20231214Staff to IPC 32-66.pdf

CHRIS BURDIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
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 2023 INTEGRATED )CASE NO.IPC-E-23-23
RESOURCE PLAN )
)SECOND PRODUCTION
)REQUESTOYTHE
)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")
provide the followingdocuments and information as soon as possible,but no later than
THURSDAY,JANURARY 4,2024.
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 telephone number of
the person preparing the documents.Please also identify the name,job title,location,and
telephonenumber of the record holder.
SECOND PRODUCTION REQUEST
TO IDAHO POWER COMPANY 1 DECEMBER 14,2023
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.32:Please explain why the Company built the followingconstraints into its
AURORA Long Term Capacity Expansion ("LTCE")model:
a.Please explain why the Company constrained the LTCE model to select between
exiting Valmy Unit 2 at the end of 2025 or converting to natural gas in 2026.IRP
at 9;
b.Please explain why the Company required Bridger Units 1 and 2 (already
converted to natural gas in 2024)to shut down at the end of 2037.IRP at 10;
c.Please explain why the Company required Bridger Units 3 and 4 to shut down at
the end of 2029 or convert to natural gas in 2030;
d.Please explain why the Company required Bridger Units 3 and 4 (if converted to
natural gas in 2030)to shut down at the end of 2037;and
e.Please explain why the Company allowed Valmy Units 1 &2 to operate
indefinitelyon natural gas,if economically favorable.
REQUESTNO.33:The Company states that it will account for the Federal Good
Neighbor Plan by modeling a range of nitrogen oxide ("NOx")allowances for Valmy and
Bridger.IRP at 23.Please explain the following:
a.Please explain the Company's NOx model in detail;
b.Please explain if the model establishes an economic penalty,like the carbon
adder,for NOx emissions.If so,please provide the penalty tables used by the
Company,and the data that supports those tables;
c.Please explain if a plant's exceedance of one or more NOx allowances results in
the shutdown,restriction,or conversion of that plant in the AURORA model;and
d.Please explain any impacts that modeling NOx had on the selection of resources
in the portfolios.
SECOND PRODUCTION REQUEST
TO IDAHO POWER COMPANY 2 DECEMBER 14,2023
REQUESTNO.34:The Company states that it "treats approximately 500 MW of
B2H's summer capacity as equivalent to a summer resource."and "200 MW of winter import
capacity as equivalent to a winter resource."IRP at 89.However,the IRP does not list these
values in any of the LTCE Results (IRP Appendix C,pp.42-71).Please explain how the
Company incorporated transmission as a resource in the LTCE analysis.
REQUESTNO.35:Figures 7.4 and 7.5 of the IRP depict the historical and forecast
load data for multiplesouthwestern balancing authorities.The Company asserts that the large
gap between summer load and winter load ensures there will be a surplus of winter power
available for purchase on the market.However,a large percentage of the southwest generation
resources are solar,so the winter generation profile will diminish in conjunction with the load
profile.Please provide the Company's analysis that compares the winter generation profile to
the winter load profile.
REQUESTNO.36:Table 7.8 lists the transmission interconnection assumptions for
each supply-side resource.Please answer the followingquestions:
a.Please provide an expanded version of Table 7.8 that includes the followingfor
each resource:
i.The raw capital cost estimate for transmission interconnection;
ii.The normalized (per kW)capital cost estimate;and
iii.An explanation of the major assumptions that drive the normalized cost
differences.
b.Please explain why the Company assumes the "Wind-Wyoming"100 MW
resource will be within 5 miles of Jim Bridger,even though the resource plan calls
for 18 new 100 MW wind resources.
c.Please explain why the Local Interconnection Assumption note for Solar PV
Utility-Scaleis nearly identical to the notes for Natural Gas resources,but the
Natural Gas resources have a normalized interconnection cost seven times larger
than Solar PV.
