20200522Harvey Direct Supplemental.pdf

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LISA D. NORDSTROM
Lead Counsel
[e-mail]
May 20, 2020
VIA ELECTRONIC FILING
Diane Hanian, Secretary
ldaho Public Utilities Commission
11331 W. Chinden Boulevard
Building 8, Suite 201-A
Boise, ldaho 83714
Case No. IPC-E-19-18
Validation of North Valmy Power Plant Unit 2 Closure in 2025
ldaho Power Company's Testimony
Dear Ms. Hanian
Attached for electronic filing in the above matter is ldaho Power Company's
Supplemental Direct Testimony of Tom Harvey.
lf you have any questions about the enclosed documents, please do not hesitate to
contact me.
Very truly yours,
I r : il !: l\,'[: D
Re
X*!-(,a.+*-*,
Lisa D. Nordstrom
LDN:sdh
Enclosures
BEFORE THE IDAIIO PI'BIJIC TJTII'ITIES COMMISSION
IN THE MATTER OF IDAITO POWER
COMPANY'S APPLICATION EOR A
DETERMINATION VAI,IDATING A NORTH
VAIMY POWER PIJAMT UNIT 2 CI-JOSURE
rN 2025.
cAsE NO. IPC-E-19-r_8
IDAI{O POWER COMPAI\TY
SUPPIJEMENTAIJ DIRECT TESTIMOIiTY
OF
TOM HARVEY
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O. Please state your name, business address, and
present position with
"Company").
A. My name
Idaho Power Company ("Idaho Power" or
is Tom Harvey and my business address
is L22L West Idaho Street, Boise, Idaho 83702. I am
employed by Idaho Power as the Vice President of Power
Supply in the Power Supply Department.
O. Have you previously submitted testimony before
the Idaho PubIic Util-ities Commission ("Commission") in
this proceeding?
A. Yes. On .fune 27, 20L9, I filed testimony
presenting the results of the Valmy Unit 2 closure analyses
supporting a December 31, 2025, end-of-life date and
requesting the Commission acknowledge the Company has
sufficiently validated t.he economic retirement date of Unit
2 is December 31, 2025, as directed by the Commission in
Order No. 34349.
O. What is the purpose of your testimony in this
case?
A. The purpose of my testimony is to present
additional validation that the economic retirement date of
Valmy Unit 2 is December 31-, 2025, based on the analyses
performed during and after the development of the Amended
201,9 Integrated Resource Plan ("IRP") filed with the
Commission on ,fanuary 31-, 2020, as directed by the
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fdaho Power Company
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1 Commission in Order No. 34349. The additional analyses
2 performed using the results of the Amended 2019 IRP
3 validate the conclusions found in the initial analysis
4 presented in my direct testimony. The results indicate
5 that, under the broad range of modeled scenarios, an exit
6 from Unit 2 prior to 2025 would result in higher costs for
7 customers and would cause system reliability concerns. The
8 analyses validate year-end 2025 as the appropriate end-of-
9 life date for Valmy Unit 2.
l-0 O. Do you have any exhibits?
11 A. Yes. Exhibit No. 1 to my testimony presents
L2 the net present value ('NPV") difference between the cost
1-3 of the Preferred Portfolio and the portfolios modeled
L4 during the Company's supplemental analyses discussed Iater
l-5 in my testimony. nxhibit No. 2 illustrates the results of
L6 the Frequency Duration Loss of Load evaluation performed.
1-7 I. THE ATIEIIDED 2019 IRP
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O. Please describe what led to the filing of the
Amended 20L9 IRP.
A. As mentioned in my direct testimony filed in
\Tune 20L9, Idaho Power used the Long-Term Capacity
Expansion ('LTCE") modeling capability of AURORA to produce
Western Electricity Coordinating Council- ('WECC")
optimized portfolios under various future conditions.
