20230404Staff 1-18 to IPC.pdf

CLAIRE SHARP .U
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION ŸÑ 2:30POBOX83720
BOISE,IDAHO 83720-0074
[phone]
IDAHO BAR NO.8026
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-23-05CERTIFICATEOFPUBLICCONVENIENCE)AND NECESSITY TO ACQUIRE )RESOURCES TO BE ONLINE BY 2024 AND )FIRST PRODUCTIONFORAPPROVALOFAPOWERPURCHASE)REQUESTOF THE
AGREEMENT WITH FRANKLIN SOLAR )COMMISSION STAFFLLC)TO IDAHO POWER COMPANY
Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Claire Sharp,Deputy AttorneyGeneral,requests that Idaho Power Company ("Company"or
"Idaho Power")provide the followingdocuments and information as soon as possible,but no
later than TUESDAY,APRIL 25,2023.
This Production Request is to be considered as continuing,and the Company is requested
to provide,by way of supplementaryresponses,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 telephonenumber of
the person preparing the documents.Please also identify the name,jobtitle,location,and
telephonenumber of the record holder.
FIRST PRODUCTION REQUEST
TO IDAHO POWER l APRIL 4,2023
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.1:Please explain how the Company will serve load if its Application is
denied.
REQUESTNO.2:Please explain how the Company will serve load if the Application
is approved and project implementation is delayed.
REQUESTNO.3:Was the Request For Proposal ("RFP")and bid evaluation process
put out for proposal?If not,why not?If yes,what companies other than Black &Veatch,LLC
were considered and what criteria was used to evaluate these companies and make a final
selection?
REQUESTNO.4:Please describe in detail "the significant third-partytransmission
constraints"Company witness Jared Ellsworth is referring to on page 7 of his direct testimony?
REQUESTNO.5:Please provide supporting worksheets which show costs and
deliverabilityof gas-fired convertible to hydrogen resources described on page 9 of Company
witness Eric Hackett's direct testimony.
REQUESTNO.6:Company witness Eric Hackett states in his direct testimony that the
Company "will own 100 percent of the Green Tags and Environment Attributes associated with
thefacility."Hackett Direct at 28.Please describe the financial benefits the Company expects to
recognize through ownership of these attributes.Please describe the benefits ratepayers will
recognize from the Company's ownership of these attributes.How will the ratepayers receive
the benefits?Please describe if ratepayers will receive benefits through the Company's annual
Power Cost Adjustment ("PCA").
FIRST PRODUCTION REQUEST
TO IDAHO POWER 2 APRIL 4,2023
REQUESTNO.7:In Company witness Eric Hackett's Exhibit No.1,pages 15-16,a
non-refundable Evaluation Fee of $10,000 and a SupplementalFee are described.Please explain
the accounting treatment used for these fees and provide a supporting worksheet that details fees
received to date.
REQUESTNO.8:Please describe the selected physical locations in detail for all solar
and battery components of the project and include detailed maps.
REQUESTNO.9:Please explain how the Company intends to mitigate supply chain
issues,and other common delays,and ensure timely completion of the proposed project,if
approved.
REQUESTNO.10:Company witness Jared Ellsworth direct testimony at 12-13 lists
several new resources includingthe Black Mesa project,the Hemingway project,various battery
storage,and upgrades at the Company's gas peaking plants that are all due to be completed at
different times throughout2023.For each project,please provide the status,estimated in service
date,and if any delays have occurred and the cause of those delays.
REQUESTNO.11:Please respond to the followingregarding other solutions
considered to meet the 2024 capacity needs:
a.Please explain what other solutions were considered to meet the 2024 capacity
needs;
b.Please explain when these solutions were considered;
c.Please explain the extent to which these solutions were explored;
d.Please explain when these solutions were dropped from further consideration;and
e.Please explain why they were not considered least-cost,least-risk solutions.