SECOND PRODUCTION REQUEST
TO IDAHO POWER COMPANY 3 DECEMBER 14,2023
REQUESTNO.37:The Company states that,Levelized Cost of Energy ("LCOE")is
not an input into the AURORA modeling performed for the IRP.IRP at 115.Please explain the
decision logic used by the AURORA LTCE model to select resources that are least-cost.Please
provide the data table that informs the model,and please provide an explanation of each of the
data fields.
REQUESTNO.38:Table 8.3 is the Levelized Cost of Capacity ("LCOC")for supply-
side resources.The Company states that the values "are presented in terms of dollars per kW of
nameplate capacity per month."IRP at 114.However,the Company also says that "expression
of these costs in terms of kW of peaking capacity can have a significant effect...."Id.Please
provide the followinginformation:
a.Please clarify the definition of peaking capacity;
b.If peaking capacity is different from a resource's Effective Load Carrying
Capacity please explain any differences and explain how peaking capacity is
determined;
c.Please provide an expanded version of Table 8.3 that includes the followingfor
each resource:
i.The raw capital cost,without normalizing,and without adjusting for the
tax credits;
ii.The raw capital cost,without normalizing,but adjusted for tax credits;
iii.The resource's assumed peaking capacity;and
iv.The resource's Total Cost per kW/mo.,adjusted for peaking capacity.
d.Please provide the basis for each resource's assumed peaking capacity;and
e.Please provide the underlyingworksheets that inform Table 8.3.
SECOND PRODUCTION REQUEST
TO IDAHO POWER COMPANY 4 DECEMBER 14,2023
REQUESTNO.39:Please explain the followingregarding Table 8.3:
a.Please explain why the Company opted to report the levelized cost per kW/month,
instead of per kW/year which has been the standard for previous IRPs;
b.Please explain why the normalized capital cost for Danskin 1 Retrofit is 60
percent higher than the normalized capital cost to build a new Combined Cycle
Combustion Turbine ("CCCT").
REQUESTNO.40:Table 8.4 is the levelized cost of energy ("LCOE")for supply-side
resources.Please explain the following:
a.Please provide the underlyingworksheets that inform Table 8.4;
b.Please explain why the capital cost for converting Danskin 1 to CCCT is $56/kW,
but the capital cost to build a new CCCT is only $36/kW.
c.Please clarify if the LCOE capacity factor is the same or different than the LCOC
peaking factor;
d.Please provide the Company's basis for each resource's LCOE capacity factor.
e.Please clarify why variable wind and solar have capacity factors ranging from 31
percent to 47 percent,while a gas CCCT has a capacity factor of only 55 percent.
REQUESTNO.41:Please explain why the Company,when calculating the LCOE for
all storage resources,does not consider the cost of energy to fill that resource.
REQUESTNO.42:The Company states that "the wholesale energy purchases and sales
made available through B2H capacity are not included in the graphed LCOE values."IRP at l15.
Please explain why the Company does not consider the cost of energy purchases in its
determination of LCOE values for transmission resources.Please explain why transmission
resources are missing from the LCOC and LCOE tables.
SECOND PRODUCTION REQUEST
TO IDAHO POWER COMPANY 5 DECEMBER 14,2023
REQUESTNO.43:Table 8.5 lists the unquantifiable attributes of various resources.
Please explain if and how the AURORA LTCE model considers these attributes in its resource
selection.If the LTCE model does not consider them,please explain how the Company uses the
attribute information to select resources.
REQUESTNO.44:In the Company's response to Production Request No.10,the
Company stated that "[t]he estimated cost has been updated to reflect preliminary bids received
for materials and construction."As supplement to the Company's Confidential Attachment 1,
please provide the following:
a.Please explain when the Company expects to have finalized bids for materials and
construction;
b.Please explain what the new line item "BPA funding of 2023 Permitting"entails;
c.Please explain the decrease for the cost estimate for "BPA's Share of Pre-
Construction Costs";
d.Please explain if the cost estimate for the "Right of Way Option Costs"reflects
the final cost of Right of Way expenses or a portion of Right of Way expenses
incurred to date;
e.Please explain why there is a decrease for the cost estimate "Transmission Line
Construction &Mitigation Contingency";and
f.Please explain the increase for the cost estimate of "BPA Permitting Buyout".
