20220503IPC to Staff 38-42.pdf

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May 3, 2022
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VIA ELECTRONIC Ei'A!L
Jan Noriyuki, Secretary
ldaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg 8,
Suite 2o1-A(83714)
PO Box 83720
Boise, ldaho 83720-0074
Re: Case No. IPC-E-2143
ln the Matter of ldaho Power Company's2021 lntegrated Resource Plan
Dear Ms. Noriyuki:
Attached for electronic filing is ldaho Power Company's Response to the Second
Production Request of the Commission Staff in the above-entitled matter.
lf you have any questions about the attached document, please do not hesitate to
contact me.
Very truly yours,
An E^iOORP OomDrry
LISA D. NORDSTRO]UI
Lead Gounsel
[e-mail]
LDN:sg
Enclosures
X;!.(^t t,-*,
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]
lnordstrom@ idahopowe r.com
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO PO\A'ER
COMPANY'S 2021 INTEGRATED
RESOURCE PLAN.
CASE NO. |PC-E-2143
IDAHO PO\A/ER COMPANY'S
RESPONSE TO THE REVISED
SECOND PRODUCTION REQUEST
OF THE COMMISSION STAFF
COMES NOW ldaho Power Company ("ldaho Powef or'Companf), and in
response to the Second Production Request of the Commission Staff ("Commission' or
"Staff) dated April 12, 2022, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF.l
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REQUEST FOR PRODUCTION NO.38: Page 99 of Appendix C of the
lntegrated Resource Plan ("lRP") lists the Effective Load Carrying Capability (ELCC')
values of Proposed Demand Response and lncremental Demand Response. Please
define these two items and explain their differences.
RESPONSE TO REQUEST FOR PRODUCTION NO. 38: The "Proposed
Demand Response" represents ldaho Power's current Demand Response ('DR')
portfolio under the proposed parameter changes as described in the Application and
testimony filed in Case No. IPC-E-21-32. The "lncremental Demand Response'
represents new DR that is not yet in the Company's current DR portfolio but could be
implemented in future years. As shown in Table 11.2 on page 1 52 ol ldaho Power's
2021 lRP, the Proposed Demand Response is represented by the 300 MW shown in
2022while the 20 MW bundles shown in years 2023,2025, and 2038-2040 represent
the lncremental Demand Response selected by the AURORA modelfor the Preferred
Portfolio.
The response to this Request is sponsored by Jared Hansen, Resource Planning
Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF.2
REQUEST FOR PRODUCTION NO. 39: According to Response to Staffs
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. lf not, please explain why.
b. Please describe the relationship between Capacity Benefit Margin ("CBM") and
the ancillary services mentioned above.
c. Response to Staffs Production Request No. 11 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. PIease explain the rates that the network customers pay for the CBM services
and how the rates are determined.
RESPONSE TO REQUEST FOR PRODUCTION NO. 39:
a. The 202'l IRP load forecast includes the system load for ldaho Power's retail
customers or native load. The 2021 IRP load forecast does not include network
customer load; only the transmission capacity to serve network load is factored
into the lRP. \Mile the Company is not responsible for resource planning for
network customer Ioad, it is factored into ldaho Power's biennial local
transmission planning process, as explained on page74 of the 2021 lRP.
b. The Company believes the "ancillary services" being questioned are the
contingency reserves the Company is required to maintain as a Balancing
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF- 3
Authority area. ln the 2021 lRP, ldaho Power treated CBM like other resources in
the resource stack regarding its contribution toward meeting peak demand
needs, plus a planning margin. The planning margin includes contingency
reserves. Generating resources in the resource stack provide contingency
reserves, which, operationally, is typically the difference between the unit's
capability and its real-time output. CBM is reserve transmission capacity, so it
could be used (in an energy emergency) to facilitate power purchases from third
parties and, in turn, back off ldaho Power's other generating resources to allow
them to continue to provide contingency reserves.
c. CBM is not pre-allocated between native load and third-party network load. CBM
is available to Load Serving Entities ("LSE") within the Company's Balancing
Authority area that declare an Energy Emergency Alert 2. CBM will be granted to
each LSE based on the order in which the request is made. Should multiple
LSEs request CBM usage at the same time and the tota! of those requests
exceed the CBM available, ldaho Power will allocate the available CBM pro rata
based on the size (in megawatts) of the requests from each LSE.
d. Third-party network customers pay for CBM services through the network
transmission revenue requirement established in Attachment H of ldaho Power's
Open Access Transmission Tariff ('OATT'). Network customers are allocated a
load ratio share of the costs of the network transmission revenue requirement.
