20200702Motion to Suspend Procedural Schedule.pdf

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An IOACORP Companv
July 1 ,2020
VIA ELECTRONIC FILING
Diane Hanian, Secretary
Idaho Public Utilities Commission
11331 W. Chinden Boulevard
Building 8, Suite 201-A
Boise, ldaho 83714
Re: Case No. IPC-E-19-18
Validation of North Valmy Power Plant Unit 2 Closure in2025
ldaho Power Company's Motion to Suspend Procedural Schedule
Dear Ms. Hanian:
Attached for electronic filing in the above matter is ldaho Power Company's Motion
to Suspend Procedural Schedule.
lf you have any questions about the enclosed documents, please do not hesitate to
contact me.
Very truly yours,
LISA D. NORDSTROTi
Lead Counsel
[e-mail]
LDN:sdh
Attachment
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Lisa D. Nordstrom
LISA D. NORDSTROM (lSB No. 5733)
ldaho Power Company
1221 West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
I [e-mail]
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER'S
APPLICATION FOR A VALIDATED
ECONOMIC CLOSURE DATE FOR
NORTH VALMY POWER PLANT UNIT 2
CASE NO. IPC-E-I9-18
IDAHO POWER COMPANY'S
MOTION TO SUSPEND
PROCEDURAL SCHEDULE
Pursuant to Procedural Rule 056, ldaho Power Company (ldaho Power or
Company) submits this Motion to Suspend the Procedural Schedule to the ldaho Public
Utilities Commission (Commission) in the above-captioned case. ldaho Power seeks this
suspension to allow time for ldaho Power to conduct a comprehensive review of the
Company's lntegrated Resource Plan (lRP) modeling. As described in more detail below,
ldaho Power has experienced several complications in its efforts to implement a new
modeling approach used to develop the lRP and subsequent analyses performed in this
proceeding, While ldaho Power has previously supplemented the initial filing, and has
provided further corrections and revisions, the Company has continued to identify
additional issues that require additional diligence to ensure accuracy of certain aspects
of the IRP analysis and resulting analyses performed with respectto the economic closure
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IDAHO POWER COMPANY'S MOTION TO SUSPEND PROCEDURAL SCHEDULE -1
of Valmy. For this reason, ldaho Power has initiated a systematic audit of the Company's
IRP modeling in consultation with ldaho Powe/s internal audit division, to ensure the
reliability of the IRP's results. Idaho Power commits to concluding this audit and
proposing a revised proceduralschedule in this proceeding by no laterthan July 31 ,2020.
ldaho Power has consulted with the Commission Staff and they do not oppose the
Company's requested suspension.
I. MOTION
1. On June 27,2019, ldaho Power filed an Application requesting a
Commission order acknowledging that the Company has sufficiently validated the
economic retirement date of the North Valmy power plant Unit 2 as December 31,2025,
as directed by the Commission in Order No. 34349.1
2. On July 19,2019, the Company filed a letter in its 2019 lRP docket2 stating
that it needed additionaltime to perform modeling and analysis which would likely impact
the economic analysis conducted in this case.
3. On August 13, 2019, the Commission issued a Notice of Application stating
that no further action would be taken on ldaho Power's Application until the Company
submitted its amended 2019 lRP.
4. ldaho Power submitted its amended 2019 IRP on January 31 ,2020.
5. The Commission issued a Notice of Modified Procedure establishing
comment deadlines in Order No. 34672, on May 19,2020. To facilitate the review of the
1 ln the Matter of the Application of ldaho Power Company for Authority to lncrcase /fs Rates for Electic
Serurbe to Recover Cosfs Associated with the North Valmy Power Plant, Case No. IPC-E-19-08, Order
No. 34349 at 4-5 (May 31, 2019).
2 ln the Matter of ldaho Power Company's 2019 lntegnted Resource Plan, Case No. IPC-E-19-19.
IDAHO POWER COMPANY'S MOTION TO SUSPEND PROCEDURAL SCHEDULE-2
Company's request, Idaho Power filed supplemental direct testimony on May 22,2020,
that updated the analyses performed since the Application was submifted.
6. ldaho Power filed its original lRP on June 28, 2019. At the
recommendation of ldaho Power's lntegrated Resource Planning Advisory Council, ldaho
Poweds IRP used a Capacity Expansion Modeling (CEM) approach to build and optimize
alternative portfolios. Specifically, the Company employed the Long-Term Capacity
Expansion (LTCE) tool in AURORA, which allows for portfolios to dynamically adjust
based on the impacts of new capacity additions and other factors.
7. Subsequent to this initial filing, the Company identified an issue related to
the CEM approach, which required the Company to perform additional modeling to
confirm the accuracy of the IRP's conclusions. The LTCE modelhad optimized portfolios
for the entire Western Electricity Coordinating Council WECC) region, rather than for
ldaho Power's system in particular. For this reason, on July 19, 2019, ldaho Power
notified the Commission of the need to perform supplemental analysis to ensure that the
IRP yielded a least-cost, least-risk solution specific to ldaho Power's service area, and
asked thatthe Commission refrain from adopting a proceduralschedule untilan amended
IRP could be filed.
