20220512ICIP 1-12 to IPC.pdf

Peter J. Richardson ISB # 3195
RICHARDSON ADAMS, PLLC
515 N. 27th Street
Boise, Idaho 83702
Telephone: [phone]
Fax: [phone]
peter@richardsonadams. com
Attomeys for the Industrial Customers of Idaho Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR A
CERTIFICATE OF PUBLIC
CONVENIENCE AND NECESSITY TO
ACQUIRE RESOURCES TO BE ONLINE
BY 2023 TO SECURE ADEQUATE AND
RELIABLE SERVICE TO ITS
CUSTOMERS.
CASE NO. IPC.E-22-I3
FIRST PRODUCTION REQUEST OF
THE INDUSTRIAL CUSTOMERS OF
IDAHO POWER
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Pursuant to Rule 225 of the Rules of Procedure of the Idaho Public Utilities Commission
(the "Commission"), the Industrial Customers of Idaho Power ("ICIP") by and through its
attomey of record, Peter J. Richardson, hereby requests that Idaho Power Company ("ldaho
Power" or the "Company") provide responses to the following with supporting documents,
where applicable.
This production request is to be considered as continuing, and ldaho Power 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 responses or documents produced.
FIRST PRODUCTION REQUEST OF THE ICIP
IN CASE NO. IPC.E-22-13 PAGE I
RECEIVED
2022 May 12, PM 3:27
IDAHO PUBLIC
UTILITIES COMMISSION
Please provide an additional electronic copy, or if unavailable, a physical copy, to Dr.
Don Reading at: 6070 Hill Road, Boise, Idaho 83703, Tel: [phone]; Fax: (208) 38a- l5 I I ;
dreading@,mindsprin g. com.
For each item, please indicate the name of the person(s) preparing the answers, along
with the job title of such person(s) and the witness at hearing who can sponsor the answer.
REOUEST FOR PRODUCTION NO. 1
Please provide, in electronic format with all formulae intact where possible, all worþapers and
other documents used in the development of Idaho Power's Application in this matter.
REOUEST FOR PRODUCTION NO. 2
Please provide copies of all communications between Idaho Power and the Idaho Public Utilities
Commission and/or its Staff regarding ldaho Power's Application in this matter"
REOUEST FOR PRODUCTION NO.3
Please provide copies of all responses to production requests (both formal and informal)
provided to any other party to this proceeding.
REOUEST FOR PRODUCTION NO. 4
Idaho Power asserts at page 4 of its Application that "[A] certificate from the
Commission is required for the construction or extension of a line, plant, or system by any street
railroad, gas, electrical, telephone or water corporation." Please provide a copy of the certificate
issued by the Commission to Idaho Power for the following:
Mobile Diesel Generators installed in2002 (diesel)
Neal Hot Springs Geothermal Facility (geothermal)
Langley Gulch (gas)
Bennett Mountain (gas)
FIRST PRODUCTION REQUEST OF THE ICIP
IN CASE NO. IPC-E-22-13 PAGE 2
Danskin Mountain (gas)
Swan Falls Rebuild (hydro)
Milner Dam Rebuild (hydro)
North Valmy (coal)
Elkhorn Valley (wind)
Evander Andrews (gas)
REOUEST FOR PRODUCTION NO. 5
At page 27 of his testimony Mr. Ellsworth observes that the 150 MW Unit I of the Hells
Canyon facility "recently experíenced an outage unexpectedly . . . and is now out oJ'service
indefinitely. " Please provide a compete update as to the status of Unit 1, including the date of
fault, probable causes and prognosis for repair and retuming the unit to service. Please explain
whether (and how) this 150 MW outage is incorporated in Mr. Ellsworth's conclusion that the
company is 30 MW long in 2023.
REOUEST FOR PRODUCTION NO. 6
Mr. Ellsworth states atpage 28 of his direct pre-filed testimony that"given the various
increments and decrements, including the 120 MW of battery storage, to the load and resource
balance, the Company estimates that it will exceed the 0.05 LOLE threshold by approximately 30
MW in 2023, net oJ'current, near-term.factors." Please provide the workpapers or spreadsheets
showing the "various increments and decrements" that supports Mr. Ellsworth's conclusion
regarding the 30 MW excess of the 0.05 LOLE. Please also identify and quantify the net effect
ofthe "near-term factors" he references.
