20220118ICIP 1-12 to IPC.pdf

Peter J. Richardson
ISB No. 3195
Richardson Adams, PLLC
515 N.27th Street
P.O. Box 7218
Boise, Idaho 83702
Telephone: [phone] I
Fax: [phone]
peter@richardsonadams. com
Attorneys for the Industrial Customers of Idaho Power
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
THE IDAHO POWER COMPANY FOR
AUTHORITY TO ESTABLISH A NEW
SCHEDULE TO SERVE SPECULATIVE
HIGH-DENSITY LOAD CUSTOMERS.
CASE NO. IPC-E-21-37
FIRST PRODUCTION REQUEST OF
THE INDUSTRIAL CUSTOMERS OF
IDAHO POWER TO IDAHO POWER
COMPANY
Pursuant to Rule 225 of the Rules of Procedure of the Idaho Public Utilities Commission
(the "Commission"), the Industrial Customers of ldaho Power ("ICIP") by and through their
attorney of record, Peter J. Richardson, hereby requests that ldaho Power Company ("ldaho
Powsr" or the "Company") provide the following documents.
This production request is to be considered as continuing, and the Company is requested
to provide by way of supplemental responses additional documents that it or any person acting
on its behalf may later obtain that will augment the documents produced.
Please provide one physical copy and one electronic copy, if available, of your answer to
Mr. Richardson at the address noted above. Please provide an additional electronic copy, or if
unavailable a physical copy, to Dr. Don Reading at: 6070 Hill Road, Boise, Idaho 83703,
dreadi ng@m i ndspri ng.com.
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RECEIVED
2022 JAN 18 PM 3:39
IDAHO PUBLIC
UTILITIES COMMISSION
For each item, please indicate the name of the person(s) preparing the answer(s), along
with the job title of such person(s) and the witness at hearing who can sponsor the answer.
REQUEST FOR PRODUCTION NO. t:
Please provide copies of all of the Company's responses to data requests from the IPUC
Staff (or any other party) in this matter. Please include responses to informal as well as formal
requests and oral as well as written requests.
REQUEST FOR PRODUCTION NO. 2:
Please provide copies of all similar tariffs and commission orders from jurisdictions other
than ldaho, and general research reviewed/analyzed in preparing the Company's application in
this case.
REQUEST FOR PRODUCTION NO.3:
The Company is proposing that the proposed HDL customer class be fully intemrptible
between June l5 and September l5 for total maximum of 225 hours per year and up to ten hours
per event. Please provide copies of Idaho Power's research/studies documenting whether HDL
customers are able operate under conditions that include intemrptions of that magnitude and
duration.
REQUEST FOR PRODUCTTON NO.4:
Please explain whether and why a fully intemrptible customer for up to 225 hours
between June l5 and September l5 (as proposed by the Company herein) may be able to actually
reduce or mitigate ldaho Power's cost to provide service by possibly increasing the Company's
overall load factor and thus making more effîcient use of the Company's existing distribution,
transmission and/or generation resources.
ICIP First Data Request of IPCo - IPC-E-2I-37 2
R-EQUEST FOR PRODUCTTON NO. 5:
Please identify the "energy use density or intensity" in terms of kWh/ft2 for the fifteen
highest "energy use density or intensity" customers currently on Idaho Power's system. What
other indicia of energy use density or intensity, other than kWh/ft2, did the Company evaluate?
Please provide copies of the Company's research on the appropriate energy use density or
intensity measure for use in its proposed tariff. If no other indicia of energy usage intensity
density were considered, please explain why or why not.
REQUEST FOR PRODUCTION NO. 6:
The "Applicability" section of the Company's proposed Schedule 20 atpage 20-l
provides that,*Applícable Speculative High-Density Load Large Power Service Rates are
mandatoryfor Customers who register q metered Demand of 1,000 kí4 or more per Billing
period for a minimum of three billing periods .. . ." On the same page, the proposed schedule
provides that it is" [AJpplícable to Customers whose metered energy usage exceeds 2,000 kWh
per Billing Period for a minimum of three Bitling Periods.. . ." Please clarify the applicable
threshold(s) the Company is proposing to use for the applicability of its proposed Schedule 20.