Specifically, the AURORA LTCE modeling was performed using
HARVEY, SUPP DI
Idaho Power Company
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1 three natural gas forecasts and four carbon emissions
2 adders, with the Boardman-to-Hemingway transmission line
3 project (*82H') and without.
4 The result was 24 separate portfolios, all with a
5 Valmy Unit 2 shutdown date of 2025, that included varied
5 amounts of nameplate generation additions, creating a
7 diversity of resource mixes. While retiring Valmy Unit 2
8 prior to 2025 was an option available for selection within
9 the logic of the LTCE model, none of the 24 portfolios
10 included an early retirement of this unit. When analyzing
11 the portfolio results as part of a different case filed by
L2 the Company, Idaho Power discovered an issue within the
13 logic of the LTCE modeling in AURORA that warranted further
1,4 investigation.
15 O. What concerns did the Company have with the
L5 logic built into the LTCE modeling of AURORA?
L7 A. It was determined that while optimizing
18 resource build-out portfolios for the WECC region, of which
19 Idaho Power's balancing authority is part, AURORA appeared
20 to be modifying the resource timing of the Company's
2L resources to the benefit of the WECC. While optimizing and
22 reducing costs for the WECC region, the Company was
23 concerned that the results did not reflect the least cost
24 portfolio for Idaho Power and its customers.
HARVEY, SUPP DI
Idaho Power Company
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a. How did the Company address this issue with
the LTCE modeling logic?
A. To ensure the final preferred portfolio was
optimized for Idaho Power, the Company manually modified a
subset of the top-performing WECC-optimized portfolios to
arrive at the least-cost, least risk portfolio specific to
fdaho Power. Through this process, the annual level of
reserves on the system was evaluated and resource additions
and retirements were modified to determine if a more
economically optimal result could be achieved. Extra
attention was given to the Jim Bridger Coal Plant
("Bridger") to ensure the shutdown dates of these units
were developed to yield the best possible economic and
reliability outcome for the Company and its customers.
II. SUPPLEMEIITAIJ VAIJM:I IINIT 2 CIJOSITRE AI{AIJYSES
A. Did the manual modification result in any
changes to the Valmy Unit 2 shutdown date of 2025?
A. No. The logic of the capacity e:q>ansion model
allowed Unit 2 to retire Ln 2025 or earlier. In all- 24
LTCE scenarios, Unit 2 did not shut down prior Lo 2025. In
fact, the manual modification resulted in only two changes
to Idaho Power's preferred portfol-io: the removal of a
solar resource no longer available and the shift of demand
response procurement to later in the planning period. There
were no changes associated with any coal-fired generating
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Idaho Power Company
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units within the action plan window; the portfolios
continue to indicate favorable economics associated with
the exit of five of seven units by 2026.
O. Did the Company perform any additional
analyses of the portfolio results to further validate the
Unit 2 2025 shutdown date?
A. Yes. Given the concerns around the LTCE
model's ability to fu11y optimlze for Idaho Power's
specific system, additional analysis was performed to
further validate that year-end 2025 is the optimal exit
date from Valmy Unit 2 for Idaho Power and its customers.
To accomplish this, Idaho Power performed a comprehensive
analysisl to further validate the Unit 2 2025 shutdown date,
comparing the NPV differences between the portfolio costs
of the amended IRP portfolios with a series of alternative
futures, including:
. a Valmy Unit 2 shutdown of 2024 under planning
natural gas and planning CO2 cost assumptions,
. a Valmy Unit 2 shutdown of 2023 under planning
natural gas and planning CO2 cost assumptions,
I The analysis presented in this testimony $ras initially
performed in response to discovery from Commission Staff("Staff") issued in this case. Therefore, the figures
presented herein reflect those provided to parties throughthe discovery process.
