20220124IPC to IIPA 1-10.pdf

LISA D. NORDSTROM
Lead Counsel
[e-mail]
January 24, 2022
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 Idaho Irrigation Pumpers Association, Inc.’s First Set of Data
Requests to Idaho Power in the above entitled matter.
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 non-confidential portion of the FTP site was provided to all parties on December 2,
2021.
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
2022 JAN 24 PM 4:41
IDAHO PUBLIC
UTILITIES COMMISSION
IDAHO POWER COMPANY’S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S
FIRST SET OF DATA REQUESTS- 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 IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.’S
FIIRST SET OF DATA REQUESTS

COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), and in
response to Idaho Irrigation Pumpers Association, Inc.’s (“IIPA”) First Set of Data
Requests to Idaho Power dated January 3, 2022, herewith submits the following
information:
IDAHO POWER COMPANY’S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S
FIRST SET OF DATA REQUESTS- 2
REQUEST FOR PRODUCTION NO. 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 1:
a) The Equivalent Forced Outage Rate (“EFOR”) of the Simple Cycle
Combustion Turbine (“SCCT”) used in this analysis was 6 percent. An
EFOR of 6 percent represents a generator that is forced off, or incurs an
unplanned outage, 6 percent of its running time. Planned outages are not
a component of the Effective Load Carrying Capability (“ELCC”)
methodology.
b) The ELCC was not computed for dispatchable resources (such as an
SCCT); ELCC values were only calculated for non-controllable and
energy-limited resources such as Demand Response (“DR”), solar, and
wind. The contribution to peak of dispatchable resources is modeled using
monthly capacities and corresponding EFOR values.
IDAHO POWER COMPANY’S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S
FIRST SET OF DATA REQUESTS- 3
c) As previously stated, the ELCC was not computed for dispatchable
resources such as an SCCT. The ELCC analysis calculates the perfect
generation displaced by the selected resource. When determining the
ELCC of the DR portfolio for the cost effectiveness equation, Idaho Power
chose to replace the perfect generator in the ELCC calculations with the
resource identified in the Settlement Agreement, an SCCT whose EFOR
was greater than zero. The SCCT has an assumed EFOR value of 6
percent. This SCCT with an EFOR of 6 percent was applied instead of a
perfect generator, and the ELCCSCCT of the 492 MW DR portfolio was then
calculated to be 55 percent.
d) Please see the attachment provided for this response which contains the
hourly Loss of Load Probability data for the 55 percent ELCCSCCT of the
DR portfolio calculation for all four test years. The ELCC calculations
utilize four test years of historical hourly output data to provide realistic
weather shapes.
The response to this Request is sponsored by Jared Ellsworth, Transmission,
Distribution & Resource Planning Director, Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S
FIRST SET OF DATA REQUESTS- 4
REQUEST FOR PRODUCTION NO. 2:
Please refer to the Direct Testimony of Jared L. Ellsworth, pages 22 and 23.
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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 2:
a) The “similar program parameters such as seasonal restriction, hours per
year, etc.” refers to the DR programs in the Northwest Power and
Conservation Council assessment. The assessment showed 584
megawatts (“MW”) of total DR potential for the Company’s service area
and using similar parameters to Idaho Power’s current DR programs, that
IDAHO POWER COMPANY’S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S
FIRST SET OF DATA REQUESTS- 5
potential was further refined to 492 MW. Programs such as Critical Peak
Pricing and Conservation Voltage Reduction were removed to provide a
more accurate potential value on what the current programs could
achieve.
b) As stated in part a), all three of the Company’s DR programs have similar
program parameters used to identify the 492 MW of DR potential used in
the analysis.
c) Idaho Power determined the size of an effective-equivalent SCCT by
implementing the ELCC methodology, utilizing an SCCT with an assumed
Effective Forced Outage Rate of 6 percent, instead of a perfect generator.
Utilizing the DR portfolio nameplate of 492 MW, the 2023 load and
resource balance, and averaging over the four test years used in the
analysis produces the effective-equivalent SCCT nameplate, as shown in
the table below produced by Idaho Power’s internally developed Loss of
Load Expectation (“LOLE”) MATLAB® algorithm.
Effective-Equivalent
SCCT Nameplate
ELCCSCCT for DR Portfolio
Nameplate of 492 MW
Test Year 1 323 MW 66%
Test Year 2 272 MW 55%
Test Year 3 266 MW 54%
Test Year 4 225 MW 46%
Avera e 272 MW 55%

