20230822Staff 3-23 to IPC.pdf

CHRIS BURDIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION U
PO BOX 83720
BOISE,IDAHO 83720-0074
[phone]
IDAHO BAR NO.9810
Street Address for Express Mail:
11331 W CHINDEN BLVD,BLDG 8,SUITE 201-A
BOISE,ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER )
COMPANY'S APPLICATION FOR A )CASE NO.IPC-E-23-20
CERTIFICATE OF PUBLIC CONVENIENCE )
AND NECESSITY TO ACQUIRERESOURCES )TO BE ONLINE IN BOTH 2024 AND 2025 AND )SECOND PRODUCTION
FOR APPROVAL OF AN ENERGY STORAGE )REQUESTOF THE
AGREEMENT WITH KUNA BESS,LLC )COMMISSION STAFF
)TO IDAHO POWER COMPANY
Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Chris Burdin,Deputy AttorneyGeneral,requests that Idaho Power Company ("Company"or
"Idaho Power")provide the followingdocuments and information as soon as possible,but no
later than,TUESDAY AUGUST 29,2023.1
This Production Request is to be considered as continuing,and the Company is requested
to provide,by way of supplementary responses,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 telephone number of
'Staffis requesting an expedited response.If responding by this date will be problematic,please call Staff's
attorney at [phone].
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REQUEST TO IDAHO POWER 1 AUGUST 22,2023
the person preparing the documents.Please also identify the name,job title,location,and
telephone number 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.3:The followingsources show an incremental capacity deficit of 125
MW in 2025:
The 2021 IntegratedResource Plan ("2021 IRP")at 142 and 170;
Hackett's Direct Testimony at 8;
However,the followingsources show an incremental capacity deficit of 115 MW in
2025:
Application at 6;
Ellsworth's Direct Testimony at 23;and
Please reconcile the numbers.
REQUESTNO.4:What is the energy source that will be used to charge the Kuna
Battery Energy Storage System ("BESS")?
REQUESTNO.5:Round Trip Efficiency (RTE)=Discharging Energy ÷
Charging Energy.Exhibit No.6 of Hackett's Direct Testimony.The Application states that
Section 1.1 of the ESA contains a Guaranteed Round-TripEfficiency as of the Commercial
Operation Date of 85.9 percent which decreases 0.22 percent annually.Please respond to the
following.
a.Please explain whether it is typical to have a Guaranteed Round-Trip Efficiency
lower than 90 percent for a new BESS project and provide evidence to support
your answer;and
b.Please explain whether a 0.22 annual decrease is typical and provide evidence to
support your answer.
REQUESTNO.6:The Application states that at the time the proposals for 2022
Request For Proposals ("2022 RFP")were being evaluated,the 2025 capacity deficiency had
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REQUEST TO IDAHO POWER 2 AUGUST 22,2023
increased,so Idaho Power selected the next most cost-effective resource to meet the 2025
capacity deficiency.Application at 9.Page 18 of Ellsworth's Direct Testimony states that the
updated capacity deficiency in 2025 is 178 MW.Please respond to the following:
a.When did the 2025 capacity deficiency increase to 178 MW?
b.Please provide the Load and Resource Balance ("L&R")for the 178 MW;
c.Please confirm that reasons listed on Pages 10 and 11 of Ellsworth's Direct
Testimony are all the reasons that caused the deficit increase from the previous
2025 capacity deficiency identified in the 2021 IRP to the updated incremental
178 MW deficit in 2025.If not,please provide additional reasons;and
d.Please provide the updated L&R that shows the updated capacity position of 13
MW of capacity length in 2024,after the proposed resources are added.
REQUESTNO.7:The Application states that during preparation of the 2023 IRP,as
the load and resource balance was refreshed,it was determinedthat a capacity shortfall still
exists in 2024,so the Company added a 24 MW BESS to meet the 2024 capacity deficiency.
Application at 10.Page 18 of the Ellsworth's Direct Testimony states that the shortfall is 8 MW.
