20231114Staff 1-19 to IPC.pdf

ADAM TRIPLETT
DEPUTY ATTORNEY GENERAL .*
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE,IDAHO 83720-0074 SSION
[phone]
IDAHO BAR NO.10221
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 )CASE NO.IPC-E-23-27
APPROVAL OF THE CAPACITY )DEFICIENCY PERIOD TO BE UTILIZED )FOR AVOIDED COST CALCULATIONS )FIRST PRODUCTION
)REQUESTOF THE
)COMMISSION STAFF
)TO IDAHO POWER COMPANY
Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Adam Triplett,Deputy Attorney General,requests that Idaho Power Company ("Company")
provide the followingdocuments and information as soon as possible,but no later than
TUESDAY,DECEMBER 5,2023.
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
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 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.1:Page 4 of the Application states that the Company uses the most
recent,relevant,and accurate information available in this case.Please respond to the following
regarding the load forecast used.
a.Please explain when the load forecast was created;
b.Please compare the load forecast used in this case and the load forecast used in
the last capacity deficiency case (Case No.IPC-E-21-09)that determined a 2023
first deficit year and explain the difference between the two forecasts;
c.Please provide the workpapers that compare the two forecasts;and
d.Please explain what causes any difference.
REQUESTNO.2:Please respond to the followingquestions regarding Figure No.1
shown during Portfolio ReliabilityAnalysis presentationin the August 15,2023,Integrated
Resource Plan Advisory Council meeting.
Figure No.1 Reliability &Capacity Assessment Tool ("RCAT")ModelingFlowchart
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 2 NOVEMBER 14,2023
a.Please explain how "System Adjusted Load"is determined;
b.Please explain the test years used to determine the capacity deficiency,why these
test years were selected,and how test years are adjusted to align with the monthly
peak of each forecasted Load and Resource ("L&R")year over the planning
horizon;
c.Please explain whether the adjustments used to align with each forecasted L&R
year occurs to each year throughoutthe entire planning horizon;
d.Please explain if such adjustments take place before the step of netting out the
capacity of "Run of Rivers","Variable Energy Resources","Cogeneration &
Small Power Production"in Figure No.1.If not,where are these adjustments
located in Figure No.1;and
e.Please explain how "net load"is derived and how the amounts of "Run of
Rivers","Variable Energy Resources","Cogeneration &Small Power
Production"are determined.Do the amounts depend on the test years and the
alignment of test years to the L&R years?
REQUESTNO.3:Please respond to the followingregarding the annual capacity
position of each test year.
a.Please confirm that the annual capacity position of each test year is the amount of
capacity needed during hours of highest risks;
b.Does each year in the entire planning horizon have different hours of highest
risks?Please explain;
c.Please explain how hours of highest risks are identified and provide a workpaper
to illustrate the process;and
d.Please explain how annual capacity positions are determined based on hours of
highest risks and provide a workpaper to illustrate the process.
REQUESTNO.4:Please respond to the followingregarding the Effective Load-
Carrying Capability ("ELCC")results listed on Page 92 of Appendix C of the 2023 Integrated
Resource Plan ("IRP").
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 3 NOVEMBER 14,2023
a.The results include "ELCC of Existing and Expected Resources"and "ELCC of
Future Resources."Please explain the difference between "Expected Resources"
and "Future Resources."
b.Is "ELCC of Future Resources"used in this case?If so,please explain why they
are appropriate for establishing the first capacity deficiency date.
c.Is the "ELCC of Existing and Expected Resources"used in this case?If so,
please explain how it is used.
d.Is the "ELCC of Existing and Expected Resources"used to determine the amount
of "Run of Rivers","Variable Energy Resources","Cogeneration &Small Power
Production"capacity reflected in Figure No.1 above?
e.Please explain how "ELCC of Existing and Expected Resources"and "ELCC of
Future Resources"are determined and whether there is a difference between the
two methods.
