20220503IPC to Staff 1-21-Redacted.pdf

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DONOVAN WALKER
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May 3,2022
VIA ELECTRONIC FILING
Jan Noriyuki, Secretary
ldaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg 8,
Suite 201-A (83714)
PO Box 83720
Boise, ldaho 83720-0074
Re Case No. IPC-E-22-06
ln the Matter of ldaho Power Company's Application for Approval of a
Replacement Special Contract with Micron Technology, lnc. and A Power
Purchase Agreement with Black Mesa Energy, LLC
Dear Ms. Noriyuki
Attached for electronic filing is ldaho Power Company's Response to the First
Production Request of the Commission Staff in the above-entitled matter.
The confidentia! attachments and responses will be provided under separate cover to
the parties who sign the Protective Agreement in this mafter.
Please feel free to contact me directly with any questions you might have about this
filing.
Very truly yours,
Donovan E. Walker
DONOVAN E. WALKER (lSB No. 5921)
ldaho Power Company
1221 West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: (208) 3886936
[e-mail]
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POIA/ER
COMPANY'S APPLICATION FOR
APPROVAL OF A REPLACEMENT
SPECIAL CONTRACT WTH MICRON
TECHNOLOGY, INC. AND A PO\A'ER
PURCHASE AGREEMENT WTH BLACK
MESA ENERGY, LLC.
CASE NO. |PC-E-22-06
IDAHO PO\A/ER COMPANY'S
RESPONSE TO FIRST
PRODUCTION REQUEST OF
THE COMMISSION STAFF TO
IDAHO PO\A/ER COMPANY
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COMES NOW ldaho Power Company ('ldaho Powef or "Company"), and in
response to the First Production Request of the Commission Staff ("IPUC or
Commission') dated April 12, 2022, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO PO\A'ER COMPANY. 1
REQUEST FOR PRODUCTION NO. 1: Please provide, allworkpapers and
other documents (in electronic format with all formulas intact) used in the development
of the Application and Testimonies including, but not limited to, the no-harm analysis,
("net present value") NPV revenue requirement, cost of service, and rates.
RESPONSE TO REQUEST FOR PRODUCTION NO. 1: Please see the
confidentia! attachments provided for this request. ConfidentialAttachment 1 is the
workpaper for the Embedded Energy Fixed Cost Charge and the Renewable Capacity
Credit. ConfidentialAttachment 2 is the workpaper for the no-harm analysis.
Derivation of the Embedded Energy Fixed Cost Charge follows methodology
originally developed to determine the embedded energy rate in ldaho Power's
Community Solar Pilot Program.l While the Community Solar Pilot Program was
suspended in 2019, the embedded energy rate was derived through continuation of the
methodology and includes allapproved base rate revenue requirement filings, with the
most recent approved change effective January 1,2021.2
Workpapers for the Renewable Capacity Contribution are provided as part of the
Response to Request for Production No. 12, and imputed debt workpapers are provided
as part of the Response to Request for Production No. 21.
ln preparation of this response, it was identified that allocation of the resource
buildout revenue requirement between Micron and all other customers in the "with"
scenario referenced the ratio for power supply expense allocation which excludes
1 ln the Matter of ldaho Power Company's Application for Approval of New Tariff Schedule 63, A
Community Solar Pilot Prcgram, Case No. IPC-E-I6-14, filed June 22,2016; suspended April 26, 2019
(lPC-E-19-05; Order No. 34317).
2 ln the Matter of ldaho Power Company's Application to Decrcase /fs Rafes for Electic Seryrbe for Cosfs
Associafed with the Boardman Power Plant, IPC-E-20-32, Order No. 34885, issued December 31,2020.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY.2
energy served to Micron by the Black Mesa LLC ("BIack Mesa') Power Purchase
Agreement (.PPA'). Revenue requirement allocation is based on the system, generation
level energy ratio for Micron and all other customers. The correct ratio was referenced
for revenue requirement allocation in the'lvithout'scenario, and the Confidential
Attachment has been updated for the "with'scenario to reference the correct ratio. The
resulting change is a reduction in revenue requirement for all other customers in the
"with' scenario, increasing the net present value benefit after imputed debt impact to
$4,111,833, from $2,489,443listed on Aschenbrenner Exhibit No.3.
