20220201IPC to IIPA Supplemental 10.pdf

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February 1,2022
VIA ELECTRONIC FILING
Jan Noriyuki, Secretary
ldaho Public Utilities Commission
11331 West Chinden Blvd., Building 8
Suite 201-A
Boise, ldaho 83714
Case No. IPC-E-21-32
ln the Matter of ldaho Power Company's Application forApproval to Modify
Its Demand Response Programs
Dear Ms. Noriyuki:
Attached for electronic filing, pursuant to Order No. 35058, is ldaho Power
Company's Supplemental Response to ldaho lrrigation Pumpers Association, lnc.'s First
Set of Data Requests in the above entitled mafter.
If you have any questions about the attached document, please do not hesitate to
contact me.
Very truly yours,
LISA D. NORDSTROM
Lead Counsel
I [e-mail]
LDN:sg
Attachment
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Lisa D. Nordstrom
LISA D. NORDSTROM (lSB No. 5733)
ldaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
I n ordstrom@ ida h ooower. com
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UT!LITIES COMMlSSlON
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR
APPROVAL TO MODIFY ITS DEMAND
RESPONSE PROGRAMS.
CASE NO. !PC-E-21-32
IDAHO POWER COMPANY'S
SUPPLEMENTAL RESPONSE TO
IDAHO IRRIGATION PUMPERS
ASSOCIATION, INC.'S F!RST SET
OF DATA REQUESTS
COMES NOW, ldaho Power Company ("ldaho Powef or "Company'), hereby
supplements its response to ldaho lrrigation Pumpers Association, lnc.'s ('llPA") First
Set of Data Requests to ldaho Powerdated January 3,2022 and herewith submits the
following information:
IDAHO POWER COMPANY'S SUPPLEMENTAL RESPONSE TO IDAHO IRRIGATION PUMPERS
ASSOCIATION, INC.'S FIRST SET OF DATA REQUESTS- 1
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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 lrrigation Peak Rewards Program.
b. Please explain why the incentive payment for the lrrigation Peak Rewards
Program is less than half the avoided cost estimate of $51 .42 per kW per
year.
RESPONSE TO REQUEST FOR PRODUCTION NO. {O:
a. On a total cost per kW basis, the Flex Peak program is lower than the
lrrigation 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 ldaho 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 lrrigation Peak Rewards customers.
b. \Mile the proposed lrrigation Peak Rewards incentive payment is less than
half the avoided cost estimate, the overall lnigation 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.
SUPPLEMENTAL RESPONSE TO REQUEST NO. 10:
Subsequent to filing its Response to llPA's First Set of Production Request, the
Company received an llPA request for additional information related to program
expenditures. Specifically, ldaho Power was asked to provide information related to
IDAHO POWER COMPANY'S SUPPLEMENTAL RESPONSE TO IDAHO IRRIGATION PUMPERS
ASSOCIATION, INC.'S FIRST SET OF DATA REQUESTS- 2
historic annual non-incentive costs for the program, how are the costs of signing up for
the program capitalized and/or depreciated, and why the program costs for the other DR
programs are so much lower than irrigation.
Supplement 2 of the Company's DSM Annua! Report contains Flex Peak and
lrrigation Peak Rewards program specific reports, which break down program costs into
additional categories. DSM Annual Reports for program years 2018 -2020 are
available on the Company's website (Enerqv Efficiencv Pro
Power). lf requested, the Company can make prior program year reports available. ln
addition, the individual DR program sections of the DSM Annua! Report contain
incentive and cost information. For referenoe, see pages 30, 112, and 127 of the 2020
DSM Annual Report for information related to the A/C Cool Credit Program, the C&l
Flex Peak Program, and the Peak Rewards programs, respectively.
Administrative costs of the programs are expensed through the respective ldaho
and Oregon Energy Efficiency Riders in the year they are incurred. ldaho incentive
costs are collected through base rates, with variances being adjusted for using the
Company's Annual Power Cost Adjustment ("PCA") mechanism. Oregon incentives are
expensed through the Oregon Rider. No costs associated with the DR programs are
capitalized.
The capacity of the lrrigation Peak Rewards program is usually eight to ten times
larger than the Company's other two DR programs, which correlates with the difference
in total dollar costs. ln Response No. 9 to llPA's First Set of Data Requests, the costs of
the proposed programs, on a per kW basis, are expected to be relatively the same. This
assumes the maximum 60-hour dispatch of the DR programs to include the variable
IDAHO POWER COMPANY'S SUPPLEMENTAL RESPONSE TO IDAHO IRR]GATION PUMPERS
ASSOCIATION, INC.'S FIRST SET OF DATA REQUESTS.3
incentive payments for the Flex Peak and lnigation programs. Actua! per kW costs
between the programs could vary based on the number of events called in a season.
The response to this Request is sponsored by Quentin Nesbitt, Customer
Research & Analysis Leader, ldaho Power Company.
DATED at Boise, ldaho, this 1st day of February 2022
Xr;^0.fl"*+r-*,
LISA D. NORDSTROM
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S SUPPLEMENTAL RESPONSE TO IDAHO IRRIGAT]ON PUMPERS
ASSOCIATION, INC.'S FIRST SET OF DATA REQUESTS- 4
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 1st day of February 2022,1 served a true and
correct copy of ldaho Power Company's Supplemental Response to ldaho lrrigation
Pumpers Association, lnc.'s First Set of Data Requests upon the following named parties
by the method indicated below, and addressed to the following:
Gommission Staff
Riley Newton
Deputy Attorney General
ldaho Public Utilities Gommission
11331 W. Chinden Blvd., Bldg No. 8,
Suite 201-A (83714)
PO Box 83720
Boise, lD 83720-0074
ldaho lrrigation Pumpers Association, lnc.
Eric L. OIsen
Echo Hawk & Olsen, PLLC
505 Pershing Ave., Ste. 100
P.O. Box 6119
Pocatello, ldaho 83205
Lance Kaufman
Aegis lnsight
4801 W. Yale Ave.
Denver, CO 80219
ldaho Gonservation League
Benjamin J. Otto
Emma E. Sperry
ldaho Conservation League
710 N. 6th Street
Boise, Idaho 83702
lndustrial Customers of ldaho Power
Peter J. Richardson
Richardson Adams, PLLC
515 N. 27m Street
P.O. Box 7218
Boise, ldaho 83702
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IDAHO POWER COMPANY'S SUPPLEMENTAL RESPONSE TO IDAHO IRRIGATION PUMPERS
ASSOCIATION, INC.'S FIRST SET OF DATA REQUESTS . 5
Dr. Don Reading
6070 Hill Road
Boise, ldaho 83703
Micron Technology, lnc.
Austin Rueschhoff
Thorvald A. Nelson
Austin W. Jensen
Holland & Hart LLP
555 17th Street, Suite 3200
Denver, CO 80202
Jim Swier
Micron Technology, !nc.
8000 South FederalWay
Boise, lD 83707
Boise City
Ed Jewell
Deputy City Attomey
Boise City Attorney's Office
150 N. Capitol Blvd. P.O. Box 500
Boise, lD 83701-0500
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tnelson @hollandha rt.com
awiensen@holland hart.com
aclee@holland hart. com
q lqarqanoama ri@holla nd ha rt.com
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bo isecitvatto rnev@citvofbo ise. o ro
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Stacy Gust, Regulatory Administrative
Assistant
IDAHO POWER COMPANY'S SUPPLEMENTAL RESPONSE TO IDAHO IRRIGATION PUMPERS
ASSOCIATION, INC.'S FIRST SET OF DATA REQUESTS - 6