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