20220922IPC 5-23 to ICL.pdf

SEHffii]ECIIVED
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An DACORP ComFny
September 22,2022
VIA ELECTRONIC FILING
Jan Noriyuki, Secretary
!daho Public Utilities Commission
11331 W. Chinden BIvd., Bldg 8,
Suite 201-A (83714)
PO Box 83720
Boise, ldaho 83720-0074
Re Case No. IPC-E-22-22
ln the Matter of ldaho 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 lmplement Changes to
Schedules 6, 8 and 84 for Non-Legacy Systems
Dear Ms. Noriyuki:
Attached for electronic filing is ldaho Power Company's Second Production
Request to the ldaho Conservation League in the above-referenced matter.
lf you have any questions about the documents referenced above, please do not
hesitate to contact me.
Very truly yours,
Megan Goicoechea Allen
Corporate Counset
m [e-mail]
MGA:sg
Attachment
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Megan Goicoechea Allen
LISA D. NORDSTROM (lSB No. 5733)
MEGAN GOICOECHEA ALLEN (lSB No. 7623)
ldaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
!nordstrom@ida hooower. com
mqoicoecheaallen@ ida hopower. com
Attorneys for ldaho Power Company
BEFORE THE !DAHO PUBLIC UTILITIES COMMISSION
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 IMPLEMENT
CHANGES TO SCHEDULES 6, 8, AND
84 FOR NON-LEGACY SYSTEMS
CASE NO. !PC-E-22-22
IDAHO POWER COMPANY'S
SECOND PRODUCTION
REQUEST TO THE IDAHO
CONSERVATION LEAGUE
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COMES NOW, ldaho Power Company ("ldaho Powe/'or "Company"), and hereby
requests that the ldaho Conservation League ("lCL") answer the following production
requests and provide the following information and documents in accordance with the
Commission's Rules of Procedure and applicable scheduling orders and notices to be
issued by the Commission in this proceeding.
IDAHO POWER COMPANY'S SECOND PRODUCTION REQUEST TO THE IDAHO CONSERVATION
LEAGUE - 1
Please provide information that ls responsive to this request as soon as possible
but no later than October 6,2022.
This production request is to be deemed continuing in nature and ICL is requested
to provide, through supplementation, additional documents or information that is
responsive to this request that it, or any person acting on its behalf, may later come into
possession or become aware of.
REQUEST FOR PRODUCTION NO.5: Page 2 of the Crossborder Energy Review
("Review") of ldaho Power's Value of Distributed Energy Resources ("VODER") Study
states that, "avoided energy costs should reflect more timely and accurate data than the
IRP forecast or the three-year rolling averages used by !PC. For example, they could be
based on EIM prices from the prior 12 months, adjusted based on natural gas forward
market prices for the next year." Please respond to the following questions:
a) How should a historical market price be adjusted utilizing a natural gas
forward market price?
b) How would a real market price that is adjusted based on a natura! gas
forward market be a better adjustment than using the actual market price?
REQUEST FOR PRODUCTION NO. 6: Page 3 of the Review states that the "!ow
ELCC is surprising, given that the 2021 IRP shows that the ELCC of IPC's existing solar
resources are over 60%, and the new Jackpot solar project that lPC ls adding inlate2022
or 2023 has an ELCC of 34o/o. Yes, utility scale solar facilities that use tracking arrays will
have somewhat higher ELCCs than fixed rooftop arrays, and the ELCC of solar generally
will decline as more solar is added to a utility's resource mix, but the difference between
a 34o/o ELCC for new utility scale solar and 7.60/o for new rooftop solar is excessive."
IDAHO POWER COMPANY'S SECOND PRODUCTION REQUEST TO THE IDAHO CONSERVATION
LEAGUE - 2
a) Please explain why it is reasonable to compare the ELCCs of a utility-scale
solar facility with tracking capabilities that exports gllenergy generated for
all production hours to the grid to behind-the-meter customer generation
that exports only the excess energy which is typically lower during the hours
of highest risk for the utility?
