for each month?
c. If so, are the resource capacity amounts determined at the same point in time when
the highest load occurs each month?
d. Please confimr that the Energy Efficiency used to adjust for peak load in Table
10.7 is determined in the Energy Efficiency Potential Study and includes existing
and future energy efficiency deemed to be cost-effective from the Utility Cost
Test.
e. Why are *EE Bundles" not used to adjust for peak load?
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 4 FEBRUARY II,2O22
f. Why are "EE Bundles" included as a New Resource in Table 10.7 of the 2021 IRP
but were not included as a New Resource in the Excel file in Response to Staffs
Production Request No. I in Case No. IPC-E-21-09?
g. Please explain the reasons for the differences in capacity arnounts between IRP
Table 10.7 and the Excel file in Response to Staffs Production Request No. I in
Case No. IPC-E-21-09.
Table 10.7 in 2021 IRP Response to StafPs
Production Request No. I
in Case No. IPC-E-21-09
Bridger 663MW 703MW
Valmy 12lMw 136MW
Langley Gulch 306MW 300Mw
Gas Peakers 365MW 4l6MW
Elkhorn 15MW 5MW
REQUEST NO. 10: Please explain how the "Available Transmission dThird-Party
Secured" are determined in Table 10.7 in the202l IRP and provide workpapers that calculate the
capacity amounts.
REQUEST NO. 11: Please respond to the following regarding Emergency Transmission
(CBIO in Table 10.7 in the 2021 IRP.
a. Please explain in detail how Capacity Benefrt Margin (*CBM") is used in the
Company's system. ln the explanation, please provide specific examples when
CBM is used, by whom (i.e, native load customers, transmission customers, etc.),
and if there ure any restrictions or circumstances when it isn't or should not be
used.
b. How is the 330 MW of CBM determined? Is the amount of CBM capacity in
addition to the rated capacity of the transmission line or is it a portion of the rated
capacity of the line? Please explain.
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 5 FEBRUARY II,2O22
c. How will CBM be used in the Northwest Power Pool's ('NWPP") Reserve
Sharing Program?
REQUEST NO. 12: The Company's Reply Comments in Case No. IPC-E-19-19 state
that FERC determined it was important for the reliability of the system for utilities to create two
margins that are deducted from Available Transfer Capacity ("ATC"): Transmission Reliability
Margin (*TRM") and CBM. Please define TRM, describe the situations in which TRM can be
used, and explain why TRM is not included in load and resource balance.
REQUEST NO. 13: Please respond to the following questions regarding non-owned
reserve capacity, which can be defined as a decrease to resource capacity representing the
capacrty required to provide reserves for load and generation by entities within the Company's
balancing authority area ("BA"{") such as a municipal or co-operative.
a. Are there any wholesale customers that operate in the Company's BAA
purchasing non-owned reserve capacity?
b. If so, what rates do these customers pay for the non-owned reserve capacity?
c. How is the non-owned reserve capacity modeled in the AURORA model and in
the load and resource balance, respectively?
REQUEST NO. 14: Direct Testimony of Jared Ellsworth in Case No. IPC-E-21-12
states thar the industry standard for resource planning is a Loss of Load Event ("LOLE") of no
more than I event in l0 years or an LOLE of 0.1 days per year. What is the source for the current
industry standard?
REQUEST NO. 15: Page I 17 of the 2021 IRP and Response to Staffs Production
Request No. 20 in Case No. IPC-E-21-32 state tbat the 0.05 days per year threshold aligns with
the reliability threshold used by the Northwest Power and Conservation Council ("NWPCC").
Please provide the specific document or report from the NWPCC to support this claim.
