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HomeMy WebLinkAbout20230420Staff 1-20 to IPC.pdfMICHAEL DUVAL DEPUTY ATTORNEYS GENERAL IDAHO PUBLIC UTILITIES COMMISSION -a ŸÑ PO BOX 83720 BOISE,IDAHO 83720-0074 (208)334-0320 IDAHO BAR NOS.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 )CASE NO.IPC-E-23-08 PARTICIPATION IN THE WESTERN )RESOURCE ADEQUACYPROGRAM )FIRST PRODUCTION )REQUESTOF THE )COMMISSION STAFF )TO IDAHO POWER COMPANY Staff of the Idaho Public Utilities Commission,by and throughits attorney of record, Michael Duval,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,MAY 11,2023. 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,job title,location,and telephonenumber of the record holder. FIRST PRODUCTION REQUEST TO IDAHO POWER l APRIL 20,2023 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 provide an Excel spreadsheet,with all formulas intact, showing itemized costs and benefits of the Company participating in the Western Resource Adequacy Program ("WRAP"),by calendar year through2030.Please include cost/benefit analyses from the Company (Utility Cost Test)and ratepayer's perspectives (Ratepayer Impact Analysis). REQUESTNO.2:Please provide worksheets that show the Company's assumptions and calculations of the WRAP Administration Charges. REQUESTNO.3:Company witness Williams states:"WRAP participants must pay non-compliance charges if they fail to meet the requirements of the forward-showing and operations programs.These non-compliance charges include Deficiency Charges and Delivery Failure Charges,and they are designed to result in compliance from all participants."Williams Direct at 22.Please explain the likely magnitude of the charges and the factors that would determine the magnitude of each type of charge.Please explain whether the Company will seek recovery for these charges and the conditions when they would or would not seek recovery. REQUESTNO.4:If the Company opts for fully binding WRAP participation,and subsequently changes its mind,please explain the requirements for the Company to exit WRAP, the likelytimeline,and the likely costs. REQUESTNO.5:Please provide workpapers detailing analysis and assumptions for any other costs associated with participation in the WRAP (i.e.,operations costs,incremental resource or transmission costs,penalties,exit costs,etc.).Please specify if costs are specific to the binding period. FIRST PRODUCTION REQUEST TO IDAHO POWER 2 APRIL 20,2023 REQUESTNO.6:Company witness Williams states:"The Reliability and Capacity Assessment Tool analysis found that WRAP,by providing capacity resources to the Company on that single worst day,resulted in the Company needing 14 megawatts ('MW')less of perfect generationto meet an annual Loss of Load Expectation ('LOLE')of 0.1 event-days per year." Williams Direct at 15.Please provide the data and worksheets showing this determination. REQUESTNO.7:Company witness Williams states:"The cost savings presented above assumes the Company will rely on the WRAP operations program's resource sharing only once per year...Leveraging the program more frequentlywould potentiallyresult in additional avoided cost savings."Williams Direct at 17.Please answer the followingquestions: a.Please explain how leveraging the program more frequentlymight result in additional avoided cost savings; b.Please explain and quantifyany penalties or consequences wheneverthe Company uses the WRAP resource sharing,whether once a year,or more frequently; c.Please explain if there are limits on how frequentlythe Company can use the WRAP resource sharing each year;and d.Please explain if any expenses would be reduced if the Company does not use the WRAP resource sharing. REQUESTNO.8:Please explain the benefits the Company expects by committing to an earlier binding date. a.Please include a current list of other utilities and their binding/non-binding status; and b.Please describe metrics and considerations the Company will use to evaluate the feasibility of committing to an earlier binding date. REQUESTNO.9:Please provide a text-searchable version of Exhibit No.1. FIRST PRODUCTION REQUEST TO IDAHO POWER 3 APRIL 20,2023 REQUESTNO.10:The success of WRAP rests on the likelihood that some participants will have surplus capacity when other participants have need.Please provide any information the Company used to assess the likelihood of resources being available during the Company's critical capacity hours.Please provide the peak season (winteror summer)for all other utilities participating in the WRAP. REQUESTNO.11:Some WRAP participants are subject to clean energy mandates. Please answer the following: a.Please explain how WRAP will incorporate those mandates into its forward showing and operations programs;and b.Please explain if the Company will be either indirectly or directly required to provide clean power into the WRAP programs. REQUESTNO.12:Please explain how the Company's differing calculation for Planning Reserve Margin ("PRM")may impact the resource and transmission capacity requirements determined by the WRAP. REQUESTNO.13:Please describe how the reduction in planning reserve margin PRM expected from participating in the WRAP will affect the Company's capacity deficiency dates. REQUESTNO.14:Please clarify how the forward showing program will set prices and engage members to reserve generationcapacity and transmission capacity. REQUESTNO.15:Please provide the settlement quantities and prices calculated by Western Power Pool ("WPP")for the Summer 2023 season holdback requirements and energy deployments described in Blackwell Direct at 16. REQUESTNO.16:For resources to be used for the WRAP Summer 2023 season, please provide the expected WRAP Tariff holdback compensation that is described in Blackwell Direct at 19. FIRST PRODUCTION REQUEST TO IDAHO POWER 4 APRIL 20,2023 REQUESTNO.17:Please describe how often the Company expects to hold back or deploy resources into the WRAP. REQUESTNO.18:Please explain if the Company plans to file any notices or cases with the IPUC prior to committing to a binding period with the WRAP. REQUESTNO.19:Please explain if the Company expects to use its demand response programs as a resource available for use in the WRAP forward showing program. a.If yes,please provide workpapers detailing the cost-effectiveness analysis of the Company's demand response programs using the avoided resource investment benefit of participating in the WRAP. b.If not,please explain why not. REQUESTNO.20:Company witness Blackwell notes that WRAP methods for assessing resource adequacy are significantlydifferent than the Company's methods.Blackwell Direct at 5.This will create a new layer of planning factors that the Company might consider. For example,each resource will have a different capacity contribution for WRAP in the summer, for WRAP in the winter,and for the Company's internal Load and Resource Balance.Please describe how the Company plans to manage this additional complexity.Please explain how the Company will prioritize between those differences when making planning resource decisions. DATED at Boise,Idaho,this day of April 2023. Michael Duval Deputy AttorneyGeneral i:umisc:prodreq/ipce23.8mdms prod req l FIRST PRODUCTION REQUEST TO IDAHO POWER 5 APRIL 20,2023 CERTIFICATE OF SERVICE I HEREBY CERTIFY THAT I HAVE THIS 20th DAY OF APRIL 2023,SERVED THE FOREGOING FIRST PRODUCTION REQUESTOF THE COMMISSION STAFF TO IDAHO POWER COMPANY,IN CASE NO.IPC-E-23-08,BY E-MAILING A COPY THEREOF,TO THE FOLLOWING: LISA D NORDSTROM ALISON WILLIAMS MEGAN GOICOECHEA ALLEN IDAHO POWER COMPANY IDAHO POWER COMPANY PO BOX 70 PO BOX 70 BOISE ID 83707-0070 BOISE ID 83707-0070 E-MAIL:awilliams@idahopower.com E-MAIL:lnordstrom@idahopower.com muoicoecheaallen@idahopower.com dockets@idahopower.com SECRET RY CERTIFICATE OF SERVICE