20220819Staff 26-55 to IPC.pdf

.-. Ii".':
Street Address for Express Mail:
11331 W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
RILEY 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
COMPANY'S APPLICATION TO
COMPLETE THE STUDY REVIEW PHASE
OF THE COMPREHENSIVE STUDY OF
COSTS AND BENEFITS OF ON-SITE
CUSTOMER GENERATION & FOR
AUTHORITY TO IMPLBMENT CHANGES
TO SCHEDULES 6, 8, AND 84
it;i i:.' 3b
CASE NO.IPC.E-22.22
SECOND PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO IDAHO POWER COMPAI{Y
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Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Riley Newton, Deputy Attorney General, requests that Idaho Power Company ("Company" or
"Idaho Power") provide the following documents and information as soon as possible, but no later
than FRIDAY, SEPTEMBER 9,2422.
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 identift the name, job title, location, and
telephone number of the record holder.
SECOND PRODUCTION REQUEST
TO IDAHO POWER I AUGUST 19,2022
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. 26: Appendices 4.4 and 4.5 are the net hourly and real-time exports for
year 2021. Please provide Appendices 4.4 and 4.5 broken out by Schedule 6, 8, and 84. Please
clarifu how the Schedule 84 customer data is netted for two-meter customer implementations.
REQUEST NO.27: The Value of Distributive Energy Resources ("VODER") study at
41 discusses the calculation of avoided cost of energy based on seasonal time-variant export
credit values, using the seasonal and time differentials of the Company's Demand Response
Program.
a. Please explain why a capacity-related on-peak/off-peak time differentiation is used
for determining a time-differentiated avoided cost of energy rate.
b. Please provide justification for the proposal of using the seasonal and time
differentials (on-peak and off-peak) of the Demand Response Program.
c. Please explain why the Company did not use other types of capacity-related on-
peak/off-peak time differentiations such as: (l) The peak/non-peak information
approved in Order No. 35294 in Case No. IPC-E-21-35; (2) The highest risk hours
under the Effective Load Carrying Capability ("ELCC") method; (3) The highest
risk hours under the National Renewable Energy Laboratory ("NREL") 8760
method. In your response, please explain what the highest risk hours are under the
ELCC method and the NREL 8760 method, respectively.
d. Please explain why the Heavy Load period and the Light Load period described in
the VODER study at 37 are not used to determine a time-differentiated avoided
cost ofenergy rate.
REQUEST NO. 28: Please explain why the Company did not use other types of
capacity-related on-peak/off-peak time differentiations to calculate avoided cost of capacity, such
as: (l) the peak/non-peak information approved in Order No. 35294 (Case No. IPC-E-21-35); (2)
the highest risk hours under the ELCC method; (3) the highest risk hours under the NREL 8760
method.
SECOND PRODUCTION REQUEST
TO IDAHO POWER 2 AUGUST 19,2022
REQUEST NO.29: Please explain why the Company did not use other types of
capacity-related on-peak/off-peak time differentiations to calculate avoided transmission and
distribution capacity costs, such as: (1) the peak/non-peak information approved in Order
No. 35294 (Case No. IPC-E-21-35); (2) the highest risk hours under the ELCC method; (3) the
highest risk hours under the NREL 8760 method; and (4) local peak hours.
REQUEST NO. 30: Order No. 35284 at l8 states "[w]e also find it reasonable and fair
for the study to adopt the Company's offered improvements to wording and clarification of the
use of net peak. We direct the Company to study the use of first deficit year, the identif,rcation
and evaluation of methods for identiffing system coincident peak, the exploration of different rate
designs, and the evaluation of potential differences between customers with and without storage."
a. Please identifu the first def,rcit year used in determining avoided cost of capacity in
the VODER study. If this is not provided in the VODER study, please provide it.
b. Please identiff the evaluation of methods for identifring system coincident peak in
the VODER study. If this is not provided in the VODER study, please provide it.
REQUEST NO.31: The VODER study at 47 states "ELCC determines an individual
generator's contribution to the overall system reliability and is primarily driven by the timing of
the highest risk hours, or Loss of Load Probability ("LOLP") hours." Please explain what the
highest risk hours are and how they are determined.
REQUEST NO.32: The VODER study at 48 discusses the NREL 8760 method. Please
confirm that the highest risk hours under this method are the top 100 net load hours. If so, please
provide the top 100 net load hours.
