20220411IPC to ICL 1-10.pdf

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April 1 1,2022
VIA ELECTRONIC EMAIL
Jan Noriyuki, Secretary
ldaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg 8,
Suite 201-A (83714)
PO Box 83720
Boise, ldaho 83720-0074
Case No. IPC-E-2143
ln the Matter of ldaho Power Company's 2021 lntegrated Resource Plan
Dear Ms. Noriyuki:
Attached for electronic filing, pursuant to Order No. 35058, is ldaho Power
Company's Response to the First Production Request of ldaho Conservation League in
the above entitled matter.
An ID COIP Comp.ny
LISA D. NORDSTROM
Lead Goungel
[e-mail]
LDN:sg
Enclosures
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Re
The confidential attachment will be provided under separate cover to the parties
who have signed the Protective Agreement in this matter.
lf you have any questions about the attached documents, please do not hesitate
to contact me.
Very truly yours,
Lisa D. Nordstrom
LISA D. NORDSTROM (lSB No. 5733)
ldaho Power Company
1221 West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
ln ord strom@ida h opower. com
Attorney for ldaho Power Company
BEFORE THE !DAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S 2021 I NTEGRATED
RESOURCE PLAN.
CASE NO. IPC-E.2143
IDAHO POWER COMPANY'S
RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE
I DAHO CONSERVATION LEAGU E
COMES NOW, ldaho Power Company ("ldaho Power' or "Company"), and in
response to the First Production Request of the ldaho Conservation League ('lCL')
dated March 21,2022, herewith submits the following information:
IDAHO PO\A'ER COMPANY'S RESPONSE TO THE F]RST PRODUCTTON REQUEST OF THE IDAHO
CONSERVATION LEAGUE.l
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REQUEST FOR PRODUCTION NO. 1: Please refer to the Preferred Portfolio
and Action Plan on pages 151-153 of the 2021 lRP.
a. Please provide a list of al! permits and other necessary approvals required to
convert Bridger units 1 and2 from coalto gas.
b. Please describe when ldaho Power will receive each required approval.
c. lf ldaho Power intends to rely on the operating partner, PacifiCorp, to secure
each approval, please explain how ldaho Power will protect ldaho Power
customers interest in each process.
d. Please provide a Iist 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 ldaho Power will ensure the necessary infrastructure
and equipment is in place and operationa! by summer 2024.
f. lf ldaho Power intends to rely on the operating partner, PacifiCorp, to manage
the acquisition and installation of all necessary equipment and resources,
please explain how ldaho Power's customers' interest will be protected.
RESPONSE TO REQUEST FOR PRODUCTION NO. 1:
a. The following permits may need to be in place before completion of the
natural gas conversion:
1. MountainWest Pipeline (formerly Dominion Energy) is responsible for
permitting for the gas delivery pipeline outside the plant fence. A
precedent agreement is currently being negotiated by PacifiCorp,
ldaho Power and MountainWest. Once signed, MountainWest will
perform studies to determine allthat is required for permitting.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE IDAHO
CONSERVATION LEAGUE- 2
2. BLM Right of Way may be required outside the fence. The pipeline will
be routed across disturbed !and.
3. Federal Certificate of Public Convenience and Necessity ('CPCN")
may be required depending on environmentalstudies on the proposed
route.
4. An application is currently being prepared to submit to the V1&oming Air
Quality Division to authorize the conversion of Units 1 and 2 to natural
gas.
5. A request wil! also be submitted to the State of h/yoming to revise their
regional haze State lmplementation Plan (.SlP') in April 2022.
6. Upon receipt of Vfoming's air permit for the gas conversions, the
permit will include a condition requiring an application to revise the
Title V permit following "completion of construction". There will be a
12-month deadline to submit the application following startup of the
gas conversions; however, the application will be submitted as quickly
as possible following receipt of a project authorization permit.
b. To the extent known by Idaho Power, the estimated permit timelines are
discussed in response (a).
c. ldaho Power is involved in the discussion and negotiations with
MountainWest and PacifiCorp. ldaho Power is also working with the
operating partner (PacifiCorp) through the entire process to secure each
approval, including the natural gas equipment supplier bids and selection and
the installation contractor through plant visits, ownership meetings, and other
IDAHO POVVER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE IDAHO
CONSERVATION LEAGUE.3
calls/meetings.
d. The following equipment has been identified for the natural gas conversion
"Outside of Fence" - Owned and permitted by gas supplier
. Gas pipeline about 1.5 miles
. Particulateseparator
. Safety relief valve
. Pressure regulating valve
. Gas line heater
. Metering station
"lnside of Fence" - Owned and performed by plant ownens
. Piping from fence to units - lf above ground will also require pipe rack
structure.
