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Home My WebLink About20230504IPC to Staff 1-11.pdf MEGAN GOICOECHEA ALLEN Corporate Counsel mgoicoecheaallen@idahopower.com May 4, 2023 Jan Noriyuki, Secretary Idaho Public Utilities Commission 11331 W. Chinden Boulevard Building 8, Suite 201-A Boise, Idaho 83714 Re: Case No. IPC-E-23-12 Application of Idaho Power Company for Authority to Implement Power Cost Adjustment (“PCA”) Rates for Electric Service from June 1, 2023, through May 31, 2024 Dear Ms. Noriyuki: Attached for electronic filing is Idaho Power Company’s Response to the First Production Request of the Commission Staff to Idaho Power Company in the above- entitled matter. The confidential attachments will be sent in a separate email to the parties who sign the Protective Agreement. If you have any questions about the attached documents, please do not hesitate to contact me. Sincerely, Megan Goicoechea Allen MGA:sg Enclosures RECEIVED 2023 May 4, 4:52PM IDAHO PUBLIC UTILITIES COMMISSION CERTIFICATE OF ATTORNEY ASSERTION THAT INFORMATION CONTAINED IN AN IDAHO PUBLIC UTILITIES COMMISSION FILING IS PROTECTED FROM PUBLIC INSPECTION Idaho Power Company’s Application for Authority to Implement Power Cost Adjustment (“PCA”) Rates for Electric Service from June 1, 2023 through May 31, 2024 Case No. IPC-E-23-12 The undersigned attorney, in accordance with Commission Rules of Procedure 67, believes that the attachments in Idaho Power Company’s Response to the First Production Request of the Commission Staff Nos. 1 and 8, dated May 4, 2023, may contain information that Idaho Power Company or a third party claims is confidential as described in Idaho Code § 74-101, et seq., and § 48-801, et seq., or is otherwise protected from public disclosure and as such is exempt from public inspection, examination, or copying. DATED this 4th day of May 2023. Megan Goicoechea Allen Counsel for Idaho Power Company IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 1 MEGAN GOICOECHEA ALLEN (ISB No. 7623) LISA D. NORDSTROM (ISB No. 5733) Idaho Power Company 1221 West Idaho Street (83702) P.O. Box 70 Boise, Idaho 83707 Telephone: (208) 388-2664 Facsimile: (208) 388-6935 mgoicoecheaallen@idahopower.com lnordstrom@idahopower.com Attorneys for Idaho Power Company BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION OF IDAHO POWER COMPANY FOR AUTHORITY TO IMPLEMENT POWER COST ADJUSTMENT (“PCA”) RATES FOR ELECTRIC SERVICE FROM JUNE 1, 2023, THROUGH MAY 31, 2024. ) ) ) ) ) ) ) ) CASE NO. IPC-E-23-12 IDAHO POWER COMPANY’S 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 20, 2023, herewith submits the following information: REQUEST FOR PRODUCTION NO. 1: Please provide the monthly number of megawatt-hours ("MWh") associated with the system base and with the actual net power costs, for all Net Power Supply Expense ("NPSE") Accounts including Federal Energy Regulatory Commission ("FERC") accounts 501 (Coal), account 536 (Water for power), account 547 (Gas), account 555 (Non-PURPA), account 565 (3rd party transmission), account 447 (Surplus Sales), account 555, (PURPA), and account 555 (Demand Response Incentives). RESPONSE TO REQUEST FOR PRODUCTION NO. 1: Please see Confidential Attachment 1 for monthly PURPA generation in megawatt-hours (“MWh”) associated with the system base net power costs. Please see Attachment 2 for monthly generation associated with system base net power costs for all non-PURPA Federal Energy Regulatory Commission (“FERC”) accounts. Docket No. IPC-E-13-20 contains additional detail regarding the Company’s base net power supply costs. Please see Attachment 3 for monthly generation associated with actual net power supply costs for April 2022 – March 2023. There are no MWhs associated with FERC accounts 536 (Water for Power), 565 (3rd Party Transmission) and 555 (Demand Response Incentives). The response to this Request is sponsored by Jessi Brady, Regulatory Analyst, Idaho Power Company. IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 2 IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 3 REQUEST FOR PRODUCTION NO. 2: In a manipulatable spreadsheet, please provide the daily totals for November, December, and January of the deferral period for the following items: a. MWh and run hours for each natural gas plant; b. MWh and run hours for each coal