REQUEST NO. 16: Response to Staffs Production Request No. 9 in Case No. IPC-E-
2l-32 states that the 2021 IRP load and resource balance is based upon 50s percentile load and
50s percentile hydro, while the method behind the202l sunmer near-term operating plan
FIRST PRODUCTTON REQUEST
TO IDAHO POWER COMPANY 6 FEBRUARY II,2O22
utilized 95m percentile load and a critical water year, and that, looking solely at the Company's
assumed available existing resources for July of 2021and excluding the applied planning margin
and reserve requirements to compare the two forecasts on equal grounds, the forecasted system
deficit increases by over 200 MW when utilizing the 95ft percentile load forecast and a critical
water year. Please answer the following questions.
a. Does the Company always use the 95tr percentile load and a critical water year for
near-term operating plans? Please explain.
b. How does the Company define a critical water year?
c. Why does the Company use 50ft percentile load and 50s percentile hy&o for load
and resource balance in the IRP, but use 95s percentile load and a critical water
year for operational planning and how do they compare?
REQIIEST NO. 17: Please respond to the following questions regarding changes to the
B2H Transmission Line project (Letter to IPUC dated January 19,2022). Do the changes impact
any modehng results for the 2021IRP?
a. If yes, please provide workpapers that quantiff the impact the changes have on
capaci ty requirements.
b. If yes, please provide workpapers that quanti& the impact on Company's capacity
deficit date.
c. If yes, please describe and quantifr any changes to portfolios.
REQUEST NO. 18: Please quantifu the impact ofNWPP requirements on ELCC,
LOLE, and planning reserve margin calculations and results in the 2021 IRP.
REQIIEST NO. 19: Please verifr and provide evidence that selected portfolios achieve a
LOLE of 0.5 days per year.
REQTIEST NO.20: Please explain the analysis represented by the graph and table
provided in Response to StaffProduction Request No. 20 in Case No. IPC-E-ZI-32. ln addition
to the explanation, please provide the following:
FIRST PRODUCTTON REQUEST
TO IDAHO POWER COMPANY 7 FEBRUARY II,2O22
a. The workpapers (with formulas intact) used to calculate the amounts in the table
and the gaph.
b. The sources of information and a description for all inputs used in the workpapers.
c. The percentile(s) of the peak load forecast for each test year and for 2021 relative
to the peak load forecast included in the 2021 IRP if it were backcast to each of
the test years.
REQUEST NO.21: In the April22,202l, workshop, the Company said that regulation
requirements may be relaxed for computing efficiency resulting in potential capacity shortfalls
and loss of load. Please explain how the Company reconciled these shortfalls.
REQUEST NO. 22: In response to Audit Request No. 2 dated luly 7,2021,the
Company said that it has perforrned test scenarios with the 2019 IRP input to veriff and validate
that software enhancements will optimize for tdaho Power and that it will continue to evaluate
Long-Term Capacity Expansion (*LTCE') results during the202l IRP process to ensure the
optimal portfolio is developed. Please respond to the following.
L How did the Company evaluate the202l IRP results to ensure that the resources
selected are cost-optimized for the Company's system?
b. What is specifically being optimized for the region versus what is optimized in the
Company's system through co-optimization?
c. Are there any conflicts that can occur between the two sets of objective functions,
and if there are conflicts, how the model resolves them.
REQUEST NO. 23: In response to Audit Request 4(f) dated July 7, 2021, the Company
responded with several potential ways it will verifu that generation capacity via B2H will be
available to meet the Company's capacity deficits after the line has been built. Please provide an
update of the Company's efforts to veriff that generation will be available and provide a
timeframe when the Company will begin securing commifinents from generalors.
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 8 FEBRUARY II,2O22
REQUEST NO.24: The natural gas forecast used to develop the IRP has changed (see
Case No. IPC-E-21-35). Please explain the differences in the natural gas forecast and identifr
potential changes in the results of the IRP based on these forecast differences.
REQUEST NO.25: Please provide a status update on the B2H project. In the update,
please identiff the risks and probabilities that the transmission line will not be completed by the
timeframe included in the preferred portfolio and identifr contingencies that the Company has
developed if the project is delayed.
REQUEST NO.26: Please provide a status update on the Jackpot Solar PPA. ln the
update, please identifr the risks and probabilities that the project will not be completed and
identiff contingencies that the Company has developed if the project is cancelled or delayed.
REQIIEST NO.27: Please describe how storage costs are forecasted considering the
rapid decrease in utility-scale battery storage costs.