Please respond to the following:
a.Please explain when it was determined that the 8 MW shortfall still existed in
2024;
b.Please provide the L&R for the 8 MW shortfall;
c.Please explain what caused the 8 MW shortfall since the last deficit of 103 MW
was met by resources proposed in Case No.IPC-E-23-05.In your answer,please
rule out factors that have contributed to the determination of the 103 MW deficit;
and
d.Please provide the updated L&R that shows the updated capacity position of 6
MW of capacity length in 2025,after the proposed resources are added.
REQUESTNO.8:Page 18 of Ellsworth's Direct Testimony states that both the 8 MW
deficit in 2024 and the 178 MW deficit in 2025 are based on the assumption that the Company
can compress the American Falls outages into nine-months and maintain full American Falls
capacity through the summer months.Please respond to the following:
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REQUEST TO IDAHO POWER 3 AUGUST 22,2023
a.Please explain whether this assumption is still reasonable;
b.If the Company is not able to restore American Falls to full capacity for the
summer,what are the capacity deficits in 2024 and 2025,respectively?Please
provide the L&Rs that show these capacity deficits;and
c.After the proposed resources are added,the capacity position becomes 13 MW in
length in 2024 and 6 MW in length in 2025,assuming the Company can restore
the American Falls power plant to full capacity prior to the summer of each year.
Please explain whether 13 MW and 6 MW are reasonable amounts of capacity
lengths.
REQUESTNO.9:Please respond to the followingregarding the Battery Energy
Storage Agreement ("BESA")executed by the Company and Powin on June 8,2023.
a.Please provide a complete copy of the contract and include Exhibit E of the
contract in your response;
b.Please confirm this contract is based on a 36 MW nameplate capacity,which
includes both the 12 MW BESS in Case No.IPC-E-23-05 and the 24 MW BESS
in this case;and
c.If confirmed,please provide the page number of the contract that references the
36 MW.
REQUESTNO.10:Please provide a breakdown of the total cost estimates for the
development and construction of the 24 MW BESS,similar to the table contained in Response
No.43(b)in Case No.IPC-E-23-05.
REQUESTNO.11:Please provide a breakdown of the total cost estimates for the
developmentand construction of the 77 MW BESS,similar to the table contained in Response
No.43(b)in Case No.IPC-E-23-05.
REQUESTNO.12:The 77 MW is a reduced capacity size from the original bid size.Is
the levelized cost of capacity for the original size kept the same for the 77 MW?If not,how can
the Company guarantee this resource is the second least-cost resource?
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REQUEST TO IDAHO POWER 4 AUGUST 22,2023
REQUESTNO.13:The Company's Reply Comments in Case No.IPC-E-23-05 state
that "Idaho Power performed a quantitative and qualitative evaluation with an objective scoring
methodology to reasonablyevaluate the price and non-price attributes of each project proposal
submitted throughthe RFP process."Please respond to the following:
a.Please describe the scoring methodology;
b.Please provide the result of the qualitative evaluation,includingthe score of each
project;
c.Please provide the result of the quantitative evaluation,includingthe score of
each project;and
d.Please provide the final result that combined the quantitative evaluation and the
qualitative evaluation,including the score of each project.
REQUESTNO.14:Please list all the bids that the Company received,where the BESS
component of "BESS+Solar"and "BESS+Wind"is owned by the respondent.
REQUESTNO.15:Please confirm that AURORA selects least-cost resources based on
each project's levelized cost of capacity contained in Table 1-3 of Exhibit No.5 of Hackett's
Direct Testimony and not each project's proposal price contained in these tables.If not
confirmed,please explain how AURORA selects the least-cost resources.
REQUESTNO.16:Page 23 of Hackett's Direct Testimony states that "[t]he remaining
project,Project No.34,did not have any available transmission capacity and therefore did not
make the short list.Similarly,although modeled as part of the LTCE analysis,it was determined
that Project Nos.2,3,4,5,and 33 also did not have any available transmission capacity."Please
respond to the following:
a.Was Project No.34 included in the LTCE analysis?
b.If not,why was Project No.34 not included in the LTCE analysis,while Project
Nos,2,3,4,5,and 33 were included?
c.Is "available transmission capacity"a requirement that a bid must meet?
