20220511Staff 43-46 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:
11331 W CHINDEN BVLD,BLDG 8,SUITE 201-A
BOISE,ID 83714
Attorneyfor the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER )COMPANY'S 2021 INTEGRATED RESOURCE )CASE NO.IPC-E-21-43PLAN)
)THIRD PRODUCTION
)REQUESTOF 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 AttorneyGeneral,request that Idaho Power Company
("Company")provide the followingdocuments and information as soon as possible,or by
WEDNESDAY,MAY 18,2022.1
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
Staffis requesting an expedited response.If responding by this date will be problematic,please call Staff'sattorneyat(208)334-0312.
THIRD PRODUCTION REQUEST
TO IDAHO POWER COMPANY 1 MAY 11,2022
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
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.
REQUESTNO.43:The Company's response to Staff's Production Request No.13
states that the reserve obligations for network customer loads within the Idaho Power's balancing
authority area ("BAA")are covered as part of the planning reserve margin.Please explain how
the Company has included reserves for network customer loads in the planning reserve margin
given the following:(1)The planning reserve is determinedby a percentage multipliedby the
load forecast and Response No.39 states that the load forecast does not include network customer
loads;and (2)As mandated by NERC,the BAA must carry a contingency reserve equal to or
greater than 3%of the BAA's load,which includes the network customer loads plus 3%of the
online generationor the single largest contingency on the BAA.
REQUESTNO.44:The Company's response to Staff's Production Request No.39
states that the transmission capacity to serve network load is factored into the IRP.Please
respond to the following:
a.Please confirm that the transmission capacity is typically used to wheel power from
outside the BAA to serve network load.
b.Is the transmission capacity mentioned above excluded in the load and resource
balance ("L&R")as a resource?Please explain.
REQUESTNO.45:Does the Company currentlysell capacity services (such as load
following,balancing,and regulation reserves)to third parties located outside the BAA?If so,
please explain how the capacity and its associated transmission capacity are included in the L&R.
REQUESTNO.46:The Company's response to Staff's Production Request No.40
states that participants in the Western Power Pool Reserve Sharing Program ("Program")are able
THIRD PRODUCTION REQUEST
TO IDAHO POWER COMPANY 2 MAY l1,2022
to call on other participants for assistance if internal reserves do not fully cover a contingency.
Please respond to the following:
a.Can the capacity from the Program be considered firm?Please explain.
b.Please list all the events in 2020 and 2021 where the Company called on other
participants for assistance,including times,amounts,and utilities that the Company
contacted.
c.Please list all the events in 2020 and 2021 where the Company was called on by other
participants for assistance,including times,amounts,and utilities that the Company
was contacted by.
d.Are any of the times listed in b.and c.peak hours?Please identify.
e.Have there been any situations when the Company has requested reserves from the
Program but has not been provided,since the Program was initiated?
DATED at Boise,Idaho,this day of May 2022.
D Hardif
Deputy AttorneyGeneral
i:umisc:prodreq/ipce21.43dhyy prod req3
THIRD PRODUCTION REQUEST
TO IDAHO POWER COMPANY 3 MAY 11,2022
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 11TH DAY OF MAY 2022,SERVED THE FOREGOING THIRD PRODUCTION REQUESTOF THECOMMISSIONSTAFFTOIDAHOPOWERCOMPANY,IN CASE NO.
IPC-E-21-43,BY E-MAILING A COPY THEREOF,TO THE FOLLOWING:
LISA NORDSTROM TIM TATUM
IDAHO POWER COMPANY ALLISON WILLIAMS
PO BOX 70 IDAHO POWER COMPANY
BOISE ID 83707-0070 PO BOX 70
E-MAIL:[e-mail] BOISE ID 83707-0070
[e-mail] E-MAIL:[e-mail]
[e-mail]
KIKI LESLIE A.TIDWELL BENJAMIN J OTTO
704 N.RIVER ST.#1 EMMA E.SPERRY
HAILEY ID 83333 ID CONSERVATION LEAGUE
E-MAIL:ktidwell2022 email.com 710 N 6TH ST
BOISE ID 83702
E-MAIL:botto idahoconservation.ora
[e-mail]
PETER J RICHARDSON DR DON READING
RICHARDSON ADAMS PLLC 6070 HILL ROAD
515 N 27TH STREET BOISE ID 83703
BOISE ID 83702 E-MAIL:[e-mail]
E-MAIL:[e-mail]
KELSEY JAE MICHAEL HECKLER
LAW FOR CONSCIOUS LEADERSHIP COURTNEY WHITE
920 N CLOVER DR CLEAN ENERGY OPPORTUNITIES FOR
BOISE ID 83703 IDAHO INC
E-MAIL:[e-mail] 3778 PLANTATION RIVER DR
SUITE 102
BOISE ID 83703
E-MAIL:
[e-mail]
[e-mail]
CERTIFICATE OF SERVICE
AUSTIN RUESCHHOFF JIM SWIER
THORVALD A NELSON MICRON TECHNOLOGY INCAUSTINWJENSEN8000SFEDERALWAYHOLLAND&HART LLP BOISE ID 83707
555 17TH ST STE 3200 E-MAIL:[e-mail]
DENVER CO 80202
E-MAIL:[e-mail]
[e-mail]
[e-mail]
[e-mail]
glearganoamari hollandhart.com
JACK VAN VALKENBURG JIM KREIDERVANVALKENBURGLAWPLLCSTOPB2HCOALITIONPOBOX53160366MARVINRD
BOISE ID 83701 LA GRANDE OR 97850
E-MAIL:[e-mail] E-MAIL:[e-mail]
SECRETARY
CERTIFICATE OF SERVICE