20230728Staff 135-154 to IPC.pdf

DAYN HARDIE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE,IDAHO 83720-0074
[phone]
IDAHO BAR NO.9917
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 THE APPLICATION )OF IDAHO POWER COMPANY FOR )CASE NO.IPC-E-23-11
AUTHORITY TO INCREASE ITS RATES )AND CHARGES FOR ELECTRIC SERVICE )SIXTH PRODUCTION
IN THE STATE OF IDAHO AND FOR )REQUESTOF THE
ASSOCIATED REGULATORY )COMMISSION STAFF
ACCOUNTING TREATMENT )TO IDAHO POWER COMPANY
Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Dayn Hardie,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 FRIDAY AUGUST 11,2023.1
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 telephonenumber of
Staffis requesting an expedited response.If responding by this date will be problematic,please call Staff's
attorney at [phone].
SIXTH PRODUCTION REQUEST
TO IDAHO POWER l JULY 28,2023
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.135:Page 11 of Jessica Brady's Direct Testimony states the Public
Utility Regulatory Policies Act of 1978 ("PURPA")contracts and power purchase agreements
("PPA")are quantified outside of AURORA,but energy from these contracts is modeled as
must-take in the AURORA simulation.Please explain the following.
a.How the energy from these contracts is modeled as must-take in AURORA;and
b.The difference between PURPA contracts and PPA contracts,and why PPA
contracts should be treated as must-take like PURPA contracts.
REQUESTNO.136:Page 25 of Matt Larkin's Direct Testimony states that "Account
447.050 reflects financial payments made to Idaho Power as compensation for the Company
generating electricityto offset transmission losses to third parties wheeling through Idaho
Power's transmission system...Idaho Power is proposing to include in its base NPSE
determination both the cost of serving third party losses as well as the offsetting revenues
received through Account 447.050.Therefore,Idaho Power added 36 average megawatts
("aMW")to its load forecast utilized for AURORA modeling purposes to account for this load
service requirement,and Ms.Brady determined an offsetting revenue amount to include in
Account 447.050."Please explain the following:
a.How the 36 aMW is determined and provide workpapers with formulas intact;
b.Why the Planning Reserve Margin in the load forecast does not include reserves
addressing transmission losses and why an additional 36 aMW is added;
c.How the AURORA model determines transmission losses;and
d.Whether the 36 aMW corresponds to the amounts of transmission losses
identified in the AURORA dispatch.
REQUESTNO.137:Page 26 of Matt Larkin's Direct Testimony states that "when the
2013 NPSE Update was performed,third party wheeling customers had the option to account for
SIXTH PRODUCTION REQUEST
TO IDAHO POWER 2 JULY 28,2023
wheeling losses in two ways:1)financially-meaning the customer would pay Idaho Power to
generate the additional energy to account for the losses,or 2)physically-meaning the customer
would generate or acquire additional physical energy to account for the losses themselves,
resulting in no additional payment to Idaho Power.However,with the advent of the energy
imbalance market ("EIM"),nearly all wheeling customers now settle their losses financially,
meaning they pay Idaho Power to generate the physical energy to account for wheeling losses
through the Company's system."Please explain the following.
a.Whether the revenues associated with wheeling losses are calculated based on the
assumption that all wheeling customers choose Option 1),not Option 2);
b.Why the advent of EIM resulted in "nearly all wheeling customers now settle
their losses financially";and
c.Please provide and explain the actual rate that a wheeling customer pays the
Company to settle losses financially.
REQUESTNO.138:Order No.32821 directed the Company to include a base level of
third-partytransmission revenues in the next rate case so that deviations from the base level can
be tracked in PCA.Please respond to the following:
a.Please explain whether the Company includes transmission revenues in the NPSE;
b.If yes,please identify where the revenues are recorded;and
c.If not,please explain why the revenues are not included.
REQUESTNO.139:Jessica Brady's workpaper "Brady Workpaper 4 -565,447.050.
xlsx"states a Market Price of $31.27/MWh is "2023 Aurora generated average annual zonal
price,net of wheeling and losses."Please explain the following:
a.What "2023 Aurora generated average annual zonal price,net of wheeling and
losses"means;and
b.Why the Market Price is used to calculate revenues of wheeling losses.