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REQUEST TO IDAHO POWER 5 AUGUST 22,2023
d.If so,why were Project Nos.2,3,4,5,and 33 still modeled as part of the LTCE
analysis,when they did not meet the transmission requirement?
REQUESTNO.17:Page 23 of Hackett's Direct Testimony states "Project Nos.25,26,
and 27 were not cost-effective options because of the limited capacity benefit of the energy
storage or surplus only availability of the energy storage."Please respond to the following:
a.Is it a requirement that projects cannot have attributes of "limited capacity
benefit"or "surplus only availability"?
b.If so,why were Project Nos.25,26,and 27 still included in the LTCE analysis,
when they did not meet the requirement?
c.Is it possible for a project to be cost-effective that provides limited capacity
benefit or surplus only availability?
REQUESTNO.18:Pages 24-25 of Hackett's Direct Testimony states that after the
establishment of the short list,the RFP evaluation team provided another opportunityfor
developers to update pricing.Five of the shortlist projects provided updated pricing,where four
projects increased pricing and one project decreased pricing.Please respond to the following:
a.Which projects increased pricing?
b.Which project decreased pricing?
REQUESTNO.19:Page 31 of Hackett's Direct Testimony states that "the Company
will initiate a purchase order with a battery supplier and enter into a contract specific to the
deliveryand contract price of the BESS.Upon notification of selection by the RFP evaluation
team,the Company's Power Supply department began discussions with suppliers for
procurement of the BESS but has not yet executed a purchase order."Please respond to the
following:
a.Has the Company executed any contract to purchase the 77 MW BESS from a
supplier?
b.If so,please provide a copy of the contract.
c.If not,when does the Company plan to execute the contract?
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REQUEST TO IDAHO POWER 6 AUGUST 22,2023
REQUESTNO.20:Page 35 of Hackett's Direct Testimony provides the estimated costs
of the 77 MW BESS and the 24 MW BESS.Are the estimated costs turn-keycosts that bring the
projects from design to operation?If not,what items do the estimated costs include?Please
provide a breakdown of the estimated costs for each item.
REQUESTNO.21:Please explain why Project No.16 was not selected,when its
levelized cost was the lowest on the short list.
REQUESTNO.22:Footnote Nos.21 and 23 in Exhibit No.5 of Hackett's Direct
Testimony mention price adjustments due to overbuilds.
a.Please explain what the bidders proposed regarding overbuilds in their bids;and
b.Please explain how and why overbuilds affect pricing.
REQUESTNO.23:Please provide the overall levelized cost and annual cost and
benefit streams with a breakdown of the cost and benefit components for Project Nos.6,13,and
17 on the short list,in addition to the separate levelized costs for the solar,wind,or BESS
components already provided in the Application.
DATED at Boise,Idaho,this day of August 2023.
Chri Burdin,
Deputy AttorneyGeneral
i:umisc:prodreq/ipce23.20cbyy prod req 2
SECOND PRODUCTION
REQUEST TO IDAHO POWER 7 AUGUST 22,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 226'DAY OF AUGUST 2023,
SERVED THE FOREGOING SECOND PRODUCTION REQUESTOF THE
COMMISSION STAFF TO IDAHO POWER COMPANY,IN CASE NO.IPC-E-23-20,
BY E-MAILING A COPY THEREOF,TO THE FOLLOWING:
DONOVAN E WALKER TIM TATUM
IDAHO POWER COMPANY IDAHO POWER COMPANY
PO BOX 70 PO BOX 70
BOISE ID 83707-0070 BOISE ID 83707-0070
E-MAIL:dwalker idahopower.com E-MAIL:[e-mail]
dockets idahopower.com
SECRETARY
CERTIFICATE OF SERVICE