20221005ICL to IPC 1-4.pdf

Marie Callaway Kellner (ISB No. 8470)
710 N. 66 Street
PO Box 844
Boise,ID 83701
Telephone: [phone]
mkellner@idahoconservation. org
ritC E IVE D
iil?? 0[T -5 Plt 3: 58
ii-i,i,-'.i PUBLIC
, ' r L'iT i i' .{ c [iLt M ISS loN
Attorney for the Idaho Conservation League
Intervenor
October 5,2022
VIA ELECTRONIC FILING
JanNoriyuki
Idaho Public Utilities Commission
I l33l W. Chinden Blvd, Bldg. 8
Suite 201-A (83714)
PO Box 83720
Boise, ID 83720-0074
RE:Case No. IPC-E-22-22
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
Generation & For Authority to Implement Changes to Schedules 6, 8, and 84 for
Non-Legacy Systems
Dear Secretary Noriyuki,
Attached for electronic filing is the Idaho Conservation League's Response to the First
Production Request of Idaho Power Company in the above-referenced matter.
Please respond with any questions or concens about the above referenced matter or the
attached response and accompanytng documents.
Regards,
V Marie Callaway Kellner
Marie Callaway Kellner
ISB No. 8470
Ipeno Pusuc UrIltnBs CovruIsstoN, Case No. IPC-E-22-22
Idaho Conservation L,eague, Response to Company's First Production Request
Marie Callaway Kellner (ISB No. 8470)
710 N 66 Steet
PO Box 844
Boise,ID 83701
Telephone: [phone]
mkellner@idahoconservation. org
Attorney for the Idatro Conservation League
Intervenor
IN THE MATTER OF IDAHO )
POWER COMPAI\IY'S )
APPLICATION TO COMPLETE )
TrrE STITDY REVIEW PHASE OF )
TIIE COMPREHENSTVE STUDY )
oF cosTs AtlD BENEFTTS OF ON- )
srTE GENERATION & FOR )
AUTHORITY TO IMPLEMENT )
CHANGES TO SCHEDULES 6,8, )
AI\D 24 )
BEFORB THE IDAHO PI]BLIC UTILITIES COMMISSION
CASE NO. IPC.E.22-22
IDAEO CONSERVATION LEAGUE
RESPONSE TO TIIE FIRST
PRODUCTOTN REQUEST OF
IDAHO POWER COMPAI\TY TO
THE IDAHO CONSERVATION
LEAUGE
The Idaho Conservation League submits to the Idaho Public Utilities Commission responses to
the First Production Request of ldaho Power Company to The Idaho Conservation League, dated
September 22,2022. Supporting infonnation and attachments are referenced in responses. The following
responses and attachments are submitted:
Response to Requests for Production Numbers l, 2, 3, and 4
IPC T&D Avoided Cost and PCAFs (Confidential), submitted via FTP site and subject to
protective agreernent (MS Excel document)
IPC Avoided Generation Capacity Cost (MS Excel document)
IPC Energy Avoided Cost (MS Excel document)
Local Economy Benefit (MS Excel document)
Distribution PCAF using ICL Request No. 12 (MS Excel document)
Ioeso Punuc Utrllrms Covlrssror.r, Case No. IPC-E-22-22
Idaho Conservation League, Response to Company's First Production Request
ldaho Conservation League (lCL) Responses to ldaho Power Company (lPC)
First Production Request to ICL
October 4,2022
REQUEST FOR PRODUCTION NO. 1: Please provide all workpapers and supporting
studies for each of the fo1lowing values presented in the Crossborder Energy Review
("Review") of ldaho Power's Value of Distributed Energy Resources ('VODER') Study:
a) Avoided Energy Costs
b) Avoided Generation Capacity
c) T&D Defenal
d) Avoided Line losses
e) lntegration Costs.
Response
Please see the following workpapers provided in attachments to this response:
o IPC Energy Avoided Cost.xlsbo IPC T&D Avoided Cost and PCAFs (CONFIDENTIAL).xlsb
(lncludes IPC's CONFIDENTIAL T&D forecast investment data).
o IPC Avoided Generation Capacity Cost.xlsx
o Distribution PCAF using ICL Request No 12.xlsbo Local Economy Benefit.xlsx
a) Avoided energy costs are shown in the'lPC Energy Avoided Cost" worksheet, at cell
R20 of the "EIM" tab.
b) Avoided generation capacity costs are shown in the'lPC Avoided Generation
Capacity Cost'worksheet. These include links to the PCAF calculations contained
in the "lPC Avoided Generation Capacity Cost" worksheet.
c) T&D defenal costs are contiained in the "lPC T&D Avoided Cost and PCAF
(CON Fl DENTIAL)' worksheet.
d) Avoided line Iosses were based upon the 5.7% to 5.9% T&D losses shown in Table
4.9, at p. 59, of IPC's Value of Solar Distributed Energy Resources (VODER) study.