plant; c. MWh and run hours for each major hydro plant; d. MWh and price for non-firm power purchases; and e. MWh of total native load. RESPONSE TO REQUEST FOR PRODUCTION NO. 2: Please see Attachments 1-3 for the data requested above. Please note that non-firm power purchases, as requested in Part d, contain many purchased power components, which are summarized in Attachment 1. Details associated with bi-lateral transactions and energy imbalance market (“EIM”) transactions are included separately in Attachments 2 and 3, respectively. Not all of these components have MWh’s and/or daily prices associated with them. In addition, the MWh’s related to the EIM purchases are representative of the net activity that occurred each day, but the dollars are settled on a weekly basis and include adjustments outside of the period associated with the corresponding MWh’s and should not be viewed as dollars associated with the MWh’s reported during this same time period. The response to this Request is sponsored by Aubrae Sloan, Accounting Manager, and Camille Christen, Resource Acquisition, Planning, and Coordination Manager, Idaho Power Company. IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 4 REQUEST FOR PRODUCTION NO. 3: Please confirm if the Company redistributed or smoothed base NPSE in Exhibit No. 2 from the Aurora-generated NPSE that was last authorized by the Commission. If so, please provide workpapers that reflect the calculations/method used to derive the redistributed base. Please include all workpapers in electronic format with calculations intact. RESPONSE TO REQUEST FOR PRODUCTION NO. 3: Base NPSE in this filing are shaped according to base rate revenues from the Company’s last general rate case, in accordance with Commission Order No. 33307 issued in Case No. IPC-E-15-15. The shaping of base NPSE has remained consistent with each PCA filed since the conclusion of that case. Please see Attachment 1, which details the shaping of base NPSE by retail revenues. The response to this Request is sponsored by Jessi Brady, Regulatory Analyst, Idaho Power Company. IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 5 REQUEST FOR PRODUCTION NO. 4: Please provide an electronically sortable list of forced downtime (unscheduled) events that Company-owned generation facilities/units experienced each month during the deferral period. For each forced downtime event, please include the facility/unit name, the facility/unit nameplate capacity, the type of generation, the length of downtime, the amount of lost production in MWhs, and the cause and resolution of the event. RESPONSE TO REQUEST FOR PRODUCTION NO. 4: Please see Attachment 1. The response to this Request is sponsored by Jessi Brady, Regulatory Analyst, Idaho Power Company. IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 6 REQUEST FOR PRODUCTION NO. 5: Please provide an electronically sortable list of all Company-owned facility/unit unforced downtime (scheduled) events during the deferral period. For each event, include the facility/unit name, the facility/unit nameplate capacity, the type of generation, the date range, length of time, and purpose. RESPONSE TO REQUEST FOR PRODUCTION NO. 5: Please see Attachment 1. The response to this Request is sponsored by Jessi Brady, Regulatory Analyst, Idaho Power Company. IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 7 REQUEST FOR PRODUCTION NO. 6: Please describe when the Company knew that shortages of coal were going to occur for the Bridger Coal Plant. Please provide all coal delivery schedules that were developed for the Bridger Coal Plant starting January 1, 2022, through March 31, 2023. For each schedule, please provide the following information: a. Scheduled deliveries for at least each month across the delivery schedule time horizon including both available-to-promise (committed) and forecasted amounts. b. For each month, please provide the amount of coal in tons and the approximate amount of MWh the amount should produce; and c. For each schedule, please provide the reason, with documentation, for any changes in the monthly amounts from the previous month’s schedule. RESPONSE TO REQUEST FOR PRODUCTION NO. 6: Idaho Power first became aware of the potential for shortages of available coal supply for the Bridger Coal Plant in April 2022. Price escalation