REQUEST FOR PRODUCTION NO. 7: Page 3 of the Review states that ldaho
Power's "approach makes the mistake of ignoring that only about one-half of the
distributed solar capacity is used to produce exports; the other half serves the customers'
loads behind the meter. The amount of real-time exports in 2020-2021, as a percentage
of total output, indicates that about 52o/o of the solar capacity is used for exports. Thus
IPC's capacity contributions need to be increased by a factor of 1 divided by 0.52."
a) Please explain why the capacity contributions should be increased by a
factor of 1 over 52%?
REQUEST FOR PRODUCTION NO. 8:Page 3 of the Review states that the
"amount of real-time exports in 2021-2021 , as a percentage of total output, indicates that
about 52o/o of the solar capacity is used for exports."
a) Please provide all workpapers used to determine the 52% used in the
Review.
REQUEST FOR PRODUCTION NO. 9: Page 3 of the Review states that "[i]nstead
of using ELCCS, we prefer the use of the peak capacity allocation factor (PCAF) method."
a) Please provide all workpapers associated with the PCAF method used in
the Review.
IDAHO POWER COMPANY'S SECOND PRODUCTION REQUEST TO THE IDAHO CONSERVATION
LEAGUE - 3
REQUEST FOR PRODUCTION NO. 10: Page 3 of the Review states that the
'ELCC of solar generally will decline as more solar is added to a utility's resource mix."
a) Please explain how the PCAF is able to capture the declining contribution
of solar as penetration increases.
REQUEST FOR PRODUCTION NO. 11: Page 4 of the Review states that the
"PCAF method calculates the capacity contribution of solar exports across all hours that
have loads within 10% of the system peak hour. This method weights the solar output in
these high-load hours by how close the system load in that hour is to the annual peak
hour load. The hour with the annual peak load is weighted the most."
a) Please explain why the hour with the annual peak load should be weighted
the most.
REQUEST FOR PRODUCTION NO. 12: Page 4 of the Review states that
Crossborder "derived hourly PCAFs for IPC using system load data from 2016-2020.
Using this PCAF method, the capacity contribution of real-time solar exports is 28.6% in
2020 and 25.3o/o in 2021, for an average of 27 .0o/o."
a) Please explain what solar data was used for the 2016-2020 PCAF analysis.
b) lf a generic solar generation shape was used, please explain how the
relationship between system load, weather and production is considered in
the analysis.
c) Please provide all workpapers associated with the calculations, including
the hourly results for the PCAF 2016-2020 analysis.
d) Please explain the rationale for using 2016-2020 data and omitting the
provided 202'l data.
IDAHO POWER COMPANY'S SECOND PRODUCTION REQUESTTO THE IDAHO CONSERVATION
LEAGUE.4
REQUEST FOR PRODUCTION NO. 13: Page 4 of the Review, Table 1
Crossborder Recommendation for IPC's Avoided Generation Capacity Costs, includes
the reserve margin used in the avoided generation capacity cost calculation of 15.5o/o.
a) PIease explain why the reserve margin is a component of the solar avoided
generation capacity cost calculation and why that is a reasonable
assumption.
REQUEST FOR PRODUCTION NO. 14: Please explain why customergeneration
exported energy should be compensated based on peak load reduction attributable to
energy efficiency and/or demand response.
REQUEST FOR PRODUCTION NO. 15: Page 5 of the Review states that
'[c]ollectively, these resources can have a much larger impact to reduce IPC's need for
T&D upgrades over time - by being a much larger amount of capacity, by concentrating
load reductions in certain locations, and by moving the utility to a much lower long-term
demand trajectory."
a) Please explain how concentrating load reduction by location creates a lower
demand trajectory.
REQUEST FOR PRODUCTION NO. 16: Asset replacement projects include
replacing equipment at the end of its useful Iife, replacement of obsolete or unsupported
equipment, and relocating equipment such as due to alignment changes (road widening).