The response to this Request is sponsored by PaulGoralski, Regulatory
Consultant, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY.3
REQUEST FOR PRODUCTION NO. 2: Please provide an update to the current
nationwide commercialsolar panel supply issues and explain how these supply issues
could impact the Black Mesa LLC Power Purchase Agreement (PPA").
RESPONSE TO REQUEST FOR PRODUCTION NO. 2: Black Mesa LLC is
wholly responsible to procure, design, and construct the facilities to meet the terms of
the Black Mesa PPA and they have continued to relay confidence to ldaho Power in
their ability to meet their schedule.
The response to this Request is sponsored by Eric Hackett, Projects and Design
Senior Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY.4
REQUEST FOR PRODUCTION NO. 3: Please provide an update on how the
Jackpot Solar project has been impacted by the current nationwide commercial solar
panel supply issues and explain if any provisions have been added to the Black Mesa
Energy LLC PPA to protect against or mitigate these issues.
RESPONSE TO REQUEST FOR PRODUCTION NO. 3: Jackpot Solar -I
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 5
The response to this Request is sponsored by Donovan E. Walker, Lead
Counsel, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 6
REQUEST FOR PRODUCTION NO. 4: lf Black Mesa Energy LLC cannot obtain
the necessary commercial solar panels to be operational by July 2023, please explain
how Micron's Renewable Capacity Credit payments will be impacted and if the capacity
payments would be recalculated?
RESPONSE TO REQUEST FOR PRODUCTION NO. 4: As defined in the
proposed Schedule 26 and Micron's Special Contract, the Renewable Capacity Credit
payment is provided to Micron starting the month of the Project's Renewable Capacity
Credit Eligibility Date (July 1,20231or the month following the respective Project's
commercial operation date, whichever is later. ln the example of commercia! operations
not beginning by July 2023, the Renewable Capacity Credit payment would begin the
month following actualcommercialoperation date. The Renewable Capacity Credit
payment amount would not be recalculated.
The response to this Request is sponsored by Connie Aschenbrenner, Rate
Design Senior Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY. T
REQUEST FOR PRODUCTION NO. 5: lf the project is delayed and delay
damages are enforced under the Black Mesa Energy LLC PPA due to a known supply
shortage of commercial solar panels nationwide, please provide the projected delay
damages owed to ldaho Power.
RESPONSE TO REQUEST FOR PRODUCTION NO. 5: Please see the
Company's Response to Request for Production No. 18 which provides some basic
calculations and discussed the interrelationship of Guaranteed Commercial Opeiation
Date, Delay Damages, and Project Security
The response to this Request is sponsored by Donovan E. Walker, Lead
Counsel, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY. S
REQUEST FOR PRODUCTION NO. 6: Wth a known supply shortage of
commercial solar panels, does the Company have any guarantees from Black Mesa
Energy LLC to ensure a force majeure is not applicable?
RESPONSE TO REQUEST FOR PRODUCTION NO. 6: Please see discussion
regarding force majeure in the Company's Response to Request for Production No. 3.
The response to this Request is sponsored by Donovan E. Walker, Lead
Counsel, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 9
REQUEST FOR PRODUCTION NO. 7: Please explain how a 40 megawatt
("M\M) alternating current ('AC') solar photovoltaic generating facility resource impacts
the Company's capaci$ deficiency date.
RESPONSE TO REQUEST FOR PRODUGTION NO. 7: The 40 MW alternating
current ("AC') solar photovoltaic ('P\f) generating facility resource was filed with a
renewable capacity contribution of 36.42 percent of its AC nameplate capacity, meaning
its MW capacity contribution would equate to 14.57 MW (40 MW x 36.420/o = 14.57
MW). This 14.57 MW capacity contribution would decrease ldaho Power's 2023
capacity deficiency by 14.57 MW. The 14.57 MW does not by itself alleviate the 2023
capacity deficiency identified in the 2021 lntegrated Resource Plan ("lRP"), and
therefore does not change the Company's capacity deficiency date.
