20210511IPC to ICIP 1-4.pdf

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McDOWELL RACXNER GIBSON PC
419 SW I I'h Ave, Suite 400 | Portland, OR 97205
Aonru LoulxevM(W)Wffim
Xam@ngla r.srt
May 1 1,2021
VIA ELECTRONIC FILING
Jan Noriyuki, Secretary
ldaho Public Utilities Commission
11331 W Chinden Blvd., Bldg 8,
Suite 201-A (83714)
Boise, ldaho 83720-007 4
Case No. IPC-E-21-04
In the Matter of ldaho Power Company's Application for a Determination of 2020
Demand-Side Management Expenses as Prudently lncurred
Dear Ms. Noriyuki:
Attached for electronic filing, pursuant to Order No. 34781, is ldaho Power Company's
Response to the First Production Request of the Industrial Customers of ldaho Power, Nos. 1
through 4.
lf you have any questions about the attached documents, please do not hesitate to
contact me.
Sincerely,
Adam Lowney
cc: IPC-E-21-04 Service List (via email)
Attachments
main: 503 595 3922 | fax: [phone] | www.mrg-law.com
419 SW llthAve, Suite 400 | Portland, Oregon 97205-2605
ADAM LOWNEY (lSB No.10456)
McDowell Rackner Gibson PC
419 SW 11th Avenue, Suite 400
Portland, OR 97205
Telephone: [phone]
Facsimile: [phone]
[e-mail]
LISA D. NORDSTROM (lSB No. 5733)
ldaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
I no rd strom @ id a h opowe r. com
Attorneys for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE IDAHO POWER
COMPANY'S APPLICATION FOR A
DETERMINATION OF 2O2O DEMAND-SIDE
MANAGEMENT EXPENSES AS
PRUDENTLY INCURRED.
CASE NO. !PC-E-?1-0/}
IDAHO POWER COMPANY'S
RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
THE INDUSTRIAL CUSTOMERS
OF IDAHO POWER
COMES NOW, ldaho Power Company ("ldaho Powe/' or "Company"), and in
response to the First Production Request of the lndustrial Customers of ldaho Power
("lClP") dated April 20, 2021, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
INDUSTRIAL CUSTOMERS OF IDAHO PO\A'ER - 1
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REQUEST NO. 1:
Please provide copies of allof the company's responses to data requests from
the IPUC Staff (or any other party) in this matter. Please include responses to
informal as well as formal requests and oral as well as wriften requests.
RESPONSE TO REQUEST NO. 1:
As a matter of course, copies of ldaho Power's responses to all parties' discovery
requests in this case will be provided to lClP. ldaho Power has provided no other written
responses to Staff or other parties.
The response to this Request is sponsored by Sandra Holmes, Legal
Administrative Assistant, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
INDUSTRIAL CUSTOMERS OF IDAHO POWER.2
REQUEST NO. 2:
The Company's 2020 Annual Demand-Side Management Report,
Supplement 1, Cost Effectiveness, page 4 states; "Because of this timing, updated
DSM alternate cosfs based on the 2017 IRP were used for 2021 program planning
and will be used to evaluate the 2021 cost effectiveness."
a. Does this mean that all the "2021 cost-effectiveness" for DSM
expenditures will be evaluated using the Company's cost data that are
at least four years old?
b. Have the costs incurred by ldaho Powerfor electrical energy and demand
changed over the past four years? lf the answer is in the affirmative
please identify the extents of such changes explain fully which power cost
changes have occurred over this time period.
c. Does the Company believe that the cost-effectiveness of some of their
DSM and DR programs would be different with current power cost
estimates? If the answer is yes please explain fu!!y.
RESPONSE TO REQUEST NO. 2:
a. Yes. The process has been relied upon by ldaho Power's Customer
Relations and Energy Efficiency department since 2014 and has been
discussed with and aligned on with members of the Company's Energy
Efficiency Advisory Group ("EEAG"). To determine cost-effectiveness of
its energy efficiency programs, the Company uses the demand-side
management ("DSM") alternate costs from the most recently
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
]NDUSTRIAL CUSTOMERS OF IDAHO PO\A'ER.3
acknowledged lntegrated Resource PIan ("lRP") that were relied upon for
program year budgeting and program planning purposes.
b. Yes. Energy-related costs incurred by ldaho Power have changed over
the past four years. The attachment to this response includes actual
system level net power supply costs by FERC account, as tracked
through the Company's annual Power Cost Adjustment mechanism, for
calendar years 2017 through 2020. As a result of ldaho Power's
generation fleet being predominately hydroelectric based, it is typical for
power supply costs to vary from one year to the next as streamflow
conditions change. Regarding costs associated with demand, ldaho
Power has not added any new Company-owned capacity to the system
over the time period.