REQUESTNO.12:Please provide the followingversions of Load and Resource
Balance ("L&R"):
a.The first version of L&R that the Company used to select Project No.7 and the
original design of Project No.8 (100-MW solar and 20-MW storage)in its initial
FIRST PRODUCTION REQUEST
TO IDAHO POWER 3 APRIL 4,2023
Long-Term Capacity Expansion ("LTCE")analysis.Also,please explain when
this version of L&R was created and the amount of the deficit;
b.The second version of L&R that the Company used to conduct the second LTCE
analysis to select the original design of Project No.8 (100-MW solar and 20-MW
storage).Also,please explain when this version of L&R was created and the
amount of the deficit;
c.The third version of L&R that the Company used to increase from the 20-MW
storage to the 60-MW storage in Project No.8.Also,please explain when this
version of L&R was created and the amount of the deficit;
d.The fourth version of L&R that the Company used to add an additional 12-MW
storage besides the modified Project No.8 (100-MW solar and 60-MW storage).
Also,please explain when this version of L&R was created and the amount of the
deficit;
e.Please provide the latest (from the 2023 IRP)L&R the Company has produced
and respond to the followingregarding the latest L&R:
i.Please explain when this version of L&R was created and the amount of the
deficit.
ii.Please explain whether the L&R includes any Special Customers'resources
and loads.
iii.Please explain whether the Company,with the proposed new resources,will
be able to meet the capacity needs of both summer and winter in 2024
identified in this latest L&R and support your explanation with evidence;and
f.Please explain the main drivers that have caused the evolution of these versions of
L&Rs.
REQUESTNO.13:Mr.Hackett's Direct Testimony states "Project Nos.12,13,14,and
15,were not cost-effective options because of the limited capacity benefit of the energy storage
or surplus only availability of the energy storage."Please respond to the following:
a.Please explain how the Company determined these four projects were not cost-
effective options;
b.What does "surplus only availability of the energy storage"mean;and
FIRST PRODUCTION REQUEST
TO IDAHO POWER 4 APRIL 4,2023
c.Please explain why these four projects should be removed due to "the limited
capacity benefit of the energy storage or surplus only availabilityof the energy
storage."
REQUESTNO.14:Please respond to the followingquestions regarding the LTCE
analyses in this case:
a.When the Company performed its initial LTCE analysis in this case,what other
potential resources were considered in the AURORA model,besides the 17
submitted projects?Please provide the input assumptions and the sources for
these other potential resources.Also,please explain whether the pricing of these
other potential resources reflect the impacts of the 2022 Inflation Reduction Act
("2022 IRA");
b.Mr.Hackett's Direct Testimony states AURORA "consistently selected Project
Nos.7 and 8 as the resource additions resulting in a least-cost,least-risk portfolio
for meeting the identified 2024 capacity deficiency."Please explain how a least-
cost,least risk portfolio was determined and provide evidence that shows Project
Nos.7 and 8 were consistently selected;
c.Please confirm that,although Project Nos.2,9,and 10 were not selected in the
least-cost,least risk portfolio from the initial LTCE analysis,these three projects
were added into the second LTCE analysis manually;
d.When the Company performed its second LTCE analysis in this case,what other
potential resources were considered in the AURORA model besides the final
shortlisted projects (Project Nos.2,8,9,and 10)?Please provide the input
assumptions and the sources for these other potential resources.Please explain
whether the pricing of these other potential resources reflected the impacts of the
2022 IRA;
e.Mr.Hackett's Direct Testimony states "[s]imilarto the initial LTCE analysis,
Project No.8 was consistently selected as the most cost-effective resource for
meeting the 2024 capacity deficiency."Please confirm that Project No.8 was
selected in the least-cost,least-risk portfolio.Also,please confirm that the
method for determining the least-cost,least-risk portfolio in the second LTCE
FIRST PRODUCTION REQUEST
TO IDAHO POWER 5 APRIL 4,2023
analysis was the same as in the initial LTCE analysis.If the method was
different,please explain the method used in the second LTCE analysis.Please
provide evidence that shows Project No.8 was consistently selected;and
f.Please confirm that Project Nos.2,9,and 10 were not selected in the least-cost,
least-risk portfolio in the second LTCE analysis.Also,please confirm that even
though the model did not select Project No.10,the Company selected it because it
was the next most economic resource in the final shortlist.