The response to this Request is sponsored by Jared Ellsworth, Transmission,
Distribution & Resource Planning Director, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO PO\A'ER COMPANY.lO
REQUEST FOR PRODUCTION NO. 8: Please explain when it will be known if a
10 MW portion of the Black Mesa PPA output will be dedicated to another ldaho Power
customer, as discussed on page 10 of Aschenbrenner's Direct Testimony.
RESPONSE TO REQUEST FOR PRODUCTION NO. 8: The other ldaho Power
customer interested in 10 MW of the Black Mesa PPA currently takes service under
Schedule 19, and Micron has agreed to offer 10 MW of the Black Mesa PPA to that
customer. The Company requested that Clean Energy Your Way ("CEYW') -
Construction Option is available for Schedule 19 customers as part of its Application in
that case.3 Should the Commission approve the CEYW filing, ldaho Power would
engage with the Schedule 19 customer to develop terms of a Construction offering
structure. A filing for a Renewable Construction Agreement for 1OMW of the output of
the Black Mesa PPA would occur once all parties had come to agreement on the
proposed Construction offering structu re.
The response to this Request is sponsored by Megan Ronk, Economic
Development & Innovation Director, ldaho Power Company.
3 ln the Matter of ldaho Power Company's Application to Expand Optional Customer Clean Energy
Offerings Through the Clean Energy Your Way Prograrn, Case No. IPC-E-2140, filed December 2,202'l
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY. 11
REQUEST FOR PRODUCTION NO. 9: Please explain how the Company plans
to determine the Renewable Resource output, the amount of associated credit support,
and the respective pricing components that will be adjusted on a pro-rata basis, to
reflect a 30 MW portion of the renewable capacity, as discussed on page 10 of
Aschenbrenner's Direct Testimony.
RESPONSE TO REQUEST FOR PRODUCTION NO. 9: The following
components would be based on a 75 percent I 25 percnnt pro-rata share:
o Renewable Capacity Credit
o Credit Support
o PPA output cost
While also based on a 75 percent / 25 percent pro-rata share, hourly
reconciliation of the renewable resource output would begin first with metering the
Renewable Resource output with a MV-90 meter and allocating that hourly output to the
two customers. Once the pro-rata share is allocated between the two customers, ldaho
Power would then complete hourly reconciliation of that allocated renewable resource
portion against the specific customer's hourly energy requirement to determine pricing
for usage or compensation for excess energy under the respective tariff rates. The pro-
rata share allocation effectively results in the 40 MW resource being treated as two,
individual resources of 30 MW and 10 MW with respect to application of the pricing
framework to the two customers.
The response to this Request is sponsored by Connie Aschenbrenner, Rate
Design Senior Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 12
REQUEST FOR PRODUCTION NO. 10: Please provide allworkpapers used to
derive the Embedded Energy Fixed Cost Charge discussed on pages 13-14 of
Aschenbrenner's Direct Testimony. Please provide workpapers in electronic format with
formulas enabled.
RESPONSE TO REQUEST FOR PRODUCTION NO. 10: Please see the
Company's Response to Request for Production No. 1.
The response to this Request is sponsored by Connie Aschenbrenner, Rate
Design Senior Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 13
REQUEST FOR PRODUCTION NO. 11: Please provide a comparison between
the method for recovering the Embedded Fixed Cost of Energy of the Renewable
Resource in this Case and Case No. IPC-E-2142. Please explain the rationale for any
differences between the two methods for recovering the Embedded Fixed Cost of
Energy.
RESPONSE TO REQUEST FOR PRODUCTION NO. 11: The methodology for
recovering the Embedded Fixed Cost of Energy of the Renewable resource in this case
and Case No. IPC-E-2142 are the same. However, in this case Micron's specific
embedded energy rate is utilized, while in IPC-E-2142because the Embedded Fixed
Cost of Energy only applies to Block 1 energy which is based on Schedule 19 -
Transmission rates, the Schedule 19T embedded energy rate is utilized.
The response to this Request is sponsored by Connie Aschenbrenner, Rate
Design Senior Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 14
REQUEST FOR PRODUCTION NO. 12: Please provide allworkpapers used to
derive the Renewable Capacity Contribution and Renewable Capacity Credit Rate
discussed on page 14 of Aschenbrenner's Direct Testimony. PIease provide
workpapers in electronic format with formulas enabled.
