20220121Staff 1-34 to IPC.pdf

DAYN HARDIE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BARNO.9917
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Street Address for Express Mail:
I I331 W CHINDEN BLVD, BLDG 8, SUITE 2OI.A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION TO EXPAND
OPTIONAL CUSTOMER CLEAN ENERGY
OFFERINGS THROUGH THE CLEAN ENERGY
YOUR WAY PROGRAM
CASE NO.IPC.E.2I.4O
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO IDAHO POWER COMPANY
The Staff of the Idaho Public Utilities Commission, by and through its attomey of record,
Dayn Hardie, Deputy Attorney General, requests that Idaho Power Company provide the
following documents and information as soon as possible, but no later than FRIDAY,
FEBRUARY 11,2022.
This Production Request is to be considered as continuing, and Idaho Power 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
FIRST PRODUCTION REQUEST
TO IDAHO POWER
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JANUARY 21,2022
the person preparing the documents. Please also identifu the name, job title, location, and
telephone number of the record holder.
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.
REQUEST NO. 1: Regarding the Community Solar Pilot Program approved by Order
No. 33638 in Case No. IPC-E-16-14 and subsequently suspended by OrderNo. 34317, please
answer the following:
a. The Community Solar Program was suspended due to insufficient enrollment. Please
describe how the Company will receive sufficient participation for the Subscription
options?
b. Please describe how the "high premium cost compared to regular rates" issue from
the Community Solar Pilot Program will be resolved in the new Subscription and
Construction options?
c. Please describe how the "concems about the ability to achieve a return on
investment" issue from the Community Solar Pilot Program will be resolved in the
Subscription and Construction options?
REQUEST NO. 2: In the Application at 8, the Company states "Idaho Power will
record unsold amounts as a charge to the Company's Operation and Maintenance f'O&M"]
expense." Please confirm the O&M expense would be for the Clean Energy Your Way program
If not, please explain.
REQUEST NO.3: The Company's Application at l2 states "based on customer
interest, Idaho Power believes it can fully subscribe the offering as described above with a 50-
100 megawatt resource" for the Subscription option. Please describe how the Company is
determining the approximate size of 50-100 megawatt resource based on customer interest?
How will the Company determine the final size of the resource for the Subscription option?
FIRST PRODUCTION REQUEST
TO IDAHO POWER 2 JANUARY 21,2022
REQUEST NO. 4: For the proposed Clean Energy Your Way Subscription option,
please answer the following:
a. Will customers have any input for the resource selected for this option?
b. When will the Company begin signing up customers for the program?
c. At what percentage of participation and enrollments for the program would the
Company deem suffrcient to operate the program?
d. Will residential customers be able to select term lengths longer than month-to-month?
REQUEST NO. 5: The proposed Construction and Subscription options both implement
a two-phase approach with the second phase requiring Commission approval. Why does the
Company not include proposed tariff language in its Application for the Subscription option
when the Construction offering includes tariff language in this filing? If available, please
provide a copy of the proposed Clean Energy Your Way - Subscription option Tariff.
REQUEST NO. 6: What is the Company's intent for reporting on each option for the
Clean Energy Your Way program?
REQUEST NO. 7: Please describe how the Company will account for the proposed
Subscription and Construction options in the Integrated Resource Plan.
REQUEST NO. 8: Please answer the following about Marketing expenses:
a. Please provide the annual estimated cost of marketing for Clean Energy Your Way
Program broken down by each option (Flexible, Subscription, Construction).
b. Does the Company plan to cap marketing expenses for the program? [f so, at what
percentage or dollar value does the Company plan to Cap expenses.
c. Does the Company plan to cap marketing expenses for each option (Flexible,
Subscription, and Construction) in the program? If so, at what percentage or dollar
value does the Company plan to Cap expenses.
d. Will the Company report marketing expenses for the entire program or individually
for each option (Flexible, Subscription, and Construction)?