REQUESTNO.15:Please conduct nine new LTCE model runs using the latest 2023
IRP base input assumption while varying carbon and natural gas price forecasts based on the
followingtable:
Zero Planning Case High Low Planning High
Carbon Carbon Carbon Gas Case Gas
Gas
Scenario 1 X X
Scenario 2 X X
Scenario 3 X X
Scenario 4 X X
Scenario 5 X X
Scenario 6 X X
Scenario 7 X X
Scenario 8 X X
Scenario 9 X X
For each model run,please provide the Net Present Value ("NPV")Portfolio Cost Analysis
result and identify whether the proposed resources and/or other bidder projects were selected to
fill the upcoming deficits for each scenario.
Please conduct the analysis using the followingassumptions for all model runs:
a.The Company's latest L&R provided in Request No.1(e);
b.Project No.2 included as a resource available for selection by the LTCE model with
the updated pricing that reflects the impacts of the 2022 IRA;
c.Modified Project No.8 (100-MW Solar +60 MW storage)included as a resource
available for selection by the LTCE model with the updated pricing that reflects the
impacts of the 2022 IRA;
FIRST PRODUCTION REQUEST
TO IDAHO POWER 6 APRIL 4,2023
d.Project No.9 included as a resource available for selection by the LTCE model with
the updated pricing that reflects the impacts of the 2022 IRA;
e.Modified Project No.10 (12-MW storage)included as a resource available for
selection by the LTCE model with the updated pricing that reflects the impacts of the
2022 IRA;and
f.Updated resource pricing for all other resources available for selection by the LTCE
model with updated pricing that reflects the impact of the 2022 IRA,as well as all
bidder projects that were not selected as a result of the initial LTCE analysis but
satisfy all other hard constraints (e.g.transmission availability).
REQUESTNO.16:Please explain why the Company does not seek cost recovery
associated with the 72 MW of energy storage projects but seek cost recovery associated with the
100-MW solar project in this case.
REQUESTNO.17:Please provide the followinginformation regarding the Company's
request for an exemption to the Oregon Public Utilities Commission ("OPUC")Resource
Procurement Rules for this project:
a.Please provide a copy of the exemption request filed with the OPUC;
b.Please provide status of the exemption request and approval by the OPUC;
c.Please provide confirmation that the Company is in compliance with the OPUC
resource acquisition process;
d.If not confirmed,please describe the specific exceptions to the OPUC rules that
apply in this case;and
e.Please provide actions the Company is taking to comply with the OPUC rules to
mitigate the need for exemptions in future proceedings.
REQUESTNO.18:Do the Proposal Prices and the Levelized Cost of Capacity in Table
No.1,No.2,and No.3 in Exhibit 4 include transmission interconnection costs?
FIRST PRODUCTION REQUEST
TO IDAHO POWER 7 APRIL 4,2023
DATED at Boise,Idaho,this day of April 2023.
Claire Sharp,
Deputy AttorneyGeneral
i:umisc:prodreq/ipce23.5csyy prod req l
FIRST PRODUCTION REQUEST
TO IDAHO POWER 8 APRIL 4,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 4th DAY OF APRIL 2023,SERVED
THE FOREGOING FIRST PRODUCTION REQUESTOF THE COMMISSION STAFF
TO IDAHO POWER COMPANY,IN CASE NO.IPC-E-23-05,BY E-MAILING A
COPY THEREOF,TO THE FOLLOWING:
DONOVAN E WALKER TIM 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:ttatum idahopower.com
[e-mail]
SECRETÀkY
CERTIFICATE OF SERVICE