20230615Staff 19-43 to IPC.pdf

CHRIS BURDIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE,IDAHO 83720-0074
[phone]
IDAHO BAR NO.9810
Street Address for Express Mail:
11331 W CHINDEN BLVD,BLDG 8,SUITE 201-A
BOISE,ID 83714
Attorneyfor the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER )
COMPANY'S APPLICATION FOR A )CASE NO.IPC-E-23-05
CERTIFICATE OF PUBLIC CONVENIENCE )
AND NECESSITY TO ACQUIRERESOURCES )TO BE ONLINE BY 2024 AND FOR )REDACTED SECOND
APPROVAL OF A POWER PURCHASE )PRODUCTION REQUESTOF
AGREEMENT WITH FRANKLIN SOLAR LLC )THE COMMISSION STAFF
)TO IDAHO POWER COMPANY
Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Chris Burdin,Deputy AttorneyGeneral,requests that Idaho Power Company ("Company"or
"Idaho Power")provide the followingdocuments and information as soon as possible,but no
later than THURSDAY,JUNE 29,2023.1
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 telephone number of
i Staff is requesting an expedited response.If responding by this date will be problematic,please call Staff s
attorney at [phone].
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REQUEST TO IDAHO POWER 1 JUNE 15,2023
the person preparing the documents.Please also identify the name,job title,location,and
telephonenumber 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.19:Table 3 of the 2022 All Source Request for Proposals ("RFP")
shows that power purchase agreements ("PPAs")were not allowed for the storage components of
the products "Battery Energy Storage (BESS)","Solar +BESS",and "Wind +BESS";only asset
purchases are allowed for the storage components.Please respond to the following:
a.Please explain why PPAs are not allowed for the storage components and provide
evidence to support your answer.
b.Please reconcile the statement made in Hackett,DI,page 34 that "[t]he RFP did
not restrict ownership structure or resources,"with the fact that PPA-based
storage projects were not allowed for submission in the RFP.
REQUESTNO.20:Page 21 of Mr.Hackett's Testimony states that the Inflation
Reduction Act of 2022 ("2022 IRA")provides for extension of the current investment tax credits
("ITC")and production tax credits ("PTC")and a new ITC for standalone energy storage.Please
respond to the following:
a.Please confirm that the 100 MW solar project paired with the 60 MW BESS is
eligible for the current,extended ITC,while the 12 MW standalone BESS is
eligible for the new ITC provided in the 2022 IRA.
REQUESTNO.21:Please confirm that for "gas-fired convertible to hydrogen"
products,the gas-fired plant component can be a reciprocating gas engine,a combined cycle
combustion turbine,a simple cycle combustion turbine,or an aeroderivative listed on Exhibit N
of the 2022 RFP.Also,please explain why gas-fired plants not_convertibleto hydrogen are not
considered in the 2022 RFP.
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REQUEST TO IDAHO POWER 2 JUNE 15,2023
REQUESTNO.22:Please explain why liquidated damages due to Output Shortfall
(Section 7.12.2.3 of PPA)does not consider transmission costs (see detailed discussions in
Staff's comments and Idaho Power's reply comments in Case No.IPC-E-22-29).
REQUESTNO.23:Please respond to the followingregarding Seller's Cost to Cover
(Section 1.147 of PPA):
a.Please confirm that Seller's Cost to Cover is intended to compensate the Seller in
case Idaho Power does not accept the Seller's energy and the Seller has to sell the
energy somewhere else at a lower price.
b.If confirmed,please explain whether the Seller can sell both energy and Green
Tags.
c.If the Seller can sell both energy and Green Tags,please explain why Seller's
Cost to Cover does not consider the values of Green Tags.
REQUESTNO.24:Section 4.1 of PPA states the contract term is years.Please
provide the life expectancy of the 100 MW solar panels.Also,please explain whether the
Company or the Seller plans to maintain performance and capacity over the contract term and/or
extend the life expectancy of the solar panels,if the life expectancy is shorter than the contract
term?
REQUESTNO.25:Please answer the followingregarding the 60 MW BESS and the
12 MW BESS:
a.Please provide the life expectancy of the two BESS systems.
b.Please explain whether the Company plans to maintain performance and capacity
of the BESS projects over the expected life of the battery and/or contract term of
the solar PPA.
