20220503IPC to Staff 1-7.pdf

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Lisa D. Nordstrom
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An[T COAPComp.ny
P.O. Bor 70 (83707)
lZll W. ld.ho 5t.
Boise, lD 83702
LISA D. NORDSTROiI
Lead Counsel
[e-mail]
May 3,2022
Jan Noriyuki, Secretary
ldaho Public Utilities Commission
11331 W. Chinden Boulevard
Building 8, Suite 201-A
Boise, ldaho 83714
Re Case No. !PC-E-22-11
Application of ldaho Power Company for Authority to Implement Power Cost
Adjustment CPCA') Rates for Electric Service from June 1,z022,through May
31,2023
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 confidential attachments will be provided under separate cover to the parties who
sign the Protective Agreement in this matter.
lf you have any questions about the attached documents, please do not hesitate to
contact me.
Sincerely,
X*!.("*+r,-*,
LDN:sg
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]
ln o rd strom@ ida h opower. com
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
AUTHORITY TO IMPLEMENT POWER
cosT ADJUSTMENT ("PCA') RATES
FOR ELECTRIC SERVICE FROM JUNE
1,2022, THROUGH MAY 31 ,2023.
CASE NO. IPC-E-22-11
IDAHO POWER COMPANY'S
RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE
COMMISSION STAFF
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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 dated April22,2022,
herewith submits the following information:
IDAHO PO\A'ER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 1
REQUEST FOR PRODUGTION NO. 1: Please provide a list of all ldaho Power
customers who purchased Company-owned Renewable Energy Credits ('RECs") that are
being passed through the Power Cost Adjustment ('PCA") Schedule 55. Please include
in the response the fuel type for the RECs, purchase price, quantity of RECs, and date
purchased.
RESPONSE TO REQUEST FOR PRODUGTION NO. 1: Please see Confidential
Attachment 1 for all Idaho Power customers who purchased Company-owned Renewable
Energy Credits ('RECs") that are being passed through the Power Cost Adjustment.
The response to this Request is sponsored by Suzanne Smith, Senior Program
Specialist, ldaho Power Company.
IDAHO POVVER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 2
REQUEST FOR PRODUCTION NO. 2: Please provide all workpapers used to
derive the finalfigures included in the exhibits in electronic formatwith allformulas intact.
RESPONSE TO REQUEST FOR PRODUCTION NO. 2: Please see Excel
Attachments 1 - 4.
Excel Attachment 1 was used in preparation of Exhibit No.1 (2022-2023 PCA
Forecast) as well as the tables found in the direct testimony of Jessica G. Brady. Excel
Attachment 2 contains the calculations for the PCA rate components. ExcelAttachments
3 and 4 were used in preparation of Exhibit No. 3 (2022 ROE Determination Revenue
Sharing Benefits).
The response to this Request is sponsored by Jessi Brady, Regulatory Analyst,
ldaho Power Company.
IDAHO POIA/ER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF.3
REQUEST FOR PRODUCTION NO. 3: Please provide the monthly number of
megawatt-hours ('MWh') associated with the system base and actual net power costs for
all Net Power Supply Expense ("NPSE") Accounts including Federal Energy Regulatory
Commission ('FERC") accounts 501 (Coal), account 536 (Water for power), account 547
(Gas), account 555 (Non-PURPA), account 565 (3rd party transmission), account 447
(Surplus Sales), account 555, (PURPA), and account 555 (Demand Response
lncentives).
RESPONSE TO REQUEST FOR PRODUGTION NO. 3: Please see Confidential
Aftachment 1 for monthly PURPA generation in megawatt-hours ('MWh") associated with
the system base net power costs. Please see Excel Attachment2lor monthly generation
associated with system base net power costs for all non-PURPA Federal Energy
Regulatory Commission ("FERC") accounts. Docket No. IPC-E-13-201 contains
additional detail regarding the Company's base net power supply costs.
Please see ExcelAttachment 3 for monthly generation associated with actual net
power supply costs for April 2021 - March 2022. There are no MWhs associated with
FERC accounts 536 (Water for Power), 565 (3rd Pafi Transmission) and 555 (Demand
Response lncentives).
The response to this Request is sponsored by Jessi Brady, Regulatory Analyst,
ldaho Power Company.
IDAHO PO\'\'ER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 4
REQUEST FOR PRODUCTION NO.4: Did the Company re-distribute or smooth
base NPSE in this year's filing? lf so, please provide workpapers that reflect the
calculations/method used to derive the revenue-smoothed (redistributed) base NPSE
included in Exhibit No. 2 from the Aurora generated NPSE thatwas last authorized by the
Commission for the deferral period for all NPSE accounts. Please include all workpapers
in electronic format with calculations intact.