Page 5 of the Review states that "replacement projects are demand-related in that they
are necessary to keep the grid's capacity from declining."
IDAHO POWER COMPANY'S SECOND PRODUCTION REQUEST TO THE IDAHO CONSERVATION
LEAGUE - 5
a) Please explain how asset replacement projects can be deferred through
customer generation exported energy. Please be specific to ldaho Power's
system and its growing customer base, including how customer generation
could defer projects such as replacing an aged customer distribution
transformer, replacing out of date communications equipment, and
replacing damaged pole plant.
REQUEST FOR PRODUCTION NO. 17: !n Table 2 Crossborder
Recommendation for IPC's T&D Defenal Cosfs shows different 'Solar Capacity
Contribution" for Transmission and Distribution.
a) Please explain why these values are different and provide associated
supporting data.
REQUEST FOR PRODUCTION NO. 18: Page 4 of the Review states that the
"PCAF method calculates the capacity contribution of solar exports across all hours that
have loads within 10o/o of the system peak hour."
a) Please veriff if this indicates that the T&D Deferra! Costs should apply to
exports only during those hours with loads within 10o/o of system peak.
b) lf not, please explain the reason for applying those T&D Deferral Costs to
other hours of energy export.
REQUEST FOR PRODUCTION NO. 19: Page 7 of the Review states that the
'marginal losses associated with behind-the-meter solar resources are higher than
system average losses because much of the solar output occurs in the afternoon hours
when loads and losses are higher."
IDAHO POWER COMPANY'S SECOND PRODUCTION REQUEST TO THE IDAHO CONSERVATION
LEAGUE - 6
a) Please provide data to support the statement that much of the solar output
occurs when loads and losses are higher.
REQUEST FOR PRODUCTION NO. 20: Page 8 of the Review states that "[i]n the
absence of an up-to-date study of marginal line losses, it is reasonable to double IPC's
system average resistive line losses from 20'12, to 11.60/o."
a) Please provide any documentation or data that supports the idea that
doubling the losses is reasonable.
REQUEST FOR PRODUCTION NO. 21: Page 8 of the Review states that the
"scenario whose resource mix most closely resembles the subsequent 2021 IRP's
preferred plan is Case 9 - the High Solar with 200 MW Storage case." However, the base
case in the integration study already includes 131 MW of solar contracts plus 120 MW
from Jackpot solar.
a) Please explain how a scenario that includes 794 MW of new solar, for a
total of 1,045 MW closely resembles the IRP where only 420 MW of solar
were in the preferred portfolio in the next 5 years.
REQUEST FOR PRODUCTION NO. 22: Please explain the fuel hedging value
that exists under each of the following avoided energy inputs for an Export Credit Rate
("ECR"):
a) lntegrated Resource Plan - ldaho Power Price
b) ICE Mid-C lndex Price
c) Energy Imbalance Market Load Aggregation Point ("ELAP") Price
IDAHO POWER COMPANY'S SECOND PRODUCTION REQUEST TO THE IDAHO CONSERVATION
LEAGUE - 7
REQUEST FOR PRODUCTION NO. 23: For each of the co-authors of the
Crossborder Energy Review ("Review'), R. Thomas Beach and Patrick G. McGuire,
please provide the following to the extent not included with ICL's initial comments:
a) A curriculum vitae and/or resume;
b) A list of any and all cases or matters in which he has offered testimony, live
or prepared, within the preceding four (4) years and include on whose behalf
the testimony was provided;
c) A Iist of all publications authored in the previous ten (10) years;
d) A statement of the compensation to be paid for the Review and any
testimony provided in this matter; and
e) A copy of all materials provided by ICL or another Party to this case in
relation to the Review.
IDAHO POWER COMPANY'S SECOND PRODUCTION REQUEST TO THE IDAHO CONSERVATION
LEAGUE - 8
DATED at Boise, ldaho, this 22nd day of September2022.