. Constant High pressure regulating station.
. lnert gas purging system
. Gas coalescer/particulate filter - Pending design
. Safety relief valves
. Shut off valves
. Pressure reducing valve station (each unit)
. Flow Metering Station (each unit)
. Gas Burner flow Control station (each unit)
. Gas lgniter flow control station (each unit)
. Burner and ignitor vent valves (each unit)
. Gas leak monitoring and alarming system
IDAHO POVVER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE IDAHO
CONSERVATION LEAGUE-4
. Additional Burner Management System (BMS) modules and relays for
Distributed Control System (DCS)
. 20 Gas burners and burner tips (each unit)
. 20 Gas ignitors (each unit)
. 20 Flame proving scanners (each unit) - Pending design
. Primary air duct modifications - Pending design
e. ldaho Power, PacifiCorp, and the contractors are working together to ensure
the project will be completed by summer 2024. ldaho Power will remain in
contact with the operating partner, and contractors as necessary. ldaho
Power believes that competent Project Managers have been assigned to the
conversion by PacifiCorp and they have allthe necessary resources. This
project is supported by a large team of corporate and plant employees with
the skills to ensure an on-time completion. ldaho Power will be engaged
through plant visits, ownership meetings, and other calls/meetings to protect
ldaho Powe/s customers' interest.
f. Please see response (e).
The response to this Request is sponsored by John Carstensen, Joint Projects
Leader, ldaho Power Company.
IDAHO PO\A'ER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE IDAHO
CONSERVATION LEAGUE- 5
REQUEST FOR PRODUCTION 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 2: The Net Present Value
and annual costs for the Clean Energy by 2035 and2045l scenarios is not available
because ldaho Power ran Long term Capacity Expansion AURORA models for the 2035
and 2045 scenarios, but not a costing level AURORA run. The 2035 and 2045 Clean
Energy scenarios were analyzed to compare resource selection to the preferred
portfolio. Costing runs would require additional assumptions and analysis not performed
as part of the 2021 IRP analysis.
The response to this Request is sponsored by Jared Hansen, Resource Planning
Leader, ldaho Power Company.
1 The request notes a Clean by 2O40 portfolio, however, the Company did not run this scenario. The
Company evaluated Clean by 2035 and 2045 scenarios.
IDAHO POVVER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE IDAHO
CONSERVATION LEAGUE- 6
REQUEST FOR PRODUCTION 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 3: The portfolio emission
forecast for all portfolios with Long-Term Capacity Expansion ('LTCE') results is
provided in the Excel attachment to this request.
The response to this Request is sponsored by Jared Hansen, Resource Planning
Leader, Idaho Power Company.
IDAHO POVVER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE IDAHO
CONSERVATION LEAGUE- 7
REQUEST FOR PRODUCTION 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 4: The planning
conditions natural gas forecast used in the 2021 IRP was provided by S&P Global
Platts, and a discussion of their methodology can be found in the 2021 IRP report
section'NaturalGas Price Forecast" starting on page 103. The naturalgas price
forecast is included as ConfidentialAttachment 1 to this response.
As discussed in the .Natural Gas Price Forecast" section of the 2021 lRP, ldaho
Power tested the impact of higher gas prices in the IRP by using Energy lnformation
Administration's ('ElAs") Low Oil & Gas Supply forecast from EIA's Annual Energy
Outlook 2021. A detailed discussion of EIA's methods and sources can be found in their
Annual Energy Outlook 2021.
The response to this Request is sponsored by Jared Hansen, Resource Planning
Leader, ldaho Power Company.
IDAHO POIA'ER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE IDAHO
CONSERVATION LEAGUE- 8
REQUEST FOR PRODUCTION NO.5: Please describe how ldaho Power
balances the costs and risks, both quantitative and qualitative, when assessing portfolio
options. For example, does ldaho Power weigh these three factors differently, and if so,
how?
RESPONSE TO REQUEST FOR PRODUCTION NO. 5: The full discussion of
risk, both quantitative and qualitative, when assessing portfolio options can be found in
the 'Cost Analysis' and 'Risk Analysis' sections in Chapter 10 of the 2021 IRP Report.
Additionally, the 'Stochastic Risk Analysis' section of the 2021 IRP technical Appendix C
assesses the effect on portfolio costs when certain variables differ from the planning
case levels.
The response to this Request is sponsored by Jared Hansen, Resource Planning
Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE IDAHO
CONSERVATION LEAGUE- 9
REQUEST FOR PRODUCTION NO.6: Please referto the2021 lRP page 122
that describes the 100 o/o Clean by 2035 and 100% Clean by 2045 Scenarios. Please
explain why ldaho Power replaced the retired gas plants with a nuclear resource instead
of allowing the Aurora model to select an optimal resource.