We doubled the average line loss value of 5.8% to determine a marginal line loss
value of 11.6o/o. Please see the Regulatory Assistance Project (RAP) paper
referenced in footnote 14,for the explanation why marginal losses are greater than
average losses. We assume losses grow with the square of load, as explained in
footnote 3.
e) lntegration costs are taken from Table ESI of Appendix 4.15 of the VODER study.
See the total integration cost shown for Case 9, High Solar + 200 MW Storage.
REQUEST FOR PRODUGTION NO. 2: Please prcvide allworkpapers and supporting
studies for Fuel Hedging values presented in the Grossborder Energy review of Idaho
PoweCs VODER Study.
Resoonse
Please refer to the workpapels provided in response to Request for Production No. 1.
The Fuel Hedging value is included in the'Hedge'tab of the IPC Avoided Energy Cosf
worksheet.
REQUEST FOR PRODUCTION NO. 3: Please prcvide allworkpapers and supporting
studies for the value of Avoided Costs of Carbon Emissions in the Crossborder Energy
review of ldaho Powefs VODER Study.
Response
Please refer to the workpapers provided in rcsponse to Request for Prcduc'tion No. 1.
The Avoided Cost of Carbon nalue is included in the "CO2" tab of the'lPC Avoided
Energy Cosfl worksheet, at cell C37.
REQUEST FOR PRODUCTION NO.4: Please provide allworkpapers and supporting
studies for each of the value of Societa! Benefits of Distributed Solar Generation in the
Crossborder Energy review of ldaho Power's VODER Study. For each of these values,
please provide a detailed explanation of how these reflect the cost that currently are
embedded in customers' rates for electric service.
a) Carbon Social Cost and Methane Leakage
b) Health Benefits of Reducing Criteria Air Pollutants
c) Water
d) Local Economic Benefits
e) Land Use
f) Reliability and Resiliency
g) Customer Choice
Response
Please refer to the workpapers provided in response to Request for Production No. 1
a) The Carbon Social Cost and Methane Leakage values are included in the "CO2" tab
of the .lPC Avoided Energy Cost" worksheet; see cells D39 and G37, respectively.
b) The avoided emissions of criteria pollutants are shown on the 'AVERT" tab; see
cells H9:H12.
c) As described in footnote 45, avoided water use is based on AWEA's 2016 estimate
that 226 MWh of wind energy avoided 87 billion gallons of water, at a cost of $1 ,000
per acre-foot. We calculated $1.2 per MWh = (87 billion gallons) I (226 million MWh)
x ($1,000 per acre-foot) / (325,851 gallons per acre-foot).
d) See the "Loca! Economy Benefit.xlsx" worksheet.
Assuming that22o/o of residential solar PV costs are spent in the local economy, as
explained at page 18 of the Crossborder Energy Review, the workpaper computes a
$3,307 first year local economy benefit for installation of a 5.6 kW-DC solar PV
system. We divide the NPV of these first year Iocal economy benefits by the 258-
year NPV of solar output. On a 25-year levelized basis, assuming a 5o/o participant
discount rate, and O.5o/o annual degradation, the result is a levelized $ per MWh
value of $30.2 per MWh, as shown in cell C18.
e) As described at page 18 of our review, Land Use benefits were determined based
upon the product of an ldaho agricultural land value $ZAZ per acre) and utility-scale
solar plant land requirement of (4 acres per GWh). Thus, $262lacre x 4 acre/GWh=
$1.05 $/MWh, which rounds to $1.1 per MWh.
0 We did not assign a numerical value to Reliability and Resiliency.g) We did not assign a numerical value to Customer Choice.
Please be aware that our study does not assert that these benefits "reflect [costs] that
currently are embedded in customers' rates for electric service." Nonetheless, these
are quantifiable benefits that do accrue to !PC's ratepayers, based mostly on mitigating
the externalities associated with the production of electricity on IPC's system. ln other
words, these would represent costs embedded in rates for electric service if IPC's rates
reflected the full external costs of its energy production activities.