d) Please see the attachment provided for this response. The Company’s
internally developed LOLE MATLAB® algorithm is comprised of a
multitude of interplaying scripts which apply the methods and equations
IDAHO POWER COMPANY’S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S
FIRST SET OF DATA REQUESTS- 6
described in the Reliability Evaluation of Power Systems (Billinton & Allan,
1984) textbook.
 Billinton, Roy, and Ronald N. Allan. Reliability Evaluation of Power
Systems. Pitman Books Limited, 1984.
e) Please see the attachments provided for this response which contain the
data necessary to determine the effective-equivalent SCCT nameplate for
each level of DR MW.
The response to this Request is sponsored by Jared Ellsworth, Transmission,
Distribution & Resource Planning Director, Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S
FIRST SET OF DATA REQUESTS- 7
REQUEST FOR PRODUCTION NO. 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 3:
a. The AURORA model is fed an 8,760 DR shape for each of the years in the
Integrated Resource Plan (“IRP”) planning horizon, meaning DR
dispatchability is based upon the supplied 20-year, hourly shape. The DR
shape is constructed by applying the DR MW nameplate incrementally to the
predetermined hours of highest risk; the dispatchability of DR in the AURORA
model is constrained to the DR portfolio parameters.
b. Yes.
c. Dispatch costs are not applied to the DR portfolio in the AURORA model.
Incrementally selectable DR is modeled with the following levelized fixed
costs ($/MW-week) during the Long-Term Expansion Modeling runs:
 First 100 MW (in 20 MW increments):
- $986 per MW-week (for non-leap years)
- $983 per MW-week (for leap years)
 Next 180 MW (in 20 MW increments):
- $1,572 per MW-week (for non-leap years)
IDAHO POWER COMPANY’S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S
FIRST SET OF DATA REQUESTS- 8
- $1,568 per MW-week (for leap years)
The response to this Request is sponsored by Jared Hansen, Resource Planning
Leader, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S
FIRST SET OF DATA REQUESTS- 9
REQUEST FOR PRODUCTION NO. 4:
Please provide the expected enrollment in MW, by year, from 2022 to 2026 for
each DR program under the proposed parameters.
RESPONSE TO REQUEST FOR PRODUCTION NO. 4:
For input into the 2021 IRP, the Company assumed 300 MWs of DR capacity
would be available each year from 2022 through 2026. This estimate assumes
approximately 22 MW from Residential Air Conditioner Cycling, 30 MW from
Commercial & Industrial Flex Peak, and 248 MW from Irrigation Peak Rewards.
The response to this Request is sponsored by Quentin Nesbitt, Customer
Research & Analysis Leader, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S
FIRST SET OF DATA REQUESTS- 10
REQUEST FOR PRODUCTION NO. 5:
Please provide the expected enrollment in MW, by year, from 2022 to 2026 for
each DR program under the current program parameters.
RESPONSE TO REQUEST FOR PRODUCTION NO. 5:
With the current program parameters, the Company estimates the DR portfolio
capacity to stay around 380 MW starting in 2022, which is a similar level to the 2021 DR
capacity. The 380 MW assumes approximately 28 MW from Residential Air Conditioner
Cycling, 35 MW from C&I Flex Peak, and 315 MW from Irrigation Peak Rewards.
The response to this Request is sponsored by Quentin Nesbitt, Customer
Research & Analysis Leader, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S
FIRST SET OF DATA REQUESTS- 11
REQUEST FOR PRODUCTION NO. 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 6:
a) Please see Attachment 1 provided for this response. The previously
provided Attachment 3 to ICIP’s Request No. 1 combined two separate
analyses where different DR portfolio capacities were used. There was the
380 MW case with the current DR program capacity and the 492 MW of
potential DR capacity identified in the Northwest Power and Conservation
Council assessment. The last 50 MW for each scenario was available
from 10:00pm – 11:00pm. Therefore, the tables are the same up to 330
MW and diverge from that point. When combining the tables, the formulae
IDAHO POWER COMPANY’S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S
FIRST SET OF DATA REQUESTS- 12
was removed to keep the correct values and show the ELCC of 380 MW
and 492 MW.
b) The calculated ELCC values were based on Idaho Power’s expected 2023
load and resource balance. This includes the Company’s existing
resources, plus those known at the time of the analysis, which included
the addition of the 120 MW nameplate Jackpot Solar Project. As for load,
the four historical test years were used for weather shaping and scaled to
have the same peak load as the forecasted 2023 system peak load.
c) Please see Attachment 2 provided for this response which contains the
DR MWh portfolio curtailment by hour for each of the four test years for
the following DR portfolio scenarios. Idaho Power’s internally developed
LOLE MATLAB® algorithm was coded to dispatch the maximum capability
of the DR portfolio.
DR Portfolio
Nameplate DR Portfolio Parameters
Scenario 1 300 MW Proposed DR Portfolio Parameters
Scenario 2 492 MW Proposed DR Portfolio Parameters