The network transmission revenue requirement is determined using the
Company's Federal Energy Regulatory Commission ("FERC") transmission
formula rate process, which updates rates annually.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF-4
The response to this Request is sponsored by Jared Elbworth, Transmission,
Distribution, & Resource Planning Director, ldaho Power Company.
IDAHO POWER COMPANYS RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF- 5
REQUEST FOR PRODUCTION 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. lf not included in the load and resource balance, please explain why.
RESPONSE TO REQUEST FOR PRODUCTION NO.40:
a. Standards established by the North American Electric Reliability Corporation
(NERC') and the Western Electricity Coordinating Council ("\ /ECC") require all
balancing authorities to carry reserves for defined categories of contingencies.
As permitted by NERC and WECC standards, participating balancing authorities
within the Northwest Power Pool (N\A/PP; now the Western Power Poolor
'WPP") have instituted the l ,PP Reserve Sharing Program for Contingency
Reserves. By sharing Contingency Reserves, participants are entitled to use not
only their own "internal' reserye resour@s but are able to call on other
participants for assistance if internal reserves do not fully cover a contingency.
The \&PP Reserve Sharing Program is automated, operating through direct
communication of data and Contingency Reserve deployment signals between
the reserve sharing computer system and the participating balancing authorities.
The WPP staff is responsible for preparing and submitting required NERC and
\A/ECC compliance reports, and responding to compliance audits, on behalf of
thttps://www.nwpp.orq/private-media/documents/NvvPP RSG Prooram Documentation -
RSG Approved 2022 0112.pdf
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF.6
the WPP Reserve Sharing Group for BAL-002. As such, participants are relieved
of BAL-002 compliance reporting obligations, and do not report to NERC or
WECC on BAL-002 compliance individually. ln short, ldaho Power is able to
meet its Contingency Reserve obligations more reliably and efficiently by
participating in the WPP through sharing the responsibility of the requirement and
resources with other members of the pool. As a WPP participant.
b. This program is not directly reflected in the load and resource balance.
Obligations associated with the program are expected to be met by the
Company's planning margin.
c. The program is excluded from the load and resource balance because ldaho
Power does not assume that the program can be relied on during system peak
demand.
The response to this Request is sponsored by Jared Hansen, Resource Planning
Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF- 7
REQUEST FOR PRODUCTION 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
f -in-20 Loss of Load Expectation ('LOLE') target?
RESPONSE TO REQUEST FOR PRODUCTION NO. 4l: The Portfolio
Reliability Results on page 100 in the Loss of Load Expectation section of Appendix C -
Technical Report shows the LOLE by year and the additional generation added to
achieve the depicted LOLE values. ln years 2037-2040 of the Preferred Portfolio,
additional generation resources were required to stay below the LOLE threshold of 0.05
days per year. The yearly LOLE values for the Preferred Portfolio without additional
generation resources in years 2037-2040 is shown in Figure 10.4 on page 139 of Idaho
Power's 2021 lntegrated Resource Plan; the graphic highlights the LOLE for the years
2037 through 2040 exceeding the reliability threshold when no additionalgeneration
resouroes are added.
