20211202IPC to ICIP 1-18.pdf

LISA D. NORDSTROM
Lead Counsel
[e-mail]
December 2, 2021
VIA ELECTRONIC FILING
Jan Noriyuki, Secretary
Idaho Public Utilities Commission
11331 West Chinden Blvd., Building 8
Suite 201-A
Boise, Idaho 83714
Re: Case No. IPC-E-21-32
In the Matter of Idaho Power Company’s Application for Approval to Modify
Its Demand Response Programs
Dear Ms. Noriyuki:
Attached for electronic filing, pursuant to Order No. 35058, is Idaho Power
Company’s Response to the First Production Request of Industrial Customers of Idaho
Power in the above entitled matter.
Due to the voluminous nature of confidential and non-confidential 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. Because certain attachments contain confidential
information, the FTP site is divided between confidential and non-confidential information.
The login information for the non-confidential portion of the FTP site will be provided to
all parties, while the login information for the confidential portion will only be provided to
those parties who have executed the Protective Agreement in this matter.
If you have any questions about the attached documents, please do not hesitate
to contact me.
Very truly yours,
Lisa D. Nordstrom
LDN:sg
Attachments
RECEIVED
2021 DEC -2 PM 3:24
IDAHO PUBLIC
UTILITIES COMMISSION

CERTIFICATE OF ATTORNEY

ASSERTION THAT MATERIALS REQUESTED AND PROVIDED DURING THE
COURSE OF AN IDAHO PUBLIC UTILITIES COMMISSION PROCEEDING
ARE PROTECTED FROM PUBLIC INSPECTION

Case No. IPC-E-21-32

The undersigned attorney, in accordance with RP 67, believes that portions of
attachments 1 and 2 to Response 6, and attachments 1-5 to Response 7 of the First
Production Request of the Industrial Customers of Idaho Power, may contain
information that Idaho Power Company or a third party claims is confidential as
described in Idaho Code § 74-101, et seq., and § 48-801, et seq., and as such is
exempt from public inspection, examination, or copying.

DATED this 2nd day of December 2021.

Lisa D. Nordstrom
Counsel for Idaho Power Company

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST SET OF PRODUCTION REQUEST OF
INDUSTRIAL CUSTOMERS OF IDAHO POWER- 1
LISA D. NORDSTROM (ISB No. 5733)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
[e-mail]

Attorney for Idaho Power Company

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF IDAHO POWER
COMPANY’S APPLICATION FOR
APPROVAL TO MODIFY ITS DEMAND
RESPONSE PROGRAMS.
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CASE NO. IPC-E-21-32

