20220614Staff 1-21 to IPC.pdf

DAYN HARDIE
RILEY NEWTON
DEPUTY ATTORNEY GENERALS
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE,IDAHO 83720-OO
(208) 334-03t2103t8
IDAHO BAR NO. 9917 I 11202
Street Address for Express Mail:
I I33I W CHINDEN BVLD, BLDG 8, SUITE 2OI-A
BOISE,ID 837I4
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPAI\TY,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-22-13
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
IDAHO POWER COMPANY
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The Staff of the Idaho Public Utilities Commission, by and through its attorney of
record, Riley Newton, Deputy Attomey General, request that Idaho Power Company
("Company" or "ldaho Power") provide the following documents and information as soon as
possible, or by TUESDAY, JULY 5,2022.
This Production Request is 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 produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations. The Company is reminded that responses
pursuant to Commission Rules of Procedure must include the name and phone number of the
person preparing the document, and the name, location, and phone number of the record holder
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 1 JUNE 14,2022
and if different the witness who can sponsor the answer at hearing if need be. See IDAPA
31.01.01.228.
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. 1: In reference to Idaho Power's peak electric energy need identified in
2023. Applicationat2. Please provide the following:
a. Please identiff all potential resources considered by the Company to offset the
capacity need.
b. For each resource identified above, provide the size in megawatts ("MW") and its
effective load carrying capacity ("ELCC").
c. Please explain the process and criteria used to select a Battery Energy Storage System
("BESS") as compared to the other resources identified above. Please include all
workpapers and analysis used to conduct the selection process.
REQUEST NO.2: Did the Company consider a battery demand response program,
similar to the PacifiCorp Wattsmart Battery Program available to customers of Rocky Mountain
Power in southeastern Idaho? [f so, please provide the Company analysis used in considering the
program for meeting the Company's peak electric energy need identified in 2023. lf the
Company did not consider a similar program, please explain why.
REQUEST NO.3: Please answer the following items related to control of the facility:
a. Please explain in detail the meaning of "fully controlled" in reference to a
dispatchable resource. Application at 5.
b. Please explain why the necessary level of control would be impossible to obtain
through a Purchase Power Agreement ("PPA").
c. Is the Company aware of other PPAs with other utilities that provide similar levels of
dispatchability and control.
REQUEST NO. 4: Please answer the following regarding the Company's need to own
the BESS versus procuring the resource through a PPA.
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 2 JUNE 14,2022
a. Please provide the criteria the Company used to determine whether the Company
needs to own the resource versus the resource being provided through a PPA.
b. Please explain how Company ownership either meets or fails to meet each criterion
and to what extent. Please provide specific evidence to support the rationale.
c. Please explain how a PPA either meets or fails to meet each criterion and to what
extent. Please provide specific evidence to support the rationale.
d. Please explain the decommissioning risks associated with a Company-owned BESS as
compared to the decommissioning risk of the BESS through a PPA.
e. Where the Company identified deficiencies of obtaining the resource through a PPA
as compared to the resource being Company-owned, please provide specific examples
where these deficiencies have occurred and quantiff the impacts to economic,
operational, maintenance, reliability, and regulatory factors.
REQUEST NO. 5: Please provide an analysis regarding decommissioning of the 120
MW BESS at the end of its operational life. Please include specific decommissioning costs, the
potential for salvage, and issues related to environmental disposal impacts.
REQUEST NO. 6: Please provide the executed contract and documents describing the
technical specifications for the facilities. Application at 6.
REQUEST NO. 7: Is there a contingency included in the contract requiring a CPCN?
REQUEST NO. 8: Idaho Commission RFP guidelines, per Commission Order No.
32745, require the Company to "comply with RFP guidelines applicable in its Oregon service
area." Please list all the RFP guidelines the Company is out of compliance with.
REQUEST NO. 9: Please provide the Company's request for a waiver of Oregon's RFP
rules, Oregon Staff s testimony and/or comments regarding the waiver request, and the Oregon
Commission's final order.