and volatility in the gas and power markets drove generation at Bridger higher while at the same time coal supplies were becoming more constrained. The decision was made in April to nominate additional delivery of stockpiled coal at Bridger Coal Company to the plant for the balance of 2022. a-c.) Coal delivery plans for the Jim Bridger plant prepared during the January 2022 through March 2023 period are provided in Attachment 1. Significant changes in the plans are described in the workbook. The response to this Request is sponsored by Randy Henderson, Principal Joint Projects Coordinator, Idaho Power Company. IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 8 REQUEST FOR PRODUCTION NO. 7: Please provide the actual amount of coal delivered, the amount of coal consumed and the ending inventory in tons for each month from January 1, 2022, through March 31, 2023, for the Bridger Coal Plant. RESPONSE TO REQUEST FOR PRODUCTION NO. 7: Coal delivered and consumed by month for January 2022 through March 2023, as well as monthly ending inventory balances for the Bridger Plant are provided in Attachment 1. The response to this Request is sponsored by Randy Henderson, Principal Joint Projects Coordinator, Idaho Power Company. IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 9 REQUEST FOR PRODUCTION NO. 8: For the alternative source of coal from Powder River Basin for the Bridger plant, when did the Company begin considering it and actively establishing it? Please provide evidence. RESPONSE TO REQUEST FOR PRODUCTION NO. 8: Idaho Power and PacifiCorp began taking steps to secure coal supply from Powder River Basin (“PRB”) in early September 2022. The partners issued a joint request for proposal (“RFP”) in late September seeking coal to be delivered to the plant as soon as November 2022. Due to the challenges securing leased coal rail cars and finalizing firm rail transportation service with Union Pacific, coal deliveries from the PRB did not commence until April 2023. Idaho Power and PacifiCorp executed a contract with a PRB supplier in April securing up to 600K tons (200K tons Idaho share) for delivery for the remainder of 2023. The confidential RFP packet (Confidential Attachment 1) that went to suppliers in September 2022 is provided with this response as evidence of Idaho Power’s efforts to acquire PRB coal. The response to this Request is sponsored by Randy Henderson, Principal Joint Projects Coordinator, Idaho Power Company. IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 10 REQUEST FOR PRODUCTION NO. 9: When did the Company know that shortages of coal were going to occur for the Valmy Coal Plant? Please provide all coal delivery schedules that were developed for the Valmy Coal Plant starting January 1, 2022 through March 31, 2023. For each schedule, please provide the following information: a. Scheduled deliveries for at least each month across the delivery schedule time horizon including both available-to-promise (committed) and forecasted amounts; b. For each month, please provide the amount of coal in tons and the approximate amount of MWh the amount should produce; and c. For each schedule, please provide the reason, with documentation, for any changes in the monthly amounts from the previous month’s schedule. RESPONSE TO REQUEST FOR PRODUCTION NO. 9: Idaho Power became concerned about low inventory balances at Valmy in May 2022, as price escalation and volatility in the gas and power markets began to impact generation. Due to these rapidly changing conditions, Idaho Power contacted western coal suppliers seeking additional coal for the balance of 2022. No additional coal was available for purchase in 2022 that met plant coal quality specifications. Historically, Valmy coal RFPs for the upcoming year are issued in the fall of the preceding year. For 2023, however, efforts to procure supply were accelerated, and NV Energy and Idaho Power issued a joint RFP in June 2022. Coal delivery plans for the Valmy plant prepared during the January 2022 through March 2023 period are provided in Attachment 1. Significant changes in the plans are described in the workbook. IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 11 The response to this Request is sponsored by Randy Henderson, Principal Joint Projects Coordinator, Idaho Power Company. IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 12 REQUEST FOR PRODUCTION NO. 10: Please provide the actual amount of coal delivered, the amount of coal consumed and the ending inventory in tons for each month from January 1, 2022, through March 31, 2023, for the Valmy Coal Plant. RESPONSE TO REQUEST FOR PRODUCTION NO. 10: Coal delivered and consumed by month for January 2022 through March 2023, as well as monthly ending inventory balances for the Valmy Plant are provided in Attachment 1. The response to this Request is sponsored by Randy Henderson, Principal Joint Projects Coordinator, Idaho Power Company. IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 13 REQUEST FOR PRODUCTION NO. 11: Please provide the order lead time for coal deliveries to the Valmy plant from all established vendors. Please provide evidence of the lead times including how the lead times changed starting January 1, 2022, through March 31, 2023. RESPONSE TO REQUEST FOR PRODUCTION NO. 11: Power and gas prices during Spring 2022 were higher than typical seasonal prices. As a result, Valmy was operated throughout Q2 2022, depleting plant inventory. In response, Idaho Power took steps to acquire more coal. Difficulties acquiring additional coal for Valmy during 2022 beyond initially contracted amounts were not driven by typical order lead time issues. Suppliers did not have sufficient uncommitted production capacity and stockpiled coal available for Valmy that met plant quality specifications. Recent coal RFP activities, volumes, and timelines are summarized in Attachment 1. The response to this Request is sponsored by Randy Henderson, Principal Joint Projects Coordinator, Idaho Power Company. IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 14 DATED at Boise, Idaho, this 4th day of May 2023. ________________________________ MEGAN GOICOECHEA ALLEN Attorney for Idaho Power Company IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 15 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 4th day of May 2023, I served a true and correct copy of Idaho Power Company’s 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 Claire Sharp Deputy Attorney General Idaho Public Utilities Commission Po Box 83720 Boise, Idaho 83720-0074 Hand Delivered U.S. Mail Overnight Mail FAX X _E-mail Claire.Sharp@puc.idaho.gov ________________________________ Stacy Gust, Regulatory Administrative Assistant BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-23-12 IDAHO POWER COMPANY CONFIDENTIAL REQUEST NO. 1 ATTACHMENT NO. 1 SEE ATTACHED SPREADSHEET IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-23-12 IDAHO POWER COMPANY REQUEST NO. 1 ATTACHMENT NO. 2 SEE ATTACHED SPREADSHEET BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-23-05 IDAHO POWER COMPANY REQUEST NO. 1 ATTACHMENT NO. 3 SEE ATTACHED SPREADSHEET BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-23-12 IDAHO POWER COMPANY REQUEST NO. 2 ATTACHMENT NO. 1 SEE ATTACHED SPREADSHEET BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-23-12 IDAHO POWER COMPANY REQUEST NO. 2 ATTACHMENT NO. 2 SEE ATTACHED SPREADSHEET BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-23-12 IDAHO POWER COMPANY REQUEST NO. 2 ATTACHMENT NO. 3 SEE ATTACHED SPREADSHEET BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-23-12 IDAHO POWER COMPANY REQUEST NO. 3 ATTACHMENT NO. 1 SEE ATTACHED SPREADSHEET BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-23-12 IDAHO POWER COMPANY REQUEST NO. 4 ATTACHMENT NO. 1 SEE ATTACHED SPREADSHEET BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-23-12 IDAHO POWER COMPANY REQUEST NO. 5 ATTACHMENT NO. 1 SEE ATTACHED SPREADSHEET BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-23-12 IDAHO POWER COMPANY REQUEST NO. 6 ATTACHMENT NO. 1 SEE ATTACHED SPREADSHEET BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-23-12 IDAHO POWER COMPANY REQUEST NO. 7 ATTACHMENT NO. 1 SEE ATTACHED SPREADSHEET BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-23-12 IDAHO POWER COMPANY CONFIDENTIAL REQUEST NO. 8 ATTACHMENT NO. 1 SEE ATTACHED DOCUMENT BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-23-12 IDAHO POWER COMPANY REQUEST NO. 9 ATTACHMENT NO. 1 SEE ATTACHED SPREADSHEET BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-23-12 IDAHO POWER COMPANY REQUEST NO. 10 ATTACHMENT NO. 1 SEE ATTACHED SPREADSHEET