20220121Staff 1-17 to IPC.pdf

RILEY NEWTON
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-007 4
(208) 334-03r8
IDAHO BAR NO. 11202
Street Address for Express Mail:
I I33I W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORB THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF'THE APPLICATION OF
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
COMMISSION STAFF
TO IDAHO POWER COMPANY
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Riley Newton, Deputy Attorney General, requests that Idaho Power Company ('oCompany")
provide the following documents and information as soon as possible, but no later than
FRTDAY, FEBRUARY 11, 2022.
This Production Request is to be considered as continuing, and the Company 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 documents or information produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name, job title, and telephone number of
the person preparing the documents. Please also identify the name, job title, location, and
telephone number of the record holder.
FIRST PRODUCTION REQUEST
TO IDAHO POWER
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1 JANUARY 21,2022
In addition to the written copies provided as response to the requests, please provide all
Excel spreadsheets and electronic files on CD with formulas intact and enabled.
RB,QUEST NO. 1: Please provide the workpapers used to derive the capacity costs and
demand charge discussed on page 14 of the Application. Please include any source input data
used.
REQUEST NO. 2: Please explain the rationale for the Company's proposal to reallocate
the portion of cost-of-service derived summer generation capacity costs from on-peak demand
charge to a standard demand charge.
RE,QUEST NO.3: Please provide the workpapers used to derive the marginal energy
pricing discussed on page 15 of the Application. Please include any source input data used.
REQUEST NO. 4: Please provide an electronic copy of the workpapers used to create
Attachment 2, with all formulae enabled.
REQUEST NO. 5: Please provide the definitions including any applicable measurable
standards for the characteristics of a High Density Load (HDL) customer mentioned on page 12
of the Application and included in the proposed Schedule 20 tariff.
REQUEST NO. 6: Please explain how the parameters for interruptible service discussed
on page 14 of the Application were determined and are applicable to the proposed Schedule 20
class. Please also explain if the interruptible parameters will change if they are modified or not
approved in IP C -E-21 -32.
REQUEST NO. 7: In the Application, page 16, the Company states, "Upon Commission
approval of a new schedule, the Company will transition qualiffing customers the Commission-
approved Schedule 20." Please respond to the following:
FIRST PRODUCTION REQUEST
TO IDAHO POWER 2 JANUARY 21,2022
a. Please explain how the Company will be able to determine if an existing customer
qualifies for Schedule 20, by including the specific measurable standards identified
above.
b. Please explain how the Company will be able to identiff if an existing customer starts
cryptocurrency mining in the future.
c. Please explain if the Company has identified other business operations, besides
cryptocurrency mining, which may meet some of the criteria for Schedule20.
REQUEST NO. 8: Please explain in detail how the design of this new customer class
will prevent disaggregation and relocation as discussed on page 4 of the Application and how the
Company plans to enforce compliance to prevent it.
REQUEST NO. 9: Please provide all workpapers supporting the figures and tables
found in the Application in Excel format with formulae intact.
REQUEST NO. 10: Please provide a timeline of construction for the necessary
upgrades to connect a proposed Schedule 20 customer, on average.
REQUEST NO. 1l: Please provide a list of current Idaho Power customers that would
qualifr for the proposed Schedule 20.
REQUEST NO. 12: Please provide a list of Idaho Power customers that have
intemrptible service agreements, like those proposed in Schedule 20. Do not include those that
participate in a Demand Response program.
REQUEST NO. 13: Please provide an average projected cost to upgrade the system to
hook up a potential high-density load customer. Include a list of equipment and the respective
cost in your response.
REQUEST NO. 14: Please provide the accounting treatment of proposed Schedule 20
customers deposits and infrastructure upgrades.
FIRST PRODUCTION REQUEST
TO IDAHO POWER J JANUARY 21,2022
REQUEST NO. 15: If a customer that qualifies for this class doesn't want intemrptible
service, what options does this customer have? Please explain.
REQUEST NO. 16: Could the intemrptible requirement for Schedule 20 customers be
replaced by a requirement to participate in some form of Demand Response? Please provide a
discussion of the feasibility.
REQUEST NO. 17: Please provide the notice to customers prior to interruption of
servlce.
DATED at Boise,Idaho, tnis Zl{ Ourof January 2022.
Riley
Deputy A General
i:umisc:prodreq/ipce2l.37mme prod req I
FIRST PRODUCTION REQUEST
TO IDAHO POWER 4 JANUARY 21,2022
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 2IST DAY OF JANUARY 2022,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY, IN CASE NO.
IPC-E-2I-37, BY E.MAILING A COPY THEREOF, TO THE FOLLOWING:
LISA NORDSTROM
IDAHO POWER COMPANY
PO BOX 70
BOrSE ID 83707-0070
E-MAIL: [e-mail]
[e-mail]
PETER J RICHARDSON
RICHARDSON ADAMS PLLC
515 N 27TH ST
PO BOX 7218
BOISE ID 83702
E-MAIL : oeter(E richardsonadams.com
ELIZABETH A KOECKERITZ
GIVENS PURSLEY LLP
60I W BANNOCK ST
BOISE ID 82702
E-MAIL: [e-mail]
CONNIE ASCHENBRENNER
RATE DESIGN SENIOR MGR
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL : caschenbrenner(E idahopower.com
DON READING
6070 HILL ROAD
BOISE ID 83703
E-MAIL: [e-mail]
SECRET Y
CERTIFICATE OF SERVICE