20220304Staff 35-55 to IPC.pdf

DAYN HARDIE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03t2
IDAHO BARNO.9917
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Street Address for Express Mail:
1 1331 W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, ID 83714
Attomey 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-21.40
SECOND 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,
Dayn Hardie, Deputy Attomey General, requests that Idaho Power Company provide the
following documents and information as soon as possible, but no later than FRIDAY,
MARCH 25,2022.
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
SECOND PRODUCTION REQUEST
TO IDAHO POWER
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MARCH 4,2022
the person preparing the documents. Please also identifr 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.35: Please provide a copy of the Green Power Program Biennial
Prudency Report and workpapers for years 2020 and 2021. If not complete, please provide the
expected completion date and supplement this response with the completed report.
REQUEST NO. 36: For the Green Power program, please provide the total
Renewable Enerry Credit ("REC") purchases for Idaho in 2021 and include RECs that
were pnrchased in 2022 to fulfill 2021 program requirements.
REQUEST NO. 37: For the Green Power program in202l, please provide the
timing of the reconciliation of REC purchase and account balances.
REQUEST NO. 38: For the Green Power program, please provide a detailed
break-down of the 2021 program forecasted budget against actual revenue and actual
expenses for 2021, including but not limited to: administration. marketing costs, community
education and outreach, and program fund balance.
REQUEST NO.39: For the Green Power program in202l, please describe the
efforts the Company made in202l to promote initiative, education, and project
opportunities in Idaho.
REQUEST NO.40: For the Green Power program, please provide a list of Solar
4R School projects that were funded during 2021. In the response provide a brief
description and cost of each project.
REQUEST NO. 41: Please provide annual and cumulative Idaho 2021 participation
results for the Green Power program. Please breakdown participation by month.
SECOND PRODUCTION REQUEST
TO IDAHO POWER 2 MARCH 4,2022
REQUEST NO. 422 For the Green Power program in 2021, please provide total
blocks and kWh purchased by Green Power customers for Idaho and for the Company's
system.
REQUEST NO. 43: For the Green Power program, please provide program REC
purchase detail including: generator, location, quantity, total price. price per REC, date
purchased, and weighted average price on behalf of Idaho customers in 2O21.
REQUEST NO. 44: For Option 3, the Large Purchase Option of the Flexible offering in
Schedule 62, please answer the following:
a. Please explain the how the Company ensures that tailored agreements for Option
3 Large Purchase Option will not cost shift to Options I and2 of the Flexible
offering.
b. Please explain the process for ensuring that the price per REC is appropriately
priced in the tailored agreement(s).
c. Please explain if the accounting treatment for Option 3 will be separate from
Options I and2 for the Flexible offering. If so, please provide accounts and
details. It not, please explain why not.
d. Will customers have an opportunity to purchase Company owned RECs?
REQUEST NO. 45: In response to Production Request No. 9a, which states "the Large
Purchase Option was first offered following the2016 modifications to Schedtle 62." Please
answer the following:
a. Please provide direct reference to Tariff Advices, Case Numbers, and/or other
forms of communications where the Large Purchase Option was proposed,
approved, and acknowledged by the Commission. [n the response, please include
copies of documents, attachments, emails, and/or presentations where this was
communicated with the Commission.
b. For each year beginning in 2016 through2022, please provide all contracts and
invoices for the purchase(s) of Company-Owned RECs through the Large
SECOND PRODUCTION REQUEST
TO IDAHO POWER J MARCH 4,2022
Purchase Option. In the response, please include, but not limited to, Company
workpapers for the Power Cost Adjust ("PCA"), price per REC, RECs purchased,
REC type, cost, true-up REC purchases, and Idaho's allocation of REC revenue.
c. Please explain if the Large Purchase Option referenced in Production Request No
9a is different than Large Renewable Energy Purchase Option in the Power Cost
Adjustment ("PCA").
d. Of the 60 business customers that sought out information on the Large Purchase
Option, please explain how the Company selected the seven businesses to
purchase Company-owned RECs.
e. Please explain the process to ensure that the price per Company-owned REC is
appropriately priced to ensure they are based on fair market value.
REQUEST NO.46: For Options 1,2, and 3 in the Clean Energy Your Way - Flexible
offering, please explain if the Company will sell Company-owned RECs to support the purchases
in the offering. If so, please explain the Company's accounting process for ensuring revenue for
Company-owned RECs are passed through the PCA.
REQUEST NO. 47: Please provide an estimated timeline for the Subscription option.
In the timeline, please include estimated times for when the Company expects to have a resource
and size selected, when the Company will submit their phase-2 filing, when customers will begin
signing up for the Subscription option, and when the resource should be online providing power.