REQUEST NO.28: Please provide a list of all storage technologies that the Company
considered and evaluated. Did the company include internal historical storage technology data?
REQUEST NO.29: Did the Company model degradation of battery storage? If so,
please describe how it was modeled.
REQUEST NO. 30: Regarding the statement on page 5l of the IRP, "The primary
source of cost information for the 2021 IRP is the 2020 Annual Technology Baseline report
released by the National Renewable Energy Laboratory NREL) in July 2020." What other
infonnation sources were used or considered?
REQUEST NO.31: Have any candidate distributed storage project locations been
finalized or implemented?
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 9 FEBRUARY II,2O22
REQUEST NO. 32: For the storage capacity included in the 3 lowest cost portfolios,
please provide a breakdown of the types of storage included (battery, pump€d hydro, etc.)
REQUEST NO.33: Please provide the amount of the incremental transmission wheeling
revenue credit that was included for B2H portfolios and explain how the amount was developed.
Also, please provide the workpapers with formulas intact that deterrrined the arnount of the
credit.
REQIIEST NO.34: Regarding the impact of the additional resource cost from the20l9
preferred portfolio included in the 2021 sales and load forecast how much would the sales and
load forecast change if the additional resource cost from the 2021 IRP preferred portfolio was
used instead of the resource cost from the 2019 preferred portfolio?
REQIIEST NO.35: Please provide the tables on pages 66 through 88 in Appendix C of
the202l IRP in Excel fonnat.
REQIIEST NO.36: Please provide the total NPV and annual cost/value strearns over the
2}-year planning horizon for each of the portfolios that were run through the portfolio cost
analysis. For each of the annual cost and value streams, please provide an annual breakdown by
fixed and variable cost. For fixed cost please break down the costs firther by fixed O&M and
capital cost. For variable cost, at a minimr,m, please provide a breakdown by purchased power
net power cost ('T.IPC'), PURPA NPC, company-generation NPC, surplus sales, demand
response (*DR") incentive payments, third-party transmission, and REC revenue. Please provide
in Excel fonnat with all formulas enabled.
REQUEST NO.37: For each of the portfolios that were run through the portfolio cost
analysis, please provide a breakdown of the annual Megawatt-hours from each of the supply-side
resources (including DR) included in the IRP across the 20-year planning horizon. Please
provide in Excel forrnat with all formulas enabled.
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPAI.IY 10 FEBRUARY II,2O22
DATED dBoisc,I&ho, this fltr dayofFebruary 2A22.
De[nfyAtumsy G,emeral
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FIRST PRODUCIIOI{ REQUEST
TO IDAHOPCIWERCOMPAIVY 11 FEBRUARY II"2W2
CERTIHCATE OF SERVICE
I TIEREBY CERTIFY THAT I I{AVE THIS l ITH DAY OF FEBRUARY 2022,
SERVED THE FOREGOING FIRST PRODUCTION REQTIEST OF TIIE
COMIVtrSSION STAFF, IN CASE NO. IPC-E-2143, BY E-MAILING A COPY
TI{EREOF, TO TTM FOLLOWING:
SECRETARY
LISA NORDSTROM
IDAHO POWER COMPANY
PO BOX 70
BOrSE tD 83707-0070
E-MAIL: lnordstrom@,idahopower.com
dockets@idahopower. com
TIM TATUM
ALLISON WILLIAMS
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL : [e-mail]
awi I liams@,idahopower. com
KIKI LESLTE A. TIDWELL
704 N. RIVER ST. #I
HAILEY ID 83333
E-MAIL: [e-mail]
BENJAMIN J OTIO
EMMA E. SPERRY
ID CONSERVATION LEAGUE
7IO N 6TH ST
BOISE TD 83702
E-MAIL: [e-mail]
esperr.v @idahoconservation. org
PETER J RICHARDSON
RICHARDSON ADAMS PLLC
515 N 27TH STREET
BOISE D 83702
E-MAIL: peter@richardsonadams. com
DR DON READING
6070 HILL ROAD
BOISE ID 83703
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE