20240131IPC to Staff 74-75 Supplemental.pdf

LISA D. NORDSTROM
Lead Counsel
[e-mail]

January 31, 2024

VIA ELECTRONIC EMAIL

Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg 8,
Suite 201-A (83714)
PO Box 83720
Boise, Idaho 83720-0074

Re: Case No. IPC-E-23-23
Idaho Power Company’s 2023 Integrated Resource Plan

Dear Commission Secretary:

Enclosed for electronic filing, please find Idaho Power Company’s Supplemental
Response to the Third Production Request of Commission Staff.

If you have any questions about the attached filing, please do not hesitate to
contact me.

Very truly yours,

Lisa D. Nordstrom
LDN:cd
Attachments
RECEIVED
Wednesday, January 31, 2024 4:06PM
IDAHO PUBLIC
UTILITIES COMMISSION
IDAHO POWER COMPANY’S SUPPLEMENTAL RESPONSE TO THE THIRD PRODUCTION
REQUEST OF THE COMMISSION STAFF- 1
LISA D. NORDSTROM (ISB No. 5733)
MEGAN GOICOECHEA ALLEN (ISB No. 7623)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
[e-mail]
[e-mail]

Attorneys for Idaho Power Company

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF IDAHO POWER
COMPANY’S 2023 INTEGRATED
RESOURCE PLAN.
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CASE NO. IPC-E-23-23

IDAHO POWER COMPANY’S
SUPPLEMENTAL RESPONSE TO
THE THIRD PRODUCTION
REQUEST OF THE COMMISSION
STAFF

COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), and in
response to the Third Production Request of the Commission Staff (“Commission” or
“Staff”) dated January 17, 2024, herewith submits the following supplemental
information:

IDAHO POWER COMPANY’S SUPPLEMENTAL RESPONSE TO THE THIRD PRODUCTION
REQUEST OF THE COMMISSION STAFF- 2
STAFF REQUEST FOR PRODUCTION NO. 74: Please provide the Company
analysis supporting the selection of November 1 through February 28, and June 1 through
September 15, described on page 93 of Appendix C, as seasons of highest risk, in Excel
format with equations enabled and intact.
a. Please indicate the forecast year used to inform these selections; and
b. Please indicate if the analysis excludes any Energy Limited Resources
("ELR") (i.e., DR, BESS, or hybrid resources) and if so, please provide a
similar analysis with the inclusion of the excluded resource(s).
SUPPLEMENTAL RESPONSE TO STAFF’S REQUEST FOR PRODUCTION
NO. 74:
Please see the attached Excel spreadsheet for the top 90 percent of Loss of Load
Probabilities (“LOLPs”) by test year, which were utilized to determine the seasons of
highest risk. Please note that Idaho Power utilizes its internally developed Reliability and
Capacity Assessment Tool (“RCAT”) to calculate LOLPs and their corresponding
date/time stamps, so no formulas are available in the spreadsheet. The Company shared
a summary of the LOLPs utilized to determine the seasons of highest risk in a meeting
with Staff on September 11, 2023, and has also included it in the ‘Seasons_Summary’
tab of the attachment to this request. While October is included in the range for three of
the test years, the magnitude and frequency of the October LOLPs were considered
negligible in comparison to the seasons of highest risk analysis.
a. The forecast year used to inform the seasons of highest risk in the 2023 Integrated
Resource Plan (“IRP”) was 2025.

IDAHO POWER COMPANY’S SUPPLEMENTAL RESPONSE TO THE THIRD PRODUCTION
REQUEST OF THE COMMISSION STAFF- 3
b. The seasons of highest risk analysis includes all Energy Limited Resources
(“ELRs”) for the 2025 load and resource year.
The response to this Request is sponsored by Andrés Valdepeña Delgado, System
Consulting Engineer, Idaho Power Company.

IDAHO POWER COMPANY’S SUPPLEMENTAL RESPONSE TO THE THIRD PRODUCTION
REQUEST OF THE COMMISSION STAFF- 4
STAFF REQUEST FOR PRODUCTION NO. 75: Please provide Company
analysis supporting the selection of the Summer and Winter risk hours shown on page 93
and 94 of Appendix C as the hours for highest risk in Excel format with equations enabled
and intact.
a. Please indicate the forecast year used to inform these selections; and
b. Please indicate if the analysis excludes any ELRs (i.e., DR, BESS, or hybrid
resources). If so, please provide a similar analysis with the inclusion of the
excluded resource(s).
SUPPLEMENTAL RESPONSE TO STAFF’S REQUEST FOR PRODUCTION
NO. 75:
Please see the attached Excel spreadsheet for the analysis supporting the
selection of the Company’s risk hours for the 2023 Integrated Resource Plan (“IRP”).
Please note that Idaho Power utilizes its internally developed Reliability and Capacity
Assessment Tool (“RCAT”) to calculate LOLPs and their corresponding date/time stamps,
so no formulas are available in the spreadsheet.
a. The forecast year used to inform the risk hours in the 2023 IRP was 2025.
b. The hours of risk analysis excluded all Energy Limited Resources (“ELRs”) for the
2025 load and resource year. Please see the attached Excel spreadsheet for the
risk hours analysis including all ELRs.
The response to this Request is sponsored by Andrés Valdepeña Delgado, System
Consulting Engineer, Idaho Power Company.

IDAHO POWER COMPANY’S SUPPLEMENTAL RESPONSE TO THE THIRD PRODUCTION
REQUEST OF THE COMMISSION STAFF- 5
DATED at Boise, Idaho, this 31st day of January 2024.

Lisa Nordstrom
Attorney for Idaho Power Company

IDAHO POWER COMPANY’S SUPPLEMENTAL RESPONSE TO THE THIRD PRODUCTION
REQUEST OF THE COMMISSION STAFF- 6
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the 31st day of January 2024, I served a true and
correct copy of Idaho Power Company’s Supplemental Response to the Third
Production Request of the Commission Staff upon the following named parties by the
method indicated below, and addressed to the following:

Commission Staff
Chris Burdin
Deputy Attorney General
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg No. 8
Suite 201-A (83714)
PO Box 83720
Boise, ID 83720-0074

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Micron Technology, Inc.
Austin Rueschhoff
Thorvald A. Nelson
Austin W. Jensen
Holland & Hart, LLP
555 Seventeenth Street, Suite 3200
Denver, Colorado 80202

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Jim Swier
Micron Technology, Inc.
8000 South Federal Way
Boise, Idaho 83707
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________________________________
Christy Davenport
Legal Administrative Assistant