20220208IPC to ICIP 1-12.pdf

LISA D. NORDSTROM
load Counsel
[e-mail]
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February 8,2022
Jan Noriyuki, Secretary
ldaho Public Utilities Commission
11331 W. Chinden Boulevard
Building 8, Suite 201-A
Boise, ldaho 83714
Case No. IPC-E-21-37
Application of ldaho Power Company for Authority to Establish A New
Schedule to Serve Speculative High-Density Load Customerc
Dear Ms. Noriyuki:
Attached for electronic filing, pursuant to Order No. 35058, is ldaho Power Company's
Response to First Production Request of the lndustrial Customers of ldaho Power in the
above entitled matter.
!f you have any questions about the aftached documents, please do not hesitate to
contact me.
Sincerely
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Lisa D. Nordstrom
SEHM.
nLll-').\
AnD OOtPComEry
P.O. Box 70 (&t707)
1221 W. ld.ho St.
Boisc. lD 8i1702
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Enclosure
LISA D. NORDSTROM (lSB No. 5733)
ldaho Power Company
1221 West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
I n o rdstro m@ida hopower. com
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
AUTHORITY TO ESTABLISH NEW
SCHEDULE TO SERVE SPECULATIVE
H IGH.DENSITY LOAD CUSTOMERS.
CASE NO. IPC-E-21-37
IDAHO POWER COMPANY'S
RESPONSE TO FIRST
PRODUCTION REQUEST OF THE
INDUSTRIAL CUSTOMERS OF
IDAHO POWER TO IDAHO
POWER COMPANY
COMES NOW ldaho Power Company ("ldaho Powef or "Company"), and in
response to First Production Request of the lndustrial Customers of ldaho Power
('lClP') dated January 18,2022, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE INDUSTRIAL
CUSTOMERS OF IDAHO POWER TO IDAHO PO\A'ER COMPANY - 1
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REQUEST FOR PRODUCTION NO. 1:
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.
No formal or informal data requests from IPUC Staff or other parties in this case
were received prior to the time the lndustria! Customers of ldaho Power ('lClP)
submitted their first production request. Allfuture production request responses wil! be
served upon the parties who have intervened in this case, including ICIP.
The response to this Request is sponsored by Stacy Gust, Regulatory
Administrative Assistant, ldaho Power Company.
IDAHO POVVER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE INDUSTRIAL
CUSTOMERS OF IDAHO POWER TO IDAHO POVVER COMPANY - 2
REQUEST FOR PRODUGTION 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 2:
ldaho Power has not researched an exhaustive list of similar tariffs or
commission ordersl in other jurisdictions. Upon the increase in interest in Bitcoin mining
in the northwest region in early 2018,ldaho Power reviewed actions by Chelan County
Public Utility District ('Chelan PUD") in Washington State which experienced system
impacts from significant cryptocurrency mining operations seeking to locate in their
service area. Details on Chelan PUD's cryptocurrency moratorium and new High
Density Load rate schedule may be found on their website:
https://www.chelanpud.oro/mv-pud-services/rates-and-policies/hiqh-densitv-toads
The response to this Request is sponsored by Paul Goralski, Regulatory
Consultant, ldaho Power Company.
1 ldaho Power's Hoku Special Contract contemplated service may be limited when peak demand exceeds
available resources and approved transitional rates to mitigate immediate impact of its load on other
customers, ln the Matter of the Application of ldaho Power Company for Apptoval of a Specia/ Contract to
Supply Electical Power to Hoku Mateials, lnc., Case No. IPC-E48-21 , Order No. 30748, issued March
16,2009.
IDAHO PO\A'ER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE INDUSTRIAL
CUSTOMERS OF IDAHO POWER TO IDAHO PO\A'ER COMPANY - 3
REQUEST FOR PRODUCTION NO. 3:
The Company is proposing that the proposed HDL customer class be fully
interruptible between June 15 and September 15 for total maximum of 225 hours per
year and up to ten hours per event. Please provide copies of ldaho Powefs
research/studies documenting whether HDL customers are able operate under
conditions that include interruptions of that magnitude and duration.
ldaho Power did not conduct studies or research related to the impact of the
curtailment hours or curtailment event duration on Speculative High-Density Load
('HDL) customers. Rather, the focus was on ensuring that the Company avoid the need
to acquire new resources that may ultimately become stranded if Speculative HDL
customers were to relocate or cease operations. Additionally, while 225 hours
represents a maximum, that maximum should not be interpreted as an expected
number of curtailment hours.