c. Yes. The DSM alternate costs are an output from the IRP process that
takes into account power supply costs and other resource options
identified during the analysis. ldaho Power continues to monitor the cost-
effectiveness of its programs with both the current and future DSM
alternate costs in mind. For example, the proposed changes to the
Commercial & lndustrial Energy Efficiency Program this year were
evaluated to ensure they would still be cost-effective with the 2019 IRP
DSM alternate costs. However, while some measures or programs may
not be cost-effective under the 2019 IRP DSM alternate costs in the
future, other factors such as updated savings, costs assumptions, and
code changes also impact measure or program cost-effectiveness. The
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
INDUSTRIAL CUSTOMERS OF IDAHO PO\A/ER .4
Company is also evaluating how the 2021 IRP DSM alternate costs will
affect programs and measures.
ldaho Power has committed to keeping the EEAG informed if a program
or measure becomes, or is expected to become, not cost-effective. ldaho
Power doesn't take immediate action to remove a measure, but rather
works with EEAG to ensure that al! possible avenues have been
considered before proposing to sunset a program or measure due to its
cost-effectiveness.
The response to this Request is sponsored by Quentin Nesbitt, Customer
Research & Analysis Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
INDUSTRIAL CUSTOMERS OF IDAHO POWER.5
REQUEST NO. 3:
ln ldaho Power's April 8, 2021 IRPAC meeting the Company indicated that
there may be some significant changes in ldaho Power's forecast of near-term system
reliability.(https://docs.idahopower.com/pdfs/AboutUs/PlanninqForFuture/irp/2021Na
lmvSpecialStudvUpdatelRPAC.pdO. Slide 18 of the presentation indicates the
'Reliability Hurdle'could be as much as787 MW in 2023 and 862 MW in 2025. Given
the magnitude of the Company's identified capacity deficit inherent in its "Reliability
Hurdles" - when will the Company be using this data to design its demand side
management program? Please explain fully whether it would be prudent for the
Company to use this data to design energy and capacity programs for use in its most
current DSM activities.
RESPONSE TO REQUEST NO. 3:
The values referenced on the slide, included as an attachment to this response,
are the result of the Loss of Load Expectation ("LOLE') analysis to determine ldaho
Power's total reliability need to cover forecasted peak demands. This need can be met
by a combination of transmission imports, new resources, modified/expanded demand
response, or delayed retirements of resources. The Company will be using data from this
reliability analysis to inform resource requirements for the202l lntegrated Resource Plan
("lRP"), which includes an evaluation of demand-side management and traditionalsupply-
side resources. As discussed at the April 8th IRPAC meeting, the Company has
committed to evaluate its demand response programs to determine whether program
changes are needed in advance of the 2022 program year. ldaho Power also presented
how cost-effective energy efficiency is being utilized to reduce the Company's load
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
INDUSTRIAL CUSTOMERS OF IDAHO PO\A/ER - 6
forecast as wellas how additionalenergy efficiency is being ana$zed and modeled in the
2021 IRP prooess.
The response to this Request is sponsored by Jared Hansen, Resource Planning
Leader, ldaho Power Company.
IDAHO PO\AER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
INDUSTRIAL CUSTOMERS OF IDAHO PO\A'ER.7
REQUEST NO.4:
On page 8 of Company witness Pawel Goralski Direct Testimony states;
Three programs had significant increases rn savrngs in 2020 as
compared to 2019: The Commercial & lndustrial ("C&1") Program
Custom Projects option experienced a 33 percent increase due to the
completion of several large long-term projects.
Does ldaho Power anticipate any continued increases of this magnitude in
the Commercial & lndustrial ("C&1") large custom long-term projects tor 2021 or
2022? PIease explain fully.
RESPONSE TO REQUEST NO.4:
It is difficult to forecast the future participation in the Commercial & lndustrial
("C&1") Custom Projects option. ldaho Power currently has projects with estimated
energy savings of 62,000 megawatt-hours ('M\ /h") in the pipeline with
approximately 58,000 MWh expected to be completed in 2021 and 4,000 MWh in
2022. However, ldaho Power may not be apprised of all future projects that will
come through the program in 2021 and beyond.
The response to this Request is sponsored by Quentin Nesbitt, Customer
Research & Analysis Leader, ldaho Power Company.
IDAHO PO\A'ER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
INDUSTRIAL CUSTOMERS OF IDAHO PO\A/ER.8
Respectft,rlly submitted this 11tr day of May 2021.