REQUEST FOR PRODUCTION NO. 7:
The "Applicability" section of the Company's proposed Schedule 20 atpage20-2
provides that,"Service under this schedule is applicable to and may be mqndatory.for Customers
who have the ability to... ." Please reconcile the use of the two phrases"is applicable to" and
"may be mandatory. " If the proposed schedule "may be mandatory " please explain who will
make the determination as to when it is or, is not, mandatory and what criterial will be used in
making that determination.
ICIP First Data Request of IPCo - IPC-E-2I-37 IJ
REQUEST FOR PRODUCTTON NO. 8:
The Company's Application describes a common attribute of a high energy use density or
intensity as a customer that consumes "250 kwh/ft2 annually." Proposed Schedule 20 identifies
seven criteria to be applied in determining the applicability of the tariff to a particular customer.
The schedule is applicable to a customer that meets four of the seven criteria. The hrst of the
seven criteria is, "High energy use density." Proposed Schedule 20, however, does not define
the term "high energy use density." Please define or provide the criteria the Company will use in
determining, what is "high energy use density" for purposes of the applicability of proposed
Schedule 20.
REQUEST FOR PRODUCTTON NO.9:
The second of the seven criteria is, "High load factor." Proposed Schedule 20, however,
does not define the term "High load factor." Please define or provide the criteria the Company
will use in determining, what is a "High load factor" for purposes of the applicability of
proposed Schedule 20.
REQUEST FOR PRODUCTTON NO. 10:
The third of the seven criteria is, 'o[-oad that is portable and distributable." Proposed
Schedule 20, however, does not define the phrase "Load that is portable and distributable."
Please define or provide the criteria the Company will use in determining, what is a o'Load that is
portable and distributable" for purposes of the applicability of proposed Schedule 20.
REQUEST FOR PRODUCTION NO. 11:
The fourth of the seven criteria is "Highly variable load growth or load reduction... ."
Proposed Schedule 20, however, does not dehne the phrase "Highly variable load growth or load
reduction... ." Please define or provide the criteria the Company will use in determining, what is
ICIP First Data Request of IPCo IPC-E-21-37 4
"Highly variable load growth or load reduction... ." for purposes of the applicability of proposed
Schedule 20. Does the Company have load growth/variation criteria it intends to apply? If so,
please describe the criteria intended to be applied.
REQUEST FOR PRODUCTTON NO. 12:
The fifth of the seven criteria is met for a customer that has a "High sensitivity to volatile
commodity or asset prices." Please provide the criteria the Company will use in determining
whether a particular customer is highly sensitive to volatile commodity or asset prices. For
example, is it the Company's opinion that a computer chip manufacturer would be one such
customer or a food processing facility such as a yogurt or cheese processing plant?
DATED this l8th day of January 2022
Peter J.
RICHARDSON ADAMS, PLLC
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 18th day of January 2022, a true and correct copy of the within
and foregoing FIRST PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF
IDAHO POWER in Docket No. IPC-E-21-31was served electronically to:
Lisa Nordstrom
Regulatory Dockets
Idaho Power Company
lnordstrom@ idahopower. com
dockets@idahopower. com
Connie Aschenbrenner
Idaho Power Company
cashenbrenner@,idahopower. com
ICIP First Data Request of IPCo IPC-E-21-37 5
Elizabeth A. Koeckeritz
Givens Pursley LLP
601 West Bannock Street
Boise,Idaho 83701
eak@ givenspursley. com
Jan Noriyuki, Secretary
Idaho Public Utilities Commission
Jan.noriyuki@puc. idaho. gov
Prh
Peter Richardson
ICIP First Data Request of IPCo -[PC-E-21-37 6