20231103Staff 1-31 to IPC.pdf

CHRIS BURDIN E lv ED
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION 3 þDN
PO BOX 83720
BOISE,IDAHO 83720-0074 sloN(208)334-0314
IDAHO BAR NO.9810
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 IDAHO POWER )COMPANY'S 2023 INTEGRATED )CASE NO.IPC-E-23-23
RESOURCEPLAN )
)FIRST PRODUCTION
)REQUESTOF THE
)COMMISSION STAFF
)TO IDAHO POWER COMPANY
Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Chris Burdin,Deputy Attorney General,requests that Idaho Power Company ("Company")
provide the followingdocuments and information as soon as possible,but no later than
FRIDAY,NOVEMBER 24,2023.
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 COMPANY l NOVEMBER 3,2023
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 all data input files used in the Reliability and
Capacity Assessment Tool ("RCAT").Where appropriate,please separate the input files by
scenario and provide a brief description of any adjustments made to the data for that scenario.
REQUESTNO.2:Please provide all RCAT scripts used to conduct supporting analysis
for the IRP in PDF format.For each script,please include a definition for each variable used.
REQUESTNO.3:Please provide workpapers like those provided in response to Staff's
Production Request No.96 in Case No.IPC-E-23-11,showing the hourly Loss of Load
Probability ("LOLP")and monthlyLoss of Load Expectation ("LOLE")for preferred portfolio
forecast years 2025 through2030 with and without the inclusion of Battery Energy Storage
System resources.
REQUESTNO.4:Please provide the rational for using 90%of total hourly risk to
determine seasons of highest risk.
REQUESTNO.5:Please define the "time of occurrence"used to group the top 90%of
LOLP values when determining seasons of highest risk.
REQUESTNO.6:Please define the criteria that the Company uses to identify the
seasons of highest risk as November 1 throughFebruary 28 and June l through September 15.
REQUESTNO.7:Please provide the rationale for selecting the top 50%risk hours in
each month for the purpose of determining the hours of highest risk.
REQUESTNO.8:Please describe the "percent of occurrence threshold"that the
Company uses to differentiate between hours of medium risk and hours of highest risk.
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 2 NOVEMBER 3,2023
REQUESTNO.9:Please explain how the method for modeling Energy Limited
Resources accounts for the need of these resources to recharge in the event of consecutive high
net load days.
REQUESTNO.10:Please provide supporting worksheets for the updated Boardman to
Hemingway ("B2H")September 2023 cost estimates,with a breakdown of the total amount by
cost component.Additionally,please explain why the cost estimates have increased in the 2023
Integrated Resource Plan ("IRP")since the estimates provided in the Company's certificate of
public convenience and necessity filing (Case No.IPC-E-23-01).
REQUESTNO.11:Please provide further explanation of the long duration pilotproject
for the five megawatts ("MW")of storage the Company would like to explore in 2024 through
2028.Please provide examples of what the Company is considering as a long duration project.
Additionally,please explain how the Company plans to seek to receive Commission approval.
REQUESTNO.12:Please provide further explanation on the Near-Term Action Plan
to "Install cost effective distribution-connected storage between 2025 and 2028."Please provide
examples the Company is considering for distribution-connected storage locations and the
assumed total amount of capacity in MW to be acquired within the Action Plan.Additionally,
please explain how the Company will seek to receive Commission approval.
REQUESTNO.13:Please explain how much available transmission capacity the
Company assumed for each of the Gateway West phases over the 20-year planning horizon.
a.Does the Company have contracts in place for each of the expected transmission line
phases?
b.Please provide supporting workpapers that detail the amount of transmission capacity
by year for the 20-year planning horizon.
REQUESTNO.14:In the November 2026 B2H portfolio,the transmission capacity of
Gateway West phase three ("GWW3")becomes available in 2041,compared to 2040 in the
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 3 NOVEMBER 3,2023
preferred portfolio.Appendix C at 45.Please explain why and how a delay in B2H results in a
year delay in the availability of GWW3 from the preferred portfolio.