RESPONSE TO REQUEST FOR PRODUCTION NO. 6; ldaho Power allowed
the AURORA model to make resource selections in the 100 percent clean by 2045
scenario and did not replace retired gas plants with nuclear resources in that scenario
For the 100 percent clean by 2035 scenario, the AURORA model was also
allowed to make resource selections. However, ldaho Power did replace the retired gas
plants with a nuclear resource of equivalent effective capacity. As stated in the 2021
lRP report on page 122,
The AURORA model struggled to obtain a robust solution to
achieve zero emissions, WECC-wide, by 2035. To achieve a
solution lor a 100 percent clean ldaho Power system by
2035, the company modeled ldaho Power gas unit
retirements starting in early 2030, through 2035. The
company replaced the retired gas with a non-emitting
nuclear resource. The struggles of the model to achieve a
100 percent Clean by 2035 scenario are indicative of the
challenges faced by the industry to meet a 100 percent clean
target given technologies commercially available today.
Technology breakthroughs, such as cost-effective long-
duration energy storage, nuclear energy, or hydrogen, will
likely be required to meet this goal.
The nuclear resource was used as a proxy'clean flexible generating resource" to
replace the retired natural gas plants
The response to this Request is sponsored by Jared Hansen, Resource Planning
Leader, Idaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE IDAHO
CONSERVATION LEAGUE- 1 O
REQUEST FOR PRODUCTION NO.7: Please referto the2A21 lRP page 122
that describes the 100o/o Clean by 2035 and 100% Clean by 2045 Scenarios.
a. Please explain why ldaho Power modeled 100o/o clean energy WECC wide
along with 100% Clean for Idaho Power's system.
b. Please identify any costs added to the 10Qo/o clean portfolios attributed to
achieving the WECC wide goa!.
RESPONSE TO REQUEST FOR PRODUCTION NO. 7:
a. ldaho Power modeled 100 percent clean energy Western Electricity
Coordinating Council (.WECC') wide along with 100 percent Clean energy for
ldaho Power's system only for the 100 percent Clean by 2045 scenario. The
AURORA model struggled with modeling 100 percent clean energy by 2035
for the WECC, as noted on the 2021 IRP Report page 122.ldaho Power
chose to mode! 100 percent clean energy for the WECC region in the clean
by 2045 scenario to represent possible WECC/nationwide clean energy
policies that could potentially be in place by 2045.
b. ldaho Power did not perform costing level portfolio runs in the AURORA
modelfor the "clean by" scenarios that could identiff costs added or
subtracted by the \NECC goal.
The response to this Request is sponsored by Jared Hansen, Resource Planning
Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE IDAHO
CONSERVATION LEAGUE- 11
REQUEST FOR PRODUCTION NO.8: Please explain why ldaho Power limited
the SWIP North evaluation to 200 MW share of the south{o-north capacity when the
project has a WECC-approved path rating for approximately 2,000 MW bidirectionally.
RESPONSE TO REQUEST FOR PRODUCTION NO. 8: The full SWP-North
bidirectional capability was modeled in the production cost model simulation. For the
long-term capacity expansion modeling portion of the analysis, the capacity contribution
credit toward meetings ldaho Power's peak was limited to 100 megawatt('Mw') during
summer and 200 MW during winter with ldaho Power having a2OO MW south-to-north
ownership share of the project for load service. Summer capacity from the ownership
share was discounted to account for possible limitations from the southern market hubs
during the summer.
This project was evaluated in a sensitivity case in the 2021 IRP to determine
whether further exploration is warranted. Given the results, the Company plans to
engage in discussions with the developer so that ldaho Power may perform a more
detailed evaluation in future lRPs.
The response to this Request is sponsored by Curtis Westhoff, System
Consulting Engineer, ldaho Power Company.
IDAHO PO\A'ER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE IDAHO
CONSERVATION LEAGUE- 12
REQUEST FOR PRODUCTION NO. 9: Please refer to the Jim Bridger plant
forecasts on pages 102-103 of the 2021 lRP.
a. Please describe and quantiff the fuel costs associated with the Bridger coal
plant including any take-or-pay assumptions included in the Aurora modeling.
b. Please explain if ldaho 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. lf ldaho Power included Bridger must run assumptions in the Aurora
modeling, please provide capacity expansion and portfolio cost results that
remove this must run assumption.