REQUEST NO. 10: Please explain, in detail, the risk to the Company's financial health
if the 120 MW BESS is not Company-owned. Application at 3.
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY J JUNE 14,2022
REQUEST NO. 1l: Please provide a summary of the Company's experience in
operating and maintaining grid scale battery energy storage systems.
REQUEST NO. 12: Please describe the risks associated with owning and operating grid-
scale battery energy storage systems.
REQUEST NO. 13: Idaho Power required that projects that included a PPA for wind
and solar also include the transfer of ownership for the storage resource. Hackett Direct at 8.
a. Please explain the operational, reliability, and financial advantages and disadvantages
for the transfer of ownership requirement.
b. Please explain how the transfer of ownership requirement impacts customers.
c. Could a lower cost lower risk alternative have been achieved without the transfer of
ownership requirement? Explain.
REQUEST NO. 14: Jared Ellsworth's testimony states: "A key assumption used to
develop the load and resource balance for the Second Amended 2019 IRP was that Idaho Power's
exit from coal-fired operations at Valmy would free up transmission capacity for imports to Idaho
from the Southem Hubs. To reflect recent market changes, the Company eliminated this key
assumption, and assumed ldaho Power could only rely on access to the Southern Hubs to provide
50MW of capacity in the summer months." Ellsworth Direct at 10.
a. Please explain why the Company assumed, in developing the load and resource
balance for the Second Amended 2019 IRP, that its exit from coal-fired operations at
Valmy would free up transmission capacity for imports to Idaho from the Southern
Hubs.
b. Please describe in detail the "recent market changes" referred to in Jared Ellsworth's
testimony on page l0 and detailed on page 23 of his direct testimony.
c. Please explain why the Company did not have firm capacity secured from the
Southem Hubs independent of Valmy.
REQUEST NO. 15: Please provide a copy of the pre-bid presentation. Hackett Direct at
l0
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 4 JI.INE 14,2022
REQUEST NO. 16: Please identifu potential events that could cause the BESS resources
from not meeting their intended operation date. Please describe the likelihood of these events
occurring, their potential impact, and the Company's contingency plan(s) to address them.
REQUEST NO. 17: What are the expected useful and depreciable lives of the projects?
REQUEST NO. 18: Please provide copies of all bids the Company received and the
analysis the Company performed in selecting the resources.
REQUEST NO. 19: Referencing the analysis determining battery storage to be least
cost, please provide the life span used for battery storage and the documentation supporting this
conclusion.
REQUEST NO.20: Please provide the depreciable life the Company will use should
these projects be built and the documentation to supporting this determination.
REQUEST NO. 21: Please provide what the planning reserve margin ("PRM") would be
if the Company used a Loss of Load Expectation ("LOLE") of 1 day in 10 years instead of 1 day
in 20 years LOLE. Please also provide the first deficiency date using the PRM from a I day in l0
years LOLE.
DATED at Boise, Idaho, this H+\ day of Jwre 2022
Riley Newton
Deputy Attorney General
i:umisc:prodreq/ipce22. l3mrk prod reql
FIRST PRODUCTTON REQUEST
TO IDAHO POWER COMPANY 5 JUNE 14,2022
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS I4TH DAY OF JUNE 2022,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF TIIE
COMMISSION STAFF TO IDAHO POWER COMPANY, IN CASE NO.
TPC-E-22-13, 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
PETER J RICHARDSON
RICHARDSON ADAMS PLLC
515 N 27TH STREET
BOISE ID 83702
E-MAIL: [e-mail]
C. TOM ARKOOSH
AMBER DRESSLAR
ARKOOSH LAW OFFICES
9I3 W. RIVER STREET, SUITE 450
P.O. BOX 2900
BOISE,ID 8370I
E-MAIL:sh.com
Amber. [e-mail]
erin.cecil@arkoosh. com
TIMOTHY E TATUM
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: [e-mail]
DR DON READING
6070 HTLL ROAD
BOISE ID 83703
E-MAIL : [e-mail]
SECRETAR
CERTIFICATE OF SERVICE