20230414Staff 42-47 to IPC.pdf

RILEY NEWTON O
MICHAEL DUVAL
DEPUTY ATTORNEYS GENERAL AM ll:QIDAHOPUBLICUTILITIESCOMMISSION
PO BOX 83720
BOISE,IDAHO 83720-0074
[phone]/334-0320
IDAHO BAR NOS.11202 &11714
Street Address for Express Mail:
11331 W CHINDEN BLVD,BLDG 8,SUITE 201-A
BOISE,ID 83714
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER )
COMPANY'S APPLICATION FOR A )CASE NO.IPC-E-23-01
CERTIFICATE OF PUBLIC CONVENIENCE )
AND NECESSITY FOR THE BOARDMAN TO )HEMINGWAY 5OO-KV TRANSMISSION )FOURTH PRODUCTION
LINE )REQUESTOF THE
)COMMISSION STAFF
)TO IDAHO POWER COMPANY
Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Michael Duval,Deputy Attorney General,requests that Idaho Power Company ("Company"or
"Idaho Power")provide the followingdocuments and information as soon as possible,but no
later than FRIDAY,APRIL 28,2023.1
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.
*Staff is requesting an expedited response.If responding by this date will be problematic,please call Staff's
attorney at [phone].
FOURTH PRODUCTION REQUEST
TO IDAHO POWER 1 APRIL 14,2023
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 identify the name,job title,location,and
telephone number of the record holder.
In addition to the written copies provided as response to the requests,please provide all
Excel spreadsheets and electronic files with formulas intact and enabled.
REQUESTNO.42:As described by Company witness Ellsworth,the agreements in the
Term sheet will be executed followingBonneville Power Administration's ("BPA")public
process,which was to have concluded in March 2023.Ellsworth Direct at 12-13.Please provide
the following:
a.Please provide the most recent documents regarding BPA's environmental
decision process;
b.Please provide a narrative update on the status of each agreement outlined in the
Term Sheet;and
c.Please provide a supporting workpaper that updates the status of each agreement
in the Term Sheet,including its signing status,when the agreement goes into
effect,and any changes (in red-line format)made to that agreement since filing
the non-binding Term sheet with the Company's Application.
REQUESTNO.43:As a supplement to the Company's response to Production Request
No.3,please explain what is included in non-billable labor costs.Please provide any supporting
workpapers that detail items included in non-billable labor costs.
REQUESTNO.44:In Attachment 1 of the Company's response to Production Request
No.33,BPA writes,"After BPA completes the environmental studies,which is expected in
February 2023,BPA will make a fmal decision about the construction of the Longhorn
substation in response to the UEC interconnection request....BPA would design the proposed
Longhorn substation to accommodate the B2H interconnection request and other future
interconnection requests."Production Request No.33,Attachment 1 at 11.Please provide an
update of BPA's progress on this issue,and any supporting documents released by BPA.
FOURTH PRODUCTION REQUEST
TO IDAHO POWER 2 APRIL 14,2023
REQUESTNO.45:In Attachment 1 of the Company's response to Production Request
No.33,BPA writes,"For B2H to be constructed on the right-of-way,BPA's Boardman-to-Ione
transmission line must be removed first.Additionally,BPA would need to find an alternative to
serve Columbia Basin."Production Request No.33,Attachment I at 12.Additionally,
"Energization of the proposed alternative service would need to be completed by spring of
2025...."Production Request No.33,Attachment 1 at 13.Please provide the following:
a.Please provide the latest status of BPA's and the Company's efforts to complete
this piece of the B2H project,including the environmental review;and
b.BPA states that it will recover costs associated with the Boardman-to-Ione line
relocation from the Company and PacifiCorp.Please provide the estimated cost
of this project,and the Company's share.Please clarify if this cost is part of the
B2H estimate,or if it is separate.
REQUESTNO.46:The Company's response to Production Request No.29 confirms
that Mid-Columbia ("Mid-C")market prices have been substantially higher than the Integrated
Resource Plan ("IRP")forecasted prices on a sustained basis for 2021 and 2022.The
Company's response to Production Request No.30 states:
The B2H project is modeled in AURORA as additional transmission
capacity available for Idaho Power energy purchases and sales from the
Pacific Northwest.To the extent this incremental export transmission
capacity enabled additional Company resource sales over the existing
transmission system,benefits would be captured in Aurora modeling
process and reflected in total portfolio costs.