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

IDAHO POWER COMPANY’S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S
FIRST SET OF DATA REQUESTS- 13
REQUEST FOR PRODUCTION NO. 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 7:
a-c. Please see the attachment provided for this response.
d. The variable cost of each event was zero, because the Flex Peak and
Irrigation Peak Rewards programs did not meet the four-event threshold for
either program to receive variable incentive payments from 2016 to 2020.
The Residential Air Conditioner Cycling program does not have a variable
incentive payment.
The response to this Request is sponsored by Quentin Nesbitt, Customer
Research & Analysis Leader, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S
FIRST SET OF DATA REQUESTS- 14
REQUEST FOR PRODUCTION NO. 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 8:
Please see the attachment provided 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 IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S
FIRST SET OF DATA REQUESTS- 15
REQUEST FOR PRODUCTION NO. 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 9:
Please see the attachments provided for this response.
The Company has estimated the cost for Residential Air Conditioner Cycling,
Commercial & Industrial Flex Peak, and Irrigation Peak Rewards to be $44, $44, and
$47 per Kilowatt (“kW”) of capacity per year respectively with the proposed program
parameters. Because the Flex Peak and Irrigation Peak Rewards program offerings
include a variable incentive payment, the estimates assume the maximum dispatch of
60 hours for both those programs.
The response to this Request is sponsored by Quentin Nesbitt, Customer
Research & Analysis Leader, Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S
FIRST SET OF DATA REQUESTS- 16
REQUEST FOR PRODUCTION NO. 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 10:
a. On a total cost per kW basis, the Flex Peak program is lower than the
Irrigation Peak Rewards program, which provides room for a larger incentive. This is
due to the Irrigation Peak Rewards program having higher administrative costs. Further,
based on Idaho Power’s experience managing the programs, the Company believes it
takes a larger incentive to generate participation with most Flex Peak customers than it
does with many Irrigation Peak Rewards customers.
b. While the proposed Irrigation Peak Rewards incentive payment is less than
half the avoided cost estimate, the overall Irrigation Peak Rewards cost, including
administrative costs, is estimated to be around 90 percent of the avoided cost estimate.
The primary driver of the administrative costs comes from installing and maintaining
load control devices on customer equipment.
The response to this Request is sponsored by Quentin Nesbitt, Customer
Research & Analysis Leader, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S
FIRST SET OF DATA REQUESTS- 17

DATED at Boise, Idaho, this 24th day of January 2022.

LISA D. NORDSTROM
Attorney for Idaho Power Company

IDAHO POWER COMPANY’S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S
FIRST SET OF DATA REQUESTS -18
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the 24th day of January 2022, I served a true and
correct copy of Idaho Power Company’s Response to Idaho Irrigation Pumpers
Association, Inc.’s First Set of Data Requests 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

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Idaho Irrigation Pumpers Association, Inc.
Eric L. Olsen
Echo Hawk & Olsen, PLLC
505 Pershing Ave., Ste. 100
P.O. Box 6119
Pocatello, Idaho 83205
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Lance Kaufman
Aegis Insight
4801 W. Yale Ave.
Denver, CO 80219
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Idaho Conservation League
Benjamin J. Otto
Emma E. Sperry
Idaho Conservation League
710 N. 6th Street
Boise, Idaho 83702
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Industrial Customers of Idaho Power
Peter J. Richardson
Richardson Adams, PLLC
515 N. 27th Street
P.O. Box 7218
Boise, Idaho 83702