RESPONSE TO REQUEST FOR PRODUCTION NO. 12: Please see the
attachments provided for this request.
ConfidentialAttachment 1 is the workpaper for Renewable Capacity Credit Rate,
the value is also found in the Second Amended lRP, Appendix C: Technical Report
DSM FinancialAssumptions table on page 18.4
ldaho Power calculated the Renewable Capacity Contribution using National
Renewable Energy Laboratory's ("NREL") 8,760-based methodology to align with the
Company's most recently acknowledged lRP, which was modeled with an internally
developed MATLAB@ algorithm comprised of a multitude of interplaying scripts. The
data necessary to determine the Renewable Capacity Contribution value is provided in
the following aftachments:
. Data_Test_Year_1.xlsx
o Data_Test_Year_2.xlsx
o Data_Test-Year_3.xlsx
o Data_Test_YearJ.xlsx
The MATLAB@ scripts necessary to determine the Renewable Capacity
Contribution value have been provided in text file format and are listed below:
o IRP_201 9_Method_Black_Mesa_Results.txt
a ln the Matter of ldaho Power Company's 2019 lntegrafed Resource Plan, Case No. IPC-E-19-19.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY. 15
o Data_Test_Year_1.b<t
o Data_Test_YearJ.b<t
o DataJest-Year-3.brt
o Data_Test_YearJ.b<t
The response to this Request is sponsored by Shelby McNeilly, Engineer, ldaho
Power Company.
IDAHO POWER COMPANYS RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY. 16
REQUEST FOR PRODUCTION NO. 13: Please provide a comparison between
the methods for determining the Renewable Capacity Credit in this Case and in Case
No. !PC-E-2142. Please explain the rationale for any differences between the two
methods for determining the Renewable Capacity Credit.
RESPONSE TO REQUEST FOR PRODUCTION NO. 13: The method proposed
for the Renewable Capacity Credit in this case and the one in Case No. IPC-E-2142is
the same. The method in both cases relies on the methodology consistent with the
Company's most recently acknowledged IRP at the time of the Renewable Resource
agreement or PPA execution.
Because the Black Mesa PPA was executed February 16,2022, the proposed
Renewable Capacity Credit in this case utilizes the 2019 Second Amended IRP
methodology to determine the Renewable Capacity Credit. The Company has not yet
executed an agreement for a Renewable Resource related to the Energy Services
Agreement in Case No. IPC-E-2142, however depending on the timing of execution,
that credit could use either the methodology from the 2019 Second Amended IRP orthe
2021 !RP, depending on which has been most recently acknowledged by the
Commission.
The 2019 Second Amended IRP utilized the 8,760-based methodology
developed by NREL to calculate the capacity contribution associated with solar
resources. For this method, the capacity contribution is calculated by first creating a
Load Duration Curve ('LDC) of the system by sorting the net load values from highest
to lowest. Then a marginal Net Load Duration Curve ('NLDC) is created by adding the
renewable resource and re-sorting the resulting net Ioad values from highest to Iowest.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 17
The capacity contribution is calculated as the difference in area between the LDC and
NLDC during the top 100 hours. These top 100 hours are used as a prory to represent
the hours with the highest risk for loss of load.
For the 2021 lRP, ldaho Power implemented the Effective Load Carrying
Capability (.ELCC') methodology. The ELCC method is an industry standard for
determining the capacity contribution of renewable resources and it is based on the
Loss of Load Probability. Wrile the NREL 8,760-based method utilizes the top 100
hours in the NLDC as a proxy for the hours with the highest risk for loss of load, the
ELCC method directly calculates the hours of highest risk, meaning no proxy is needed.
The response to this Request is sponsored by Jared Ellsworth, Transmission,
Distribution & Resource Planning Director, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY.lS
REQUEST FOR PRODUCTION NO. 14: As discussed on page 15 of
Aschenbrenner's Direct Testimony, the Company is proposing to use the capacity
deficiency year proposed in Case No. IPC-E-21-09. Please explain if the deficiency
year in this case will change if the proposed year is modified pending the results of a
Commission Order for IPC-E-21-09.