REQUESTNO.26:Page 30 of Mr.Hackett's Testimony states that besides the Build
Transfer Agreement,Idaho Power will enter into a Shared Facilities Agreement and a Long-
Term Services Agreement for O&M Services performed by the energy storage project following
commercial operation of the project.Please respond to the following:
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REQUEST TO IDAHO POWER 3 JUNE 15,2023
a.Please explain the purpose of the Shared Facilities Agreement and list all the
parties committing to the agreement.
b.Please explain the purpose of the Long-Term Services Agreement for O&M
Services and list all the parties committed to the agreement.
c.Will the Long-Term Services Agreement for O&M Services ensure that the
performance capabilities and capacities of the project will be maintained over
their useful life?
d.Will there be a separate Long-Term Services Agreement for O&M Services for
the 12 MW BESS?Please explain.
e.Does the Company plan to seek Commission approvals of the Shared Facilities
Agreement and the Long-Term Services Agreement for O&M Services after they
are signed?
f.Does the Shared Facilities Agreement involve any extra costs?If so,please
provide the workpaper that lists each cost and explain whether each cost is
included in the bidding price.
g.Does the Long-Term Services Agreement for O&M Services involve any extra
costs?If so,please provide the workpaper that lists each cost and explain whether
each cost is included in the bidding price.
REQUESTNO.27:Page 33 of Mr.Hackett's Testimony states that the Company
estimates the 12 MW storage project is ©and the 72 MW storage is .
Please respond to the following:
a.Are the two costs all-in costs?What services and products do these costs include?
b.How are the amounts determined?Please provide a cost breakdown.
c.In the second LTCE analysis,the 60 MW BESS was originally 20 MW with a
cost of M (equal to ).However,in the Build
Transfer Agreement,the 60 MW BESS costs (equal to
M).Please explain the factors contributingto the price reduction.
d.In the second LTCE analysis,the 12 MW BESS was originally 46 MW with a
cost of M (equal to B).However,the Company
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REQUEST TO IDAHO POWER 4 JUNE 15,2023
estimates the cost associated with the 12 MW BESS is (equal to
).Please explain the factors contributingto the price increase.
REQUESTNO.28:Section 9.2.2.of PPA states the Default Security is per kW of
Nameplate Capacity Rating for the first ten years and per kW of Nameplate Capacity Rating
for the remainder term.Please explain why the per kW used in the Pleasant Valley Solar
contract in Case No.IPC-E-22-29 is not used.
REQUESTNO.29:Section 12.2.2 Remedy for Idaho Power's Failure to Purchase
states "...less amounts received by Seller pursuant to Section 12.7."Please confirm that Section
12.7 should have been Section 12.6.
REQUESTNO.30:Section 2.5 of Build Transfer Agreement lists a Base Purchase
Price of .Please describe the specific products and services included in the Base
Purchase Price.
REQUESTNO.31:Page 31 of Build Transfer Agreement states that Jackpot-Franklin
Shared Facilities Agreement shall have been amended and restated.Please explain in detail why
the agreement needs to be amended.
REQUESTNO.32:Response No.11 in Case No.IPC-E-22-13 states that the
installation of a battery storage system at a distribution substation this year will provide the
Company first-hand experience with operation and maintenance of a smaller-scale system.
Please respond to the following:
a.Has the battery storage system been installed?
b.Has the Company gained any first-hand experience from the smaller-scale
system?If so,what has been learned?
c.Has the Company gained any first-hand experience from the 40 MW and the 80
MW projects with Powin?If so,what has been learned?
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REQUEST TO IDAHO POWER 5 JUNE 15,2023
d.Based on what has been learned,did the Company consider performing the O&M
in-house rather than through a 3rd party?Please provide the cost/benefit analysis
for the two alternatives.
REQUESTNO.33:Page 10 of the Application states the Company intends on adding
the 12 MW storage to the contract executed with Powin on February 28,2022 through a change
order.Or,in the alternative,use a different supplier the Company has available.Please answer
the following:
a.Has the Company made a decision on which option to choose?
b.If so,has the Company signed a contract for the 12 MW BESS?
c.If a contract has been signed,did the parties agree to the price submitted in the
RFP?
d.Does the Company plan to submit the contract for approval?
REQUESTNO.34:Page 22 of Mr.Ellsworth's Testimony states that the Company
conducted a competitive solicitation throughan RFP to help meet Idaho Power's previously
identified capacity needs of 85 MW in 2024 and 115 MW in 2025.Please respond to the
following:
a.When were the capacity needs of 85 MW in 2024 and 115 MW in 2025
identified?
b.Was the 100 MW solar and 20 MW BESS selected to meet this original 85 MW
deficit?
c.Please provide evidence of the capacity needs of 85 MW in 2024 and 115 MW in
2025 in the form of Load and Resource Balance ("L&R").