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IDAHO POWER COMPANY’S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S
FIRST SET OF DATA REQUESTS -19
Dr. Don Reading
6070 Hill Road
Boise, Idaho 83703

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Micron Technology, Inc.
Austin Rueschhoff
Thorvald A. Nelson
Austin W. Jensen
Holland & Hart LLP
555 17th Street, Suite 3200
Denver, CO 80202
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Jim Swier
Micron Technology, Inc.
8000 South Federal Way
Boise, ID 83707
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Boise City
Ed Jewell
Deputy City Attorney
Boise City Attorney’s Office
150 N. Capitol Blvd. P.O. Box 500
Boise, ID 83701-0500
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________________________________
Stacy Gust, Regulatory Administrative
Assistant

BEFORE THE

IDAHO PUBLIC UTILITIES COMMISSION

CASE NO. IPC-E-21-32

IDAHO POWER COMPANY

REQUEST NO. 1
ATTACHMENT NO. 1
SEE ATTACHED SPREADSHEET

BEFORE THE

IDAHO PUBLIC UTILITIES COMMISSION

CASE NO. IPC-E-21-32

IDAHO POWER COMPANY

REQUEST NO. 2
ATTACHMENT NO. 1
SEE ATTACHED SPREADSHEET

BEFORE THE

IDAHO PUBLIC UTILITIES COMMISSION

CASE NO. IPC-E-21-32

IDAHO POWER COMPANY

REQUEST NO. 2
ATTACHMENT NO. 2
SEE ATTACHED SPREADSHEET

BEFORE THE

IDAHO PUBLIC UTILITIES COMMISSION

CASE NO. IPC-E-21-32

IDAHO POWER COMPANY

REQUEST NO. 2
ATTACHMENT NO. 3
SEE ATTACHED SPREADSHEET

BEFORE THE

IDAHO PUBLIC UTILITIES COMMISSION

CASE NO. IPC-E-21-32

IDAHO POWER COMPANY

REQUEST NO. 2
ATTACHMENT NO. 4
SEE ATTACHED SPREADSHEET

BEFORE THE

IDAHO PUBLIC UTILITIES COMMISSION

CASE NO. IPC-E-21-32

IDAHO POWER COMPANY

REQUEST NO. 6
ATTACHMENT NO. 1
SEE ATTACHED SPREADSHEET

BEFORE THE

IDAHO PUBLIC UTILITIES COMMISSION

CASE NO. IPC-E-21-32

IDAHO POWER COMPANY

REQUEST NO. 6
ATTACHMENT NO. 2
SEE ATTACHED SPREADSHEET

BEFORE THE

IDAHO PUBLIC UTILITIES COMMISSION

CASE NO. IPC-E-21-32

IDAHO POWER COMPANY

REQUEST NO. 7
ATTACHMENT NO. 1
SEE ATTACHED SPREADSHEET

BEFORE THE

IDAHO PUBLIC UTILITIES COMMISSION

CASE NO. IPC-E-21-32

IDAHO POWER COMPANY

REQUEST NO. 8
ATTACHMENT NO. 1
SEE ATTACHED SPREADSHEET

BEFORE THE

IDAHO PUBLIC UTILITIES COMMISSION

CASE NO. IPC-E-21-32

IDAHO POWER COMPANY

REQUEST NO. 9
ATTACHMENT NO. 1
SEE ATTACHED SPREADSHEET

BEFORE THE

IDAHO PUBLIC UTILITIES COMMISSION

CASE NO. IPC-E-21-32

IDAHO POWER COMPANY

REQUEST NO. 9
ATTACHMENT NO. 2
SEE ATTACHED SPREADSHEET

BEFORE THE

IDAHO PUBLIC UTILITIES COMMISSION

CASE NO. IPC-E-21-32

IDAHO POWER COMPANY

REQUEST NO. 9
ATTACHMENT NO. 3
SEE ATTACHED SPREADSHEET