RESPONSE TO REQUEST FOR PRODUCTION NO. 4: Base NPSE in this filing
are shaped according to base rate revenues from the Company's last general rate case,
in accordance with Commission Order No. 33307 issued in Case No. IPC-E-15-15. The
shaping of base NPSE has remained consistent with each PCA filed since the conclusion
of that case. Please see Excel Attachment 1, which details the shaping of base NPSE by
retail revenues,
The response to this Request is sponsored by Jessi Brady, Regulatory Analyst,
ldaho Power Company.
]DAHO POVVER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF.5
REQUEST FOR PRODUCTION NO. 5: Please provide supporting data on the
reservoir levels for the Upper Snake River Basin for both current and 2023 forecasted
amounts.
RESPONSE TO REQUEST FOR PRODUCTION NO. 5: Following drought
conditions in2021, reservoirs upstream of Brownlee had lowerthan normal storage at the
end of the irrigation season to carryover into the following year. On November 1, 2021,
which is the end of the irrigation year, storage in the major reservoirs above Brownlee
(which ldaho Power defines as the cumulative storage in Jackson Lake, Palisades, lsland
Park, American Falls, Anderson Ranch, Arrowrock, Lucky Peak, Lake Lowell, Cascade,
Deadwood, and Owyhee Reservoir) was 53% of normal, or only 22o/o oi the total capacity
of these reservoirs.
The winter of 202112022 began with storm cycles and snowpack building at an
above average rate in most of the basins above Brownlee. However, beginning in early
January, the Snake River Basin experienced dry conditions through approximately March,
which led to below norma! snowpack conditions across all basins upstream of Brownlee
Reservoir. ln the April 1, 2022 ldaho Water Supply Outlook Report
(https://www.wcc.nrcs.usda.gov/ftpref/supporUstates/lD/wy2022lwsorlborid422.pdf), the
Natural Resources Conservation Service listed snowpack in key basins above Brownlee
Reservoir as follows:
. Upper Snake Basins: 66 to 70% of median
. Wood and Lost Basins: 61 to 760/o of median
. Southern Snake Basins: 50 to 78% of median
. West Central Basins: 60 to 70% of median
IDAHO PO\'\'ER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 6
The low snowpack, coupled with the low carryover conditions from the prior
irrigation year, resulted in below normal water supply forecasts in the basins above
Brownlee, and subsequently in ldaho Power's streamflow forecast at its hydropower
projects. At the March Water Supply Committee meeting, hosted by the ldaho Department
of Water Resources, regional water managers provided forecasts for water supplies and
reservoir operations. Materials from the U.S. Bureau of Reclamation provide supporting
data for the following paragraphs and can be found at the following link
(https://idwr. idaho-gov/water-data/water-supply/committee/).
ln the Upper Snake, above Milner Dam, storage on March 8,2022 was 72o/o ol
normal, which corresponds to the 7th lowest storage amount in the last 46 years.
Forecasts for runoff in the Upper Snake ranged from 63 to 75o/o of normal. Reservoir
storage projections showed that the total system storage was likely to end the irrigation
season at less than 20o/o of capacity.
ln the Boise Basin, storage on March 9, 2022 was 85% of average. Forecasts
called for runoff to be approximately 80% of average. The lower storage and runoff
projections resulted in forecasts that did not predict refill of the Boise system, yielding little
to no excess flow exiting the Boise Basin beyond minimum stream flows. Projections
showed Boise Basin reservoir content at approximately 40o/o of normal at the end of the
irrigation season.
ln the Payette Basin, storage on March 9,2022 was 88% of average. Forecasts
called for runoff to be approximately 81% of average. The lower storage and runoff
projections resulted in forecasts that predicted marginal refill of the Payette system,
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 7
yielding little to no excess flow exiting the Payette Basin due to reservoir releases for
flood risk management. Projections showed Payette Basin reservoir content at
approximately 60% of normal at the end of the irrigation season.
ln the Owyhee Basin, storage on March 9, 2022 was 51o/o of average. Forecasts
called for runoff to be approximately 81% of average. Since the Owyhee Reservoir is a
multiyear system, this amount of runoff is insufficient to fill the system or lead to any
increases in streamflow downstream of Lake Owyhee.
Given current water supply and reservoir storage conditions, carryover in all major
reservoirs above Brownlee is expected to be below normalatthe end of the 2O22irrigation
season and into the start of the 2023 waler year. This reduces the Iikelihood of any
significant winter season or early flood risk management water releases through the end
of the PCA analysis period.
ldaho Power reviewed the available forecasts, along with internal hydrologic
modeling and reservoir operations models, and concurred that current and forecast
drought conditions coupled with low reservoir storage made it unlikely that any of the
regulated portions of the Snake River Basin upstream of Brownlee Reservoir would
significantly contribute to stream flows, and therefore hydropower generation, through
most of ldaho Power's hydro system during the upcoming PCA year.