RESPONSE TO REQUEST FOR PRODUCTION NO. 14: Yes. The Company
envisions the capacity deficit year used in determination of Micron's Renewable
Resource Capacity credit to be consistent with a Commission Order for IPC-E-21-09.
The response to this Request is sponsored by Connie Aschenbrenner, Rate
Design Senior Manager, ldaho Power Company.
IDAHO POVVER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POVVER COMPANY.19
REQUEST FOR PRODUCTION NO. 15; ln reference to the proposed
Renewable Capacity CreditAdjustmentdiscussed on page 16 of Aschenbrenner's
Direct Testimony, please explain the criteria for the use of the credit for future resource
additions and how the adjustment factor will be determined if an adjustment factor is
required.
RESPONSE TO REQUEST FOR PRODUCTION NO. 15: As noted on page 19
of Aschenbrenner's Direct Testimony, if ldaho Power enters into a future agreement to
develop additiona! Renewable Resources in ldaho Power's service area, ldaho Power
willsubmit a filing to the Commission that presents a no harm analysis which is the
basis for any proposed Renewable Capacity Credit Adjustment. The Company expects
to evaluate the no harm analysis to ensure acquisition of additional resources will not
result in an outcome that shifts costs to ldaho Power's other customers, including the
consideration of any imputed debt impact. An adjustment factor would be required if the
analysis shows ldaho Power's other customers would be harmed by the proposed
structure.
The response to this Request is sponsored by Connie Aschenbrenner, Rate
Design Senior Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 20
REQUEST FOR PRODUCTION NO. 16: Please provide the competitive
procurement process used to procure the Black Mesa PPA and provide the other
proposals considered in the procurement process.
RESPONSE TO REQUEST FOR PRODUCTION NO. 16: Please see the
attachments provided for this request. Attachment 1 is the 2021 All Source Request for
Proposals for Peak Capacity Resources, and ConfidentialAttachment 2 presents the
evaluation of the project submittals.
The RFP was sent to 38 developers who had expressed interest in participating
in the RFP solicitation on June 30,2021. On August 11, 2021 ldaho Power received
fourteen proposals from eleven different developers. Six proposals were screened
during an initialthreshold screen as either incomplete or not meeting the solicitation
criteria. Once the threshold screen was completed, the qualitative and quantitative
evaluations, were performed iteratively. The qualitative evaluation ranked the proposals
based on feasibility, capability, counterparty profile, and community stewardship while
the quantitative evaluation ranked the proposals by cost.
It is important to note that the Black Mesa PPA is the energy component of a 40
MW solar plus battery storage project. Because the 2021 RFP, included as Attachment
1, was seeking peak capacity resources, the Company viewed the arrangement with
Micron to be mutually beneficial. That is, Micron pays for the energy output of the solar
facility and claims the associated green attributes and ldaho Power is able to direct the
same solar output to fuel a co-located battery storage facility to be dispatched to meet
peak load. On April 29,2022,ldaho Power filed a separate case with the ldaho
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REOUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY.2l
Commission, IPC-E-22-13,5 seeking a Certifieate of Public Convenience and Necessity
('CPCN") for the 40 ltl\ / of co-located battery storage facility.
The response to this Request is sponsored by Eric Hackeft, Projects and Design
Senior Manager, ldaho Power Company.
5 ln the Matter of ldatto Power Cwtpany's Apflication for a &rtificate of Publb Convenience and
Necessdy to Aquire Resources to fu Onlirc by 2023 fo Securp Adequate and Rdiabla Serube fo fs
Cusfonoers, Caee No. IPC-E-22-13, Filed April 29,2022.
IDAHO POVI'ER COMPAI.TYS RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POVI/ER COMPANY - 22
REQUEST FOR PRODUGTION NO. 17: In reference to ldaho Power seeking
Commission approvalto incorporate pricing elements into Schedule 26 associated with
additional Renewable Resources discussed on pages 18-19 of Aschenbrenner's Direct
Testimony, please explain if the Company envisions this future filing as an opportunity
for the Commission to review the procurement process and prudence of the additional
resources.
