20220518IPC to Staff 43-46.pdf

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Lisa D. Nordstrom
An|I)AOORPComp.ry
LISA D. NORDSTROM
Lead Couneel
[e-mail]
May 1 8,2022
VIA ELECTRONIC EMAIL
Jan Noriyuki, Secretary
ldaho Public Utilities Commission
11331W. Chinden Blvd., Bldg 8,
Suite 201-A (83714)
PO Box 83720
Boise, ldaho 83720-0074
Case No. IPC-E-2143
ln the Matter of Idaho Power Company's2021 lntegrated Resource Plan
Dear Ms. Noriyuki
Attached for electronic filing is ldaho Power Company's Response to the Third
Production Request of the Commission Staff in the above-entitled matter.
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 document, please do not hesitate to
contact me.
Very truly yours,
Re
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Enclosures
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]
I n o rd strom@ida hopower. com
Attorney for ldaho Power Company
BEFORE THE !DAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S 2021 INTEGRATED
RESOURCE PLAN.
oASE NO. !PC-E-2143
IDAHO POWER COMPANY'S
RESPONSE TO THE THIRD
PRODUCTION REQUEST OF THE
COMMISSION STAFF
COMES NOW ldaho Power Company ("ldaho Powed'or "Company"), and in
response to the Third Production Request of the Commission Staff ("Commission" or
'Staff') dated May 1 1,2022, herewith submits the following information:
IDAHO POVVER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF- 1
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REOUEST FOR PRODUCTION NO.43: The Company's response to Staffs
Production Request No. 13 states that the reserve obligations for network customer
loads within the ldaho Powefs 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 determined by a percentage multiplied by 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 equalto or
greater than 3% of the BAA's load, which includes the network customer loads plus 3%
of the online generation or the single largest contingency on the BAA.
RESPONSE TO REQUEST FOR PRODUCTION NO.43: The Company's
planning reserye margin ('PRM") adequately covers its NERC reliability standard BAL-
002 obligation. The PRM also ensures the Company has sufficient resources to
continue to reliably meet customer needs during unplanned outages, extreme weather
events, poor water conditions, etc. The PRM provides the Company with flexibility to
meet its obligations, but the PRM is not calculated by summing the needs associated
with contingency reserves, unplanned outages, extreme weather events and poor water
conditions. The PRM is determined through a loss-of-load probabilistic analysis.
BAL-002 obligations are not a factor in calculating the PRM but are covered by
the PRM. Therefore, the Company must consider whether it has a sufficient PRM to
cover its BAL-002 obligations, or whether it should increase its PRM for operational
purposes. The Company reached the conclusion that it has a sufficient PRM to meet its
BAL-002 obligations through the following comparative and logicalsteps:
IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF- 2
1. Applying a PRM to the Company's load forecast, and not factoring in contingency
reserve requirements, is consistent with the Company's prior lRPs and is
consistent with many major marketsl and utilities2 in the United States.
PacifiCorp has significant network load (non-native load) in its BAA, and
therefore would be very comparable to the Company.
2. While the Company is somewhat unique in its quantity of network load, the
Company is also unique in the quantity of transmission imports that are included
within its load and resource balance (quantity relative to total peak Ioad). The
Company includes 380 megawatts ("MW') of transmission imports (pre-B2H) and
330 MW of capacity benefit margin ('CBM") in its load and resource balance. The
Company is not required to carry contingency reserves for this combined 710
MW of imports, because the resource is not in the Company's BAA. This reduced
contingency reserve obligation associated with lower BAA resources more than
offsets the increased obligation associated with network load, and non-ldaho
Power network resources in the ldaho Power BAA.
3. Finally, the Company has historically been able to meet its BAL-002 obligations,
even during extreme conditions.
The Company will continue to evaluate the impacts of network load, and non-
ldaho Power network resources on operating obligations and adjust the PRM in future
lRPs, if appropriate. There is also discussion of contingency reserves on pages 44 and
45 of lhe 2021 IRP Appendix D.
t https://spo.oro/documents/64801/2021%2Osoo%20iune%2Oresource%2Oadequacv%2Oreport.pdf
2 httos://www.pacificorp.com/contenUdam/ocorp/documents/en/pacificorp/enerqy/inteorated-resource-
olanl2021 -ro N olume%201%20-o/o209.1 5.2021%20F inal.odl (pages 309-31 2).
IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF.3
The response to this Request is sponsored by Jared Ellsworth, Transmission,
Distribution & Resource Planning Director, ldaho Power Company.
