20211019IPC to Tidwell 1-3.pdf

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LISA D. NORDSTROM
Lead Gounsel
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October 19,2021
VIA ELECTRONIC FILING
Jan Noriyuki, Secretary
ldaho Public Utilities Gommission
11331 West Chinden Blvd., Building 8
Suite 201-A
Boise, ldaho 83714
Re: Case No. IPC-E-21-21
ln the Matter of the Application of ldaho Power Company's Application to
lnitiate a Multi-Phase Collaborative Process forthe Study of Costs, Benefits,
and Compensation of Net Excess Energy Associated with Customer On-
Site Generation
Dear Ms. Noriyuki:
Aftached for electronic filing, pursuant to Order No. 35058, is ldaho Power
Company's Response to Discovery Request of KikiTidwell in the above entitled mafter.
Due to the voluminous nature of information provided in response to data requests in this
case, the Company is posting the attachments to these requests to the secure FTP site
to allow parties to view the requested information remotely. The login information for the
FTP site will be provided to all parties in a separate email.
lf you have any questions about the attached documents, please do not hesitate
to contact me.
Very truly yours,
Anlo COnPCotnpenv
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Aftachments
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: (208) 388€936
[e-mail]
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION TO INITIATE
A MULT!-PHASE COLLABORATIVE
PROCESS FOR THE STUDY OF COSTS,
BENEFITS, AND COMPENATION OF
NET EXCESS ENERGY ASSOCIATED
WTH CUSTOMER ON.SITE
GENERATION
CASE NO. |PC-E-21-21
IDAHO POWER COMPANY'S
RESPONSE TO DISCOVERY
REQUEST OF KIKI TID\A'ELL
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COMES NOW ldaho Power Company ("ldaho Powef or "Company"), and in
response to the First Discovery Request of Kiki Tidwell dated September 28, 2021,
herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO DISCOVERY REQUEST OF KIKI TIDVI/ELL - 1
REQUEST NO. 1: ldaho Power, in its June 25,2021Application to initiate a study
of the costs, benefits, and Compensation of Net Excess Energy, stated, "To more
accurately assign the appropriate share of fixed costs and unquantified benefits of on-site
generation, in Order No. 34046 the Commission directed the Company to (1) 'undertake
a comprehensive study of fixed costs'and (2) 'initiate a docket to comprehensively study
the costs and benefits of on-site generation on ldaho Power's system, as well as proper
rates and rate design, transitional rates, and related issues of compensation for net
excess energy provided as a resource to the Company."' ... 'the study must use the most
current data possible'...and'the study must be written, so it is understandable to an
average custome/'.
The Company later states in the same application that, 'Further, the Company
believes recommendations to modiff the existing offering should focus on cost-of-service
principles..." Therefore, it is materia! for the Company to disclose how currently specific
costs are allocated to gl!-customer classes through the ratemaking process in a way that
it is understandable to an average customer. I submit a Discovery Request for ldaho
Power to provide this information, including the two separate Microsoft Excelworkbooks
in which they calculate the class cost-of-service model; the Assign Module and the
Functionalized Cost Module.
RESPONSE TO REQUEST NO. 1: Please see the Attachments 1 - 3 provided
for this response.
The Class Cost-of-Service Process Guide is included as Attachment 1. The
Assign Module and Functionalized Cost Module are included in Microsoft Excelformat as
IDAHO POWER COMPANY'S RESPONSE TO DISCOVERY REQUEST OF KIKI TIDWELL.2
Attachment 2 and Attachment 3.1
The response to this Request is sponsored by Paul Goralski, Regulatory
Consultant, ldaho Power Company.
1 The Assign Module and Functionalized Cost Module workbooks provided as Attachments to this response
will not match Larkin Exhibit Nos. 3'1-36 in ldaho Powe/s last general rate case, IPC-E-I1-08, due to a
minor enor found after filing that case. ldaho Power has provided the conected Exce! workbooks which
were also provided in Response to Staffls Request No. 31 as part of Staffs 3rd Production Request in Case
No. IPC-E-11-08.