RESPONSE TO REQUEST FOR PRODUCTION NO. 17: No. As provided in the
Company's Response to Staffs Request for Production 22(d) in Case No. IPC-E-2142,
under the Clean Energy Your Way - Construction option, a customer will pay the full
cost of renewable resources procured on their behalf. The tariff rates for Micron are
independent of the cost of those resources. As a result, potential future acquisition of
resources will not reduce the costs paid by Micron to cover the cost of ldaho Power's
system providing service to them. By extension, an increase or decrease in the cost of
future resources will not change the outcome of the no-harm analysis. This certainty,
combined with the parent guarantees that protect customers, make it appropriate to
procure future resources for Micron without seeking individual Commission approval of
each resource.
The response to this Request is sponsored by Connie Aschenbrenner, Rate
Design Senior Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 23
REQUEST FOR PRODUCTION NO. 18: Please provide a comparison between
the Guaranteed Commercia! Operation Date, Project Development Security, Default
Security, and Output Guarantee provisions used in the Black Mesa PPA in this Case
and the draft PPA provided in Case No. IPC-E-21-42. Please explain the rationale for
any differences between the provisions used in the PPAs.
RESPONSE TO REQUEST FOR PRODUCTION NO. 18:
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY.24
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 25
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 26
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 27
The response to this Request is sponsored by Donovan E. Walker, Lead
Counsel, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 28
REQUEST FOR PRODUCTION NO. 19: Please explain the rationale forthe
offsetting adjustment to the 2023 storage additions discussed on page 27 of
Aschenbrenner's Direct Testimony.
RESPONSE TO REQUEST FOR PRODUCTION NO. 19: There was an
offsetting adjustment made to the storage resource additions in2023 to accountforthe
Black Mesa Solar PPA's peak capacity contribution. Black Mesa Solar and its
associated peak capacity contribution was not part of the 2021 IRP preferred portfolio,
which forms the basis for this analysis. BIack Mesa Solar PPA has a36.42 percent peak
capacity contribution and a nameplate of 40MW, so it has 40 MWX 36.420/o = 14.57
MW peak capacity contribution. To account for this additional peak capacity contribution
in the model, Idaho Power offset an equivalent amount of 2023 storage peak capacity
contribution. This puts the peak capacity of resources in the model for 2023 for this
analysis on the same level playing field as what was built in the model in the 2021 IRP
preferred portfolio. lf this offsetting adjustment was not made, the model/portfolio would
have been in a different surplus position than it was in the 2021 lRP and accurate
comparisons could not be made between this analysis and lhe 2021 IRP preferred
portfolio.
The response to this Request is sponsored by Jared Ellsworth, Transmission,
Distribution & Resource Planning Director, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 29
REQUEST FOR PRODUCTION NO. 20: Please respond to the following for the
No-Harm Analysis included in Aschenbrenner's Direct Testimony.
a. Has the Company run other 'withouf' scenarios for the No-Harm Analysis? lf so,
please explain and provide the other "without" scenarios including workpapers in
Excel format with formulas enabled.
b. Please provide a "without'scenario that does not include the proposed Micron
ESA in the analysis but includes the Black Mesa PPA in the portfolios as a must
take resource and allow the model to select the incremental resources required
to meet the constraints. Please use the same input assumptions as the 2021
lRP preferred portfolio and provide workpapers in Excelformat with formulas
enabled.
c. Please provide a "without" scenario that includes updated pricing for incremental
resources based on results from the June 30, 2021, Request for Proposal and
allow the modelto select the incremental resources required to meet the
constraints. Please use the same input assumptions as the 2021 IRP preferred
portfolio and provide workpapers in Excelformat with formulas enabled.
RESPONSE TO REQUEST FOR PRODUGTION NO. 20:
a. No. The Company only ran lhe 2021 IRP preferred portfolio as the "without'
scenario for the no-harm analysis.
b. Please see "Attachment 1 - Response to Request No. 20 - LTCE Buildout" and
.CONFIDENTIAL Attachment 2 - Response to Request No. 20 - Portfolio
Costing".
c. From the June 30,2021 RFP, only the Black Mesa Solar PPA is considered to be
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY.30
a feasible project. As such, for Part C, we included the Black Mesa Solar PPA as
a selectable new resource in 2023 in the Aurora Long Term Capacity Expansion
('LTCE') model. The Black Mesa Solar PPA was selected by the Aurora LTCE.
