20220412Staff 38-42 to IPC-Revised.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:
1 1331 W CHINDEN BVLD, BLDG 8, SUITE 2OI-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S 2021 INTEGRATED RESOURCE
PLAN
CASE NO.IPC.E-21.43
REVISED SECOND
PRODUCTION REQUEST OF
THE COMMISSION STAFF TO
IDAHO POWER COMPANY
The Staff of the Idaho Public Utilities Commission, by and through its attorney of
record, Dayn Hardie, Deputy Attorney General, request that ldaho Power Company
("Company") provide the following documents and information as soon as possible, or by
TUESDAY, MAY 3,2022.
This Production Request is continuing, and the 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 produced.
Please provide answers to each question, supporting workpapers that provide detail or are
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 name, location and phone number of the record holder
REVISED SECOND PRODUCTION
REQUEST TO IDAHO POWER COMPANY 1
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APRIL 12,2022
and if different the witness who can sponsor the answer at hearing if need be. Reference 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 formulas activated.
REQUEST NO.38: Page 99 of Appendix C of the Integrated Resource Plan ("IRP")
lists the Effective Load Carrying Capability ("ELCC") values of Proposed Demand Response and
Incremental Demand Response. Please define these two items and explain their differences.
REQUEST NO. 39: According to Response to Staffls Production Request No. 13, the
ancillary services purchased by network customers within the Company's Balancing Authority
Area are covered as part of the planning reserve margin utilized in the 2021 IRP analysis. Please
respond to the following:
a. Please confirm that the load forecast in the 2021 IRP analysis includes the load of the
network customers. If not, please explain why.
b. Please describe the relationship between Capacity Benefit Margin ("CBM") and the
ancillary services mentioned above.
c. Response to Stafls Production Request No. 1l states that CBM can be used by Load
Serving Entities within the Company's Balancing Authority, which includes the
Company's native load and third-party network load. Please explain how CBM is
allocated between the native load and third-party network load.
d. Please explain the rates that the network customers pay for the CBM services and how
the rates are determined.
REVISED SECOND PRODUCTION
REQUEST TO IDAHO POWER COMPANY 2 APRIL 12,2022
REQUEST NO. 40: Please respond to the following prompts regarding the Northwest
Power Pool ("NWPP") Reserve Sharing Programl (the contingency reserve sharing program):
a. Please describe the Company's responsibilities and benefits from the program.
b. Please explain whether this program is reflected in the load and resource balance.
c. If not included in the load and resource balance, please explain why.
REQUEST NO.41: Page 100 of Appendix C of the 2021 IRP shows Portfolio
Reliability Results. The results show the Preferred Portfolio information below. Why do these
years need additional resources when they all meet a l-in-20 Loss of Load Expectation ("LOLE")
target?
Year LOLE (d/yr)Additional Generation Resources
(Mw)
2037 0.049s 7
2038 0.0445 3
2039 0.0487 l5
2040 0.0496 t6
REQUEST NO.42: The load and resource balance in Table 10.7 of the 2021 IRP uses
the peak load, which is the highest load amount for each month, and the resource capacity
determined as a nameplate capacity with an equivalent forced outage rate applied or an ELCC
value primarily driven by the timing of high Loss of Load Probabilitv ("LOLP") hours. See
Response to Staff s Production Request No. 9 and page 96 of Appendix C of the 2021 IRP.
Please answer the following questions:
lhttps://www.nwpp.ors/private-media/documents,t{WPP_RSC_Program Documentation -
RSG Approved 2022 0ll2.pdf
REVISED SECOND PRODUCTION
REQUEST TO IDAHO POWER COMPANY 3 APRIL 12,2022
a. Are the highest LOLP hours the same as the time of peak load? Please explain. If not,
why doesn't the Company align the timing in determining load and resources?
b. Is the time of largest deficit for every hour across the year the same as the time of
highest LOLP hours? Please explain.
c. Is it possible that the largest deficit of a year occurs outside the high LOLP hours?
Please explain.
DATED at Boise, Idaho, ui, lbaay of April 2022.
Deputy Attorney General
i:umisc:prodreq/ipce2l.43dhyy prod req2
REVISED SECOND PRODUCTION
REQUEST TO rDAHO POWER COMPANY 4 APRIL 12,2022
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 12TH DAY OF APRIL 2022,
SERVED THE FOREGOING REVISED SECOND PRODUCTION REQUEST OF
THE COMMISSION STAFF TO IDAHO POWER COMPANY, IN CASE NO.
TPC-E-21-43, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
LISA NORDSTROM
IDAHO POWER COMPANY
PO BOX 70
BOISE rD 83707-0070
E-MAIL: [e-mail]
dockets@ idahopower. com
KIKI LESLIE A. TIDWELL
704 N. RIVER ST. #I
HAILEY ID 83333
E-MAIL : [e-mail]
PETER J RICHARDSON
RICHARDSON ADAMS PLLC
5I5 N 27TH STREET
BOISE ID 83702
E-MAIL: [e-mail]
KELSEY JAE
LAW FOR CONSCIOUS LEADERSHIP
920 N CLOVER DR
BOISE ID 83703
E-MAIL: kelsey@.kelsevjae.com
TIM TATUM
ALLISON WILLIAMS
IDAHO POWER COMPANY
PO BOX 70
BOISE rD 83707-0070
E-MAIL: [e-mail]
awill [e-mail]
BENJAMIN J OTTO
EMMA E. SPERRY
ID CONSERVATION LEAGUE
7IO N 6TH ST
BOISE TD 83702
E-MAIL: [e-mail]
esperr.v @ idahocon servation. or g
DR DON READING
6070 HILL ROAD
BOISE ID 83703
E-MAIL: [e-mail]
MICHAEL HECKLER
COURTNEY WHITE
CLEAN ENERGY OPPORTUNITIES FOR
IDAHO INC
3778 PLANTATION RIVER DR
SUITE IO2
BOISE ID 83703
E-MAIL:
[e-mail]
courtney @,cleanenergyopportunities. com
CERTIFICATE OF SERVICE
AUSTIN RUESCHHOFF
THORVALD A NELSON
AUSTIN W JENSEN
HOLLAND & HART LLP
555 ITTH ST STE 32OO
DENVER CO 80202
E-MAIL : [e-mail]
tnel son@hollandhart. com
awj ensen@.hollandhart. com
aclee@hollandhart. com
el gareanoamari@hollandhart. com
JACK VAN VALKENBURG
VAN VALKENBURG LAW PLLC
PO BOX 531
BOISE ID 83701
E-MAIL: [e-mail]
JIM SWIER
MICRON TECHNOLOGY INC
SOOO S FEDERAL WAY
BOISE ID 83707
E-MAIL: [e-mail]
JIM KREIDER
STOP B2H COALITION
60366 MARVIN RD
LA GRANDE OR 97850
E-MAIL: [e-mail]
-b ilA^^,^
SECRETARY
CERTIFICATE OF SERVICE