The response to this Request is sponsored by Paul Goralski, Regulatory
Consultant, ldaho Power Company.
IDAHO POI/VER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE INDUSTRIAL
CUSTOMERS OF IDAHO PO\TVER TO IDAHO POVVER COMPANY.4
REQUEST FOR PRODUCTION NO.4:
Please explain whether and why a fully interruptible customer for up to 225 hours
between June 15 and September 15 (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 overal! load factor and thus making more efficient use of the
Company's existing distribution, transmission and/or generation resources.
RESPONSE TO REQUEST FOR PRODUCTION NO.4:
ldaho Power proposed the new Schedule 20 rate class in response to potential
significant speculative load growth resulting in a need to acquire new generation
resources, at risk of becoming stranded assets with costs borne by all customers if this
customer segment relocated or ceased operations due to changes in their speculative
market.
ldaho Power has not studied how the overall system revenue requirement would
be impacted as a result of introducing the proposed customer class. However, a future
cost-of-service evaluation would be the appropriate study to determine how avoidance
of the highest capacity hours, or the time of system peak, may result in lower cost
assignment for those system components and how other customer classes may benefit
as a result. The Company believes its proposal is a reasonable near-term offering until
such a detailed study can be performed.
The response to this Request is sponsored by Paul Goralski, Regulatory
Consultant, ldaho Power Company.
IDAHO PO\A'ER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE INDUSTRIAL
CUSTOMERS OF IDAHO POWER TO IDAHO POWER COMPANY - 5
REOUEST FOR PRODUCTION NO.5:
Please identiff the "energy use densig or intensity" in terms of kWft2for the
fifteen highest "energy use density or intensity" customers currently on ldaho Power's
system. \Mat other indicia of energy use density or intensity other than k\A/h/ft2, did the
Company evaluate? PIease provide copies of the Company's research on the
appropriate energy use density or intensity measure for use in its proposed tariff. lf no
other indicia of energy usage intensity density were considered, please explain why or
why not.
RESPONSE TO REQUEST FOR PRODUCTION NO. 5:
ldaho Power does not currently track "energy use density or intensity" for existing
customers and did not evaluate definitions other than 250 k!\rhlft2 or more annually,
which is most common in high density computing applications such as data centers.2
The Company did not consider other indicia of energy usage density or intensity due to
the multiple characteristics required to qualiff for Schedule 20, not solely based on
energy use density or intensity.
The response to this Request is sponsored by Paul Goralski, Regulatory
Gonsultant, ldaho Power Company.
2 Chelan County PUD - Schedule 35 High Density Load - Frequently Asked Questions.
https://rivww.chelanpud.orq/docsidefault-source/default-document-librarv/rate-35-hdl-faos.pdf
Additionally, examples of median Energy Use lntensity in common property types in the United States
may be found on the Energy Star website:
httos://www.enerqystar.qov/buildinos/benchmarUunderstand metricsAi,hat eui
IDAHO PO\A'ER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE INDUSTRIAL
CUSTOMERS OF IDAHO POWER TO IDAHO POVVER COMPANY - 6
REQUEST FOR PRODUCTION NO. 6:
The'Applicability" section of the Company's proposed Schedule 20 at page 20-1
provides that,"Applicable Speculative High-Density Load Large Power Servrbe Rafes
are mandatory for Customers who register a metered Demand of 1,000 kW or more per
Billing period for a minimum of three billing periods..." On the same page, the proposed
schedule provides that it is'[A]pplicable to Customers whose metered energy usage
exceeds 2,000 kWh per Billing Period for a minimum of three Billing Periods..." Please
clariff the applicable threshold(s) the Company is proposing to use for the applicability
of its proposed Schedule 20.