REQUESTNO.140:Page 12 of Jessica Brady's Direct Testimony states that "the
Company uses AURORA to model various water conditions using current loads and current
SIXTH PRODUCTION REQUEST
TO IDAHO POWER 3 JULY 28,2023
resources.At this time,37 water conditions have been evaluatedto develop an average or
normalized NPSE."Please respond to the following:
a.Please confirm that "current loads"means 2023 normalized load;
b.If not,please defme "current loads";
c.Please explain how "current loads"are developed;and
d."Exhibit No.30 -Base NPSE.xlsx"shows 37 water years from 1981 through
2017.Please explain why years after 2017 are not used.
REQUESTNO.141:Page 14 of Jessica Brady's Direct Testimony states that "Idaho
Power updated expected generation from PURPA projects based on current and expected
contracts."Please respond to the following:
a.Please explain what "current"means;
b.Are all "current"PURPA projects approved and operational?;
c.Please explain what "expected"means;
d.Are there any "expected"projects that have been approved?;and
e.If yes,what are their expected online dates?
REQUESTNO.142:Regarding the Jim Bridger Power Plant,Page 27 of Matt Larkin's
Direct Testimony states that "the Company will cease coal-fired operations at units 1 and 2 at
year-end 2023,converting these units to natural gas,with an expected online date of summer
2024."Additionally,Page 15 of Jessica Brady's Direct Testimony states that "I was directed to
model Bridger units 1 and 2 as natural gas units online for the entire 2023 test year in order to
more closely align 2023 Base Level NPSE with the time period in which rates will take effect."
Please respond to the following:
a.Please explain whether the Company will seek Commission approval to convert
Bridger units 1 and 2 to gas units;
b.If so,please explain when the Company plans to seek approval;
c.Please explain how long the conversionprocess of the plant will likelytake;and
d.Please provide evidence (such as documentations includingsigned contracts,
invoices for equipment,etc.)to show Bridger units 1 and 2 will be converted to a
gas plant at year-end 2023.
SIXTH PRODUCTION REQUEST
TO IDAHO POWER 4 JULY 28,2023
REQUESTNO.143:Page 14 of Jessica Brady's Direct Testimony states "the 2023
AURORA model includes the removal of two resources,Boardman Coal and North Valmy Unit
1."Please respond to the following:
a.Has North Valmy Unit 1 retired?
b.If not,why does the Company exclude it in the AURORA model?
c.When is the plant expected to retire?Please provide evidence to support your
answer.
REQUESTNO.144:Page 15 of Jessica Brady's Direct Testimony states that Black
Mesa Solar is scheduled to come online June 2023.Please verify the date that the project came
or will come online.
REQUESTNO.145:Page 16 of Jessica Brady's Direct Testimony states that the Black
Mesa Battery is scheduled to come online September 2023 and the 80 MW Grid Battery is
scheduled to come online June 2023.Please respond to the following:
a.Please verify the date that the 80 MW Grid Battery came or will come online;
b.If there is a delay,please provide reasons;
c.Please verify the date that the Black Mesa Battery came or will come online;and
d.If there is a delay,please provide reasons.
REQUESTNO.146:Please respond the followingregarding Demand Response.
a.Please explain why the dispatched amounts of Demand Response are the same
across all water years;
b.Please explain how the cost of Demand Response ($10,240,003)is determined
and provide workpaper with formula intact;
c.Does the cost correspond to the dispatched amounts listed in Exhibit No.30 -
Base NPSE.xlsx?Please explain;and
d.Please explain why the cost is not determined in the AURORA model.
