20230629IPC to Staff 15.pdf

DONOVAN WALKER
Lead Counsel
[e-mail]

June 29, 2023

VIA ELECTRONIC FILING

Jan Noriyuki, Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg 8,
Suite 201-A (83714)
PO Box 83720
Boise, Idaho 83720-0074

Re: Case No. IPC-E-23-05
In the Matter of Idaho Power Company’s Application for a Certificate of
Public Convenience and Necessity to Acquire Resources to be Online by
2024 and Approval of a Power Purchase Agreement with Franklin Solar LLC

Dear Ms. Noriyuki:

Attached for electronic filing, please find Idaho Power Company’s Supplemental
Response to the First Production Request of the Commission Staff to Idaho Power
Company in the above matter.

Please feel free to contact me directly with any questions you might have about
this filing.

Very truly yours,

Donovan E. Walker
DEW:sg
Enclosures
RECEIVED
2023 JUNE 29, 2023 4:42PM
IDAHO PUBLIC
UTILITIES COMMISSION

IDAHO POWER COMPANY’S SUPPLEMENTAL RESPONSE TO THE FIRST PRODUCTION REQUEST
OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 1
DONOVAN E. WALKER (ISB No. 5921)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
[e-mail]

Attorney for Idaho Power Company

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF IDAHO POWER
COMPANY’S APPLICATION FOR A
CERTIFICATE OF PUBLIC
CONVENIENCE AND NECESSITY TO
ACQUIRE RESOURCES TO BE ONLINE
BY 2024 AND FOR APPROVAL OF A
POWER PURCHASE AGREEMENT WITH
FRANKLIN SOLAR LLC.
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CASE NO. IPC-E-23-05

IDAHO POWER COMPANY’S
SUPPLEMENTAL RESPONSE
TO THE FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO IDAHO
POWER COMPANY

COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), and in
response to the First Production Request of the Commission Staff (“Commission” or
“Staff”) dated April 4, 2023, herewith supplements the following information:

IDAHO POWER COMPANY’S SUPPLEMENTAL RESPONSE TO THE FIRST PRODUCTION REQUEST
OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 2

REQUEST FOR PRODUCTION NO. 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 following table:
Zero
Carbon
Planning
Case
Carbon
High
Carbon
Low Gas Planning
Case Gas
High
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 following assumptions 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

IDAHO POWER COMPANY’S SUPPLEMENTAL RESPONSE TO THE FIRST PRODUCTION REQUEST
OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 3
impacts of the 2022 IRA;
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).
SUPPLEMENTAL RESPONSE TO REQUEST FOR PRODUCTION NO. 15:
After discussing this request with Idaho Public Utilities Commission
(“Commission”) Staff (“Staff”), and given bandwidth constraints due to overlapping
modeling efforts currently underway for development of the 2023 Integrated Resource
Plan (“IRP”), Idaho Power has completed three of the nine requested runs. These three
runs reflect the following assumptions: 1) Low Carbon, Low Gas; 2) Planning Carbon,
Planning Gas; and 3) High Carbon, High Gas. The carbon and gas forecasts utilized in
these runs reflect the most current assumptions from the development of the 2023 IRP,
though this process is currently underway and not yet final. With regard to the requested
inclusion of the impacts of the Inflation Reduction Act of 2022 (“IRA”) as detailed in
subparts b through f, projects in the long-term capacity expansion (“LTCE”) model already
incorporated expected IRA impacts.
The results of the three runs confirm the 2024 resources presented in this case,

IDAHO POWER COMPANY’S SUPPLEMENTAL RESPONSE TO THE FIRST PRODUCTION REQUEST
OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 4
as the LTCE model selected the same 2024 resources in each of the three modeled
futures. Because the three runs reflect the two “bookends” of the nine requested modeling
futures (i.e. most expensive gas and carbon, least expensive gas and carbon) as well as
the midpoint scenario (planning gas and planning carbon) Idaho Power believes these
three runs sufficiently indicate that the resources presented in this case reflect the least-
cost, least-risk option under a wide range of future assumptions. Consequently, Idaho
Power does not believe the completion of the remaining six scenarios detailed in this
request would yield any different results, as the three runs already completed indicate no
change in the selected resources under futures that stressed carbon and gas
assumptions to a greater extent than what would be modeled in the remaining six
scenarios. However, Idaho Power is able to complete these additional runs at Staff’s
request.
Additionally, at Staff’s request Idaho Power is providing the high-level portfolio
costs generated by each of the three supplemental runs in the table below. It should be
noted, however, that these costs were generated by the LTCE model and do not reflect
the full hourly costing runs that are typically performed when generating resource portfolio
costs for the IRP. It should also be noted that these costs reflect solely the LTCE modeling
results, and therefore exclude transmission costs associated with Boardman-to-
Hemingway and Gateway West. Lastly, because each run reflects a different assumed
future with regard to gas and carbon assumptions, the modeling results are not
comparable with one another because the total costs will be inherently different due to
these differing assumptions.

IDAHO POWER COMPANY’S SUPPLEMENTAL RESPONSE TO THE FIRST PRODUCTION REQUEST
OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 5
Net Present Value Results of LTCE Runs $1,000
Low Gas,
Low Carbon
Planning Gas,
Plannin Carbon
High Gas,
Hi h Carbon
Total Net
Present Value $5,660,228 $7,018,500 $9,217,856

The response to this Request is sponsored by Jared Hansen, Resource Planning
Leader, Idaho Power Company.

IDAHO POWER COMPANY’S SUPPLEMENTAL RESPONSE TO THE FIRST PRODUCTION REQUEST
OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 6
DATED at Boise, Idaho this 29th day of June 2023.

DONOVAN E. WALKER
Attorney for Idaho Power Company

IDAHO POWER COMPANY’S SUPPLEMENTAL RESPONSE TO THE FIRST PRODUCTION REQUEST
OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 7
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the 29th day of June 2023, I served a true and correct
copy of Idaho Power Company’s Supplemental Response to the First Production Request
of the Commission Staff to Idaho Power Company upon the following named parties by
the method indicated below, and addressed to the following:

Commission Staff
Chris Burdin
Deputy Attorney General
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg No. 8
Suite 201-A (83714)
PO Box 83720
Boise, ID 83720-0074

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City of Boise
Darrell Early
Deputy City Attorney
Boise City Attorney’s Office
150 N. Capitol Blvd.
PO Box 500
Boise, ID 83701
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[e-mail]

Wil Gehl
Energy Program Manager
Boise City Dept. of Public Works
150 N. Capitol Blvd.
P.O. Box 500
Boise, Idaho 83701-0500
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Stacy Gust, Regulatory Administrative
Assistant