FIRST PRODUCTION REQUEST
TO IDAHO POWER 5 JANUARY 21,2022
REQUEST NO. 9: For Option 3, the Large Purchase Option for the Flexible offering in
Schedule 62, please provide additional details about this option including the following:
a. For each year from 2016-2021, please provide the number of customers enrolled in
the Green Power Program and the amount in MWh of yearly purchases for each
customer that would meet the 750 MWh or more per year large purchase option.
b. Will customers have the immediate option of participating in this option?
c. Will customers need to nominate how many MWh per year they plan to purchase to
participate in this option?
d. Will tailored options be billed monthly, yearly, or other?
e. What type of communication will occur with the Commission for the tailored
agreements?
f. What benefits will a customer have by participating in this option versus the
Subscription offering?
REQUEST NO. 10: Schedule 62, Attachment 1, states "participants will designate one
of two billing options upon enrollment;" however, three options are provided. Which two billing
options will participants be able to participate in?
REQUEST NO. ll: Similar to Exhibit No. 2 in the Direct Testimony of Allison
Williams, please provide a mock customer bill for the Construction option.
REQUEST NO. 12: Similar to Exhibit No. 2 in the Direct Testimony of Allison
Williams, please provide a mock customer bill for a tailored agreement for Option 3: Large
Purchase Option under the Flexible option.
REQUEST NO. 13: In the Direct Testimony of Allison Williams, page 50 states "each
construction arrangement will include a no-harm revenue requirement analysis to ensure that
non-participants are held harmless." When does the Company plan to conduct this analysis and
how often will it occur? Will the Company do the same analysis for the Subscription option?
FIRST PRODUCTION REQUEST
TO IDAHO POWER 4 JANUARY 21,2022
REQUEST NO. 14: Please provide all notes and workpapers used in development of
proposed updates to Schedule 62 in Excel format, with formulae intact.
REQUEST NO. 15: Does Jackpot Solar qualifu for the proposed Clean Energy Your
Way Subscription option or the proposed Clean Energy Your Way Construction option?
REQUEST NO. 16: Are there resources that are immediately available for the proposed
Clean Energy Your Way Subscription option and/or proposed Clean Energy Your Way
Construction option. If so, please provide a list.
REQUEST NO. 17: If no resources are immediately available for proposed Schedule
62, please provide a timeline of when such resources that qualiff will be determined.
REQUEST NO. 18: What is the upfront cost to customers for the proposed Clean
Energy Your Way Subscription option and the proposed Clean Energy Your Way Construction
option?
REQUEST NO. 19: Please provide the entire accounting treatment for the proposed
Clean Energy Your Way Subscription option including, but not limited to, deferral account
numbers, expected monthly journal entries of customer participant charges, the Company's
operating expenses of such Subscription Option, cost to procure the resources for such
Subscription option, the financing costs to the Company to procure a resource for such
Subscription Option and all other relevant costs to maintain the proposed Schedule 62 Clean
Energy Your Way Subscription option? Please provide workpapers in Excel format to support
and justiff your answer.
REQUEST NO. 20: Please provide the accounting treatment for the proposed Clean
Energy Your Way Construction option including, but not limited to, monthly joumal entries of
customer participant charges, Company's operating expenses of such Construction option, cost
to procure the resources for such Construction option, the financing costs to the Company to
procure a resource for such Construction option and all other relevant costs to maintain the
FIRST PRODUCTION REQUEST
TO IDAHO POWER 5 JANUARY 21,2022
proposed Schedule 62 Clean Energy Your Way Construction option? Please provide workpapers
in Excel format to support and justi$ your answer.
REQUEST NO.21: If a waiver is granted for the Oregon Public Utilities Commission
Procurement process, what are the financial savings to participants in the proposed Schedule 62
Clean Energy Your Way Subscription Option and proposed Schedule 62 Clean Energy Your
Way Construction Option? Please provide workpapers in Excel format to support your answer.
REQUEST NO. 22: When will customers who subscribe for the proposed Clean Energy
Your Way Subscription option know what the costs will be to participate?
REQUEST NO. 23: Will the Company file an updated revenue requirement for the
proposed Clean Energy Your Way - Subscription option when resource(s) are known?
REQUEST NO. 24: What are the expected costs to operate the entire proposed
Schedule 62 Clean Energy Your Way? Please provide workpapers in Excel format supporting
your answer.