REQUESTNO.147:Page 17 of Jessica Brady's Direct Testimony states that "the
Company segmented PURPA into three categories,"PURPA Wind","PURPA Solar",and all
SIXTH PRODUCTION REQUEST
TO IDAHO POWER 5 JULY 28,2023
"other PURPA."PURPA Wind was modeled by applying a five-year average (2018 -2022)
hourly actual generation shape to the total nameplate capacity of combined PURPA wind
projects.PURPA Solar was modeled by applying the 2022 actual hourly shape to the total
monthly forecasted generation amounts.All other PURPA resources were modeled on a
monthlybasis..."Please respond to the following:
a.Please provide workpapers to show how PURPA Wind was modeled;
b.Please provide workpapers to show how PURPA Solar was modeled;
c.Please provide workpapers to show how other PURPA resources were modeled;
d.Please explain why PURPA Wind used a five-year average hourly actual
generation shape,while PURPA Solar used a one-year hourly shape;and
e.Please explain why the wind shape is applied to "nameplate",while the solar
shape is applied to "generation amounts".
REQUESTNO.148:Please respond to the followingregarding "Fixed Capacity Charge
Gas Transportation ($x 1000)"in Exhibit No.30 -Base NPSE.xlsx.
a.Please defme "Fixed Capacity Charge -Gas Transportation ($x 1000)";
b.Please explain how this item is determined or calculated;and
c.Please provide workpapers used to calculate "Fixed Capacity Charge -Gas
Transportation ($x 1000)"with formula intact.
REQUESTNO.149:Please respond to the followingregarding "Surplus Sales"in
Exhibit No.30 -Base NPSE.xlsx.
a.The "Surplus Sales"section includes "Revenue ($x 1000)"and "Revenue -No
Wheeling ($x 1000)."Please define them and describe the difference between
the two;
b.Please explain how "Revenue ($x 1000)"and "Revenue-No Wheeling ($x
1000)"are modeled differently in the AURORA model;and
c."Revenue ($x 1000)"is $24,826.5."Revenue -No Wheeling ($x 1000)"is
$19,175.3.Please explain whether the 756,582.5 MWh energy amount
corresponds to the $24,826.5 or $19,175.3 amount.
SIXTH PRODUCTION REQUEST
TO IDAHO POWER 6 JULY 28,2023
REQUESTNO.150:Page 20 of Jessica Brady's Direct Testimony states that natural
gas prices for the 2023 Base Level NPSE are forecasted to be $3.36/MMBtufor HenryHub,
$4.28/MMBtufor natural gas delivered to Bridger,and $4.70/MMBtufor natural gas delivered
to Langley,Bennett Mountain,and Danskin.Please respond to the following:
a.Please explain how $3.36/MMBtu,$4.28/MMBtu,and $4.70/MMBtuare
determined;
b.Please provide workpapers that calculate these numbers with formula intact;and
c.Please provide the 2024 natural gas forwards prices for these items and provide
workpapers that calculate these prices with formula intact.
REQUESTNO.151:Page 22 of Jessica Brady's Direct Testimony states that
transmission losses on market purchases are incorporated into the market price.Please respond
to the followingregarding transmission losses associated with market purchases.
a.Please explain how transmission losses are valued in the AURORA model.
b.Are transmission losses associated with market sales?
c.If so,should market prices be adjusted higher to incorporate transmission losses,
when the Company sells power?
REQUESTNO.152:Please respond to the followingregarding Third-Party
Transmission Expense in the workpaper "Brady Workpaper 4 -565,447.050.xlsx".Are
transmission expenses only incurred for market purchases,but not for market sales?
REQUESTNO.153:Page 24 of Jessica Brady's Direct Testimony states that Demand
Response was forecast for the 2023 test year based on Idaho-jurisdictionforecast costs
associated with projected participation in the three programs.Please respond to the following:
a.Is $10,240,003 an Idaho-jurisdictionforecast?
b.Are all other expenses in Table 5 on Page 24 of Jessica Brady's Direct Testimony
Idaho-jurisdictionexpenses or system-based expenses?
SIXTH PRODUCTION REQUEST
TO IDAHO POWER 7 JULY 28,2023
REQUESTNO.154:Referencing Exhibit No.34 -Development of System Revenue
Requirement 2023 Test Year.xlsx,please define each of the followingand explain how each item
is determined in terms of NPSE.
a."2022 Actual";
b."2022 Actual Adjustments";
c."2022 Base";
d."Forecast Adjustment";
e."2023 Unadjusted Test Year";
f."AnnualizingAdjustment";and
g."2023 Test Year".