HARVEY, SUPP DI
Idaho Power Company
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o a Valmy Unit 2 shutdown of 2024 under planning
natural gas and high CO2 cost assumptions,
. a Valmy Unit 2 shutdown of 2023 under planning
natural gas and high CO2 cost assumptions,
o a Valmy Unit 2 shutdown of 2024 under planning
natural gas and planning CO2 cost assumptions
but without B2H,
o a Valmy Unit 2 shutdown of 2023 under planning
natural gas and planning CO2 cost assumptions
but without B2H,
o a Valmy Unit 2 shutdown of 2024 under planning
natural gas and high cost CO2 assumptions but
without B2H, and
o a Valmy Unit 2 shutdown of 2023 under planning
natural gas and high CO2 cost assumptions but
without B2H.
As can be seen in the results of this analysis,
presented on Exhibit No. L, under seven of the eight
scenarios, the Preferred Portfolio reflected a lower NPV
than the portfolios with an exit of Valmy Unit 2 prior to
2025. Further, in all scenarios, the early exit from Valmy
Unit 2 resulted in a reserve margin deficit in at least one
year prior Lo 2025 without available capacity from Unit 2.
Planning margin, a commonly-used North American Electric
Reliability Corporation reliability indicator (M-1 Reserve
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Idaho Power Company
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l- Margin), is used to ensure reliable system operation in the
2 future and is intended to account for NERC reliability
3 requirements2, Ioad variability and loss of system elements
4 that may reduce the capability of existing generation
5 resources to serve demand.
5 Q. You mentioned earlier that the IRP analyzed
7 three different gas price forecasts and four potential
8 carbon adders. why did the Company only analyze a subset of
9 these futures in the current analysis?
l-0 A. The subset of future scenari-os modeled in this
11 case appropriately tests the viability of earlier shutdown
L2 dates for Valmy Unit 2 because the scenarios apply
l-3 conditions under which it would be most beneficial to
1,4 accelerate the retirement of a coal unit, i.e. scenarios in
15 which the cost of a different fuel (natural gas) is Iow,
15 and the cost of running coal facilities is highest due to
1,7 the high CO2 cost assumptions. Therefore, if it is not
18 beneficial to accelerate the exit from Valmy Unit 2 under
L9 these scenarios, it is highly unlikely that a different
20 modeled future would yield a different result.
2L a. what is the NPv difference between the cost of
22 the Preferred Portfolio and the portfolios under planning
23 natural gas and planning CO2 cost assumptions and with B2H?
HARVEY, SUPP DI
Idaho Power Company
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2 BAL-OO2-WECC-1
1 A. As can be seen on Line 1 of Exhibit No. l, the
2 NPV of the Preferred Portfolio is $758,000 less than the
3 NPv of a portfolio using a Valmy Unit 2 shutdown of 2024
4 and $l-,016,000 less than a portfolio using a Valmy Unit 2
5 shutdown of 2023 under planning natural gas and planning
6 CO2 assumptions and including B2H.
7 Q. What is the NPV difference between the cost of
8 the Preferred Portfolio and the portfolios under planning
9 natural gas and high Co2 cost assumptions and with B2H?
LO A. The NPV of the Preferred Portfolio is
l-1- $1,107,000 less than the NPV of a portfolio using a Valmy
L2 Unit 2 shutdown of 2024 and $724,000 less than a portfolio
L3 using a Valmy Unit 2 shutdown of 2023 under planning
1-4 naturaf gas and high CO2 assumptions and including B2H.
15 These results can be found on Line 2 of Exhibit No. l-.
15 O. Excluding B2H, what is the NPV difference
L7 between the cost of the Preferred Portfolio and the
18 portfolios under planning natural gas and planning CO2 cost
1-9 assumptions?
20 A. The NPV of the Preferred Portfolio is $941-,000
2L less than the NPV of a portfolio using a Valmy Unit 2
22 shutdown of 2024 under planning natural gas and planning
23 CO2 assumptions but without B2H, while the NPV of the
24 Preferred Portfolio is $538,000 greater than a portfolio
25 using a Va1my Unit 2 shutdown of 2023, as presented on Line
HARVEY, SUPP DI
Idaho Power Company
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l- 3 of Exhibit No. l-. It should be noted, however, that the
2 cost of mitigating the reliability violations created by
3 the shutdown of Unit 2 in 2023 under this scenario totaled
4 approximately $40 million under the planning gas, planning
5 carbon scenario, as detailed later in my testimony.