REQUESTNO.15:Please explain what the Company assumed for customer generation
adoption over the 20-year planning horizon in the preferred portfolio.Please provide supporting
workpapers that detail expected customer generation growth by year for the 20-year planning
horizon.
REQUESTNO.16:Please explain the Company's assumptions for electric vehicle
adoption over the 20-year planning horizon in the preferred portfolio.Please provide supporting
workpapers that detail expected electric vehicle adoption growth by year for the 20-year
planning horizon.
REQUESTNO.17:On page 31 of Appendix C,the Company stated,"From IRP year
2030 and onward,weather modification levels in the Upper Snake,Wood,and Boise River
basins were increased due to an anticipation of expanding the cloud seeding program."Please
explain how the Company modeled the expanded cloud seeding program within the 20-year
planning horizon.Please provide supporting workpapers that detail the expanded cloud seeding
program.
REQUESTNO.18:Please explain why the Company did not run a sensitivityanalysis
on a portfolio with the Southwest Intertie Project -North ("SWIP-N")transmission capacity in
the 2023 IRP,like it did in the 2021 IRP.
a.Please provide an updated cost estimate to participate in SWIP-N with the same
assumptions made for the 2023 IRP preferred portfolio;and
b.Additionally,please provide the transmission capacity the Company assumed for the
SWIP-N project and any supporting documentation or workpapers.
REQUESTNO.19:Please explain if the 2023 IRP preferred portfolio used the Western
Resource Adequacy Program's ("WRAP")capacity benefit of 14 MW as a reduction to its
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 4 NOVEMBER 3,2023
Planning Reserve Margin ("PRM")starting in 2027,therefore reducing the amount of firm future
resources needed.If so,please provide a workpaper that shows the Company's PRM without
WRAP's capacity benefit.
REQUESTNO.20:Please provide a table similar to Table 10.7 -JulyPeak Hour and
Resource Balance as shown in the 2021 IRP on pages 142-143,updated for the 2023 IRP.
REQUESTNO.21:Please answer the followingregarding the 70th percentile energy
load forecast and the 70th percentile peak load forecast used in the 2023 IRP.
a.Please list all the study areas and the analysis models in the 2023 IRP where the 70th
percentile of energy load forecast and the 70th percentile of peak load forecast are
used;
b.Please explain why and how the Company determinedthat the 70th percentile energy
load forecast was the right level to use for its planning case.Please provide evidence
and any workpapers to explain the answer;and
c.Please explain why and how the Company determined that the 70th percentile peak
load forecast was the right level to use for its planning case.Please provide evidence
and any workpapers to explain the answer.
REQUESTNO.22:The "Extreme Weather"scenario listed on Page 128 of the 2023
IRP uses (1)70th percentile energy and 95th percentile peak load forecast,and (2)a mix of wet
and dry cycles to replace 50th percentile of the distribution.Please explain why and how the
Company determined that these were the proper levels to test extreme weather.Please provide
evidence and any workpapers to explain the answer.
REQUESTNO.23:Please respond to the followingquestions regarding natural gas
forecasts used in the AURORA LTCE model and in the AURORA dispatch model.
a.Please explain whether different zones in the AURORA model use different gas hub
forecasts across the Western Electricity Coordinating Council region.
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 5 NOVEMBER 3,2023
b.Please identify the sources of data and adjustments used for each hub forecast in the
model;and
c.Does the Idaho Power zone only use the HenryHub long-term forecast,adjusted for
the basis differential and transportation costs from Sumas,Washington?If not,what
other hub forecasts are used for the Idaho Power zone?
REQUESTNO.24:Page 111 of the 2023 IRP states that "Idaho Power also relied on
EIA's alternative forecasts (High Oil and Gas Supply,and Low Oil and Gas Supply)from their
Annual Energy Outlook 2023 to examine the impact of gas prices on the IRP."Please respond to
the followingfor the AURORA LTCE model and in the AURORA dispatch model.
a.Please explain the purpose of using the EIA forecasts and why these forecasts are
reasonable alternatives;and
b.Please explain whether the EIA forecasts are adjusted in the same way as the Platt's
forecasts (i.e.,to reflect different basins,transport costs,etc.)