DATED at Boise,Idaho,this 7 day of July 2023.
Dayn Hardie
Deputy AttorneyGeneral
i:umise:prodreq/ipce23.1ldhkl prod req 6
SIXTH PRODUCTION REQUEST
TO IDAHO POWER 8 JULY 28,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 28TH DAY OF JULY 2023,SERVED
THE FOREGOING SIXTH PRODUCTION REQUESTOF THE COMMISSION
STAFF TO IDAHO POWER COMPANY,IN CASE NO.IPC-E-23-11,BY E-MAILING
A COPY THEREOF,TO THE FOLLOWING:
LISA D NORDSTROM TIMOTHY TATUM
DONOVAN E WALKER CONNIE ASCHENBRENNER
MEGAN GOICOECHEA ALLEN MATT LARKIN
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] mlarkinÑÐidahopower.com
[e-mail]
[e-mail]
KELSEY JAE MICHAEL HECKLER
LAW FOR CONSCIOUS LEADERSHIP COURTNEY WHITE
920 N CLOVER DR CLEAN ENERGY OPPORTUNITIES
BOISE ID 83703 3778 PLANTATION RIVER DR
E-MAIL:[e-mail] STE 102
BOISE ID 83703
E-MAIL:
[e-mail]
courtney cleanenergyopportunities.com
ERIC L OLSEN LANCE KAUFMAN PhD
ECHO HAWK &OLSEN PLLC 2623 NW BLUEBELL PLACE
PO BOX 6119 CORVALLIS OR 97330
POCATELLO ID 83205 E-MAIL:lance aegisinsight.com
E-MAIL:elo echohawk.com
PETER J RICHARDSON DR DON READING
RICHARDSON ADAMS PLLC 280 SILVERWOOD WAY
515 N 27TH ST EAGLE ID 83616
BOISE ID 83702 E-MAIL:[e-mail]
E-MAIL:peter richardsonadams.com
CERTIFICATE OF SERVICE
JIM SWIER AUSTIN RUESCHHOFF
MICRON TECHNOLOGY INC THORVALD A NELSON
8000 S FEDERAL WAY AUSTIN W JENSEN
BOISE ID 83707 HOLLAND &HART LLP
E-MAIL:[e-mail] 555 17TH ST STE 3200
DENVER CO 80202
E-MAIL:[e-mail]
[e-mail]
[e-mail]
[e-mail]
clmoser hollandhart.com
TOM ARKOOSH
ARKOOSH LAW OFFICES
PO BOX 2900
BOISE ID 83701
[e-mail]
erin.cecil arkoosh.com
ED JEWELL WIL GEHL
DARRELL EARLY ENERGY PROGRAM MANAGER
DEPUTY CITY ATTORNEY BOISE CITY DEPT OF PUBLIC WORKS
BOISE CITY ATTORNEY'S OFFICE PO BOX 500
PO BOX 500 BOISE ID 82701-0500
BOISE ID 83701-0500 E-MAIL:weehl cityofboise.org
E-MAIL:[e-mail]
[e-mail]
[e-mail]
MARIE CALLAWAY KELLNER BRAD HEUSINKVELD
ID CONSERVATION LEAGUE ID CONSERVATION LEAGUE
710 N 6TH ST 710 N 6TH ST
BOISE ID 83702 BOISE ID 83702
E-MAIL:mkellner idahoconservation.org E-MAIL:
bheusinkveld idahoconservation.ore
PETER MEIER DWIGHT ETHERIDGE
US DEPT OF ENERGY EXETER ASSOCIATES
1000 INDEPENDENCE AVE SW 5565 STERRETT PLACE
WASHINGTON DC 20585 STE 310
E-MAIL:[e-mail] COLUMBIA MD 21044
E-MAIL:[e-mail]
CERTIFICATE OF SERVICE
F.DIEGO RIVAS
NW ENERGY COALITION
1101 8TH AVE
HELENA MT 59601
E-MAIL:[e-mail]
SECRETARY
CERTIFICATE OF SERVICE