REQUESTNO.5:Please list all the resources used in the L&R Balance by resource
type (i.e.coal,natural gas,hydro,solar,wind,storage,market purchases,etc.)and for each
resource,provide the followinginformation.
a.Please provide the first operation date for any new resource included in the L&R
balance across the 20-year planning horizon since the last deficit date case was
filed;
b.Please provide the exit/retirement dates for any resource that exits or retires at any
point during the 20-year planning horizon in the L&R balance;and
c.Please list all the coal units that are assumed to be converted to gas in the L&R
balance and when each assumed conversion occurs.
REQUESTNO.6:Please identify differences in resources included in this case
compared to resources in the last capacity deficiency case (Case No.IPC-E-21-09)and justify
these changes.
REQUESTNO.7:Please explain how market purchase capacity is represented in the R-
CAT model and how transmission capacity affects it.In the answer,please identify any
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 4 NOVEMBER 14,2023
incremental additions of transmission capacity,the amount of contributed firm capacity to the
Company's system,and the timing of each.
REQUESTNO.8:Please explain if all firm transmission capacity included in this case
is backed by contracts.
REQUESTNO.9:Besides Capacity Benefit Margin ("CBM"),please list any other
non-firm transmission capacity included in the L&R Balance and why it is included.
REQUESTNO.10:Please explain the assumptions regarding PURPA contract renewals
and how these assumptions are justified.
REQUESTNO.11:Please explain the renewal assumptions of non-PURPA contracts in
this case and how the assumptions are justified.
REQUESTNO.12:Please identify when Valmy Unit 2 is assumed to close in the R-
CAT model.
REQUESTNO.13:Please verify whether Demand Response uses the following
assumptions:(1)existing DR programs are included at the current levels but can reflect
forecasted changes in the amount based on forecast levels of participation or knownchanges to
programs;and (2)future new DR programs are not included.If not,please explain what
assumptions are used and why they are used.
REQUESTNO.14:Please verify whether all cost-effective Energy Efficiency("EE")
programs are included based on forecasted participation.If not,please explain the EE
assumptions used in the R-CAT model.
REQUESTNO.15:Please verify whether on-site generation uses current levels but can
reflect forecasted levels of participation or known changes.If not,please explain the capacity
assumptions of on-site generation in the R-CAT model.
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 5 NOVEMBER 14,2023
REQUESTNO.16:Please explain how B2H is included in the R-CAT model.
REQUESTNO.17:Please explain whether resources proposed in Case No.IPC-E-23-
05 are included in the R-CAT model.
REQUESTNO.18:Please explain whether resources proposed in Case No.IPC-E-23-
20 are included in the R-CAT model.
REQUESTNO.19:Page 92 of Appendix C of the 2023 IRP states the Company
includes 14 MW of WRAP capacity benefit beginning in 2027 through the planning horizon.
Please answer the following:
a.Does the 14 MW of WRAP capacity contribution occur in 2027 in the L&R balance
in this case?
b.If it is different,please explain why.
c.Can each participant in the WRAP establish when their commitment for binding will
occur?Please explain.
d.Has the Company made a firm commitment when it will become binding?Please
explain.
DATED at Boise,Idaho,this /4 day of November 2023.
Adam p
Deputy AttorneyGeneral
i:umisc:prodreq/IPC-E-23-27 PR#1
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 6 NOVEMBER 14,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 14th DAY OF NOVEMBER 2023,
SERVED THE FOREGOING FIRST PRODUCTION REQUESTOF THE
COMMISSION STAFF TO IDAHO POWER COMPANY,IN CASE NO.IPC-E-23-27,
BY E-MAILING A COPY THEREOF,TO THE FOLLOWING:
DONOVAN E WALKER CAMILLE CHRISTEN
MEGAN GOICOECHEA ALLEN ENERGY CONTRACTS
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] [e-mail]
dockets idaho ower.com
SECRETARY
CERTIFICATE OF SERVICE