20230614Staff 21-24 to IPC.pdf

MICHAEL DUVAL
DEPUTY ATTORNEYS GENERAL i 4 PM 4:4 5IDAHOPUBLICUTILITIESCOMMISSION
PO BOX 83720
BOISE,IDAHO 83720-0074
[phone]
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 )SECOND PRODUCTION
)REQUESTOF THE
)COMMISSION STAFF
)TO IDAHO POWER COMPANY
Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Michael Duval,Deputy Attorney General,requests that Idaho Power Company ("Company"or
"Idaho Power")provide the followingdocuments and information as soon as possible,but no
later than WEDNESDAY,JULY 5,2023.
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
telephone number of the record holder.
SECOND PRODUCTION REQUEST
TO IDAHO POWER 1 JUNE 13,2023
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.21:Please describe the accounting treatment that the Company will
apply to the followingWestern Resource Adequacy Program ("WRAP")revenue and expenses.
a.Administrative charges (fixed and variable);
b.Energy Deployment revenue or expenses;
c.Holdback Requirement revenue or expenses;
d.Deficiency Charge;and
e.DeliveryFailure Charge.
REQUESTNO.22:The Company's responses to Production Requests Nos.6 and 7
indicate that using the WRAP once per year would avoid 14 Megawatts ("MW")of perfect
generation and using the WRAP twice per year would avoid 24 MW of perfect generation.The
first use is modeled to occur at the highest loss of load probability ("LOLP")hour in the year.
The second use is modeled to occur at the second highest LOLP hour.Please explain why the
avoided capacity appears to be additive (14MW +10MW),instead of fixed at 14 MW by the
highest LOLP hour.Please clarify if the Company thinks the avoided capacity benefit would
continue to increase for each additional 'use'of the WRAP,and if so,why it expects that to be
so.
REQUESTNO.23:Please explain how the Company would translate the WRAP's
theoretical avoided capacity benefit into actual avoided capacity benefit.Would the Company
reduce its Planning Reserve Margin ("PRM")in future Integrated Resource Plans ("IRPs")?If
so,please quantifythe anticipated reduction.If by some other method,please explain it.
REQUESTNO.24:Please explain what demand response data the Company will
provide to the forward showing program forward showing program 50th percentile ("P50")peak
load forecast (i.e.,name plate capacity,historical demand reduction,etc.).If applicable,please
explain how the provided data is different for the historic period and forecasted adjustments.
SECOND PRODUCTION REQUEST
TO IDAHO POWER 2 JUNE 13,2023
DATED at Boise,Idaho,this day of June 2023.
Michael Duval
Deputy AttorneyGeneral
i:umisc:prodreq/ipce23.8mdms prod req 2
SECOND PRODUCTION REQUEST
TO IDAHO POWER 3 JUNE 13,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 14th DAY OF JUNE 2023,
SERVED THE FOREGOING SECOND 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:[e-mail]
E-MAIL:[e-mail]
[e-mail]
[e-mail]
SECRETARY
CERTIFICATE OF SERVICE