REQUEST NO. 33: The VODER study at 54 states "[t]o determine the potential value of
on-site generation in deferring or delaying the need for Idaho Power to build T&D resources, the
study identifies coincident peak hours." Additionally, the VODER study at 55 states "the
expected exports coincident with Idaho Power system peak load at the location [and] [t]he
avoided T&D cost values of VERs [(Variable Energy Resources)] can be calculated using actual
SECOND PRODUCTION REQUEST
TO IDAHO POWER .,AUGUST 19,2022
and proposed capacity projects, the local area growth rates, and the local VER export values at the
time of the local peak."
a. Does the VODER study use coincident peak hours at the local level instead of the
system level to determine avoided transmission and distribution capacity values?
b. If so, please explain why planning for transmission and distribution is based on
local coincident peak hours, instead oflocal net peak hours.
c. Please explain how system peak load at the location is determined.
d. Please define "local area growth rates" and explain how they are determined.
e. Does "system peak load at the location" and "local peak" have the same meaning?
If not, please explain.
REQUEST NO. 34: The VODER study at 54 states that avoided transmission and
distribution capacity costs would be paid only when "the quantity of the export would need to be
sufficient to exceed the planning capacity shortfall". However, the quantity of the export is not
required to exceed the Company's capacity deficit to receive avoided generation capacity costs.
Please explain why avoided transmission and distribution costs are not counted the same way as
avoided generation capacity costs.
REQUEST NO.35: Please explain why the calculation of the Export Credit Rate
("ECR") uses different time periods of data for different components of the ECR. For example,
2020 and 2021 historical data is used to calculate capacity contribution under the ELCC and
NREL 8760 methods, whereas only the 2021 data is used to calculate avoided transmission and
distribution costs.
REQUEST NO.36: The VODER study at 55 states the data used for calculating avoided
transmission and distribution costs include each capacity project's peak capacity and peak load,
growth rate, and time of peak demand, as well as system aggregate export shapes based on real-
time and net-hourly energy measured in202l. The VODER study at 56 also mentions "expected
peak time exports".
a. Please explain how each capacity project's peak capacity is determined.
SECOND PRODUCTION REQUEST
TO IDAHO POWER 4 AUGUST 19,2022
b. Please explain how system aggregate export shapes are determined based on real-
time and net-hourly energy, respectively.
c. Please define "Solar Contribution at Peak" on Tab "Growth Projects 2007-2026"
in Appendix 4.13 Transmission and Distribution Avoided Capacity excel file.
d. Please explain how the "Solar Contribution at Peak" is calculated.
REQUEST NO. 37: Order No. 35284 at l9 states "[t]he Commission finds it reasonable
and fair to separately study avoided transmission costs and avoided distribution costs. In doing
so, the study should consider: (a) whether exports avoid construction or delay construction, (b)
individual customer-generators versus a class, and (c) configurations with and without storage."
a. Section 4.3.2 of the VODER study only discusses calculations for project deferral.
Please identiff where an analysis of project avoidance is conducted in the VODER
study. If this is not provided in the VODER study, please provide it.
b. Please identiff where an analysis of individual customer-generators versus a class
is conducted in the VODER study. If this is not provided in the VODER study,
please provide it.
c. Please identifr where an analysis of configurations with and without storage is
conducted in the VODER study. If this is not provided in the VODER study,
please provide it.
REQUEST NO.38: The VODER study at 57 states "[t]he study did not evaluate a
locational based ECR value as this is not a feasible solution within the Company's billing
system", even though Order No. 35284 at l9 states "avoided distribution costs are locational
benefits properly studied" and that "[i]t is reasonable to evaluate, for use, examples from the
Lawrence Berkeley National Lab to better value this element of the ECR." Please explain in
detail why this is not a feasible solution within the Company's billing system. [n addition, please
explain why the VODER study does not consider examples from the Lawrence Berkeley National
Lab.
SECOND PRODUCTION REQUEST
TO IDAHO POWER 5 AUGUST 19,2022
REQUEST NO.39: If a utility is in excess of energy and chooses to sell exported solar
generation into the market, please explain whether the on-site generation customers should pay
for line losses, which could potentially be a negative adjustment in the ECR they receive.
REQUEST NO. 40: Order No. 35284 at 20 states "[i]t is also reasonable to study the
difference between using static or marginal losses and the magnitude of each as part of the
valuation to be included in the ECR." Please identiff where this analysis is located in the
VODER study. If this is not provided in the VODER study, please provide it.
REQUEST NO. 4l: Table 4.9 inthe VODER study presents the Company's 2012
System Loss Study results based on On-Peak, Mid-Peak, and Off-Peak hours for summer and
winter. Please explain whether the 2012 System Loss Study results should be converted to align
with the timeframe of the Demand Response Program (or other capacity-related peak timeframes)
before being used for calculating avoided line losses.
