20220321ICL 1-10 to IPC.pdf

IPC-E-21-43 March 22, 2022 ICL FIRST PRODUCTION REQUEST 1
Benjamin J. Otto (ISB No. 8292) 710 N 6th Street
Boise, ID 83701 Ph: [phone] [e-mail]
Attorney for the Idaho Conservation League
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
POWER COMPANY’S 2021
INTEGRATED RESOURCE PLAN.
)
) ) FIRST PRODUCTION REQUST OF THE IDAHO CONSERVATION
COMES NOW the Idaho Conservation League, with the following production requests.
Along with the answer to each question, please provide any supporting documents, workpapers,
calculations, or information sources Idaho Power relies upon to support its answer. As required
by IDAPA 31.01.01.228.02, please indicate the witness who can answer question regarding the
response and who will sponsor the response at any hearing. If any responses include Excel
spreadsheets or other electronic files, please provide them with all formulas intact and activated.
As allowed by IDAPA 31.01.01.228.01, if the volume of any response indicates it would be
more feasible to do so ICL agrees to the Company depositing the response in an electronic
depository.
This production request is ongoing. Accordingly, we respectfully ask Idaho Power to
provide additional documents and information that may supplement any initial responses.
Request No 1:
Please refer to the Preferred Portfolio and Action Plan on pages 151-153 of the 2021 IRP.
a. Please provide a list of all permits and other necessary approvals required to convert
Bridger units 1 and 2 from coal to gas.
b.Please describe when Idaho Power will receive each required approval.
c.If Idaho Power intends to rely on the operating partner, PacifiCorp, to secure each
approval, please explain how Idaho Power will protect Idaho Power customers
interest in each process.
RECEIVED
2022 MAR 21 PM 2:02
IDAHO PUBLIC
UTILITIES COMMISSION
IPC-E-21-43 March 22, 2022 ICL FIRST PRODUCTION REQUEST 2
d. Please provide a list of all equipment and infrastructure necessary to receive gas at
the Bridger site and convert units 1 and 2 to gas-fired operations.
e. Please describe how Idaho Power will ensure the necessary infrastructure and
equipment is in place and operational by summer 2024.
f. If Idaho Power intends to rely on the operating partner, PacifiCorp, to manage the
acquisition and installation of all necessary equipment and resources, please explain
how Idaho Power’s customers' interest will be protected.

Request No 2:
Please provide the Net Present Value and annual costs for the Clean Energy by 2035 and Clean
Energy by 2040 portfolios in the same format as Response to Staff Production Request 36.

Request No 3:
Please provide the portfolio emission forecast for all of the portfolios with Long-Term Capacity
Expansion Results in Appendix C pages 66 - 88.

Request No 4:
Please provide a complete documentation of the natural gas price forecast used in the 2021 IRP
including all narrative descriptions of the methodology, data sources, analysis, and conclusions.

Request No 5:
Please describe how Idaho Power balances the costs and risks, both quantitative and qualitative,
when assessing portfolio options. For example, does Idaho Power weigh these three factors
differently, and if so, how?

Request No 6:
Please refer to the 2021 IRP page 122 that describes the 100% Clean by 2035 and 100% Clean
by 2045 Scenarios. Please explain why Idaho Power replaced the retired gas plants with a
nuclear resource instead of allowing the Aurora model to select an optimal resource.

Request No 7:
IPC-E-21-43 March 22, 2022 ICL FIRST PRODUCTION REQUEST 3
Please refer to the 2021 IRP page 122 that describes the 100% Clean by 2035 and 100% Clean
by 2045 Scenarios.
a. Please explain why Idaho Power modeled 100% clean energy WECC wide along
with 100% Clean for Idaho Power’s system.
b. Please identify any costs added to the 100% clean portfolios attributed to achieving
the WECC wide goal.

Request No 8:
Please explain why Idaho Power limited the SWIP North evaluation to 200 MW share of the
south-to-north capacity when the project has a WECC-approved path rating for approximately
2,000 MW bidirectionally.

Request No 9:
Please refer to the Jim Bridger plant forecasts on pages 102-103 of the 2021 IRP.
a. Please describe and quantify the fuel costs associated with the Bridger coal plant
including any take-or-pay assumptions included in the Aurora modeling.
b. Please explain if Idaho Power caused the Aurora capacity expansion model to
assume the Bridger plant must run to meet any take-or-pay coal contract minimum
quantities.
c. If Idaho Power included Bridger must run assumptions in the Aurora modeling,
please provide capacity expansion and portfolio cost results that remove this must
run assumption.

Request No 10:
Please refer to the gas plant resource forecasts on page 103 of the 2021 IRP.
a. Do Idaho Power’s gas supply contracts include any minimum take amounts and, if
so, please describe the level and timing of these amounts in detail.
b. Did Idaho Power assume any amount of must run gas resources in the Aurora
modeling?
IPC-E-21-43 March 22, 2022 ICL FIRST PRODUCTION REQUEST 4
c. If Idaho Power included must run assumptions for gas resources in the Aurora
modeling, please provide capacity expansion and portfolio cost results that remove
this must run assumption.

Respectfully submitted this 21st day of March 2022.
__________
Benjamin J. Otto
Idaho Conservation League
IPC-E-21-43 March 22, 2022 ICL FIRST PRODUCTION REQUEST 5
CERTIFICATE OF SERVICE
I hereby certify that on this 21st day of March 2022, I delivered true and correct copies of the foregoing FIRST PRODCUTION REQUEST to the following persons via the method of service noted:
_______ Benjamin J. Otto

Electronic mail only (See Order 35058): Idaho Public Utilities Commission Jan Noriyuki, Secretary
[e-mail]
Dayn Hardie, Deputy Attorney General [e-mail]

Idaho Power Lisa D. Nordstrom Timothy E. Tatum Allison Williams
[e-mail]
[e-mail] [e-mail] [e-mail]
Individual
Kiki Leslie A. Tidwell, pro se [e-mail] Industrial Customers of Idaho Power
Peter J. Richardson
Richardson, Adams, PLLC [e-mail] Dr. Don Reading
[e-mail]

Clean Energy Opportunty for Idaho Michael Heckler
Courtney White
[e-mail] [e-mail] Kelsey Jae
Law for Conscious Leadership
[e-mail] Micron Technology Jim Swier
Micron Technology, Inc
[e-mail] Auston Rueschhoff Thorvald A. Nelson
Austin W. Jensen
Holland & Hart, LLP [e-mail] [e-mail] [e-mail]
[e-mail]

StopB2H Jim Kreider StopB2H Coalition
[e-mail]
Jack Van Valkenburgh Van Valkenburgh Law, PLLC [e-mail]