IDAHO POWER COMPANY’S
RESPONSE TO THE FIRST SET OF
PRODUCTION REQUESTS OF
INDUSTRIAL CUSTOMERS OF
IDAHO POWER

COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), and in
response to the First Set of Production Requests of Industrial Customers of Idaho
Power to Idaho Power dated November 11, 2021, herewith submits the following
information:
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST SET OF PRODUCTION REQUEST OF
INDUSTRIAL CUSTOMERS OF IDAHO POWER- 2
REQUEST FOR PRODUCTION NO. 1:
Please provide, in electronic format with all formulae intact where possible, all
workpapers and other documents used in the development of Idaho Power’s Application
in this matter.
RESPONSE TO REQUEST FOR PRODUCTION NO. 1:
Please see the attachments provided via FTP site for this response. All other
workpapers and documents are provided with their corresponding production request so
that files are not duplicated.
The response to this Request is sponsored by Quentin Nesbitt, Customer
Research & Analysis Leader, and Jared Ellsworth, Transmission, Distribution &
Resource Planning Director, Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST SET OF PRODUCTION REQUEST OF
INDUSTRIAL CUSTOMERS OF IDAHO POWER- 3
REQUEST FOR PRODUCTION NO. 2:
Please provide copies of all communications between Idaho Power and the
Idaho Public Utilities Commission and/or its Staff regarding Idaho Power’s Application in
this matter.
RESPONSE TO REQUEST FOR PRODUCTION NO. 2:
Please see the attachments provided via FTP site for this response.
The response to this Request is sponsored by Lisa Nordstrom, Lead Counsel,
Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST SET OF PRODUCTION REQUEST OF
INDUSTRIAL CUSTOMERS OF IDAHO POWER- 4
REQUEST FOR PRODUCTION NO. 3:
Please provide copies of all responses to production requests (both formal and
informal) provided to any other party to this proceeding.
RESPONSE TO REQUEST FOR PRODUCTION NO. 3:
No formal or informal responses have been provided to other parties. This is the
first set of production requests received in this case.
The response to this Request is sponsored by Stacy Gust, Regulatory
Administrative Assistant, Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST SET OF PRODUCTION REQUEST OF
INDUSTRIAL CUSTOMERS OF IDAHO POWER- 5
REQUEST FOR PRODUCTION NO. 4:
At page 13 of the Company’s Application the Company states; “The Company
proposes to keep the requirement of three minimum events.” However, on page 12, for
the Flex Peak Program, the Company states; “Recognizing it may be more difficult for
some customers to participate in the later evening hours, the Company is proposing an
increase in the variable incentive after four events for the Flex Peak program.” Does this
mean for the Flex Peak Program there will be a minimum of four events each year
rather than three? Please explain fully.
RESPONSE TO REQUEST FOR PRODUCTION NO. 4:
The minimum number of events for the Flex Peak Program is proposed to remain
unchanged at three. The statement referenced was intended to highlight the proposed
increase in the variable incentive and clarifies that the variable incentive is proposed to
start with the fifth event, rather than the fourth event as dictated by the current program
parameters.
The response to this Request is sponsored by Quentin Nesbitt, Customer
Research & Analysis Leader, Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST SET OF PRODUCTION REQUEST OF
INDUSTRIAL CUSTOMERS OF IDAHO POWER- 6
REQUEST FOR PRODUCTION NO. 5:
Quentin Nesbitt’s states at page 2 of his Direct Testimony, “This is based on
updated analyses and methodologies used in the Company’s 2021 Integrated Resource
Plan (“IRP”) planning process and discussed in further detail in Mr. Ellsworth’s
testimony.” Does this mean for the Flex Peak Program the values found in the
Company’s 2021 Integrated Resource Plan (“IRP”) will be used even though they have
not yet be acknowledged by the Commission? If true, will the cost effectiveness analysis
for the Company’s other DSM programs still wait for Commission acknowledgement?
Please explain fully.
RESPONSE TO REQUEST FOR PRODUCTION NO. 5:
On pages 32-33 of Quentin Nesbitt’s testimony, Mr. Nesbitt outlines how the
Company will update the components of the avoided cost equation with every IRP.
There is an important distinction between information used for system planning and
operational decisions and information used to support backward-looking economic
evaluations. When the Company is starting a new program, making major modifications
to a program, or adding a new measure, it utilizes the current available avoided cost
data to evaluate whether a given program or measure will be cost effective in the future.
In this case, the Company referenced data from the 2021 IRP to inform future cost-
effectiveness. When determining cost-effectiveness for program evaluations and
program reporting, it is the Company’s intent to continue to utilize the most recently
acknowledged IRP values to determine the cost-effectiveness of its existing programs.
When determining the 2021 DR cost-effectiveness, the Company will rely on the current
method as outlined in the Settlement Agreement approved by the Commission in Order
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST SET OF PRODUCTION REQUEST OF
INDUSTRIAL CUSTOMERS OF IDAHO POWER- 7
No. 32923.
The response to this Request is sponsored by Quentin Nesbitt, Customer
Research & Analysis Leader, Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST SET OF PRODUCTION REQUEST OF
INDUSTRIAL CUSTOMERS OF IDAHO POWER- 8
REQUEST FOR PRODUCTION NO. 6:
At page 10 of the Quentin Nesbitt’s Direct Testimony in Table 3 he indicates a