Please provide the followinginformation:
a.Please explain the hypothetical impact of Mid-C market prices on the
determination of portfolio cost via AURORA.Should higher market prices tend
to increase or decrease the portfolio cost?Please explain the Company's
reasoning;and
b.To validate the hypothesis,please run the AURORA dispatch model for the Base
B2H scenario,but vary the market price,holding all other factors constant.The
dispatch model runs should include the normal forecast (50th percentile),a high-
price forecast (75th percentile),and a low-price forecast (25th percentile).Please
FOURTH PRODUCTION REQUEST
TO IDAHO POWER 3 APRIL 14,2023
provide for each run across the 20-year evaluation period,the net present value,
the annual benefit and cost value streams broken out separately,and the
Megawatt-hours ("MWh")and the dollar value of purchases and sales in each
year.
REQUESTNO.47:The Company's response to Production Request No.8 provided
evidence of a resource deficit based on 2021 data and assumptions.Please provide a current
Load &Resource Balance ("L&RB")that reflects known changes from the 2021 L&RB,
including changes in the load forecast and the loss or addition of resources.The updated
response should be in the same spreadsheet format that was provided in response to Production
Request No.8.Please include a narrative explanation of each change that was made in the new
response.
DATED at Boise,Idaho,this day of April 2023.
Michael Duval
Deputy AttorneyGeneral
i:umisc:prodreq/ipce23.1rnms prod req 4
FOURTH PRODUCTION REQUEST
TO IDAHO POWER 4 APRIL 14,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 14th DAY OF APRIL 2023,
SERVED THE FOREGOING FOURTH PRODUCTION REQUESTOF THE
COMMISSION STAFF TO IDAHO POWER COMPANY,IN CASE NO.IPC-E-23-01,
BY E-MAILING A COPY THEREOF,TO THE FOLLOWING:
DONOVAN E WALKER TIMOTHY TATUM
IDAHO POWER COMPANY IDAHO POWER COMPANY
PO BOX 70 PO BOX 70
BOISE ID 83707-0070 BOISE ID 83707-0070
E-MAIL:[e-mail] E-MAIL:[e-mail]
dockets idahopower.com
ERIC L OLSEN LANCE KAUFMAN PhD
ECHO HAWK &OLSEN PLLC 2623 NW BLUEBELL PLACE
PO BOX 6119 CORVALLIS OR 97330
POCATELLO ID 83205 E-MAIL:lance aegisinsight.com
E-MAIL:[e-mail]
PETER J RICHARDSON DR DON READING
RICHARDSON ADAMS PLLC 280 S SILVERWOOD WAY
PO BOX 7218 EAGLE ID 83616
BOISE ID 83702 E-MAIL:[e-mail]
E-MAIL:peter richardsonadams.com
ED JEWELL WIL GEHL
DEPUTY CITY ATTORNEY ENERGY PROGRAM MANAGER
BOISE CITY ATTORNEY'S OFFICE BOISE CITY DEPT OF PUBLIC WORKS
PO BOX 500 PO BOX 500
BOISE ID 83701-0500 BOISE ID 82701-0500
E-MAIL:[e-mail] E-MAIL:[e-mail]
dearlv citvofboise.ore
boisecÏ[e-mail]
MARIE CALLAWAY KELLNER BRAD HEUSINKVELD
ID CONSERVATION LEAGUE ID CONSERVATION LEAGUE
710 N 6TH ST 710 N 6TH ST
BOISE ID 83702 BOISE ID 83702
E-MAIL:mkellner idahoconservation.ore E-MAIL:
bheusinkveld idahoconservation.ore
CERTIFICATE OF SERVICE
JIM SWIER AUSTIN RUESCHHOFF
MICRON TECHNOLOGY INC THORVALD A NELSON
8000 S FEDERAL WAY AUSTIN W JENSEN
BOISE ID 83707 HOLLAND &HART LLP
E-MAIL:[e-mail] 555 17TH ST STE 3200
DENVER CO 80202
E-MAIL:darueschhoffidhollandhart.com
[e-mail]
[e-mail]
aclee hollandhart.com
SECRET Y
CERTIFICATE OF SERVICE