IDAHO POWER COMPANY'S RESPONSE TO DISCOVERY REQUEST OF KIKI TIDWELL. 3
REQUEST NO. 2: Through ldaho Power's 2021 lntegrated Resource Planning
process, the Company has identified that 900 MWs of additiona! generation resources
are needed to cover increased future loads, a Iarge portion of which is to primarily to cover
the peak loads in late June and early July when irrigators are putting considerable
demand on the system, along with air conditioning demand. Could ldaho Power provide
information as to why this demand from irrigation customers is not assigned to that
customer class? ldaho Power should also provide the costs to ratepayers of other
activities that could materially impact company costs of service, like cloudseeding; where
do those costs get allocated to which customers?
RESPONSE TO REQUEST NO. 2: Idaho Power disagrees with the statement in
Request No. 2 concluding that lrrigation customers are not assigned peak demand costs:
'Could ldaho Power provide information as to why thls demand from irrigation customers
is not assigned to that customer class."
Please see the Company's Response to Request No. 1 which includes Attachment
1 - Class COS Process Guide describing how the cost-of-service study allocates fixed
generation costs associated with serving peak load using an average of the three
coincident peak demands ("3CP') occurring in June, July, and August. This method of
allocation isolates the costs associated with peaking resources and allocates those costs
according to the load that is causing the investment.
While some preliminary assumptions of ldaho Power's 2021 lntegrated Resource
Plan ("lRP") have been shared with the Integrated Resource Plan Advisory Council
("!RPAC") in advance of the IRP filing, future load groMh and associated resources and
costs to meet that load growth have not yet been identified in a preferred portfolio, nor
IDAHO POWER COMPANY'S RESPONSE TO DISCOVERY REQUEST OF KIKITIDWELL.4
has the ldaho Public Utilities Commission acknowledged ldaho Power's 2021 lRP.
Traditional rate-making principles require that resources included in customer rates be
"used and useful,'thus potential future costs from an IRP are not included. At the time
new resources are placed into service, any ldaho Power request to include new resources
i n customer rates will follow cost-of-service methodology.
All costs from Company activity that impacts cost-of-service are included in the
JurisdictionalSeparation Study ('JSS') at the time of a general rate case, and those costs
are listed in Attachment 2 to the Company's Response to Request No. 1, on workbook
"JSS lmport.' Additionally, ldaho Power's Power Cost Adjustment mechanism recovers
the delta between actualvariable power supply expenses and those currently included in
base rates and is collected from customers through a per kilowatt hour charge.
The response to this Request is sponsored by Paul Goralski, Regulatory
Consultant, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO DISCOVERY REQUEST OF KIKITIDWELL.5
REQUEST NO. 3: Although part of this study's proposed scope is to also identiff
"the appropriate value of excess net energy to ensure equitable compensation for on-site
generators', ldaho Power has stated that it does not possess any studies on the benefits
of on-site generation. There are numerous studies on the benefits to the grid and to a!!
ratepayers when on-site generation and micro-grids can reduce Ioad at peak power
demands. Surely, a company of this size must possess some studies of these benefits;
can they provide any information that they have analyzed?
RESPONSE TO REQUEST NO. 3: ldaho Power disagrees with the claim in
Request No. 3 that "ldaho Power has stated that it does not possess any studies on the
benefits of on-site generation.' Please see ldaho Power's response and supplemental
response to Staffs First Production Request in Case No. IPC-E-18-15. This response
and corresponding attachments (Attachment 1 - 11) provide relevant studies and reports
conducted by the Company specific to the costs and benefits of on-site generation on
ldaho Powe/s system.
The response to this Request is sponsored by Grant T. Anderson, Regulatory
Consultant, ldaho Power Company.