WTiui^z-0[e,{
MEGAN GOICOECHEA ALLEN
Attorney for ldaho Power Company
IDAHO POWER COMPANY'S SECOND PRODUCTION REQUEST TO THE IDAHO CONSERVATION
LEAGIJE.9
CERTIFICATE OF SERVICE
! HEREBY CERTIFY that on the 22nd day of September 2022,1 served a true and
correct copy of ldaho Power Company's Second Production Request to the ldaho
Conservation League upon the following named parties by the method indicated below,
and addressed to the following:
IDAHO PO\A'ER COMPANY'S SECOND PRODUCTION REQUEST TO THE IDAHO CONSERVATION
LEAGUE - 10
Commission Staff
Riley Newton
Deputy Attorney General
ldaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg No. 8
Suite 201-A (83714)
PO Box 83720
Boise, lD 83720-0074
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ldaHydro
C. Tom Arkoosh
Amber Dresslar
ARKOOSH LAW OFFICES
913 W. River Street, Suite 450
P.O. Box 2900
Boise, ldaho 83701
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Amber.d [e-mail]
[e-mail]
ldaho Conservation League
Marie Kellner
ldaho Conservation League
710 North 6th Street
Boise, ldaho 83702
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ldaho lrrigation Pumpers Association, lnc.
Eric L. OIsen
ECHO HAWK & OLSEN, PLLC
505 Pershing Avenue, Suite 100
P.O. Box 6119
Pocatello, ldaho 83205
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Lance Kaufman, Ph.D.
4801 W. Yale Ave.
Denver, CO 80219
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City of Boise
Mary Grant
Deputy City Attorney
Boise City Attorney's Office
150 North Capitol Boulevard
P.O. Box 500
Boise, ldaho 83701-0500
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bo isecitvatto rnev@citvofbo ise. orq
Wil Gehl
Energy Program Manager
Boise City Dept. of Public Works
150 N. Capito! Blvd.
PO Box 500
Boise, ldaho 83701-0500
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lndustrial Customers of ldaho Power
Peter J. Richardson
RICHARDSON ADAMS, PLLC
515 North 27th Street (83702)
P.O. Box 7218
Boise, Idaho 83707
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Dr. Don Reading
6070 Hill Road
Boise, ldaho 83703
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Micron Technology, lnc.
Austin Rueschhoff
Thorvald A. Nelson
Austin W. Jensen
Holland & Hart, LLP
555 Seventeenth Street, Suite 3200
Denver, Colorado 80202
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[e-mail]
awiensen @holland hart. com
Jim Swier
Micron Technology, lnc.
8000 South FederalWay
Boise, ldaho 83707
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[e-mail]
IDAHO POWER COMPANY'S SECOND PRODUCTION REQUEST TO THE IDAHO CONSERVATION
LEAGUE - 1 1
Clean Energy Opportunities for ldaho
Kelsey Jae
Law for Conscious Leadership
920 N. CIover Dr.
Boise, ldaho 83703
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Michael Heckler
Courtney White
Clean Energy Opportunities for ldaho
3778 Plantation River Dr., Suite '102
Boise, lD 83703
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X Email
cou rtnev@cleanenerqvoppo rtu n ities. com
m ike @clea n ene rovo ppo rtu n ities. com
Richard E. Kluckhohn, pro se
Wesley A. Kluckhohn, pro se
2564 W. Parkstone Dr.
Meridian, ID 83646
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[e-mail]
ldaho Solar Owners Network
Joshua Hill
1625 S. Latah
Boise, lD 83705
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[e-mail]
ABC Power Company, LLC
Ryan Bushland
184 W. Chrisfield Dr.
Meridian, lD 83646
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sunshine@ abcoower.co
'\hGct[&^J-
Stacy Gust, Regulatory Administrative
Assistant
IDAHO POWER COMPANY'S SECOND PRODUCTION REQUEST TO THE IDAHO CONSERVATION
LEAGUE. 12