Because the Aurora modelselected the Black Mesa Solar PPA in the LTCE, the
attachments for Part B are also relevant for Part C. Please see the attachments
provided for that response.
Please reference the Company's CPCN filing, Case No. IPC-E-22-13,lor
additional information regarding the results of the project submittals evaluation,
as well as ConfidentialAttachment 2 to the Response to Request for Production
No. 16. In consideration of the information included in Case No. IPC-E-22-13,
ldaho Power will provide additional information as requested by Staff as it
pertains to development and evaluation of Micron's Special Contract pricing
structure.
The response to this Request is sponsored by Jared Hansen, Resource Planning
Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 31
REQUEST FOR PRODUCTION NO.21: Please provide the workpapers used to
determine the imputed debt discussed on page 29 of Aschenbrenne/s Direct
Testimony. Please provide workpapers in electronic format with formulas enabled.
RESPONSE TO REQUEST FOR PRODUCTION NO. 21: PIease see the
Confi dential Attachment provided for this req uest.
The response to this Request is sponsored by John Wonderlich, Finance Team
Leader l, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POVVER COMPANY.32
Respecttully eubmitEd this 3d day of May 2022.
A,*2tut4
DONOVAN E. WALKER
Attomey br ldaho Porvcr Company
IDAHO POI\ER COMPAI'IY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POVVER COMPAI.IY - 33
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 3rd day of May 2022,1 served a true and correct
copy of the foregoing ldaho Power Company's Response to First Production Request of
the Commission Staffto ldaho Power Company upon the following named parties by the
method indicated below, and addressed to the following:
Riley Newton
Deputy Attomey General
ldaho Public Utilities Commission
Po Box 83720
Boise, ldaho 83720-0074
Emaibd to:
R ilev. Newton@puc. idaho. qov
Gu^J=-
Stacy Gust, Regulatory Administrative
Assistant
IDAHO PO\'\'ER COMPANY'S RESPONSE TO FIRST PRODUCTION REOUEST OF THE
COMMISSION STAFF TO IDAHO POVVER COMPANY - 34
BEFORE THE
IDAHO PUBLIC UTILITIES GOMMISSION
GASE NO. IPC-E-22-06
IDAHO POWER COMPANY
CONFIDENTIAL
REQUEST NO. 1
ATTAGHMENT NO. 1
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
GASE NO. IPC-E-22-06
IDAHO POWER COMPANY
CONFIDENTIAL
REQUEST NO. 1
ATTACHMENT NO.2
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
GASE NO. IPC-E-22-06
IDAHO POWER GOMPANY
CONFIDENTIAL
REQUEST NO. 12
ATTACHMENT NO. 1
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPG-E-22-06
IDAHO POWER GOMPANY
REQUEST NO. 12
ATTACHMENTS NO. 2.10
SEE ATTACHED FILES
BEFORE THE
IDAHO PUBLIC UTILIT]ES COMMISSION
GASE NO. IPG.E-22.06
IDAHO POWER COMPANY
REQUEST NO. 16
ATTACHMENT NO. 1
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
GASE NO. IPG-E-22-06
IDAHO POWER COMPANY
CONFIDENTIAL
REQUEST NO. 16
ATTACHMENT NO. 2
BEFORE THE
IDAHO PUBLIG UTILITIES COMMISSION
GASE NO. IPC-E-22-06
IDAHO POWER COMPANY
REQUEST NO.20
ATTACHMENT NO. 1
SEE ATTACHED SPREADSHEET
BEFORE THE
IDAHO PUBLIC UTILITIES GOMMISSION
GASE NO. IPC-E-22-06
IDAHO POWER GOMPANY
CONFIDENTIAL
REQUEST NO.20
ATTACHMENT NO.2
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
GASE NO. IPC-E-22-06
IDAHO POWER COMPANY
CONFIDENTIAL
REQUEST NO. 21
ATTACHMENT NO. 1