The response to this Request is sponsored by Jared Hansen, Resource Planning
Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF. s
Year LOLE (dryr)Additional Generation Resources (MW)
2037 0.0495 7
2038 0.0445 3
2039 0.0487 15
2040 0.0496 16
REQUEST FOR PRODUCTION NO.42: The Ioad 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
hioh Loss of Load Probabilitv ("LOLPI hours. See Response to Staffs Production
Request No. 9 and page 96 of Appendix C of the 2021 IRP. Please answer the
following questions:
a. Are the highest LOLP hours the same as the time of peak load? Please explain.
lf not, why doesn't the Company align the timing in determining load and
resources?
b. ls the time of largest deficit for every hour across the year the same as the time
of highest LOLP hours? Please explain.
c. ls it possible that the Iargest deficit of a year occurs outside the high LOLP
hours? Please explain.
RESPONSE TO REQUEST FOR PRODUCTION NO. 42:
a. lt depends. ln the near-term forecast, after dispatching demand response and
storage, the Company's (.LOLE") tool shows a relatively flat nehpeak load from
the mid-afternoon untilthe evening (approximately 3:00 to 11:00 pm). This
effectively results in several hours having similar LOLPs ("Loss of Load
Probabilities'), often including the peak load hour. Higher amounts of solar,
however (absent additionaldemand response or storage), will push the net-peak,
and the highest LOLP hours, further into the evening. The Company aligns the
timing of all of these items using its LOLE tool, where the full analysis takes
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF- 9
place. Given varying 8,760-hour shapes for load, variable resources, etc., the
LOLE tooldetermines a single number surplus or deficit amount for a given time
period. The Company then uses this surplus/deficit amount to build a visual
representation of its position in a load and resource ("L&R") balance. ln other
words, the LOLE tool provides the precise answer (the surplus/deficit position
based on detailed 8,760 load and resource shapes), and the L&R balance shows
an approximation of how the Company gets to the answer. The Company starts
with peak load in the L&R balance, then assigns each resource a capacity value
based on its Effective Forced Outage Rate ('EFOR") or its Effective Load
Carrying Capability ("ELCC'), and finally determines a planning margin in the
L&R balance such that the load plus the planning margin less the resource
capacities (at their various EFORs and ELCCs) will match the calculated
surplus/deficit position derived by the LOLE analysis. Given this approach, the
Company could (for example) use a different load value in only the L&R balance,
which would simply change the calculated planning margin, but not the
surplus/deficit position because that is the key number derived in the LOLE
analysis.
b. Yes, by definition the highest LOLP hours are the hours of the largest deficit.
c. While LOLP calculations capture the probability of the system being able to meet
the demand, in actual operations, the Iargest deficit can occur at any given hour.
It is highly unlikely that the hour of largest deficit would occur outside the
identified highest LOLP hours, but an example of this would be losing several
generation resources at once on a spring day when load is low.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF.lO
The response to this Request is sponsored by Jared Ellsworth, Transmission,
Distribution, & Resource Planning Director, ldaho Power Company.
IDAHO POVVER COMPANYS RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF.11
DATED at Boise, ldaho, this 3td day of May 2022
frL"O.ff"*t -,-,,
LISA D. NORDSTROM
Attorney for ldaho Povuer Company
IDAHO POWER OOMPANY'S RESPONSE TO THE SECOND PRODUCNON REQUESTOFTHE
COMMISSION STAFF.12
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 3rd day of May 2022,1 served a true and correct
copy of ldaho Power Company's Response to the Second Production Request of the
Commission Staff upon the following named parties by the method indicated below, and
addressed to the following:
Commission Staff
Dayn Hardie
Deputy Aftorney 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. 6h 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 17h Street, Suite 3200
Denver, CO 80202
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IDAHO POVVER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF- 13
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 \Mrite
Clean Energy Opportunities for ldaho lnc.
3778 Plantation River Dr., Ste. 102
Boise, lD 83703
lndustrial Gustomers of ldaho Power
Peter J. Richardson
Richardson Adams, PLLC
515 N. 27h 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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IDAHO PO\A'ER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF- 14
Jim l(reider
STOP B2H Coalition
60366 Marvin Rd
La Grande, OR 07850
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Stacy Gust, Regulatory Adminbtathrc
Asaistant
IDA}IO POVI,ER COMPANY'S RESPONSE TO THE SECOND PRODUCNON REQUEST OF THE
coMrilssroN STAFF- 15