REQUESTNO.25:Please explain why "California Energy Commission's Integrated
Energy Policy Report Preliminary GHG Allowance Price Projections"is a reasonable planning
condition.Also,please explain how this adder is applied in the AURORA LTCE model and the
AURORA dispatch model.
REQUESTNO.26:Please explain why "Social Cost of Carbon,Methane,and Nitrous
Oxide,Interim Estimates under Executive Order 13990"is a reasonable high carbon adder.
Also,please explain how this adder is applied in the AURORA LTCE model and the AURORA
dispatch model.
REQUESTNO.27:Page 128 of the 2023 IRP states the policy conditions in Idaho that
have resulted in no Idaho-based Public Utilities Regulatory Policy Act ("PURPA")projects in
recent years.Please respond to the following:
a.What does "recent years"mean?
b.Does Idaho-based PURPA projects in the statement mean both Surrogate Avoided
Resource ("SAR")-based projects and IRP-based projects?
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 6 NOVEMBER 3,2023
c.Has the analysis considered Oregon-based PURPA projects?Why?
REQUESTNO.28:Page 128 of the 2023 IRP states that for the "New Forecasted
PURPA"scenario,the PURPA wind renewal rate is set at 100%and new PURPA contracts are
modeled at an additional 57 MW each year,starting in 2028.Please confirm that both the 100%
renewal rate and the additional 57 MW starts in 2028.
REQUESTNO.29:Page 128 of the 2023 IRP states that the 57 MW of forecasted
PURPA resources was derived by identifying the average amount of new PURPA development
the Company experienced over the ten-year period from 2012 through 2021.Please explain
whether this analysis considers Idaho-based PURPA projects,Oregon-based PURPA projects or
both.Also,please explain whether this analysis considers both the SAR-based projects and IRP-
based projects.
REQUESTNO.30:Page 162 of the 2023 IRP states that Idaho Power applied the new
Qualified Facility development assumptions after the Action Plan window,starting in 2029,to
prevent distorting resource selection in the critical near-term window and inaccurately reshaping
actions for regulatory acknowledgement.In addition,page 126 of the 2023 IRP states that the
purpose of different future scenarios is to compare "the resources selected in the Preferred
Portfolio,developedunder planning constraints and conditions,to resources selected in other
possible scenarios.This is especially useful for near-term resources."Please respond to the
following:
a.If the "New Forecasted PURPA"scenario applies after the near-term window,please
explain whether the purpose of a future scenario is defeated;and
b.Please explain why the Company is concerned with distorting resource selection and
inaccurately reshaping actions for regulatory acknowledgement from the "New
Forecasted PURPA"scenario,but not from other scenarios such as "Extreme
Weather",which eventuallyimpacts resource selections starting in 2026 inside the
Action Plan window.
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 7 NOVEMBER 3,2023
REQUESTNO.31:Page 125-126 and Figure 9.2 list ten Portfolio Options.Please
explain why Valmy conversions need to be individuallyspecified and tested,and why the
Company does not let the AURORA model select conversion decisions.
DATED at Boise,Idaho,this 3rd day of November 2023.
Chris Burdin V
or'Deputy AttorneyGeneral
i:umise:prodreq/ipce23.23 prod req 1
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 8 NOVEMBER 3,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 3rd DAY OF NOVEMBER 2023,
SERVED THE FOREGOING FIRST PRODUCTION REQUESTOF THE
COMMISSION STAFF TO IDAHO POWER COMPANY,IN CASE NO.IPC-E-23-23,
BY E-MAILING A COPY THEREOF,TO THE FOLLOWING:
LISA D NORDSTROM TIMOTHY E TATUM
MEGAN GOICOECHEA ALLEN ALISON WILLIAMS
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] awilliams idahopower.com
[e-mail]
SECRETARY
CERTIFICATE OF SERVICE