Flex Peak customer seminar and an Irrigation Peak Rewards Customer seminar were
held on August 31, 2021. Please provide a list of the attendees and their respective
affiliations, and all materials presented by Idaho Power at the seminars as well as all
notes or reports that were prepared in connection with the seminars.
RESPONSE TO REQUEST FOR PRODUCTION NO. 6:
Please see the attachments provided via FTP site for this response. Confidential
attachments 1 and 2 can be found in the confidential portion of the FTP site, and
attachments 3-9 can be found in the non-confidential portion of the site.
As the Company was compiling materials for the production requests, it became
aware of a mistake that affected three of the slides presented during the Irrigation Peak
Rewards Workshop held with customers on August 31st. Once the Company became
aware of the discrepancy, the slides were updated, and the revised materials will be
provided to those participants who had requested a copy of the workshop materials.
The revised materials are provided as attachment 5 to this response.
The response to this Request is sponsored by Quentin Nesbitt, Customer
Research & Analysis Leader, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST SET OF PRODUCTION REQUEST OF
INDUSTRIAL CUSTOMERS OF IDAHO POWER- 9
REQUEST FOR PRODUCTION NO. 7:
At page 14 of testimony Mr. Nesbitt states that Idaho Power conducted a survey
to understand how moving the dispatch hours would impact customers’
ability/willingness to participate. See also Table 4 on page 14. Please provide a copy
of the survey and the results along with all analysis or evaluation reports related to the
survey. Please identify the number of respondents for each category program identified
in Table 4 on page 14 of Mr. Nesbitt’s testimony.
RESPONSE TO REQUEST FOR PRODUCTION NO. 7:
Please see the attachments provided via FTP site for this response.
Confidential attachments 1-5 can be found in the confidential portion of the FTP
site, and attachments 6-12 can be found in the non-confidential portion of the site. The
number of respondents for each category listed in Table 4 are as follows: 295 A/C Cool
Credit respondents, 90 Irrigation Peak Rewards respondents, and 24 Flex Peak
respondents.
The response to this Request is sponsored by Quentin Nesbitt, Customer
Research and Analysis Leader, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST SET OF PRODUCTION REQUEST OF
INDUSTRIAL CUSTOMERS OF IDAHO POWER- 10
REQUEST FOR PRODUCTION NO. 8:
Mr. Nesbitt indicates at page 23 of his direct testimony that the Company
conducted an analysis, based on actual customer loads, that showed the proposed
scalar method for the DOA was accurate 86 percent of the time when compared to the
current method. Please provide a copy of the analysis, the date used, and any
spreadsheets used in the analysis.
RESPONSE TO REQUEST FOR PRODUCTION NO. 8:
Please see the attachments provided via FTP site for this response.
The response to this Request is sponsored by Quentin Nesbitt, Customer
Research & Analysis Leader, Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST SET OF PRODUCTION REQUEST OF
INDUSTRIAL CUSTOMERS OF IDAHO POWER- 11
REQUEST FOR PRODUCTION NO. 9:
At page 21 of the Jared Ellsworth’s Direct he states that the additional system
benefits of a SCCT over a 492 MW DR portfolio for the first five years of the company’s
planning horizon is $38.11. Please provide a copy of the referenced analysis, the data
used, and any spreadsheets used in the referenced analysis.
RESPONSE TO REQUEST FOR PRODUCTION NO. 9:
Please see the attachments provided via FTP site for this response.
The response to this Request is sponsored by Jared Ellsworth, Transmission,
Distribution & Resource Planning Director, Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST SET OF PRODUCTION REQUEST OF
INDUSTRIAL CUSTOMERS OF IDAHO POWER- 12
REQUEST FOR PRODUCTION NO. 10:
Quentin Nesbitt’s Direct Testimony states, a” A dollar per kW cost would be
calculated annually for each of the Company’s DR programs and the overall portfolio,
assuming the maximum 60 hours of operation.” [page 31.] Also, “The Company
proposes to annually run the production cost models from the most recently
acknowledged IRP to update the additional system benefits of the proxy resource
component since this value is also dependent on the total DR portfolio capacity.” [page
33]. And, as asked in Request No, 5, “This is based on updated analyses and
methodologies used in the Company’s 2021 Integrated Resource Plan (“IRP”) planning
process and discussed in further detail in Mr. Ellsworth’s testimony.” Please list for each
element to be used in the cost-effectiveness evaluation of the Demand Response
program the source of the data input to be used in the calculations, and the time period
of the evaluation. Please explain fully the rational for using each of the input data sets.
RESPONSE TO REQUEST FOR PRODUCTION NO. 10:
The primary elements to be used in the backward-looking cost-effectiveness
evaluation of Idaho Power's Demand Response (“DR”) programs will include a
combination of inputs from the most recently acknowledged IRP and inputs that are
updated annually, as follows:
The levelized capacity fixed costs of a proxy resource: the resource and
associated costs will be based on the most-recently acknowledged IRP.
The Effective Load Carrying Capability (“ELCC”) of the annual DR nameplate
capacity compared to a proxy resource: The ELCC will be updated annually based on
the enrolled capacity in the DR programs.
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST SET OF PRODUCTION REQUEST OF
INDUSTRIAL CUSTOMERS OF IDAHO POWER- 13

The additional system benefits of the proxy resource: Will be recalculated
annually based on inputs from the most recently acknowledged IRP and the updated
ELCC information.
The response to this Request is sponsored by Jared Ellsworth, Transmission,
Distribution & Resource Planning Director, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST SET OF PRODUCTION REQUEST OF
INDUSTRIAL CUSTOMERS OF IDAHO POWER- 14
REQUEST FOR PRODUCTION NO. 11:
Please reference Table 5 at page 16 of Mr. Nesbitt’s direct testimony. Please
provide the workpapers and show how the dollars “per kW per season” figures were
derived, please annotate your answer using ‘reality’ based hypothetical examples to
demonstrate the mechanics of the calculations for the following:
(A) Flex Peak rows labeled “Existing and Proposed,” showing $29.25 and
$42.25 per kW per season, respectively
(B) Irrigation Peak Rewards rows labeled “Existing and Proposed,” showing
$16.00 and $25.20 per season, respectively.
The goal of this DR, is to allow the reader to replicate the cost calculations for the
various programs currently being offered as well as for the programs as they have been
proposed to be modified.
RESPONSE TO REQUEST FOR PRODUCTION NO. 11:
(A): The existing Flex Peak program pays an incentive of $3.25 per nominated
Kilowatt (“kW”) per week to a customer or calculated kW reduction if there are events.
There are nine weeks between June 15 and August 15. The derivation of $29.25 per
kW per season is calculated by multiplying $3.25 per nominated kW by 9 weeks. The
proposed season is from June 15 to September 15, which is 13 weeks. The proposed
$42.25 per kW per season is calculated by multiplying $3.25 per nominated kW by 13
weeks.
(B): The existing Irrigation Peak Rewards program pays an incentive of $5.00
per kW per billing and $0.0076 per Kilowatt-hour (“kWh”) per billing month. There are
two months between June 15 and August 15. The derivation of $16 per kW per season
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST SET OF PRODUCTION REQUEST OF
INDUSTRIAL CUSTOMERS OF IDAHO POWER- 15
is calculated by multiplying $5.00 per kW x 2 months = $10 per kW. Then using an
estimate of 400 hours a customer would run their pumps in a month, 400 hours x 1 kW
x $0.0076 per kWh = $3.04 per month x 2 months = $6.08 per kW. When added to the
$10 per kW, this results in approximately $16 per kW.
The proposed season is from June 15 to September 15 which is three months.
The proposed $25.20 per kW per season is calculated by taking the proposed incentive
of $5.25 per kW x 3 months = $15.75 per kW. Then estimating a customer would run
approximately 400 hours in a month for two months, and 380 hours for one month, the
calculation would be 400 hours x 1 kW x $0.008 per kWh = $3.20 per month x 2 months
= $6.40 + (380 hours x 1 kW x $0.008 per kWh = $3.04 per month x 1 month) = $9.44
per kW. $9.44 per kW added to the $15.75 per kW results in approximately $25.20 per
kW per season. The 400 and 380 hours are the Company’s estimates of the time
irrigators would run their pumps in a typical irrigation month, and the $0.008 per kwh is
the proposed Energy Credit.
Because customer’s irrigation hours will vary, the $25.20 per kW is only an
example of the benefit the customer may receive. The actual incentive the customer
receives will depend on the number of kilowatt hours used during their applicable billing
cycles.
The response to this Request is sponsored by Quentin Nesbitt, Customer
Research & Analysis Leader, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST SET OF PRODUCTION REQUEST OF
INDUSTRIAL CUSTOMERS OF IDAHO POWER- 16
REQUEST FOR PRODUCTION NO. 12:
At page 13 of its Application the Company reminds the Commission that “The
programs (Demand Response Programs) were previously limited from growing during a
time with the IRP analysis show no near-term capacity deficits.” Please identify the date
the programs were so limited and the length of time (in years) that is referenced by the
phrase “no near-term capacity deficits.” In other words, how many years of surplus
capacity were anticipated at the time the Commission limited the programs from
growing?
RESPONSE TO REQUEST FOR PRODUCTION NO. 12:
The Commission approved the Settlement Agreement, which limited marketing of
the demand response programs in Order No. 32923, issued on November 12, 2013.
The 2013 IRP showed that the peak-hour projected loads did not show a peak-hour
deficit until July 2016. Therefore, the expected years of surplus capacity was anticipated
to be three years.
The response to this Request is sponsored by Quentin Nesbitt, Customer
Research & Analysis Leader, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST SET OF PRODUCTION REQUEST OF
INDUSTRIAL CUSTOMERS OF IDAHO POWER- 17
REQUEST FOR PRODUCTION NO. 13:
How many years of surplus capacity does the company anticipate as of the date
of the Company’s application in this matter? Please cite to the supporting Commission
orders or other controlling documents supporting the Company’s answer.
RESPONSE TO REQUEST FOR PRODUCTION NO. 13:
As of the date of the Company’s application in this matter (October 1, 2021), the
Company’s first expected capacity deficiency was expected to occur in 2023. As more
fully explained in the application and Jared Ellsworth’s Direct Testimony in Case No.
IPC-E-21-12, on April 26, 2021, Idaho Power issued a Request for Proposal to acquire
a resource to be in-service before 2023 for the delivery of firm capacity and energy
during the summer months through 2025. The Commission subsequently acknowledged
December 31, 2025 as the exit date for Valmy Unit 2 in Order No. 35217 and indicated
that the Commission expects the Company to continue to evaluate all possible options
that would allow it to exit Valmy Unit 2 before December 31, 2025.
The response to this Request is sponsored by Jared Ellsworth, Transmission,
Distribution & Resource Planning Director, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST SET OF PRODUCTION REQUEST OF
INDUSTRIAL CUSTOMERS OF IDAHO POWER- 18
REQUEST FOR PRODUCTION NO. 14:
Reference paragraph 35 of the Company’s Application which discusses the
Irrigation Out-of-Demand Season Energy Credit. Please explain the apparent
discrepancy between the Company’s proposal to compensate irrigation customers (who
pay no demand charge) to reduce their demand on the Company’s system. Has the
Company considered whether it might be an effective conservation tool to actually
impose a demand charge as a potential method of reducing the use of no-cost-to-the-
irrigation-customer demand?
RESPONSE TO REQUEST FOR PRODUCTION NO. 14:
The incentive structure for each of the demand response programs is designed
to incentivize customers to participate so that cost-effective load reduction is achieved.
The Out-of-Demand Season Energy Credit is not a discrepancy. It is necessary
because some customer’s billing demand could end before September 15th based on
their billing cycle, and they would not receive a demand credit as part of the fixed
incentive for their participation in the Irrigation Peak Rewards program. This ensures all
potential Irrigation Peak Rewards Program participants are equally incentivized and
compensated consistently regardless of which billing cycle they are on.
The Company has recently considered the merits of modifications to rate design
for all customer classes as outlined in the Fixed Cost Report in Case No. IPC-E-18-16.
However, the Company did not consider proposing any rate design changes as part of
this case.
The response to this Request is sponsored by Quentin Nesbitt, Customer
Research & Analysis Leader, Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST SET OF PRODUCTION REQUEST OF
INDUSTRIAL CUSTOMERS OF IDAHO POWER- 19
REQUEST FOR PRODUCTION NO. 15:
Mr. Ellsworth references at page 5 of his direct testimony “Examples of
generation resources Idaho Power does not have operational control over are wind,
solar, and PURPA resources.” Please explain why Idaho Power does not have
operational control over its non-PURPA wind resources. Does Idaho Power have
operational control over its non-PURPA geothermal resources? Please explain why or
why not.
RESPONSE TO REQUEST FOR PRODUCTION NO. 15:
Idaho Power has power purchase agreements with one non-PURPA wind
resource and two non-PURPA geothermal resources. Like with PURPA resources,
Idaho Power does not own or operate these resources. The contracts between Idaho
Power and the owners of these resources require Idaho Power to purchase the net real
power output of these resources. Idaho Power does not have the ability to dispatch
them and does not have control over the real power output. However, Idaho Power
may be excused from taking delivery of and paying for the output in certain limited
circumstances, such as outages or events of Force Majeure.
The response to this Request is sponsored by Jared Ellsworth, Transmission,
Distribution & Resource Planning Director, Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST SET OF PRODUCTION REQUEST OF
INDUSTRIAL CUSTOMERS OF IDAHO POWER- 20
REQUEST FOR PRODUCTION NO. 16:
Please identify the test years used in the table for each of the four test years on
page 17 or Mr. Ellsworth’s direct testimony.
RESPONSE TO REQUEST FOR PRODUCTION NO. 16:
The test years used for the analysis in the Demand Response filing correspond
to the following historical years in the table below:
Test Year Actual Year
Test Year 1 2017
Test Year 2 2018
Test Year 3 2019
Test Year 4 2020

The response to this Request is sponsored by Jared Ellsworth, Transmission,
Distribution & Resource Planning Director, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST SET OF PRODUCTION REQUEST OF
INDUSTRIAL CUSTOMERS OF IDAHO POWER- 21
REQUEST FOR PRODUCTION NO. 17:
If an event is called in the Flex Peak program, does the actual reduction in kW
replace the nominated kW in the payment calculation? Please explain.
RESPONSE TO REQUEST FOR PRODUCTION NO. 17:
Yes, when program events are called for the Flex Peak Program, participating
customers will be paid based on the amount of kW reduction they provide. Payment
comes from the event average reduction, so if an event is four hours long, they will be
paid based on the event average kW demand reduction. The fixed incentive is $3.25 per
nominated kW per week, not per event. If a participating customer has two events in
one week, the event performance is averaged. In cases where the reduction achieved is
less than the nominated amount, there is an incentive adjustment of $2.00 per kW not
achieved for each hour of the event. The actual kW reduction does replace the
nomination for payment purposes, but the nomination and/or incentive adjustment is still
used in the determination of the payment.
The response to this Request is sponsored by Quentin Nesbitt, Customer
Research & Analysis Leader, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST SET OF PRODUCTION REQUEST OF
INDUSTRIAL CUSTOMERS OF IDAHO POWER- 22
REQUEST FOR PRODUCTION NO. 18:
At page 18 of Mr. Ellsworth’s direct testimony he notes that the proposed
incentive adjustment will approximately nullify a customer’s fixed incentive if the
customer opts out of four events throughout the program season. Is it true, under this
proposal, that if a customer opts out of the last four events in a season, but participated
and delivered their nominated reduction in each of the first (for example) eleven events,
that the customer’s fixed incentive would be nullified? Please explain.
RESPONSE TO REQUEST FOR PRODUCTION NO. 18:
The incentive adjustment of $2.00 per kW not achieved is intended to nullify any
incentive amount for the season when participants nominate load reduction but do not
provide kW reduction during four events. The possible scenario mentioned where a
customer signs up and performs correctly for some number of events, but then does not
provide any kW reduction for four events, the incentive adjustment is intended to reduce
their incentive to near zero. This incentive design corresponds to the fact that there is
an incentive paid per week even when there are no events.
Also, this structure is designed such that the Company can better rely on the
program nominations. However, Flex Peak participants can opt-out of events without
penalty if they advise Idaho Power by 10:00 AM the Thursday prior to the week they are
not able to participate. They will be opted-out if any events are called that week. If this
occurs the participant will not get paid for the event (temporarily setting their nomination
of 0 kW), nor will they have an incentive adjustment for the event. If the customer has
not opted-out and just not able to perform, they would be subject to the incentive
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST SET OF PRODUCTION REQUEST OF
INDUSTRIAL CUSTOMERS OF IDAHO POWER- 23
adjustment for every hour of the event their reduced kW amount was below their
nominated kW amount.
The response to this Request is sponsored by Quentin Nesbitt, Customer
Research & Analysis Leader, Idaho Power Company.