REQUESTNO.45:As supplement to the Company's response to Production Request
No.13,please explain if the Company has considered any alternative actions if the Gateway
West Phase 1 ("GWWl")is delayed beyond 2029.If so,please provide the Company's
considered actions.Additionally,please explain who the project manager for Segments 8 and 10
will be.
REQUESTNO.46:As supplement to the Company's Attachment 1 for its response to
Production Request No.15,in excel format,please provide the historical total Customer Count
by month for:
a.Residential Customer Class:for 2012 through 2023;
SECOND PRODUCTION REQUEST
TO IDAHO POWER COMPANY 6 DECEMBER 14,2023
b.Commercial Customer Class:for 2012 through 2023;and
c.IrrigationCustomer Class:for 2012 through 2023.
REQUESTNO.47:In the Company's Attachment 1 for its response to Production
Request No.15,the Residential and Irrigation customer generation forecasts both transition to
using a customer forecast month over month growth in 2034 and 2029,respectfully.Please
explain why the Commercial customer generation forecast does not transition to a similar
forecast.
REQUESTNO.48:As supplement to the Company's response to Production Request
No.16 -Attachment 1,please provide the R.L.Polk &Co.;Moody's AnalyticsForecast that the
Company used in its forecast for electric vehicle adoption.
REQUESTNO.49:In the Company's response to Production Request No.17,the
Company stated that "[o]ncethe built-out precipitation benefits were estimated,the process for
determining the hydro resource impact followed the same modeling procedures as with the
current build-out precipitation benefits."Please provide and explain the assumed benefits of the
built-out precipitation.
REQUESTNO.50:As supplement to the Company's response to Production Request
No.18,please explain any anticipated customer benefits for the Company's involvement in
Southwest Intertie Project -North ("SWIP-N").Please provide the assumptions used in
determining benefits.
REQUESTNO.51:As supplement to the Company's response to Production Request
No.20 -Attachment 1,please explain the following:
a.In the "Preferred Portfolio"tab,please explain why the amount of "Transmission"
does not change from the amount provided in the "Pre IRP"tab;and
b.In the "Preferred Portfolio"tab,please explain why the Company's "Highest Risk
Season"changes to "Winter"in 2028 rather than 2027 as described in the "Pre
IRP"tab.
SECOND PRODUCTION REQUEST
TO IDAHO POWER COMPANY 7 DECEMBER 14,2023
REQUESTNO.52:In its August Energy EfficiencyAdvisory Group ("EEAG")
meeting,the Company discussed changing the methodology used to plan and evaluate its
Demand Side Management("DSM")programs from "acknowledged"to "filed"IRP avoided
costs.Please explain if the Company is implementing that change as of this filing and,if so,
provide the reasoning and support for the change.
REQUESTNO.53:In the November 8 EEAG,the Company presented the "Cost-
Effectiveness Refresher and 2024 preview"showing several updates to the DSM avoided cost
calculation.Please answer the followingand provide supporting workpapers in excel format
with equations intact and enabled:
a.Please explain how the Company differentiates risk into the low,mid and high
risk time blocks for each season;and
b.Please explain the methodology used to calculate the seasonal risk allocation
factor.
REQUESTNO.54:Please list the selected energy efficiencybundles for each forecast
year.Please provide a list of measures and the associated input information for each selected
bundle.
REQUESTNO.55:Please list the selected Demand Response ("DR")bundles for each
forecast year.Please provide a list of the measures and the associated input information for each
selected bundle.
REQUESTNO.56:Please provide workpapers supporting the avoided cost averages
shown in Appendix C at 18.Please clearly show each avoided cost component (e.g.,avoided
energy,avoided capacity,transmission and distribution deferral)and any calculations relevant to
supporting those values.