RESPONSE TO REQUEST FOR PRODUGTION NO. 9:
a. ldaho Power internally developed a coalfuelforecast for Bridger using fueling
requirements from the 2019 IRP, the most recent operating budgets from
Bridger Coa! Company, and contracted and forecasted coalvolumes needed
from its third-party coal supplier Black Butte Coal Company. Available supply
and forecasted costs/prices from these fuelsources were combined to
determine a forecasted delivered coa! cost for the Jim Bridger plant, stated in
dollars per million British Thermal Units ("mmBTU's"). fhe2021 IRP Bridger
coal fuel forecast calculations, assumptions and inputs are provided in the
attached confidentia! Excel workbook.
b. Jim Bridger units are modeled as must run resources to mimic typical
operation of the units.
c. ldaho Power does not have capacity expansion or portfolio cost results that
IDAHO POIA'ER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE IDAHO
CONSERVATION LEAGUE- 1 3
model the Jim Bridger unite under a different set of operating assumptions.
The response to thia Request is sponsored by Jared Hansen, Resource Planning
Leader, ldaho Power Company.
IDAHO PO\'\ER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE IDAHO
CONSEFIVATION LEAGUE- 1 4
REQUEST FOR PRODUCTION NO. 10: Please refer to the gas plant resource
forecasts on page 103 of the 2021 lRP.
a. Do ldaho Powe/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 ldaho Power assume any amount of must run gas resources in the
Aurora modeling?
c. lf ldaho 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 10:
a. ldaho Power's gas supply does not currently or $pically include "minimum
take" and no such provisions were modeled in the 2021 lRP.
b. ldaho Power did not model its gas resources as must run.
c. N/A, see response to "b."
The response to this Request is sponsored by Jared Hansen, Resource Planning
Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE IDAHO
CONSERVATION LEAGUE- 1 5
DATED at Boise, ldaho, this 11th day of April 2A22.
,f*fr-ff"ur.-*,
LISA D. NORDSTROM
Attomey for ldaho Power Company
IDAHO POYT,ER COITIIPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE IDAHO
CONSERVATION LEAGUE. 16
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 1 1th day of April 2022, I served a true and
correct copy of ldaho Power Company's Response to the First Production Request of
the ldaho Conservation League upon the following named parties by the method
indicated below, and addressed to the following:
Commission Staff
Dayn Hardie
Deputy Attorney General
ldaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg No.8,
Suite 201-A (83714)
PO Box 83720
Boise, lD 83720-0074
ldaho Conservation League
Benjamin J. Otto
Emma E. Sperry
ldaho Conservation League
710 N. 6th Street
Boise, ldaho 83702
Kiki Leslie Tidwell
704 N. River Street #1
Hailey, lD 83333
Micron Technology, lnc.
Austin Rueschhoff
Thorvald A. Nelson
Austin Jensen
Holland & Hart LLP
555 17th Street, Suite 3200
Denver, CO 80202
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esperrv@ ida hoconservation. o rq
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awiensen @ hol la nd ha rt.com
aclee@hollandha rt.com
q [e-mail]
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE IDAHO
CONSERVATION LEAGUE- 1 7
Jim Swier
Micron Technology, lnc.
8000 South FederalWay
Boise, lD 83707
Clean Energy Opportunities for ldaho
Kelsey Jae
Law for Conscious Leadership
920 N. Clover Dr.
Boise, lD 83703
Michael Heckler
Courtney Vftite
Clean Energy Opportunities for ldaho lnc.
3778 Plantation River Dr., Ste. 102
Boise, lD 83703
lndustrial Customers of ldaho Power
Peter J. Richardson
Richardson Adams, PLLC
515 N.27th Street
Boise, ldaho 83702
Dr. Don Reading
6070 Hill Road
Boise, ldaho 83703
STOP B2H Coalition
Jack Van Valkenburgh
Valkenburgh Law, PLLC
P.O. Box 531
Boise, ldaho 83701
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cou rtnev@cleane nerovopportu n ities.com
michael (daleanene ities.com
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IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE IDAHO
CONSERVATION LEAGUE- 1 8
Jim Kreider
STOP B2H Coalition
60366 Marvin Rd
La Grande, OR 97850
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\n "-^t euAJ=
Stacy Gust, Regulatory Administrative
Assistant
IDAHO POVIJER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE IDAHO
CONSERVATION LEAGUE. 1 g
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
GASE NO. IPC-E-21-43
IDAHO POWER COMPANY
REQUEST NO.3
ATTACHMENT NO. 1
SEE ATTACHED SPREADSHEET
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
GASE NO. IPC-E-21-43
IDAHO POWER COMPANY
CONFIDENTIAL
REQUEST NO.4
ATTACHMENT NO. 1
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-21-43
IDAHO POWER COMPANY
CONFIDENTIAL
REQUEST NO.9
ATTACHMENT NO. 1