REQUEST NO.25: How will the Company hold non-participants harmless when
Schedule 62 costs exceed revenues?
REQUEST NO.26: Please provide the accounting treatment and impact on non-
participants when Schedule 62 revenues exceed costs.
REQUEST NO. 27: Please provide the accounting treatment and an explanation of how
the Company will hold non-participants harmless from those that participate in the proposed
Clean Energy Your Way Construction option?
REQUEST NO. 28: For the Subscription Offering, please provide a detailed
explanation through examples using assumed values for the different components of the rate
design and by using a likely proxy resource, how the Company will ensure non-participating
FIRST PRODUCTION REQUEST
TO IDAHO POWER 6 JANUARY 21,2022
customers are held harmless for two scenarios: l) the resource is fully subscribed; and 2) the
resource is not fully subscribed, requiring energy from the resource being passed through the
PCA. Please include the following for the two scenarios.
a. The calculations for the program charge.
b. The calculation for the program credit.
c. The amounts included in the participant's bill.
d. The items and amounts that will be passed through the PCA using the new PCA
format.
REQUEST NO.29: Please describe any market research the Company has performed to
determine the price range customers are willing to pay for the Subscription offering. If a price
range has been determined, please explain if current available resources are able to meet the
price range.
REQUEST NO. 30: For the Construction Offering, please provide a detailed
explanation through examples using assumed values for the different components of the rate
design and by using a likely proxy resource, how the Company will ensure non-participating
customers are held harmless. Please provide the calculations for the following hourly situations
relative to paragraph 39 of the Application by including the calculations for the different rate
components and the items and amounts that will be passed through the PCA:
a. When the renewable resource is not generating, and the customer is consuming
energy.
b. When the renewable resource is generating, but it is generating less than the amount
the customer is consuming.
c. When the renewable resource is generating, but it is generating more than the amount
the customer is consuming.
d. When the renewable resource is generating, and the customer is not consuming
energy.
REQUEST NO.3l: Please fully describe the competitive procurement process the
Company envisions for the Subscription and Construction offering resources. In the response,
FIRST PRODUCTION REQUEST
TO IDAHO POWER 7 JANUARY 21,2022
please indicate, for the two types of offerings, if the Company plans to receive competitive bids,
and whether the Company is targeting resources in the form of PPAs, company-owned resources,
or both. Please provide justification for the Company's preferred approach.
REQUEST NO. 32: Please confirm the resources obtained for the Subscription and
Construction Offering are either Company owned or contracted by the Company through a PPA.
If not, please explain.
REQUEST NO. 33: Please explain the risks associated with the Company owning the
generation resource versus the resource being obtained through a PPA for the Subscription
offering and Construction offering, sep arately.
REQUEST NO. 34: For the Construction Offering, please explain if funding a resource
that is Company owned through Contribution in Aid of Construction (CIAC) charged to
participants is possible. Also please provide the advantages and disadvantages of funding the
capital cost of the resource through a CIAC versus the Company recovering the capital
exclusively through customer rates.
DATED at Boise, Idaho, thirL\f day of Janu ary 2022.
Dayn
Deputy Attorney General
i:umisc:prodreq/ipce2 l.40dhtttrrcme prod req I
FIRST PRODUCTION REQUEST
TO IDAHO POWER 8 JANUARY 21,2022
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 21't DAY OF JANUARY 2022,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPAIYY, IN CASE NO. IPC-E-21-40,
BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
LISA NORDSTROM
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: [e-mail]
dockets@idahopower. com
PETER J RICHARDSON
RICHARDSON ADAMS PLLC
515 N 27TH ST
PO BOX 7218
BOISE ID 83702
E-MAIL: [e-mail]
BENJAMIN J OTTO
EMMA E SPERRY
ID CONSERVATION LEAGUE
710 N 6TH ST
BOISE ID 83702
E-MAIL: botto@.idahoconservation.org
esperry@idahoconservation. org
ALISON WILLIAMS
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: [e-mail]
[e-mail]
DON READING
6070 HILL ROAD
BOISE ID 83703
E-MAIL: [e-mail]
J, /D,-^-
SECRETAR'i/
CERTIFICATE OF SERVICE