IDAHO POVVER COMPANYS RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF.4
REQUEST FOR PRODUCTION NO. '14: The Company's response to Staffs
Production Request No. 39 states that the transmission capacity to serve network load
is factored into the lRP. 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. ls the transmission capacity mentioned above excluded in the load and resource
balance ('L&R') as a resource? Please explain.
a. Correct, transmission capacity is used to whee! power from outside the ldaho
Power BAA to serve network customer load.
b. Yes, transmission capacity set aside for network customer usage is excluded
from the load and resource balance for determining the forecasted capacity
surplus/deficit for ldaho Power native load customers.
ln the load and resource balance workbook submitted in the Company's
response to Staffs Production Request No. 10, the existing Bonneville Power
Administration ("BPA") network customer load forecasts can be found in row 82
of the tab labeled 'ATC Background." The additional BPA Eastern ldaho network
customer forecasts associated with (Boardman to Hemingway ("B2H") are in row
89. An additionaloffset is included in row 90 to conservatively assume BPA
utilizes their entire 550/250 MW share of B2H. The network customer loads are
subtracted from the transmission capacity resulting in the tota! capacity used for
the planning reserve margin determination in row 92.
IDAHO PO\A'ER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF- 5
The reeponEe to thiE Reguest is sponsold by Curtis \FCesthofr, $yetem
Consulting Engineer, ldaho Porer Company.
IDAHO POT'\ER COMPANYS RESPONSE TO THE THIRD PRODUOTION REQUEST OF THE
COMMISSION STAFF.6
REQUEST FOR PRODUCTION NO.45: Does the Company currently sell
capacity services (such as load following, balancing, and regulation reserves) to third
parties located outside the BAA? lf so, please explain how the capacity and its
associated transmission capacity are included in the L&R.
RESPONSE TO REQUEST FOR PRODUCTION NO. 45: No, ldaho Power does
not currently sell capacity services to third parties located outside its BAA.
The response to this Request is sponsored by Josh Harris, Rea!-Time Balancing
Operations Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF- 7
REQUEST FOR PRODUCTION NO.46: The Company's response to Staffs
Production Request No. 40 states that participants in the Western Power Pool Reserve
Sharing Program ("Program") are able 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 identiff.
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?
RESPONSE TO REQUEST FOR PRODUCTION NO. 46:
a. Yes, the capacity from the program can be considered firm. Each participating
entity is required to set aside generation to contribute their share of the pool's
reserve requirement. lf an entity calls on reserves, generation is made available
by participants to satisff the request.
b. Please see attached Confidential spreadsheet labeled "Reserve
Requests_20z0 2021.x1sx" to find the requested data. The tab titled
'Request_Summary_2020_2021_8" Iists the events that ldaho Power called on
other participants for assistance, including times, amounts, and BAA's providing
IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF. S
the assistance.
c. Please see attached Gonfidential spreadsheet titled "Reserve
Requests_20z0 2021.xlsx" to find the requested data. The tab titled
"Request_Summary_2020_2021_C" lists the events that Idaho Power provided
other participants with assistance, including times, amounts, and BAA's receiving
the assistance.
d. Within the same Confidential spreadsheet for parts "b'and "c'. above, column F
in each tab, titled "Peak", indicates with a "Yes' if the request was made during
peak hours. For purposes of this data request, peak hours are considered June
15 - September 15 and during the hours of 1400 -22OOPDT.
e. No, there have not been any instances where a reserve sharing request was
made by ldaho Power, but the energy was not provided.
The response to this Request is sponsored by Josh Harris, Real Time Balancing
Operations Leader, ldaho Power Company.
IDAHO POVVER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF- 9
DATED at Boise, ldaho, this 18th day of May 2022.
frL!.ff"*t^-*,
LISA D. NORDSTROM
Attomey for ldaho Porer Company
IDAHO PO\TT'ER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
coMMlsstoN STAFF- 10
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 18th day of May 2022,1 served a true and
correct copy of ldaho Power Company's Response to the Third 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 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. 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 17th Street, Suite 3200
Denver, CO 80202
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esperrv@ id a h oco n se rvatio n. oro
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tnelso n @ h olla nd ha rt. com
awiensen @holla nd hart.com
aclee@holland ha rt.com
[e-mail]
IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF- 11
Jim Swier
Micron Technology, lnc.
8000 South FederalWay
Boise, lD 83707
Glean Energy Opportunities for ldaho
Kelsey Jae
Law for Conscious Leadership
920 N. Clover Dr.
Boise, lD 83703
Michael Heckler
Courtney VUhite
Clean Energy Opportunities for ldaho !nc
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 Goalition
Jack Van Valkenburgh
Valkenburgh Law, PLLC
P.O. Box 531
Boise, ldaho 83701
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cou rtnev@cleanenerovopportu n ities.com
mike@cleanenerqvopportu nities. com
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IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF- 12
Jim Kreider
STOP B2H Coalition
60366 Marvin Rd
La Grande, OR 97850
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\ft..+ &^^J=
Stacy Gust, Regulatory Administrative
Assistant
IDAHO POVVER COil,IPANY,S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF.13
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISS]ON
GASE NO. IPC-E-21-43
IDAHO POWER COMPANY
CONFIDENTIAL
REQUEST NO.46
ATTACHMENT NO. 1
SEE ATTACHED SPREADSHEET