REQUEST NO. 42: The VODER study at 59 discusses transforrner core losses, and
states "[t]he 2012 System Loss Study determined the loss percentages for the transmission
system, distribution system, distribution primary voltage, and the distribution secondary voltage."
a. Please define transformer core losses.
b. Please define distribution primary voltage and distribution secondary voltage.
c. Please explain whether losses associated with distribution primary voltage and
losses associated with distribution secondary voltage are two types of transformer
core losses.
d. Please explain whether losses of the transmission system, distribution system,
distribution primary voltage, and the distribution secondary voltage can all be
avoided by customer-generator exports.
REQUEST NO. 43: The VODER study at 59 states that20l2 System Loss Study was
done for both energy losses and for peak losses. Please define both types oflosses and explain
whether the loss percentages listed in Table 4.8 and Table 4.9 of the VODER study represent
energy losses, peak losses, or both. If they only list one type, please provide the other type.
SECOND PRODUCTION REQUEST
TO IDAHO POWER 6 AUGUST 19,2022
REQUEST NO. 44: Please explain how the 5.80% annual line loss percentage is
determined in Figure 4.14 of the VODER study.
REQUEST NO. 45: Please respond to the following regarding Avoided Line Loss in
Figure 4.18 of the VODER study.
a. Please explain what line loss percentages are used to calculate Off-Peak Avoided
Line Loss and how they are determined.
b. Please explain what line loss percentages are used to calculate On-Peak Avoided
Line Loss and how they are determined.
c. Please explain whether the line loss percentages are applied to the avoided cost of
energy (energy losses), the avoided cost ofcapacity (peak losses), or both.
d. Please explain whether the line loss percentages are different when applied to the
avoided cost ofenergy (energy losses) and the avoided cost ofcapacity (peak
losses).
REQUEST NO. 46: If on-site generation of solar energy is to be certified in Westem
Renewable Electricity Generation Information System ("WREGIS") by a customer, can all the
generation be certified, or can only the exported generation portion be certified? If on-site
generation of solar energy is to be certified in WREGIS by Idaho Power on behalf of the
customers, can all the generation be certified, or can only the exported generation portion be
certified?
REQUEST NO. 47: Order No. 35284 at 21 states that "changes in costs for distribution
circuits are appropriate to study." Please explain whether the VODER study analyzes changes in
costs for distribution circuits. If not, please explain why.
REQUEST NO. 48: The VODER study at 67 uses an integration charge of $2.93 per
Megawatt hour ("MWh"), determined in the Base 2023 Case of the 2020 VER Integration Study,
and states that "[t]his integration rate could be utilized until Idaho Power completes its next
integration study and integration costs for customer-generators could be evaluated directly."
Please estimate the deviation of an integration charge today from the 52.93 per MWh, given the
SECOND PRODUCTION REQUEST
TO IDAHO POWER 7 AUGUST 19,2022
differences between key assumptions/inputs that should be used today and key assumptions/inputs
used in the2020 VER Integration Study. Some examples for consideration are shown in the
following table.
Today's Assumptionsflnputs 2020' s Assum ptions/Inputs
Latest forecast for 2023 load.2020 VER Integration Study at 10 states
"[t]o estimate 2023 loads, E3 used load
growth projections from [daho Power to
uniformly increase 2019 loads by
approximately 5 percent total to 2,081
aMW."
Latest 2023 VER profiles determined 2020 VER Integration Study at l0 states
"the 2019 historical VER profiles were used
to derive the2023 VER profiles."
Updated new solar assumptions, if available 2020 VER Integration Study at l l states
"for the 2023 base case, it was reasonable to
assume that25l MW of new solar was
online in their service territory ( l3 I MW of
unspecified PURPA contracts and 120 MW
form the planned Jackpot Solar facility)."
Updated wind assumptions for 2023, if
available.
2020 VER Integration Study at 11 states
"ldaho Power also proposed that the2023
wind capacity remain the same as that from
2019;'
Updated unit capacities, if available.2020 VER [ntegration Study at 13 lists unit
capacities in20l9 and2023 by generator
and resource Wpe.
REQUEST NO. 49: The VODER study at 64 states "Figure 4.15 depicts customer
exports compared to the Company's utility scale solar with both outputs normalized based on
their peaks for the first week of the four quarters of 2021."
a. How does Figure 4.15 reflect day-ahead and hour-ahead real time uncertainty?
b. Please describe the normalization process based on the peaks of the first week for
the four quarters of 2021.
c. For "July 2021" in Figure 4.15, please explain why customer exports do not align
with utility scale solar as compared to January, April, and October of 2021?
d. Given "July 2021", please explain why the Company still believes "[t]his data
shows that the shapes are comparable and highly correlated" and "[t]hese figures
SECOND PRODUCTTON REQUEST
TO IDAHO POWER 8 AUGUST 19,2022
support utility scale solar as a good proxy for customer-generator exports for the
purposes of studying integration costs." VODER study at 64.
