20220412Staff 1-21 to IPC.pdf

. ,. i.; !..1,1 i i.,:' ! iY'*HRILEY NEWTON
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. II2O2
IN THE MATTER OF IDAHO POWER
COMPAI\Y'S APPLICATION FOR APPROVAL
OF A REPLACEMENT SPECIAL CONTRACT
WITH MICRON TECHNOLOGY,INC. AND A
POWER PURCHASE AGREEMENT WITH
BLACK MESA ENERGY,LLC
- Ftl t , t 4:-i.'Fl'r\:lr
Street Address for Express Mail:
I1331 W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, ID 83714
Attomey for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
)
)
)
)
)
)
)
)
)
CASE NO.IPC.E-22-06
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO IDAHO POWER COMPAI\Y
The Staff of the Idaho Public Utilities Commission, by and through its attomey of record,
Riley Newton, Deputy Attorney General, requests that Idaho Power Company ("Company")
provide the following documents and information as soon as possible, but no later than
TUESDAY, MAY 3,2022.
This Production Request is to be considered as 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 or information produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name, job title, and telephone number of
the person preparing the documents. Please also identifr the name, job title, location, and
telephone number of the record holder.
FIRST PRODUCTION REQUEST
TO IDAHO POWER 1 APRIL 12,2022
In addition to the written copies provided as response to the requests, please provide all
Excel spreadsheets and electronic files on CD with formulas intact and enabled.
REQUEST NO. 1: Please provide, all workpapers 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.
REQUEST NO.2: Please provide an update to the current nationwide commercial solar
panel supply issues and explain how these supply issues could impact the Black Mesa LLC
Power Purchase Agreement ("PPA").
REQUEST 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.
REQUEST NO. 4: If 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?
REQUEST NO. 5: If 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 Idaho Power.
REQUEST NO. 6: With 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?
FIRST PRODUCTION REQUEST
TO IDAHO POWER 2 APRIL 12,2022
REQUEST NO. 7: Please explain how a 40 megawatt ("MW") alternating current
("AC") solar photovoltaic generating facility resource impacts the Company's capacity
deficiency date.
REQUEST 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 Idaho Power customer, as discussed on
page l0 of Aschenbrenner's Direct Testimony.
REQUEST 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.
REQUEST NO. 10: Please provide all workpapers 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.
REQUEST 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-21-42. Please explain the rationale for any differences between the two methods for
recovering the Embedded Fixed Cost of Energy.
REQUEST NO. 12: Please provide all workpapers used to derive the Renewable
Capacity Contribution and Renewable Capacity Credit Rate discussed on page 14 of
Aschenbrenner's Direct Testimony. Please provide workpapers in electronic format with
formulas enabled.
REQUEST NO. 13: Please provide a comparison between the methods for determining
the Renewable Capacity Credit in this Case and in Case No. IPC-E-21-42. Please explain the
rationale for any differences between the two methods for determining the Renewable Capacity
Credit.
FIRST PRODUCTION REQUEST
TO IDAHO POWER J APRIL 12,2022
REQUEST NO. 14: As discussed on page l5 of Aschenbrenner's Direct Testimony, the
Company is proposing to use the capacity deficiency year proposed in Case No. IPC-E-2l-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.
REQUEST NO. 15: In reference to the proposed Renewable Capacity Credit
Adjustment discussed 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.
REQUEST 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.
REQUEST NO. 17: In reference to Idaho Power seeking Commission approval to
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.
REQUEST NO. 18: Please provide a comparison between the Guaranteed Commercial
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.
REQUEST NO. 19: Please explain the rationale for the offsetting adjustment to the
2023 storage additions discussed on page 27 of Aschenbrenner's Direct Testimony.
FIRST PRODUCTION REQUEST
TO IDAHO POWER 4 APRIL 12,2022
REQUEST NO. 20: Please respond to the following for the No-Harm Analysis included
in Aschenbrenner's Direct Testimony.
a. Has the Company run other "without" scenarios for the No-Harm Analysis? If 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 portfolio 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 IRP
preferred portfolio and provide workpapers in Excel format 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 model to 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 Excel format with formulas enabled.
REQUEST NO. 21: Please provide the workpapers used to determine the imputed debt
discussed on page 29 of Aschenbrenner's Direct Testimony. Please provide workpapers in
electronic format with formulas enabled.
DATED at Boise, Idaho, this l7! auy of April 2022.
Riley Newton
Deputy Attorney General
i:umisc:prodreq/ipce22.8mlc prod req I
FIRST PRODUCTION REQUEST
TO IDAHO POWER 5 APRIL 12,2022
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 12M DAY OF APRIL 2022, SERVED
THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMIITSSION STAFF
TO IDAHO POWER COMPAIYY, IN CASE NO. IPC-E-22-06, BY E-MAILING A
COPY THEREOF, TO THE FOLLOWING:
DONOVAN E WALKER
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: [e-mail]
dockets@.idahopower. com
TIM TATUM
CONNIE ASCHENBRENNER
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE