20211110ICIP 1-18 to IPC.pdf

Peter J. Richardson ISB # 3195
Gregory M. Adams ISB # 7454
RICHARDSON ADAMS, PLLC
515 N. 27'h Street
Boise,Idaho 83702
Telephone: [phone]
Far [phone]
[e-mail]
glee@richardsonandoleary. com
Attorneys for the tndustrial Customers of Idaho Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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TN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR
APPROVAL TO MODIFY TTS DEMAND
RESPONSE PROGRAMS
CASE NO.IPC.E.2I.32
FIRST PRODUCTTON REQUEST OF
THE INDUSTRIAL CUSTOMERS OF
IDAHO POWER
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Pursuant to Rule 225 of the Rules of Procedure of the Idaho Public Utilities Commission
(the "Commission"), the lndustrial Customers of [daho Power (*ICIP") by and through its
attorney of record, Peter J. Richardson, hereby requests that ldaho Power Company ("Idaho
Power" or the "Company") provide responses to the following with supporting documents,
where applicable.
This production request is to be considered as continuing, and tdaho Power is requested
to provide by way of supplementary responses additional documents that it or any person acting
on its behalf may later obtain that will augment the responses or documents produced.
FIRST PRODUCTION REQI.JEST OF THE ICIP
TN CASE NO. IPC-8.21.32_ PAGE I
Please provide an additional electronic copy, or if unavailable, a physical copy, to Dr.
Don Readingat 6A7O Hill Road, Boise, Idaho 83703, Tel: [phone]; Fax: [phone]l l;
[e-mail]
For each item, please indicate the name of the person(s) preparing the answers, along
with the job title of such person(s) and the witness at hearing who can sponsor the answer.
REOUEST FOR PRODUCTION NO.I
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.
REOUEST FOR PRODUCTION NO. 2
Please provide copies of all communications between ldaho Power and the Idaho Public Utilities
Commission and/or its Staffregarding Idaho Power's Application in this matter.
REOUEST 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.
REOUEST FOR PRODUCTION NO.4
At page l3 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
rninimum of four events each year rather than three? Please explain fully.
FIRST PRODUCTION REQUEST OF THE ICIP
IN CASE NO. IPC-E.21.32 _ PAGE 2
REOUEST FOR PRODUCTION NO.5
Quentin Nesbitt's states at pageZ of his Direct Testimony, "This is based on updated analyses
and methodologies used in the Company's2O2l Integrated Resource Plan ("lRP") 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 lntegrated Resource Plan ("lRP")
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
acknowledgment? Please explain fully.
REOUEST FOR PRODUCTION NO.6
At page l0 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 affrliations, 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.
REOUEST FOR PRODUCTION NO.7
At page t4 of his 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 identifu the number of
respondents for each category program identified in Table 4 on page 14 of Mr. Nesbitt's
testimony.
FIRST PRODUCTION REQUEST OF THE ICIP
TN CASE NO. IPC.E.2I-32 _ PAGE 3
REOUEST FOR PRODUCTION NO. E
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 data used, and any spreadsheets used in the analysis.
REOUEST FOR PRODUCTION NO.9
At page 2l of the Jared Ellsworth's Direct he states that the additional system benefits of a
SCCT over a 492MW DR portfolio for the first five years of the company's planning horizon is
$38.1 L Please provide a copy ofthe referenced analysis, the data used, and any spreadsheets
used in the referenced analysis.
REOUEST FOR PRODUCTION NO. IO
Quentin Nesbitt's Direct Testimony states, "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 3l .] 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 lntegrated Resource Plan ("lRP") 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.
FIRST PRODUCTION REQUEST OF THE ICIP
IN CASE NO. IPC-E-2 I-32 _ PAGE 4
REOUEST FOR PRODUCTION NO. IT
Please reference Table 5 at page l6 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.
REOUEST FOR PRODUCTION NO. 12
At page l3 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?
REOUEST 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.
FIRST PRODUCTION RLQUEST OF THE ICIP
IN CASE NO. IPC-E.21-32_ PAGE 5
REOUEST FOR PRODUCTION NO. 14
Reference paragraph 35 of the Company's Application which discusses the lrrigation 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-tothe-irrigation-customer demand?
REOUEST 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 ldaho 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.
REOUEST FOR PRODUCTION NO. 16
Please identify the test years used in the table for each of the four test years on page l7 or Mr.
Ellsworth's direct testimony.
REOUEST FOR PRODUCTTON 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.
REOUEST FOR PRODUCTTON NO. 18
At page l8 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
FIRST PRODUCTION REQUEST OF THE ICIP
INCASE NO. IPC.E-21.32_ PACE 6
last fimr cvorrtc in a soasorr" but portioipat€d ad dcliverd their nomlnmd roductim in och of
thc first (for oxrylQ elevcn ovcnts, that the sustomcde fixed incentive would be nullificd?
Plascexplain
DalGd this lOtb day of November 2A21.
RICHARDSON ADAIT{S, PLLC
FTRSIT PRODUCTTON REQLJEST OF THE ICIP
IN CASE NO. IPGE.2T.32 - PAGE 7
I HEREBY CERTIFY that on the lOth day of November 2O2l,a true and correct copy of the
within and foregoing FIRST PRODUCTION REQUEST of the lndustrial Customers of Idaho
Power in Case No. IPC-E-21-32 was served, by electronic copy only, to:
Lisa Nordstrom
Regulatory Dockets
Idaho Power Company
lnordshom@ idahopower.com
dockets@ i dahopower.com
Jan Noriyuki, Secretary
Idaho Public Utilities Commission
[e-mail]. gov
Benjamin J. Otto
Idaho Conservation League
B otto@.i dahoconservat ion.org
Eric Olson
Idaho lrrigation Pumpers Assoc.
Echo Hawk & Olson, PLLC
elo@.echohawk.com
Jim Swier
Micron Technology, Inc.
[e-mail]
Peter Richardson
ISB # 3195
FIRST PRODUCTION REQUEST OF THE ICIP
TN CASE NO. IPC.E.2I-32 _ PAGE 8
Commission Secretary
Idaho Public Utilities Commission
secretary@puc. idaho. eov
Connie Aschenbrenner
Idaho Power Company
[e-mail]
Emma E. Sperry
Idaho Conservation League
esperrv@idahoconservati on.org
Lance Kaufman
Idaho Inigation Pumpers Assoc.
AEGIS Insight
lance@aeisi nsi ght.com
Austin Rueschhoff
Thorvald A. Nelson
Austin W. Jensen
darueschho ffi@hol landhart. com
[e-mail]
awjensen@ hol landhart.com
[e-mail]
gl [e-mail]