20220104IIPA 1-10 to IPC.pdf

IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S FIRST SET OF DATA REQUESTS – Page 1
CASE NO. IPC-E-21-32
Eric L. Olsen (ISB# 4811)
ECHO HAWK & OLSEN, PLLC
505 Pershing Ave., Ste. 100
P.O. Box 6119
Pocatello, Idaho 83205
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Attorney for Intervenor Idaho Irrigation Pumpers Association, Inc.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY’S APPLICATION FOR
APPROVAL TO MODIFY ITS DEMAND
RESPONSE PROGRAMS
CASE NO. IPC-E-21-32
IDAHO IRRIGATION PUMPERS
ASSOCIATION, INC.’S FIRST SET
OF DATA REQUESTS
Idaho Irrigation Pumpers Association, Inc. (“IIPA”), by and through undersigned Counsel,
hereby submits its First Data Requests to Idaho Power, pursuant to Commission Rule 225, as
follows:
1.Please refer to the Direct Testimony of Jared L. Ellsworth, page 12.
a.Please provide the planned and unplanned outage rates assumed for a simple cycle
combustion turban.
b.Please provide the ELCC of a simple cycle combustion turban.
c.Please explain how the ELCC calculations for a simple cycle combustion turban
account for planned and unplanned outages.
d.Please provide the loss of load probability by hour under PG1 and PG2. Please
provide such data for both the ELCC calculations for the DR programs supporting
a 55 percent ELCC and the ELCC calculations for the SCCT.
2.Please refer to the Direct Testimony of Jared L. Ellsworth, pages 22 and 23.
RECEIVED
2022 JAN 04 AM 9:25
IDAHO PUBLIC
UTILITIES COMMISSION

IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S FIRST SET OF DATA REQUESTS – Page 2
CASE NO. IPC-E-21-32

a. Please identify which of the existing Idaho Power DR programs are considered to
have “similar program parameters such as seasonal restrictions, hours per year,
etc.”
b. For each DR program not identified in part a above, please indicate what the
estimated ELCC of the program is expected to be.
c. Please explain how the company calculates the “effective equivalent SCCT’s
nameplate”.
d. Please provide Idaho Power's LOLE calculator created in MATLAB referred to in
Request No. 9 - Attachment 2 - DR_SCCT_Capacity_Contribution_Results.xlsx.
e. Please provide the effective equivalent SCCT’s nameplate for each level of DR
MW included in ICIP Response attachment “Request No. 1 - Attachment 3 - ELCC
Workpaper”. If Idaho Power does not have such data please provide data necessary
to calculate the effective equivalent SCCT’s nameplate for each level of DR.
3. Please refer to the Direct Testimony of Jared L. Ellsworth page 21.
a. Please explain how DR dispatchability is modeled in Aurora.
b. Are DR resources Aurora dispatch parameters equivalent to the proposed DR
program parameters? If no, why not?
c. Please provide the dispatch costs assumed in Aurora for the DR resources.
4. Please provide the expected enrollment in MW, by year, from 2022 to 2026 for each DR
program under the proposed parameters.
5. Please provide the expected enrollment in MW, by year, from 2022 to 2026 for each DR
program under the current program parameters.

IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S FIRST SET OF DATA REQUESTS – Page 3
CASE NO. IPC-E-21-32

6. Please refer to ICIP Response attachment “Request No. 1 - Attachment 3 - ELCC
Workpaper”.
a. Please refer to cells D14, G14, J14, and M14:O14. These numbers are hard coded
while adjacent cells use formulae. When formulae are applied to these cells the
ELCC changes from 55.9 percent to 56.8 percent. Please explain which ELCC
value is correct.
b. Are the ELCC values calculated in this workpaper calculated based on Idaho
Power’s existing system, or do they assume resources and load? If the values
include incremental resources and load, identify each assumed resource (including
resource type and nameplate capacity) and incremental load not presently part of
Idaho Power’s system.
c. For each test year and DR size, please provide the total MWh of curtailment, by
hour of day for the DR resource.
7. Please refer to the Direct Testimony of Quentin Nesbitt page 5 table 1. Please provide the
following data for each curtailment event, separately for each demand response program
from 2016 to 2020:
a. Date and time of curtailment.
b. MW of enrollment called for curtailment, by hour.
c. MW of achieved curtailment, by hour.
d. Variable cost of event.
8. Please refer to the Direct Testimony of Quentin Nesbitt page 5 table 1. Please provide the
data in this table separately for each demand response program from 2016 to 2020.

IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S FIRST SET OF DATA REQUESTS – Page 4
CASE NO. IPC-E-21-32

9. Please refer to the Direct Testimony of Quentin Nesbitt page 32. Please provide the
forecasted cost per kW per year for each DR program under the proposed DR parameters.
10. Please refer to the Direct Testimony of Quentin Nesbitt page 16.
a. Please explain why the incentive for the Flex Peak program is larger than the
incentive for the Irrigation Peak Rewards program.
b. Please explain why the incentive payment for the Irrigation Peak Rewards program
is less than half the avoided cost estimate of $51.42 per kW per year.

DATED this 3rd day of January, 2022.
ECHO HAWK & OLSEN

_____________________________________
ERIC L. OLSEN

IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S FIRST SET OF DATA REQUESTS – Page 5
CASE NO. IPC-E-21-32

CERTIFICATE OF SERVICE

I HEREBY CERTIFIY that on this 3rd day of January, 2022, I served a true, correct and
complete copy of the Petition of Idaho Irrigation Pumpers Association, Inc. for Leave to Intervene
to each of the following, via U.S. Mail or private courier, email or hand delivery, as indicated
below:

Jan Noriyuki, Secretary
Idaho Public Utilities Commission
P.O. Box 83720
11331 W. Chinden Blvd.
Building 8, Suite 201-A
Boise, ID 83714
[e-mail]

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Lisa D. Nordstrom
Connie Aschenbrenner
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
[e-mail]
[e-mail]
[e-mail]

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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
[e-mail]

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Lance Kaufman
Aegis Insight
4801 W. Yale Ave.
Denver, CO 80219
[e-mail]

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IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S FIRST SET OF DATA REQUESTS – Page 6
CASE NO. IPC-E-21-32

Benjamin J. Otto
Emma E. Sperry
Idaho Conservation League
710 N. 6th Street
Boise, ID 83702
[e-mail]
[e-mail]

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Peter J. Richardson
Richardson, Adams, PLLC
515 N. 27th Street
PO Box 7218
Boise, ID 83702
[e-mail]

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Dr. Don Reading
6070 Hill Road
Boise, ID 83703
[e-mail]

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Jim Swier
Micron Technology, Inc.
8000 South Federal Way
Boise, ID 83707
[e-mail]

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Austin Rueschhoff
Thorvald A. Nelson
Austin W. Jensen
Holland & Hart, LLP
555 17th Street Suite 3200
Denver, CO 80202
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]

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IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S FIRST SET OF DATA REQUESTS – Page 7
CASE NO. IPC-E-21-32

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

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_____________________________________
ERIC L. OLSEN