DATED at Boise, Idaho, this 2nd day of December 2021.

LISA D. NORDSTROM
Attorney for Idaho Power Company

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST SET OF PRODUCTION REQUEST OF
INDUSTRIAL CUSTOMERS OF IDAHO POWER -24
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the 2nd day of December 2021, I served a true and
correct copy of Idaho Power Company’s Responses to the First Set of Production
Request of Industrial Customers of Idaho Power upon the following named parties by the
method indicated below, and addressed to the following:

Commission Staff
Riley Newton
Deputy Attorney General
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg No. 8,
Suite 201-A (83714)
PO Box 83720
Boise, ID 83720-0074

Hand Delivered
U.S. Mail
Overnight Mail
FAX
__X_ FTP Site
X Email: [e-mail]

Idaho Irrigation Pumpers Association, Inc.
Eric L. Olsen
Echo Hawk & Olsen, PLLC
505 Pershing Ave., Ste. 100
P.O. Box 6119
Pocatello, Idaho 83205
Hand Delivered
U.S. Mail
Overnight Mail
FAX
X FTP Site
X Email [e-mail]

Lance Kaufman
Aegis Insight
4801 W. Yale Ave.
Denver, CO 80219
Hand Delivered
U.S. Mail
Overnight Mail
FAX
X FTP Site
X EMAIL [e-mail]

Idaho Conservation League
Benjamin J. Otto
Emma E. Sperry
Idaho Conservation League
710 N. 6th Street
Boise, Idaho 83702
Hand Delivered
U.S. Mail
Overnight Mail
FAX
X FTP Site
X EMAIL [e-mail]
[e-mail]

Industrial Customers of Idaho Power
Peter J. Richardson
Richardson Adams, PLLC
515 N. 27th Street
P.O. Box 7218
Boise, Idaho 83702

Hand Delivered
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Overnight Mail
FAX
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X EMAIL [e-mail]

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST SET OF PRODUCTION REQUEST OF
INDUSTRIAL CUSTOMERS OF IDAHO POWER - 25
Dr. Don Reading
6070 Hill Road
Boise, Idaho 83703

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FAX
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X EMAIL [e-mail]

Micron Technology, Inc.
Austin Rueschhoff
Thorvald A. Nelson
Austin W. Jensen
Holland & Hart LLP
555 17th Street, Suite 3200
Denver, CO 80202
Hand Delivered
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X FTP Site
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[e-mail]
[e-mail]
[e-mail]
[e-mail]

Jim Swier
Micron Technology, Inc.
8000 South Federal Way
Boise, ID 83707
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Overnight Mail
FAX
X FTP Site
X EMAIL [e-mail]

Boise City
Ed Jewell
Deputy City Attorney
Boise City Attorney’s Office
150 N. Capitol Blvd. P.O. Box 500
Boise, ID 83701-0500
Hand Delivered
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[e-mail]

________________________________
Stacy Gust, Regulatory Administrative
Assistant