The response to this Request is sponsored by Frank Gariglio, Engineering Leader,
ldaho Power Company.
IDAHO PO\A'ER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 8
REQUEST FOR PRODUCTION NO. 6: Please provide the length of time and
amount of production in MWhs lost for forced downtime (unscheduled) that Company-
owned generation facilities/units experienced each month during the deferral period. For
each forced downtime, please explain the cause and resolution of the downtime
RESPONSE TO REQUEST FOR PRODUCTION NO. 6: Please see Excel
Attachment 1.
The response to this Request is sponsored by Jessi Brady, Regulatory Analyst,
ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 9
REQUEST FOR PRODUCTION NO. 7: Please provide all Company-owned
facility/unit unforced downtime (scheduled) including the date range, length of time, and
reason that occurred during the deferral period.
RESPONSE TO REQUEST FOR PRODUGTION NO. 7: Please see Excel
Aftachment 1.
The response to this Request is sponsored by Jessi Brady, Regulatory Analyst,
ldaho Power Company.
IDAHO POVVER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF.lO
DATED at Boise, ldaho, this 3rd day of May2022.
&; P.zf"t t.-*,
LISA D. NORDSTROM
Attomey for ldaho Power Oompany
IDAHO POVI'ER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF.11
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 First Production Request of the
Commission Staff to ldaho Power Company upon the following named parties by the
method indicated below, and addressed to the following:
\kle,lh &,4t.
Stacy Gust, Regulatory Administrative
Assistant
IDAHO PO\A'ER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 12
Commission Staff
Dayn Hardie
Deputy Attorney General
ldaho Public Utilities Commission
11331 W. Chinden Blvd., BIdg No. 8,
Suite 201-A (83714)
PO Box 83720
Boise, lD 83720-0074
Hand Delivered
_U.S. Mai!
Overnight Mail
_FAX
FTP SiteX Email: [e-mail]
lndustria! Customers of ldaho Power
Peter J. Richardson
515 N. 27th Street
Boise, ldaho 83702
Hand Delivered
_U.S. Mail
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FTP SiteX Email: [e-mail]
Dr. Don Reading
6070 Hill Road
Boise, ldaho 83703
Hand Delivered
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Overnight Mail
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FTP SiteX Email:[e-mail]
BEFORE THE
IDAHO PUBL]C UTILITIES COMMISSION
cAsE NO. IPC-E-22-11
IDAHO POWER COMPANY
CONFIDENTIAL
REQUEST NO. 1
ATTACHMENTNO. 1
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
GASE NO. IPC-E,22-11
IDAHO POWER COMPANY
REQUEST NO.2
ATTACHMENTNO. 1
SEE ATTACH ED SPREADSH EET
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
GASE NO. IPC-E-22-11
IDAHO POWER COMPANY
REQUEST NO.2
ATTACHMENTNO.2
SEE ATTACHED SPREADSHEET
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
GASE NO. IPC.E.22.11
IDAHO POWER COMPANY
REQUEST NO.2
ATTACHMENTNO.3
SEE ATTACH ED SPREADSH EET
BEFORE THE
I DAHO PU BLIC UTI LITIES COMTUIESION
GASE NO, IPC.E.22.11
IDAHOPOWER COMPANY
REQUEST NO.2
ATTAGHMENTNO.4
SEE ATTACHED SPREADSHEET
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
GASE NO. IPC-E-22-11
IDAHO POWER COMPANY
CONFIDENTIAL
REQUEST NO.3
ATTACHMENTNO. 1
BEFORE THE
IDAHO PU BLIC UTILITIES COMMISSION
CASE NO. IPC-E-22-11
IDAHO POWER GOMPANY
REQUEST NO.3
ATTACHMENTNO.2
SEE ATTACH ED SPREADSHEET
BEFORE THE
IDAHO PUBLIG UTILITIES COMMISS]ON
GASE NO. IPC-E-22-11
IDAHO POWER COMPANY
REQUEST NO.3
ATTACHMENTNO.3
SEE ATTACH ED SPREADSH EET
BEFORE THE
IDAHO PUBLIC UTILIT]ES COMMISSION
GASE NO. IPC-E-22-11
IDAHO POWER COMPANY
REQUEST NO.4
ATTACHMENTNO. 1
SEE ATTACHED SPREADSHEET
BEFORE THE
IDAHO PUBLIG UTILITIES COMMISSION
CASE NO. IPG.E.22.11
IDAHO POWER COMPANY
REQUEST NO.6
ATTACHMENT NO. 1
SEE ATTACH ED SPREADSHEET
BEFORE THE
IDAHO PUBLIG UTILITIES COMMISS]ON
CASE NO. IPC-E-22-11
IDAHO POWER COMPANY
REQUEST NO.7
ATTACHMENTNO. 1
SEE ATTAGHED SPREADSHEET