RESPONSE TO REQUEST FOR PRODUCTION NO. 6:
Schedule 20 is applicable to primary or transmission service level customers
whose metered energy usage exceeds 2,000 kilowaft-hour ('k\Mr") per Billing Period for
a minimum of three Billing Periods during the most recent 12 consecutive Billing
Periods, and meet the following:
Customers who have the ability to relocate quickly in response to short-term
economic signals and meet four or more of the following criteria:
. High energy use density;
. High load factor;
. Load that is portable and distributable;
. Highly variable load growth or load reduction as an individual customer
and/or in aggregate with similar customers in the Company's service area;
. High sensitivity to volatile commodity or asset prices;
. Part of an industry with potentia! to quickly become a large concentration
IDAHO POVVER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE INDUSTRIAL
CUSTOMERS OF IDAHO POWER TO IDAHO POWER COMPANY - 7
of power demand;
. Lack of credit history or ability to demonstrate financial viability,
The distinction referenced in the question is related to when'Speculative High-
Density Load Large Power Service Rates'are applicable (for customers who register a
metered Demand of 1,000 kilowatt (k\M) or more for three or more Billing Periods in
the most recent 12 Billing Periods) versus when 'Speculative High-Density Load Large
Genera! Service Rates" are applicable (for customers whose metered Demand has not
equaled or exceeded 1,000 kW more than twice during the most recent 12 Billing
Periods). Both rates are contained in the proposed Schedule 20.
The response to this Request is sponsored by Pau! Goralski, Regulatory
Consultant, ldaho Power Company.
TDAHO POVVER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE INDUSTRIAL
CUSTOMERS OF IDAHO POWER TO IDAHO POVVER COMPANY - 8
REQUEST FOR PRODUGTION NO. 7:
The "Applicability" section of the Company's proposed Scheduled 20 al page 20-
2 provides that, "Serurce under this schedule is applicable to and may be mandatory for
Customers who have the ability to ....' Please reconcile the use of the two phrases "r's
applicable fo" and 'may be mandatory." If the proposed schedule "may be mandato{
please explain who will make the determination as to when it is or, is not, mandatory
and what criterialwill be used in making the determination.
RESPONSE TO REQUEST FOR PRODUCTION NO. 7:
ldaho Power will determine whether service is mandatory under Schedule 20
based on an evaluation of the criteria outlined in the schedule's applicability section.
The response to this Request is sponsored by Paul Goralski, Regulatory
Consultant, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE INDUSTRIAL
CUSTOMERS OF IDAHO POWER TO IDAHO POVVER COMPANY - 9
:
The Company's Application describes a common attribute of a high energy use
density or intensity as a customer that consumes '250 k!ryh/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 first 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 8:
A customer that consumes 250 kl /h/ft2 or more annually is the criteria to
determine high energy use density for applicability of proposed Schedule 20.
The response to this Request is sponsored by Paul Goralski, Regulatory
Consultant, ldaho Power Company.
IDAHO POVVER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE INDUSTRIAL
CUSTOMERS OF IDAHO POWER TO IDAHO POI/VER COMPANY. 1O
REQUEST FOR PRODUGTION NO. 9:
The second of the seven criteria is, .High load factor.' Proposed Schedule 20,
however, does not define the term "High Ioad 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 9:
Load factor of 85% or higher is the criteria to meet "high load factof for the
purposes of the applicability of proposed Schedule 20.
The response to this Request is sponsored by Paul Goralski, Regulatory
Consultant, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE INDUSTRIAL
CUSTOMERS OF IDAHO PO\'\'ER TO IDAHO POWER COMPANY - 11
:
The third of the seven criteria is,'Load 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 Load that is portable and distributable' for purposes of the applicability of
proposed Schedule 20.
RESPONSE TO REQUEST FOR PRODUGTION NO. {O:
"Load that is portable and distributable" is a characteristic of Application-Specific
lntegrated Circuit ('ASlC") or other highly specialized cryptocurrency specific hardware.
A single machine is approximately the size of a shoe box and ranges in load from 1.3
kW to over 3 kW. ASIC and other mining machines have limited infrastructure needs,
namely electricity and internet, and may be disaggregated quickly. To illustrate,
machines at one central location of 1 megawatt ("MW') could easily disaggregate to 10
locations of 100 kW each, which is not typical of traditional data centers that are
designed with more permanent placement of equipment.