FIRST PRODUCTION REQUEST OF THE ICIP
IN CASE NO. IPC-E-22-13 PAGE 3
REOUEST FOR PRODUCTION NO. 7
At page 29 of Mr. Ellsworth's pre-filed direct testimony he observes several "near-term
factors" that are instructing its evaluation of its resource needs for 2024. One of those near-term
factors are "implications of the Western Resource Adequacy Program (WRAP)." Please explain
the relationship between the Company's resource needs for 2024 and the WRAP.
REOUEST FOR PRODUCTION NO. 8
Another of the "near-term factors" being considered are the *72lr4W of PURPA solar
contracts" in Oregon. Are the referenced 72 MW of PURPA solar contracts included in the
Company's calculation of its current load resource deficit analysis? If not please explain why
not? What is the expected online date and size of each solar contract? Please identify any of the
solar contracts (if any) that are outside of Idaho Power's balancing authority.
R.EOUEST FOR P CTION NO.9
What is the contribution to capacity for PURPA solar projects? That is, what percentage
of a PURPA solar project's nameplate capacity receives a capacity credit or payement? Please
provide documentation for your calculation.
REOUEST FOR PRODUCTION NO. 10
At the top of page 29 of Mr. Ellsworth's pre-filed testimony he observes that the "120
MW of battery storage was pursued and procured a least cost/least risk method of meeting the
2023 capacity deficit..." Please explain whether the"l20 of battery storage" is the least
cost/least risk method or whether it is one of several possible (e.g. a least cost/least risk) method
of meeting the 2023 capacity deficit. Provide all workpapers and other relevant supporting
documentation to your response. Please identify and itemize by major component (land
FIRST PRODUCTION REQUEST OF THE ICIP
IN CASE NO. IPC-E-22.I3 PAGE 4
acquisition, battery units, interconnection, royalties, charging costs, etc. etc) the total expected
cost of the "120 battery storage" method of meeting the 2023 capacity deficit.
REOUEST FOR PRODUCTION NO. 11
At page l8 of Mr. Hackett's pre-filed testimony he states that Idaho Power has executed a
contact with Powin Energy Corporation for the purchase of BESS (battery energy storage
system). Please confirm whether or not Powin Energy Corporation is qualified to do business in
the state of Idaho as a foreign corporation. Please provide documentation for your response.
REOTIEST F'OR DUCTION NO. 12
At page 13 of Mr. Tatum's pre-filed testimony he states that the Company filed for an
exception to the Oregon Resource Procurement Rules on March 18,2022. What is the status of
that application? Does the Company anticipate an order in this docket before the Oregon
application is ruled upon or vice versa? Please explain the rationale for your answer. If the
Oregon Commission denies the Company's application for an exception, is it the Company's
plan to withdraw this application?
l2th dayof 2022
J ISB #95
RICHARDSON ADAMS, PLLC
FIRST PRODUCTION REQUEST OF THE ICIP
IN CASE NO. IPC-E-22-I3 PAGE 5
I HEREBY CERTIFY that on the l2th day of |y'ray 2022, a true and correct copy of the within
and foregoing FIRST PRODUCTION REQUEST of the Industrial Customers of Idaho Power in
Case No. IPC-E-22-13 was served, by electronic copy only, to:
Donovan Walker
Regulatory Dockets
Idaho Power Company
dwalker@idahopowe. com
dockets@ idahopower. com
Jan Noriyuki, Secretary
Idaho Public Utilities Commission
an.norl
Tom Arkoosh
Amber Dresslar
[e-mail]
amber
erin. cecil@arkoosh. com
ISB # 319s
FIRST PRODUCTION REQUEST OF THE ICIP
IN CASE NO. IPC-E-22-13 PAGE 6
Commission Secretary
Idaho Public Utilities Commission
secretary@puc. idaho. sov
Tim Tatum
Idaho Power Company
ttatum@,idahop ow er. c om