REQUESTNO.57:In Staff s Comments for the 2021 IRP,it recommended that the
Company discuss and explore adjusting the 20 MW threshold cap on additional DR capacity
with its EEAG and Integrated Resource Planning and Advisory Committee in the development
SECOND PRODUCTION REQUEST
TO IDAHO POWER COMPANY 8 DECEMBER 14,2023
of the 2023 IRP.Please describe the consideration and discussion given to the topic.Please
provide the reasoning for continuingto model DR selections using the 20 MW threshold cap.
REQUESTNO.58:Page 96 of Appendix C of the 2023 IRP states that "[w]hilethe
identified seasons and hours capture over 95%of the total hourly risk,the magnitude of LOLP
values vary."Please explain whether "95%"should have been "90%"as described on Page 92.
REQUESTNO.59:Response to Staff Production Request No.21(b)states:
"The 70th percentile energy load forecast was utilized in response to the selection
of the 70th percentile peak load forecast for reliabilitypurposes.The Company
considers it important to maintain consistency in the relationship between the
energy and peak load forecast percentiles."
Please respond to the following:
a.Please explain why it is important to maintain consistency in the relationship
between the energy and peak load forecast percentiles;
b.Has the Company ever allowed inconsistency in the relationship between the
energy and peak load forecast percentiles in any past IRPs?If so,please describe
when they were different and why;
c.Please list all of the marginal cost rates,avoided cost rates,and rates for
consumption that are leveraged from the IRP that would be different depending
on whether the Company used a 50th percentile energy load forecast instead of the
70th percentile energy load forecast (e.g.PURPA IRP-based rates,DSM avoided
cost rates,Schedule 20 marginal cost rates,etc.);
d.For each of the rates listed above,please provide which percentile energy load
forecast is actually used,and explain the Company's justification for each;
e.Please explain whether using a 50th percentile energy load forecast instead of the
70th percentile energy load forecast would cause a difference in the loss of load
probabilityheat maps and/or timeframes used to determine performance-based
capacity payments for CEYW-Construction customers,DR program timeframes,
Time-of-Use Rates,etc.;and
SECOND PRODUCTION REQUEST
TO IDAHO POWER COMPANY 9 DECEMBER 14,2023
f.Please confirm that all the portfolios in the Portfolio Costing Analysis use 70th
percentile energy load forecast.
REQUESTNO.60:Response to Staff Production Request No.21(c)states:
Idaho Power moved forward with the combination of the 70th peTCenÍiÏ€
peak load forecast and a 0.1 event-days per year LOLE threshold for the
2023 IRP,as it produced similar reliability results when compared to the
combination of the 50th percentile peak load forecast and a 0.05 event-days
per year LOLE threshold.
Please explain whether "similar reliability results"refer to the 0-MW capacity position and 16-
MW capacity position in the 2021 IRP case and the 2023 IRP case,respectively,contained in the
"Response to Staffs Request No.21 -Attachment 1 -Load Forecast &Loss of Load
Expectation"Excel file.If not,please explain,define,and provide the "similar reliability
results."
REQUESTNO.61:The "Extreme Weather"scenario uses 70*percentile energy and
95*percentile peak load forecast.Please confirm that the 70th percentile energy is used in
determining the cost of the portfolio selected under the 95*percentile peak.If not confirmed,
please explain how the 70th percentile energy load forecast is used for the Extreme Weather
scenario.
REQUESTNO.62:Response to Staff Production Request No.24 states that "[t]he EIA
forecasts also validate the stochastic gas price forecast spread."Please respond to the following:
a.Please explain how the EIA forecasts validate the stochastic gas price forecast
spread;
b.Please explain whether the EIA forecasts are used in the Natural Gas Sampling
described on Page 84 of Appendix C of the 2023 IRP;and
c.If so,please explain how the EIA forecasts are used in the Natural Gas Sampling
described on Page 84 of Appendix C of the 2023 IRP.
REQUESTNO.63:Figure No.I was shown during Portfolio Reliability Analysis
presentation in the August 15,2023,Integrated Resource Plan Advisory Council meeting.