The response to this Request is sponsored by Paul Goralski, Regulatory
Consultant, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE INDUSTRIAL
CUSTOMERS OF IDAHO PO\A'ER TO IDAHO POVVER COMPANY - 12
REQUEST FOR PRODUCTION NO. 11:
The fourth of the seven criteria is "Highly variable load grov'rth or load
reduction..." Proposed Schedule 20, however, does not define the phrase "Highly
variable load growth or load reduction..." Please define or provide the criterial the
Company will use in determining, what is "Highly variable load groMh or load
reduction..." for purposes of the applicability of proposed Schedule 20. Does the
Company have load growth/variation criteria it intends to apply? lf so, please describe
the criterial intended to be applied.
RESPONSE TO REQUEST FOR PRODUCTION NO. {1:
The Company has not determined the specific load growth or variation criteria;
rather, ldaho Power would evaluate the changes in requested load growth or load
reductions from customers on a case-by-case basis.3
The response to this Request is sponsored by Paul Goralski, Regulatory
Consultant, ldaho Power Company.
3 ldaho Power's Rule K, Change in Load Characteristic, requires'the Customer shall give the Company
prior notice before making any significant change in either the amount or electrical character of the
Custome/s electrical load thereby allowing the Company to determine if any changes are needed in the
Company's equipment or distribution system.'
httos://docs. idahooower.com/pdfs/aboutus/ratesrequlatorv/tariffs/35.pdf
IDAHO PO\A'ER COMPANY'S RESPONSE TO F]RST PRODUCT]ON REQUEST OF THE INDUSTRIAL
CUSTOMERS OF IDAHO POWER TO IDAHO PO\A'ER COMPANY - 13
REQUEST FOR PRODUCTION 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, it is 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?
RESPONSE TO REQUEST FOR PRODUCTION NO. 12:
ldaho Power highlights that the criteria of "high sensitivity to volatile commodity
or asset prices" is not the sole determination of applicability of Schedule 20. Rather, as
identified on page 12 of the Company's Application, "high sensitivity to volatile
commodity or asset prices' could be one of the four (4) or more characteristics required
to meet the designation as a high-density speculative load. Based on the significant
price declines and increases for Bitcoin as documented in the Company's Application,
customer sensitivity to an asset such as cryptocurrencies would meet the criteria. A
computer chip manufacturer or food processing facility would not qualiff for Schedule
20 due to not meeting the criteria of "Customers who have the ability to relocate quickly
in response to short-term economic signals" and requirement to meet four of more of
the remaining criteria.
The response to this Request is sponsored by Paul Goralski, Regulatory
Consultant, ldaho Power Company.
IDAHO PO\A/ER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE INDUSTRIAL
CUSTOMERS OF IDAHO POWER TO IDAHO POWER COMPANY - 14
DATED at Boise, ldaho, this 8th day of February 2022.
X;!.ff"*t *,
LISA D. NORDSTROM
Attorney for ldaho Power Company
IDAHO POVVER COMPANYS RESPONSE TO FIRST PRODUCTION REQUEST OF THE INDUSTRU\L
CUSTOMERS OF IDAHO POVIJER TO IDAHO POVT'ER COMPANY. 15
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 8th day of February 2022, I served a true and
correct copy of ldaho Power Company's Response to First Production Request of the
lndustrial Customers of ldaho Power to ldaho Power Company upon the following named
parties by the method indicated below, and addressed to the following:
Commission Staff
Riley Newton
Deputy Attorney General
ldaho Public Utilities Commission
11331 W. Chinden Blvd., BIdg. No. 8,
Suite 201-A (83714)
PO Box 83720
Boise, lD 83720-0074
lndustrial Customers of ldaho Power
Peter J. Richardson
Richardson Adams, PLLC
515 N.27th Street
P.O. Box 7218
Boise, ldaho 83702
Dr. Don Reading
6070 Hill Road
Boise, lD 83703
2140 Labs LLC
Elizabeth A. Koeckeritz
Givens Pursley LLP
601 W. Bannock Street
Boise, ldaho 83702
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5,hc",* (}^t,
Stacy Gust, Regulatory Administrative
Assistant
IDAHO POVVER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE INDUSTRIAL
CUSTOMERS OF IDAHO POWER TO IDAHO PO\A'ER COMPANY. 16