REQUEST NO. 50: The VODER study at 65 states "[i]ntegration costs are also caused
by uncertainty in the 15-minute and 5-minute timeframes. Idaho Power does not collect customer
data on these timeframes; therefore, it is challenging to directly compare customer exports and
utility scale solar." Please explain what the Company means by "Idaho Power does not collect
customer data on these timeframes," when customer meters can measure on real time intervals.
REQUEST NO. 51: The VODER study at 7l states "the energy input would be updated
every other year along with or directly after receiving acknowledgement of an IRP." VODER
study at 72 states "[t]he levelized fixed cost of the avoided resource is determined in ldaho
Power's IRP. Therefore, it would be reasonable to expect this input only to be updated every
other year."
a. Please explain whether the energy input could be updated after an IRP is filed.
b. Please confirm that the levelized fixed cost of the avoided resource could be
updated every other year along with or directly after an IRP is filed or
acknowledeed.
REQUEST NO. 52: The VODER study evaluates two methods for calculating avoided
cost of capacity: flat annual rates and seasonal time variant rates. However, Chapter 5 Frequency
of Export Credit Rate Updates only discusses update frequency of the flat annual ECR.
a. Please explain how the Company plans to update seasonal time variant avoided
cost of capacity.
b. If the update depends on the Demand Response Program, please explain how
frequently the Company plans to update the program.
c. Please explain whether the avoided cost of capacity can be calculated based on the
peak hours that the Company files with the Commission annually on October 15.
d. If so, please explain whether the update can occur annually in the October l5
filing.
SECOND PRODUCTION REQUEST
TO IDAHO POWER 9 AUGUST 19,2022
REQUEST NO. 53: If the Company is going to do a full Cost of Service study, please
explain whether the Company is going to analyze how compensations of ECR will affect the total
system costs. In addition, please explain whether the impacts could potentially affect all classes.
REQUEST NO.54: The VODER study at 84 states "[i]n development of CCOS inputs,
Schedule 84 customers are not included in the customer sample for Schedule 9, 19, or 24." Please
explain why Schedule 84 customers are not included in the customer sample for Schedule 9,19,
or24.
REQUEST NO. 55: The VODER study at 94 states that customer generation is a must-
take resource similar to Public Utility Regulatory Policies Act of 1978 (*PURPA") qualiffing
facilities, so these costs should not be subject to the 95%15% sharing mechanism. Please explain
why all must-take resources should not be subject to the sharing mechanism.
DATED at Boise, Idaho, this
l ]\*of August 2022.
Riley Newton
Deputy Attorney General
i:umisc:prodreq/ipceZ2.Z2mtrc prod req 2
SECOND PRODUCTION REQUEST
TO IDAHO POWER l0 AUGUST 19,2022
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 19th DAY OF AUGUST 2022,
SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY, IN CASE NO. IPC-E-22-22,
BY E-MAILING A COPY THEREOF, TO THE FOLLOWNG:
LISA NORDSTROM
MEGAN GOICOECHEA ALLEN
IDAHO POWER COMPANY
PO BOX 70
BOrSE rD 83707-0070
E-MAIL: I .coln
m go icoecheaall en@,idaho power. com
doc ket s@)i d aho po wer. con'r
C TOM ARKOOSH
AMBER DRESSLAR
ARKOOSH LAW OFFICES
PO BOX 2900
BOISE ID 83701
E-MAIL: [e-mail]
[e-mail]
KELSEY JAE
LAW FOR CONSCIOUS LEADERSHIP
920 N CLOVER DR
BOISE ID 83703
E-MAIL: kelsev@,kelseyiae.com
ERIC L OLSEN
ECHO HAWK & OLSEN PLLC
PO BOX 61 19
POCATELLO ID 83205
E-MAIL: elo(Eec u'k.cortt
TIMOTHY TATUM
CONNIE ASCHENBRENNER
GRANT ANDERSON
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: [e-mail]
[e-mail]
ganderson@idahopolver. com
MICHAEL HECKLER
COURTNEY WHTTE
CLEAN ENERGY OPPORTUNITIES
3778 PLANTATION RIVER DR
SUITE 102
BOISE ID 83703
E-MAIL:
mike@c leanenergyopportunit ies.com
courtney@cleanenergyor:portunities.com
ELECTRONIC ONLY
ERIN CECIL
E-MAIL: [e-mail]
LANCE KAUFMAN PhD
4801 W YALE AVE
DENVER CO 80219
E-MAIL : [e-mail]
Y
CERTIFICATE OF SERVICE