SECOND PRODUCTION REQUEST
TO IDAHO POWER COMPANY 10 DECEMBER 14,2023
Figure No.1 Reliability &Capacity Assessment Tool ("RCAT")Modeling Flowchart
Response to Staff Production Request No.2 (a)in Case No.IPC-E-23-27 states that the System
Adjusted Load =System Load +Demand Response Dispatched.Response to Staff Production
Request No.2 (d)in Case No.IPC-E-23-27 states that "the adjustments to the test year hourly
load take place before any resources are netted out."Please respond to the following.
a.Please explain whether the "System Load"in "System Adjusted Load =System
Load +Demand Response Dispatched"refers to the adjustedi test year hourly
load based on a given Load and Resource ("L&R")year.
b.Please explain how the "Demand Response Dispatched"is determined.In the
response,please clarify if it is based on the actual Demand Response data in the
corresponding test year and whether any adjustment was needed.
REQUESTNO.64:In Figure No.I above,Net Load is further adjusted by Energy
Limited Resources,which include Battery Energy Storage System,Demand Response,and
Hybrid.Please respond to the following.
I "adjusted"by scaling each month individuallysuch that each month in a test year has the same peak as the
forecasted monthly peak for a givenLoad and Resource ("L&R")year.
SECOND PRODUCTION REQUEST
TO IDAHO POWER COMPANY 11 DECEMBER 14,2023
a.Please explain how Energy Limited Resources and their three components are
determined and whether they depend on a test year or a Load and Resource year?
b.Please define "Hybrid".
REQUESTNO.65:Response to Staff Production Request No.2 (e)in Case No.IPC-E-
23-27 states that the net load is derived by subtracting the generationthat Idaho Power does not
control (such as run-of-river hydro,wind,solar,and cogeneration and small power production)
from the system-adjusted load,and that "the historical data of these resources is scaled up or
down dependingon additions and/or retirements in any given L&R year."Please explain in
detail and provide illustrative examples to show how "the historical data of these resources is
scaled up or down depending on additions and/or retirements in any given L&R year."
REQUESTNO.66:The Effective Load-Carrying Capability ("ELCC")results listed on
Page 92 of Appendix C of the 2023 IRP include "ELCC of Existing and Expected Resources"
and "ELCC of Future Resources".Response to Staff Production Request No.4 (a)in Case No.
IPC-E-23-27 further states that Expected Resources "are resources that are under contract and/or
expected to come online in the near-term but not yet in service"and Future Resources "are
resources that do not have a contract."Response to Staff Production Request No.4 (e)in Case
No.IPC-E-23-27 states that both the "ELCC of Existing and Expected Resources"and the
"ELCC of Future Resources"are calculated using the "last-in"ELCC methodology.Please
respond to the following:
a.Please explain and provide an illustrative example of the "last-in"ELCC
methodology.
b.Please explain if there is any different treatment for Existing Resources,Expected
Resources,and Future Resources under the "last-in"ELCC methodology.
c.Please explain how historical generationdata of Existing Resources are used in
the "last-in"ELCC methodology.
d.Please explain how forecasted generation profiles of Expected Resources and
Future Resources are used in the "last-in"ELCC methodology.
SECOND PRODUCTION REQUEST
TO IDAHO POWER COMPANY 12 DECEMBER 14,2023
e.Does AURORA use the ELCC of Existing Resources or the historical generation
data of Existing Resources?
f.Please confirm that AURORA uses the ELCC of Expected Resources and Future
Resources and explain how AURORA uses the ELCC.
g.Please explain whether, for the same type of Future Resources, ELCC will change
over time across different L&R years.
DATED at Boise, Idaho, this 14th day of December 2023.
i:umisc:prodreq/IPC-E-23-23 PR# 2
SECOND PRODUCTION REQUEST TO IDAHO POWER COMPANY 13
Chris Burdin Deputy Attorney General
DECEMBER 14, 2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 14TH DAY OF DECEMBER 2023,SERVED THE FOREGOING SECOND 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 83707-0070E-MAIL:[e-mail] E-MAIL:[e-mail]
[e-mail] [e-mail]
[e-mail]
Ida Elmasian
CERTIFICATE OF SERVICE