5 Q. Excluding B2H, what is the NPV difference
7 between the cost of the Preferred Portfolio and the
8 portfolios under planning natural gas and high CO2 cost
9 assumptions?
L0 A. The NPV of the Preferred Portfolio is
l-l- $1,1-03,000 less than the NPV of a portfolio using a Valmy
L2 Unit 2 shutdown of 2024 and $223,000 Iess than a portfolio
13 using a Valmy Unit 2 shutdown of 2023 under planning
1-4 natural gas and high CO2 assumptions but excluding B2H.
15 Please see Exhibit No. 1, Line 4 for the detailed results.
l-5 a. You indicated that in aI1 scenarios the early
L7 exit from Valmy Unit 2 resulted in reliability violations
18 in at least one year prior to 2025 without the available
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capacity from Unit 2. What
planning margin?
was the resulting impact to the
A. In a1l eight of the scenarios described
earlier and performed as part of the comprehensive LTCE
analysis, a planning margin shortfall occurred in either
2024 or 2025. A drop below the 15 percent planning margin
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Idaho Power Company
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results in the need to delay the exit of a Bridger coal
unit or accelerate the need for another resource.
a. Did Idaho Power perform any further analysis
to address the planning margin shortfall?
A. Yes. Idaho Power performed an additional
analysis to ensure that a more optimal result could not be
attained by accelerating the shutdown of Valmy Unit 2 and
addressing the resulting planning margin shortfall with a
different resource decision.
a. Please describe this analysis.
A. The Company utilized a delay in the exit of a
Bridger coal unit to address the planning shortfatl created
by the early exit of Valmy Unit 2 prior to 2025. Because
the reliability violations occurred prior to 2026, Idaho
Power did not differentiate between the scenarios that
included B2H and those that do not, as the modeling changes
specific to the timing differences associated with exiting
from Valmy Unit 2 prior Lo 2025 and delaying the first
Bridger unit exit are captured prior to the in-service date
of B2H.
a. What were the
mitigation analysis?
A. The results of
results of the reliability
the reliability mitigation
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As can be seen, a delay in the
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exit of a Bridger coal unit
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Idaho Power Company
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l- to accelerate the exit of Valmy unit 2 resulted in
2 significantly higher portfolio costs. The NPV of the
3 Preferred Portfolio is $29.22 million less than the NPV of
4 a portfolio using a Valmy Unit 2 shutdown of 2024 and
5 #29.43 million less than a portfolio using a Valmy Unit 2
5 shutdown of 2023 under planning natural gas and planning
7 CO2 cost assumptions. Under planning natural gas and high
I CO2 cost assumptions, the NPV of the Preferred Portfolio is
9 $26.24 million less than the NPV of a portfolio using a
10 Valmy Unit 2 shutdown of 2024 and $25.44 million less than
l-1 a portfolio using a Valmy Unit 2 shutdown of 2023.
L2 a. Did the Company evaluate the construction of
l-3 another resource rather than the delay of a Bridger unit
L4 exit to mitigate the reliability issues caused by an early
1-5 Valmy Unit 2 exit?
1"5 A. Yes. However, because the planning margin
17 shortfall occurs as early as 2024, resource procurement
18 rules and construction timeframes would prevent the
l-9 addition of any supply-side resources in that amount of
20 time. A movement in the exit date from a Bridger unit is
2L the next best option for meeting load if valmy Unit 2 was
22 shutdown prior lo 2025.
