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Home My WebLink About20241206IPC to Staff 1-3.pdf wmIQAW POWER. MEGAN GOICOECHEA ALLEN Corporate Counsel meloicoecheaallen(a�idahopower.com RECEIVED Friday, December 6, 2024 IDAHO PUBLIC December 6, 2024 UTILITIES COMMISSION VIA ELECTRONIC MAIL Commission Secretary Idaho Public Utilities Commission 11331 West Chinden Blvd., Building 8 Suite 201-A Boise, Idaho 83714 Re: Case No. IPC-E-24-37 Idaho Power Company's Application for Modifications to the Company's Irrigation Demand Response Program, Schedule 23 and Commercial & Industrial Demand Response Program, Schedule 82 Dear Commission Secretary: Attached for electronic filing is Idaho Power Company's Response to the First Production Request of the Commission to Idaho Power Company in the above-entitled matter. If you have any questions about the attached documents, please do not hesitate to contact me. Very truly yours, �-/Owr T I,0%4Uq. Mm Megan Goicoechea Allen MAG:sg Enclosures MEGAN GOICOECHEA ALLEN (ISB No. 7623) LISA D. NORDSTROM (ISB No. 5733) Idaho Power Company 1221 West Idaho Street (83702) P.O. Box 70 Boise, Idaho 83707 Telephone: (208) 388-2664 Facsimile: (208) 388-6936 mgoicoecheaallen(a�idahopower.com Inordstrom(c)_idahoppower.com Attorneys for Idaho Power Company BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF IDAHO POWER ) COMPANY'S APPLICATION FOR ) CASE NO. IPC-E-24-37 MODIFICATIONS TO THE COMPANY'S ) IRRIGATION DEMAND RESPONSE ) IDAHO POWER COMPANY'S PROGRAM, SCHEDULE 23 AND ) RESPONSE TO THE FIRST COMMERCIAL & INDUSTRIAL DEMAND ) PRODUCTION REQUEST OF RESPONSE PROGRAM, SCHEDULE 82 ) THE COMMISSION STAFF TO IDAHO POWER COMPANY COMES NOW, Idaho Power Company ("Idaho Power" or "Company"), and in response to the First Production Request of the Commission Staff ("Commission" or "Staff") dated November 26, 2024, herewith submits the following information: IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY- 1 REQUEST FOR PRODUCTION NO. 1: Please provide workpapers supporting the cost effectiveness of the Company's proposed changes in excel format with formulas intact and enabled. RESPONSE TO REQUEST FOR PRODUCTION NO. 1: See the attached "Response to Staff Request No. 1 - Attachment.xlsx". The workbook contains information supporting cost-effectiveness analyses for the following proposed changes: • Irrigation Peak Rewards ("IPR") variable payment on the fourth event • IPR early interruption option o The workbook contains details on how the price level is set. The Company expects minimal costs and set the incentive level for this proposal to ensure cost effectiveness based on the modeled analysis but is not yet able to conduct a standard analysis on this change. • Flex Peak variable payment on the fourth event • Flex Peak incentive for automation of systems o The Company has provided a worksheet showing the impact on overall program cost effectiveness as well as a supplemental sheet detailing the cost effectiveness on a per-system basis. o In preparation of the Company's response to discovery, it identified the actual increase to the program cost per kilowatt ("kW") would be $0.35, rather than the $0.08 cited in paragraph 28 of the Company's Application. The Company regrets the error in the IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY- 2 Application and notes the program would still remain cost-effective when accounting for the $0.35 impact. • Flex Peak baseline adjustment cap modification o The workbook contains the Company's analysis of the impacts if the proposed baseline modification had been applied to program year 2023. The overall cost per kW would have increased from $36.40 to $36.82. The program would still be cost effective with this increase. The following proposals are not expected to have a significant impact on cost- effectiveness: • IPR group C clarifying language; • IPR emergency dispatch clarifying language; • Flex Peak day-of load adjustment review process; or • Flex Peak nomination flexibility. The response to this Request is sponsored by Billie McWinn, Energy Efficiency Program and Customer Analysis Leader, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY- 3 REQUEST FOR PRODUCTION NO. 2: Please describe the expected incremental capacity potential and costs associated with the proposed Peak Rewards early interruption option. RESPONSE TO REQUEST FOR PRODUCTION NO. 2: While the Company is not able to predict incremental participation and capacity with precision, it is generally aware— based on customer feedback—that some current participants may change to this option and new additional participants may also elect this option. For context, prior to the 2022 irrigation season, the Company had approximately 300 megawatts ("MW") of capacity in the Irrigation Peak Rewards program. After program modifications where later hours are now required, the program has around 40 MW less enrolled capacity. Based on a survey sent in 2023, the Company understands that some participants have elected not to participate because of the later hours of the program and some participants indicated they would participate and with more locations under the proposed 9 pm, early interruption, option. In its analysis, the Company modeled the early interruption option to bring in an incremental 20 MW of new capacity. The analysis also assumed 20 MW of existing participation switching from the standard option to the early interruption option. The Company does not anticipate incurring a material amount of costs associated with launching, accommodating, and marketing the option. Participants under this option will be incented at approximately 50 percent of the amount that standard-option participants are incented. The incentive amount was set in a manner that will keep the program cost per kW equal to or less than the cost prior to offering the option. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY-4 The response to this Request is sponsored by Billie McWinn, Energy Efficiency Program and Customer Analysis Leader, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY- 5 REQUEST FOR PRODUCTION NO. 3: Please provide the analysis conducted by the Company supporting the underestimated baselines caused by the current baseline cap methodology referenced in the Application at 10. RESPONSE TO REQUEST FOR PRODUCTION NO. 3: See attached "Response to Staff Request No. 3 -Attachment.xlsx". The workbook contains the analysis conducted by the Company on the underestimation of the baselines caused by the current baseline cap methodology. The response to this Request is sponsored by Billie McWinn, Energy Efficiency Program and Customer Analysis Leader, Idaho Power Company. Respectfully submitted this 6th day of December 2024. n I f9CC� l,l�J(l�vl. MEGAN GOICOECHEA ALLEN Attorney for Idaho Power Company IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY- 6 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 6th day of December 2024, 1 served a true and correct copy of Idaho Power Company's Response to the First Production Request of the Commission Staff to Idaho Power upon the following named parties by the method indicated below, and addressed to the following: Commission Staff Hand Delivered Michael Duval U.S. Mail Deputy Attorney General Overnight Mail Idaho Public Utilities Commission FAX 11331 W. Chinden Blvd., Bldg No. 8 FTP Site Suite 201-A (83714) X Email Michael.Duval(c�puc.idaho.gov PO Box 83720 Boise, ID 83720-0074 Stacy Gust Regulatory Administrative Assistant IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY- 7 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-24-37 IDAHO POWER COMPANY REQUEST NO. 1 ATTACHMENT SEE ATTACHED SPREADSHEET BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-24-37 IDAHO POWER COMPANY REQUEST NO. 3 ATTACHMENT SEE ATTACHED SPREADSHEET