REQUEST NO. 48: Page 4l of Ms. Williams direct testimony describes assigning
unsubscribed energy cost at or below reasonable avoided cost. What avoided cost is the
Company referencing and what method(s) does the Company plan on using for determining the
avoided cost?
REQUEST NO. 49: In response to Production Request No. 19, the Company states that
"Idaho Power has filed phase one which seeks approval of the foundational concepts of program
design and structure." Will the Company alter these foundational concepts of the program
SECOND PRODUCTION REQUEST
TO IDAHO POWER 4 MARCH 4,2022
design and structure between this filing and the phase 2 filing? For example, can the Program
Charges and Credits identified in this filing be changed or modified in the phase 2 filing?
REQUEST NO. 50: Given that each IRP is acknowledged and not authorized, what is
the approval process for values that will be determined in future IRPs that will be included in the
proposed Schedule 62 Clean Energy Your Way Construction rates? Please provide the specific
language that allows this approval process in proposed Schedule 62.
REQUEST NO. 51: Please explain the scope of the changes that can be made to the
Clean Energy Your Way Construction rates in the Company's next general rate case.
Specifically, can changes to rate design and cost-of-service methods impact the rates paid and
credits received by participants in the Clean Energy Your Way Construction option? If so,
please provide the specific language that allows such change(s) in the proposed Schedule 62.
REQUEST NO. 52: If the Embedded Energy Fixed Cost rate is subject to change in the
Company's next general rate case, will the Clean Energy Your Way Construction Schedule 62
Option rate(s) also change? [f so, please provide the specific language that allows such
change(s) in the proposed Schedule 62.
REQUEST NO. 53: If rate design for all Schedules is subject to change in the
Company's general rate case, or filings that adjust base rates, will the Clean Energy Your Way
Construction rate design(s) also change? If so, please provide the specific language that allows
such change(s) in the proposed Schedule 62.
REQUEST NO. 54: Please explain if RECs from the "new" renewable resources
provided for the proposed Clean Energy Your Way Subscription and Clean Energy Your Way
Construction should be based on generation or consumption?
REQUEST NO. 55: Please explain why Idaho customers who consume the excess
generation from Clean Energy Your Way Subscription and Clean Energy Your Way
Construction should not be allocated the associated RECs?
SECOND PRODUCTION REQUEST
TO IDAHO POWER 5 MARCH 4,2022
DATED at Boise, Idaho, *(/$day of March 2a22.
Dayn
Deputy Attorney General
i:umisc:pro&e{ipce2l.40dhtrhcme prod req 2
SECOND PRODUCTION REQI.JEST
TO IDAHO POWER 6 MARCH 4,2022
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 4th DAY OF MARCH 2022, SERVED
THE FOREGOING SECOND PRODUCTION REQUEST OF THE COMMISSION
STAFF TO IDAHO POWER COMPANY, IN CASE NO. IPC-E-21-40, BY E-MAILING
A COPY THEREOF, TO THE FOLLOWING:
LISA NORDSTROM
TDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: [e-mail]
docket s@ i dahapatryqr. cam
PETER J RICHARDSON
RICHARDSON ADAMS PLLC
5I5 N 27TH ST
PO BOX 7218
BOISE ID 83702
E-MAIL: [e-mail]
BENJAMIN J OTTO
EMMA E SPERRY
ID CONSERVATION LEAGUE
7IO N 6TH ST
BOISE ID 83702
E-MAIL: botto@.idahoconservation.ore
esperr.y @ idahoconservation. or g
VICKI M BALDWIN
PARSON BEHLE & LATIMER
201 SOUTH MAIN STREET SUITE ISOO
SALT LAKE CITY UT 84I I I
E-mail: [e-mail]
ED JEWELL
DEPUTY CITY ATTORNEY
BOISE CITY ATTORNEYS OFF
PO BOX 500
BOISE ID 83701-0500
E-MAIL : ej [e-mail]
Boi seC itvAttorney @cityofboise.ore
ALISON WILLIAMS
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: awilliams(Eidahopower.com
[e-mail]
DON READING
6070 HILL ROAD
BOISE ID 83703
E-MAIL : [e-mail]
NORMAN M. SEMANKO
PARSONS BEHLE & LATIMER
8OO WEST MAIN STREET SUITE I3OO
BOISE TD 83702
E-mail: nsemanko@,parsonsbehle.com
Electronic Service Only:
STEVE W CHRISS
DIRECTOR ENERGY SERVICES
WALMART INC
E-mail : [e-mail]
WIL GEHL
ENERGY PROGRAM MANAGER
BOISE CITY DEPT OF PUBLIC WORKS
PO BOX s00
BOISE ID 8370I
E-MAIL: [e-mail]
Y
CERTIFICATE OF SERVICE