23 O. To what resource procurement rules is Idaho
24 Power subject?
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Idaho Power Company
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A. Under the Oregon rules governing Resource
Procurement for Electric Utilities, which are applicable to
Idaho Power in its Idaho jurisdiction, the Company
estimates that the entire process to procure and construct
additional generation would take a minimum of approximately
5 years. In Case No. fPC-E-l-0-03, the Idaho Commission
directed Idaho Power in Order No. 32745 to comply with
resource procurement rules applicable in its Oregon service
area, "should the Company coilrmence an RFP process for a new
supply-side resource prior to the devetopment of Idaho-
specific RFP guidelines. " These rules would hlnder the
Company's abil-ity to have availabLe a supply-side resource
prior to 2024. Consequently, the Company does not believe
acquisition of an additional supply-side resource is a
practical option given the timing of the resource
deficiency.
A. Did the Company consider demand response as a
viable option for mitigating the reliability impacts of an
early Valmy Unit 2 shutdown?
A. Demand response is considered a resource that
is able to meet peak demand and, as such, is factored into
Idaho Power's 15 percent peak planning margin. However,
demand response is not a resource able to broadly address
reliability constraints or reserve requirements.
Contingency events can occur any time throughout the year.
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Idaho Power Company
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1 The 390 MW of demand response on Idaho Power's system i-s
2 onJ-y available in the summer during specific hours.
3 Q. How did the Company determine specifically
4 when the reserve margin deficits occurred?
5 A. Idaho Power performed a Freguency Duration
5 Loss of Load evaluation to determine when resources are
Z required to address reserve margin deficits. The evaluation
8 inctuded 100 iterations of the year 2025 from the preferred
9 portfolio with a Valmy Unit 2 exit modeled in 2023. The
10 results are included as Exhibit No. 2 to my testimony with
l-1 the hours in which current demand response programs are
12 available shaded. As can be seen, a large number of the
l-3 loss of toad events occur during non-peak hours for which
L4 current demand response programs are unavailable.
15 O. Please summarize the results of the additional
l-5 validation performed by the Company that the economic
1-7 retirement date of Valmy Unit 2 Ls December 31-, 2025.
18 A. The additional comprehensive analysis
L9 performed by Idaho Power to validate the Unit 2 shutdown
20 date compared the net present value differences between the
21, portfolio costs of the amended IRP portfolios with a series
22 of alternative futures, and further resolved any planning
23 margin shortfalls created by a shutdown of Valmy Unit 2
24 before 2025 by delaying the exit of a Bridger unit. Under
25 seven of the eight scenarios, the Preferred Portfolio
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Idaho Power Company
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reflected a lower NPV than the portfolios with the exit of
Valmy Unit 2 prior Lo 2025. In addition, in all eight
scenarios, the early exit from Valmy Unit 2 resulted in
reliability violations without available capacity from Unit
2. Lastly, delaying the exit of a Bridger unit to meet the
planning margin shortfalls resulted in significantly higher
portfolio costs than the Preferred Portfolio.
ITI. CONCIJUSION
o What conclusions can be drawn from these
10 results?
A. As directed by the Commission in Order No.
34349, Idaho Power performed Unit 2 closure analyses as
part of the 2019 IRP process. The additional analyses
performed using the results of the Amended 2019 IRP
validate the conclusions found in the initial analysis
presented in my direct testimony. The results indicate
that, under the broad range of modeled scenarios, an exit
from Unit 2 prior Lo 2025 would result in higher costs for
customers and would cause system reliability concerns. The
analyses validate year-end 2025 as the appropriate end-of-
life date for Valmy Unit 2.
a. Does this complete your testimony?
A. Yes, it does.
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HARVEY, SUPP DI
Idaho Power Company
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1 DECITARATION OF TOM HAR\IEY
2 T, Tom Harvey, declare under penalty of perjury
3 under the laws of the state of ldaho:
4 L. My name is Tom Harvey. I am employed by
5 Idaho Power Company as the Vice President of Power Supply
5 in the Power Supply Department.
