20220323IPC to Staff 18-20.pdf

LISA D. NORDSTROM
Lead Counsel
[e-mail]
March 23, 2022
Jan Noriyuki, Secretary
Idaho Public Utilities Commission
11331 W. Chinden Boulevard
Building 8, Suite 201-A
Boise, Idaho 83714
Re: Case No. IPC-E-21-37
Application of Idaho Power Company for Authority to Establish A New
Schedule to Serve Speculative High-Density Load Customers
Dear Ms. Noriyuki:
Attached for electronic filing, pursuant to Order No. 35058, is Idaho Power Company’s
Response to the Second Production Request of the Commission Staff in the above
entitled matter.
If you have any questions about the attached documents, please do not hesitate to
contact me.
Sincerely,
Lisa D. Nordstrom
LDN:sg
Enclosure
RECEIVED
2022 MAR 23 PM 4:13
IDAHO PUBLIC
UTILITIES COMMISSION
IDAHO POWER COMPANY’S RESPONSE TO SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 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 THE APPLICATION
OF IDAHO POWER COMPANY FOR
AUTHORITY TO ESTABLISH NEW
SCHEDULE TO SERVE SPECULATIVE
HIGH-DENSITY LOAD CUSTOMERS.
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CASE NO. IPC-E-21-37

IDAHO POWER COMPANY’S
RESPONSE TO SECOND
PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO
POWER COMPANY

COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), and in
response to Second Production Request of the Commission Staff (“IPUC or
Commission”) dated March 2, 2022, herewith submits the following information:
IDAHO POWER COMPANY’S RESPONSE TO SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 2
REQUEST FOR PRODUCTION NO. 18: In the Application, page 5, the
Company states, “Within the span of several months, Idaho power received seventeen
(17) viable and unique inquires totaling over 1,950 MW.” Please respond to the
following:
a. Have any of the 17 inquiries continued to pursue obtaining service with the
Company after the initial inquiry?
b. For each of the inquiries that have continued pursuit of service with the
Company, what service schedule did they request and which of the current
schedules provides the best fit for their service requirements.
c. For each of the 17 inquiries that did not pursue service, please provide the
reasons for discontinuing pursuit of service.
RESPONSE TO REQUEST FOR PRODUCTION NO. 18:
a. No. After conducting their initial due diligence, the 17 inquiries are not
currently pursuing service.
b. Please see the answer to (a).
c. The 17 inquiries did not provide specific reasons for not pursuing service with
Idaho Power.
The response to this Request is sponsored by Megan Ronk, Economic
Development & Innovation Director, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 3
REQUEST FOR PRODUCTION NO. 19: Because of the Company’s obligation
to serve, if the Company was to establish a schedule for High Density Load Customers
that was not interruptible, what protections would need to be included that would protect
remaining customers from paying for potential stranded assets? Please include any
specific changes that would need to be made to existing schedules or rules, including
but not limited to changes to Rule L: Deposits.
RESPONSE TO REQUEST FOR PRODUCTION NO. 19: In advance of the
Company’s filing to require High Density Load customers to be interruptible, Idaho
Power also evaluated a moratorium for commercial High Density Load customers
similar to what was enacted by the Chelan County and Douglas County Public Utility
Districts in Washington State.1 Other than a potential moratorium, the Company has not
evaluated establishing a schedule for High Density Load customers which does not
include interruptibility and does not have a list of customer protections for an alternate
proposal. The intent of Idaho Power’s filing requiring interruptibility is in consideration of
potential future stranded costs borne by all other Idaho Power customers arising from
the need for additional investment in the Company’s generation and transmission
infrastructure to serve the proposed Schedule 20 customer segment. The Company’s
existing standard service schedules do not offer the forum to address the potential for
stranded assets associated with generation and transmission infrastructure investment

1 Washington State County Moves to Limit New Bitcoin Mining Firms, Coindesk, March 21, 2018.
https://www.coindesk.com/markets/2018/03/21/washington-state-county-moves-to-limit-new-bitcoin-
mining-firms/

Douglas PUD puts moratorium on new data centers, crypto miners, The Wenatchee World, May 17, 2019.
https://www.wenatcheeworld.com/business/douglas-pud-puts-moratorium-on-new-data-centers-crypto-
miners/article_6872aeec-78df-11e9-8c8b-b752987751bc.html

IDAHO POWER COMPANY’S RESPONSE TO SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 4
to serve a speculative customer segment.
The response to this Request is sponsored by Paul Goralski, Regulatory
Consultant, Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 5
REQUEST FOR PRODUCTION NO. 20: In reference to the 90 percent Effective
Load Carrying Capability (“ELCC”) and the required 225 hours of possible curtailment
mentioned in Response to Staff’s Production Request No. 6. Please respond to the
following:
a. Please explain how the 90 percent ELCC threshold was determined.
b. Please provide the workpapers with formulae enabled used to determine 225
hours of possible curtailment.
RESPONSE TO REQUEST FOR PRODUCTION NO. 20:
a. The Effective Load Carrying Capability (“ELCC”) of a simple cycle combustion
turbine is slightly above 90 percent. The Company believes an ELCC of 90
percent for Schedule 20 coupled with the ability to curtail Schedule 20
demand during a system emergency (as provided for in Rule J, Continuity,
Curtailment and Interruption of Electric Service) will avoid the need to add
incremental capacity resources.
b. ELCC analysis supporting the 225 hours of possible curtailment was
determined using Idaho Power’s Loss of Load Expectation (“LOLE”) tool,
which was created in MATLAB® and requires a license to run. The MATLAB®
algorithm is comprised of a multitude of interplaying scripts which apply the
methods and equations described in the Reliability Evaluation of Power
Systems (Billinton & Allan 1984) textbook. Idaho Power has provided the
scripts as attachments to this response and can host an on-site meeting to
demonstrate the tool, if desired.

IDAHO POWER COMPANY’S RESPONSE TO SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 6
 Billinton, Roy, and Ronald N. Allan. Reliability Evaluation of Power
Systems. Pitman Books Limited, 1984.
The response to this Request is sponsored by Jared Ellsworth, Transmission
Distribution & Resource Planning Director, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 7
DATED at Boise, Idaho, this 23rd day of March 2022.

LISA D. NORDSTROM
Attorney for Idaho Power Company

IDAHO POWER COMPANY’S RESPONSE TO SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 8
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the 23rd day of March 2022, I served a true and
correct copy of Idaho Power Company’s Response to Second Production Request of the
Commission Staff to Idaho Power Company 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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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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Dr. Don Reading
6070 Hill Road
Boise, ID 83703
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2140 Labs LLC
Elizabeth A. Koeckeritz
Givens Pursley LLP
601 W. Bannock Street
Boise, Idaho 83702
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________________________________
Stacy Gust, Regulatory Administrative
Assistant

BEFORE THE

IDAHO PUBLIC UTILITIES COMMISSION

CASE NO. IPC-E-21-37

IDAHO POWER COMPANY

REQUEST NO. 20

ATTACHMENT 1

SEE ATTACHED ZIP FILE