IDAHO PO\A'ER COMPANY'S RESPONSE TO DISCOVERY REQUEST OF KIKI TIDWELL - 6
DATED at Boise, ldaho, this 19th day of October 2021
frLrt.Zft*t.-*,
LISA D. NORDSTROM
Attorney for ldaho Power Company
IDAHO POWER COMPA].IY'S RESPONSE TO DISGOVERY REQUEST OF KIKI TTDWELL. T
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 19th day of October 2021 I served a true and correct
copy of IDAHO POWER COMPANY'S RESPONSE TO DISCOVERY REQUEST OF KlKl
TIDWELL upon the following named parties by the method indicated below, and addressed to
the following:
Gommission Staff
Erick Shaner
Deputy Attorney General
ldaho Public Utilities Commission
11331 W. Ghinden Blvd., Bldg No. 8, Suite
201-A (83714)
PO Box 83720
Boise, lD 83720-0074
lndustrial Customers 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
ldaHydro
C. Tom Arkoosh
ARKOOSH LAW OFFICES
913 W. River Street, Suite 450
P.O. Box 2900
Boise, ldaho 83701
ldaho Conservation League and NW
Energy Coalition
Benjamin J. Ofto
ldaho Conservation League
710 North 6th Street
Boise, ldaho 83702
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IDAHO POWER COMPANY'S RESPONSE TO DISCOVERY REQUEST OF KIK!TIDWELL - 8
ldaho Clean Energy Association
Kevin King
ldaho Clean Energy Association
PO Box2264
Boise, ldaho 83702
Clean Energy Opportunities
Michael Heckler
Courtney \Mrite
Clean Energy Opportunities for ldaho lnc.
3778 Plantation River Dr., Suite 102
Boise, lD 83703
Kelsey Jae
Law for Conscious Leadership
920 N. Clover Dr.
Boise, lD 83703
ldaho Solar Ownerc Network
Joshua Hill
ldaho Solar Owners Network
1625 S. Latah
Boise, lD 83705
Micron Technology, lnc.
Austin Rueschhoff
Thorvald A. Nelson
Austin W. Jensen
Holland & Hart, LLP
555 Seventeenth Street, Suite 3200
Denver, Colorado 80202
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mike@cleanenerqvopportun ities.com
cou rtnev@cleanenerqvopportu n ities.com
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tnelson@holland hart.com
awiensen @holland hart.com
aclee@holland hart.com
q lo a ro a n oa ma ri@ h olla nd h a rt. co m
IDAHO POWER COMPANY'S RESPONSE TO DISCOVERY REQUEST OF KIKITIDWELL - 9
Jim Swier
Micron Technology, lnc.
8000 South FederalWay
Boise, ldaho 83707
City of Boise
Ed Jewell
Deputy City Attorney
Boise City Attorney's Office
150 North Capitol Boulevard
P.O. Box 500
Boise, ldaho 83701 -0500
Kiki Leslie A. Tidwell
704 N. River Street #1
Hailey, ldaho 83333
ldaho lrrigation Pumpers Association, lnc.
Eric L. Olsen
ECHO HAWK & OLSEN, PLLC
505 Pershing Avenue, Suite 100
P.O. Box 6119
Pocatello, ldaho 83205
Richard E. Kluckhohn
Wesley A. Kluckhohn
2544 W. Parkstone Dr.
Meridian, lD 83646
ABC Power Go. LLC
Ryan Bushland
184 W. Chrisfield Dr.
Meridian, lD 83646
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bo isecitvattro ney@citvofbo ise. o ro
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IDAHO POVVER COMPANY'S RESPONSE TO DISCOVERY REQUEST OF KIKI TID\A'ELL - 1O
Comet Energy LLC
George Stanton
13601 W. McMillan Rd. Ste
102 PMB 166
Boise, lD 83713
ldahome Solar, LLC
Tyler Grange
2484 N. Stokesberry Pl. #100
Meridian, !D 83646
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&r"J=
Stacy Gust
Reg ulatory Administrative Assistant
IDAHO POWER COMPANY'S RESPONSE TO DISCOVERY REQUEST OF KIKITIDI/'JELL - 11