ADAM LO\ANEY
LISA D. NORDSTROM
Attomeys for ldaho Porrer Company
IDAHO POVI/ER COMPAhIY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
INDUSTRIAL CUSTOMERS OF IDAHO POV\JER - 9
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 11th day of May 2021, I served a true and correct
copy IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO PO\ /ER upon the following
named parties by the method indicated below, and addressed to the following:
Commission Staff
Matt Hunter
Deputy Attorney General
ldaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg No. 8,
Suite 201-A(83714)
PO Box 83720
Boise, lD 83720-0074
ldaho Public Utilities Gommission
Jan Noriyuki, Secretary
11331 W. Chinden Blvd., BIdg 8,
Suite 201-A(83714)
PO Box 83720
Boise, ldaho 83720-007 4
lndustrial Customer of ldaho Power
Peter J. Richardson
RICHARDSON ADAMS, PLLC
515 North 27th Street (83702)
P.O. Box 7218
Boise, ldaho 83707
Dr. Don Reading
6070 Hill Road
Boise, ldaho 83703
ldaho Conservation League
Benjamin J. Otto
710 N.6th Street
Boise, ldaho 83702
City of Boise
Mary Grant
Hand Delivered_U.S. Mail
_Overnight Mail
-FAX
X Email [e-mail]
Hand Delivered
_U.S. Mail
_Overnight Mail
-FAX
X Email [e-mail]
ian. norivuki@puc. idaho.oov
_Hand Delivered
_U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
_Hand Delivered
_U.S. Mail
_Overnight Mail
_FAXX EMAI L dread [e-mail]
Hand Delivered
_U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
Hand Delivered
U.S. Mail
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
INDUSTRIAL CUSTOMERS OF IDAHO PO\A/ER - 1O
Deputy Gity Aftomey
BOISE CITY ATTORNEY'S OFFICE
150 N. Capitol Blvd.
P.O. Box 500
Boise, ldaho 83701-0500
Ovemight Mail
FA)(X Ernail [e-mail]
Bo ise C itvAtto rnelr@ cityofu o ise. o ro
ilA,{*^Til!
Alisha Till, Paralegal
IDAHO POVIJER COMPAIYYS RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
INDUSTRIAL CUSTOMERS OF IDA}IO POVVER - 11
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
GASE NO. IPC-E-21-04
IDAHO POWER COMPANY
ATTACHMENT 1 TO REQUEST NO 2
TO
IDAHO POWER COMPANY'S RESPONSE TO
FIRST PODUCTION REQUEST OF THE
INDUSTRIAL CUSTOMERS OF IDAHO POWER
tPc-E-21-04
Attachment in Reponse to lclP's Request #2b
FERC Account
l, Account 501
for Power, Account 535
Other Fuel, Account 547
Purchased Power (Non-PURPA), Account 555
3rd Party Transmission, Account 555
PURPA, Account 555
Demand Response lncentives, Account 555
us Sales, Account 447
Actual Power Supply Costs by FERC Account
20L7 2018
s
s
S
S
s
s
s
107,893,563
37,667,L68
62,179,755
4,568,399
175,2L6,523
6,993,314
(31,471,509)
LL5,523,97t s
2,450,000 s
17,344,443 s
85,220,479 s
3,602,155 s
t95,39L,544 s
7,L5L,73O s
(71,403,373) s
2019
105,256,965 s
2,100,000 s
5L,276,L09 s
79,404,5L4 s
2,844,842 s
L93,9L9,947 s
6,996,236 s
(91,928,998) s
2020
LL9,677,8!
480,0(
52,749,L|
95,594,3(
4,027,51
2OO,78L,7(
6,533,74
5
s
s
s
s
5
s
$ ?63,037,312 $ 355,280,949 s 349,869,615 $ 4L7.,436,8t
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
GASE NO. IPC-E-21-04
IDAHO POWER COMPANY
ATTACHMENT 2TO REQUEST NO. 3
TO
IDAHO POWER COMPANY'S RESPONSE TO
FIRST PODUCTION REQUEST OF THE
INDUSTRIAL CUSTOMERS OF IDAHO POWER
IPGE-21{4
Attacfimant in Reponsa to lClPs Request fr!
Reliability Hurdle - LOLE Results
With Current DR Program
202S.Reliabllity Need {lmports + New
naeourse$ + New,DR}
(LOLE=0.1days/year)
Assumptions
2022 year-end Valmy 2 exit
2022year-end Bridger unit exit
Addition of Jackpot Solar
,852 Mw
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