REQUESTNO.35:Page 24 of Mr.Hackett's Testimony states that between the time
when the refreshed Long-Term Capacity Expansion ("LTCE")analysis was performed and when
contract negotiations were to begin,the 2024 capacity need had increased,so the 20 MW BESS
became a 60 MW BESS.Please respond to the following:
a.Please confirm that the capacity need in 2024 before the increase was 85 MW.If
not,how much capacity was needed before the increase?
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REQUEST TO IDAHO POWER 6 JUNE 15,2023
b.What was the new capacity need after the increase?What factors drove the
increase?
c.When was this increased capacity need identified?
d.Please provide evidence of the new capacity need after the increase in the form of
L&R.
REQUESTNO.36:Page 24 of Mr.Ellsworth's Testimony states that Idaho Power's
most recently updated L&R has identified a 2024 capacity need of 103 MW.Please respond to
the following:
a.What factors drove the increase of capacity needs to 103 MW from the previous
deficit?
b.When was the capacity need of 103 MW in 2024 identified?
c.Please provide evidence of the 103 MW capacity need in the form of L&R.
REQUESTNO.37:Please provide the Company's latest L&R that is used in the
AURORA model run in Response to Staff Production Request No.15.Also,please respond to
the following:
a.What was the capacity position identified in this L&R?
b.What factors drove the change of capacity needs from 103 MW to this capacity
position?
c.When was this capacity position identified?
REQUESTNO.38:Response No.14 (b)states that the indicative AURORA modeling
scenarios consistently selected Project Nos.7 and 8 in the first LTCE analysis.Please answer
the following:
a.Please describe each scenario and explain why each scenario is used and how it
determines the selected resources are least-risk resources.
b.Please indicate whether these scenarios are used in the second LTCE analysis.
c.If not,please describe the scenarios used in the second LTCE analysis and explain
the reason for the change.
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REQUEST TO IDAHO POWER 7 JUNE 15,2023
d.Please provide all the workpapers of the results under each scenario,showing that
the selected resources are least-cost and least-risk,compared to other resources.
REQUESTNO.39:Please explain why the Company did not open the requirements for
additional 40 MW and 12 MW of storage to RFP bidders.
REQUESTNO.40:Please describe any weighting factors the Company used in both
qualitative and quantitative bid analysis and explain if these factors were included in bid
solicitation materials.
REQUESTNO.41:Response to Staff Production Request No.3 in Case No.IPC-E-22-
13 states that Idaho Power believes the December 2021 RFP (the 2022 RFP)allows for slightly
more time to determine whether the operational needs can be met through a third-partyowned
battery storage agreement.Please provide all additional information the Company has learned
includingthe pros and cons of 3rd PRTty OWHOTShip since submitting this response.
REQUESTNO.42:Please respond to the followingregarding charging prices:
a.The RFP requires that,for proposals of solar paired with storage or wind paired
with storage where the Company owns the storage component,Respondent must
provide the price of charging the energy storage from the solar or wind resources.
What is the price of charging the 60 MW BESS in this case?Where is the price
listed in the PPA or Build Transfer Agreement?
b.Please explain how the price is modeled in AURORA.
REQUESTNO.43:Please respond to the followingregarding all-in costs:
a.Please provide the workpaper that shows the all-in cost of the 60 MW BESS and a
breakdown of the all-in cost,and explain what cost items are considered in the bid
price.
b.Please provide the workpaper that shows the all-in cost of the 12 MW BESS and a
breakdown of the all-in cost,and explain what cost items are considered in the bid
price.
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REQUEST TO IDAHO POWER 8 JUNE 15,2023
c.Please explain whether the 100 MW solar paired with the 60 MW BESS and the
12 MW standalone BESS are still the least-cost projects among all projects on the
final short list,when all the additional costs (e.g.O&M costs)outside the bid
prices are considered.Please provide evidence to support your answer.
d.Please provide the workpaper that shows the all-in costs and a cost breakdown of
the all-in cost for the storage projects proposed in Case No.IPC-E-22-13,and
compare each cost category to the same cost categories for the 60 MW BESS and
the 12 MW BESS projects in this case.
DATED at Boise,Idaho,this /day of June 2023.
Chris Burdin,
Deputy AttorneyGeneral
i:umise:prodreq/ipce23.5cbyy prod req 2 redacted
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REQUEST TO IDAHO POWER 9 JUNE 15,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 15th DAY OF JUNE 2023,SERVED
THE FOREGOING REDACTED SECOND 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:dwalker idahopower.com E-MAIL:[e-mail]
dockets idahopower.com
SECRETARY
CERTIFICATE OF SERVICE