8. ldaho Power filed its Amended IRP on January 31, 2020. This Amended
IRP identified eight modifications to the original !RP,3 and implemented a new manual
modeling step to ensure that the LTCE results yielded the best possible economic and
reliabili$ outcomes for ldaho Power's system and customers. lmportantly, these changes
resulted in only two modifications to the preferred portfolio's near-term 2}19-2026Action
3 See Cover Letter to Amended 2019 lRP, Case No. IPC-E-19-19 , at 1-2 (Jan. 31, 2020) (setting out the
eight specific changes).
IDAHO POWER COMPANY'S MOTION TO SUSPEND PROCEDURAL SCHEDULE -3
Plan: (1) the removal of the Franklin Solar facility, and (2) the addition of 5 megawatts
(MW) of demand response in 2031, rather than in 2026.
9. Subsequently, on May 29,2020, the Company provided a correction to the
IRP related to the costs associated with the Jim Bridger Power Plant (Bridger). The need
for this correction was identified while preparing a response to a discovery request in a
separate docket before the ldaho Public Utilities Commission. While reviewing the
Company's modeling outputs, it became clear that certain Bridger-related costs had
inadvertently been excluded from portfolios in which a Bridger unit was exited prior to the
existing shutdown date of 2034. This conection required the replacement of seven pages
in the Company's Amended IRP but did not impact the Company's recommendation of
the Prefened Portfolio-which remained the least-cost, least-risk solution to serve
customers.
10. ln recent weeks, the Company has identified necessary changes in the
Amended lRP. These newly discovered issues have prompted ldaho Power to initiate a
comprehensive review of its Amended !RP. The review is being performed by a
multidisciplinary team of Company subject matter experts (!RP Review Team) including
participants from the Company's internal audit division.
11. This new internal review and audit process is carefully analyzing all aspects
of the Company's modeling. This process involves the following general steps:
o First, the IRP Review Team is examining how specific inputs-such as
forecast data, operational constraints, and financial assumptions-are
developed for inclusion in the AURORA model.
o Secon4 the IRP Review Team is investigating how inputs are adjusted or
converted for incorporation into the AURORA model and that the inputs
were correctly entered. For instance, some inputs must be converted from
one type of measurement to another in order to accommodate the AURORA
IDAHO POWER COMPANY'S MOTION TO SUSPEND PROCEDURAL SCHEDULE -4
program, and the review team is checking to ensure that all such
conversions were performed correctly.
o Third, the IRP Review Team is analyzing how the AURORA model handles
the various inputs within the model itself (i.e., the modeling logic), to make
sure that the model is using the proper data inputs in the proper processes
and that the modeling settings and options are suitably selected.
o Fourth, the review team is examining the consistency and accuracy of the
AURORA model's outputs, to ensure that the model produces logical and
consistent results.
The Company anticipates that this review and audit process will take approximately 2-3
weeks.
12. Once ldaho Power's internal review and audit is complete-and no later
than July 31, 2020-the Company will provide a status update to the Commission and
will propose a corresponding new procedural schedule. Until the results of this analysis
are complete, however, the Company is unable to accurately forecast the time necessary
to provide any revised modeling and analysis that may be required. As a result, ldaho
Power respectfully requests that the procedural schedule be suspended until the
Company has provided a further update by no later than July 31 , Z0ZO.
t!. coNcLustoN
ldaho Power has commenced a comprehensive review and audit of its Amended
2019 IRP modeling, and asks that the Commission suspend the procedural schedule in
this docket until the Company provides a further update by no later than July 31 ,2020.
DATED at Boise, ldaho, this 13tday of July 2020.
X,^- !.fl^rut^-*,
LISA D. NORDSTROM
Attorney for ldaho Power Company
IDAHO POWER COMPANY'S MOTION TO SUSPEND PROCEDURAL SCHEDULE -5
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 1st day of July 2020 I served a true and conect
copy of IDAHO POWER COMPANY'S MOTION TO SUSPEND SCHEDULE upon the
following named parties by the method indicated below, and addressed to the following:
Commission Staff
Edward Jewell
Deputy Attorney General
ldaho Public Utilities Commission
472 West Washington (83702)
P.O. Box 83720
Boise, ldaho 83720-0074
ldaho ConserYation League
Benjamin J. Ofto
ldaho Conservation League
710 North 6th Street
Boise, ldaho 83702
lndustrial Customert of ldaho Power
Peter J. Richardson
RICHARDSON ADAMS, PLLC
515 North 27s Street (83702)
P.O. Box 7218
Boise, ldaho 83707
Dr. Don Reading
6070 Hill Road
Boise, Idaho 83703
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Sandra D. Holmes
Leg al Adm inistrative Assistant
IDAHO POWER COMPANY'S MOTION TO SUSPEND PROCEDURAL SCHEDULE 6