7 2. on behalf of Idaho Power, I present this
8 pre-fi1ed supplemental direct testimony and Exhibit Nos. l--
9 2 in this matter.
l-O 3. To the best of my knowledge, my pre-filed
11 supplemental direct testimony and exhibits are true and
12 accurate.
l-3 I hereby declare that the above statement is true to
L4 the best of my knowtedge and belief, and that I understand
15 it is made for use as evidence before the ldaho Public
1,6 Utilities Commission and is subject to penalty for perjury.
L7 SIGNED this 22nd day of May 2020, at Boise, Idaho.
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Tom ,J. Harvey
HARVEY, SUPP DI
Idaho Power Company
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BEFORE THE
IDAHO PUBLIC UTILITIES GOMMISSION
cAsE NO. IPC-E-19-19
IDAHO POWER COMPANY
HARVEY, SUPP DI
TESTIMONY
EXHIBIT NO. 1
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BEFORE THE
IDAHO PUBLIG UTILITIES COMMISSION
GASE NO, IPC.E.19.18
IDAHO POWER COMPANY
HARVEY, SUPP DI
TESTIMONY
EXHIBIT NO.2
FREQUENCY DURATION LOSS OF LOAD EVALUATION
Prcfened Porttolio with a Valmy Unit 2 Exit in 2023
Year:2025
LOL Frequensy by Hour of Day
Hour Count
(Hourc|
LOt
Percentate
by Hour
l:fi)AM 4 2.!yt$
2:fllAM 5 3.6,6
3:00 AM 2 1.4%
4:00 AM 1 o.7%
10:00 AM 2 1.4%
11:00 AM 5 4.?%
12:00 PM 6 4.3%
1:00 PM 5 3.6t6
2:l!0 PM 6 4.rr$
3:00 PM 6 4.?%
rl:00 PM 11 8.OYo
5:00 PM L2 8.7%
6:00 PM L2 8.VYr
7:00 PM 9 6.5r
E:00 PM 9 6.5t6
9:fit PM 13 9.4%
10:00 PM 11 8.9?6
l1:il!PM 1t 8.0%
12:00 AM 7 5.1%
Tota!138 100.0%
Exhibit No. 2
Case No. IPC-E-19-18
T. Harvey Supp Dl
Page 1 of 1
LISA D. NORDSTROM (lSB No. 5733)
ldaho Power Company
1221\Nest ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
I no rd stro m @ i da h opower. co m
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILlT!ES COMMISSION
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER FOR A VALIDATED
ECONOMIC CLOSURE DATE FOR NORTH
VALMY POWER PLANT UNIT 2
CASE NO. |PC-E-19-18
IDAHO POWER COMPANY'S
CERT!FICATE OF SERVICE
I HEREBY CERTIFY that on this 22nd day of May 2020,1 served a true and correct
copy of the within and foregoing IDAHO POWER COMPANY'S SUPPLEMENTAL
DIRECT TESTIMONY OF TOM HARVEY upon the following named parties by the
method indicated below, and addressed to the following:
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Commission Staff
Edward Jewell
Deputy Attomey General
ldaho Public Utilities Commission
472 West Washington (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
Hand Delivered
_U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
IDAHO POWER COMPANY'S CERTIFICATE OF SERVICE - 1
Idaho Conservation League
Benjamin J. Otto
ldaho Conservation League
710 North 6s Street
Boise, ldaho 83702
U.S. Mai!
_Overnight Mail
_FAXX Email [e-mail]
lndustrial Customers of ldaho Power
Peter J. Richardson
RICHARDSON ADAMS, PLLC
515 North 27h Street (83702)
P.O. Box 7218
Boise, ldaho 83707
_Hand Delivered
_U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
Dr. Don Reading
6070 Hill Road
Boise, ldaho 83703
_Hand Delivered
_U.S. Mail
Overnight Mail
_FAXX Email [e-mail]
J"..22-zH,a--
Sandra D. Holmes
Lega! Adm inistrative Assistant
IDAHO POWER COMPANY'S CERTIFICATE OF SERVICE - 2