20220325IPC to Staff 35-55.pdf

LISA D. NORDSTROM
load Counsel
[e-mail]
March 25,2022
Jan Noriyuki, Secretary
ldaho Public Utilities Commission
11331 W. Chinden Boulevard
Building 8, Suite 201-A
Boise, ldaho 83714
Case No. IPC-E-2140
Application to Expand Optional Customer Clean Energy Offerings Through
the Clean Energy Your Way Program
Dear Ms. Noriyuki
Attached for electronic filing, pursuant to Order No. 35058, is ldaho Power Company's
Response to the Second Production Request of the Commission Staff in the above
entitled mafter.
The confidential attachments will be provided only to the parties who execute the
Protective Agreement in this matter.
lf you have any questions about the attached documents, please do not hesitate to
contact me.
Sincerely,
Re
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Lisa D. Nordstrom
lrnAOoiPComoary
P.O. Box 70 (83707)
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Boisc. lD 83702
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Enclosures
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]
[e-mail]
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION TO
EXPAN D OPTIONAL CUSTOMER
CLEAN ENERGY OFFERINGS
THROUGH THE CLEAN ENERGY YOUR
WAY PROGRAM.
CASE NO. !PC-E-2140
IDAHO POWER COMPANY'S
RESPONSE TO SECOND
PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO
POWER COMPANY
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COMES NOW ldaho Power Company ("ldaho Powef or'Company"), and in
response to Second Production Request of the Commission Staff ('IPUC or
Commission") dated March 4,2022, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY.l
REQUEST FOR PRODUCTION NO. 35: Please provide a copy of the Green
Power Program Biennial Prudency Report and workpapers for years 2O2O and 2021. lf
not complete, please provide the expected completion date and supplement this
response with the completed report.
RESPONSE TO REQUEST FOR PRODUCTION NO. 35: The report for program
years 2O2O and 2021 is currently in-process and is anticipated to be completed and filed
in June 2022. The 2022 report will be filed under Case No. IPC-E-16-1 3, and the
Company will supplement this response when the report is available.
The response to this Request is sponsored by Kelley Noe, Regulatory
Consultant, ldaho Power Company.
IDAHO PO\'\'ER COMPANY'S RESPONSE TO SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY.2
REQUEST FOR PRODUCTION NO. 36: For the Green Power program, please
provide the total Renewable Energy Credit ('REC") purchases for ldaho in 2021 and
include RECs that were purchased in 2022 to fulfill 2021 program requirements.
RESPONSE TO REQUEST FOR PRODUCTION NO. 36: ln 2021, ldaho
participants purchased 29,377.36 RECs. ldaho Power placed two orders with the REC
vendor for the Green Power Program to fu!fill these sales. January through June REC
sales were ordered in July 2021and July through December REC sales were ordered in
January 2022. All RECs purchased for calendar year 2O2'l were transferred from the
vendor to ldaho Power in January 2022.
The response to this Request is sponsored by Suzanne Smith, Senior Program
Specialist, ldaho Power Company.
IDAHO PO\A'ER COMPANY'S RESPONSE TO SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 3
REQUEST FOR PRODUCTION NO. 37: For the Green Power program in 2021 ,
please provide the timing of the reconciliation of REC purchase and account balances.
RESPONSE TO REQUEST FOR PRODUCTION NO. 37= For 2021, January
through June REC purchases were paid in November 2021. July through December
REC purchases were paid in January 2022.
The response to this Request is sponsored by Suzanne Smith, Senior Program
Specialist, ldaho Power Company.
IDAHO POVVER COMPANY'S RESPONSE TO SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY-4
REQUEST FOR PRODUCTION 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 lor 2021, including but not limited to; administration,
marketing costs, community education and outreach, and program fund balance.
RESPONSE TO REQUEST FOR PRODUCTION NO. 38: The total Program
budget in2021was $315,355.13 and totalexpenses were $325,898.37. Participant
funds (revenue) paid $253,663.57 of the totalexpenses and $72,234.80 was funded by
ldaho Power. Program revenue in 2021 was $296,817.50. As of December 31, 2021,
the Program fund balance was $369,082.42. The July through December 2021 REC
expense did not debit unti! January 2022. The detailed budget, revenues, and actual
expenses for 2021are provided as an attachment to this response.
The response to this Request is sponsored by Suzanne Smith, Senior Program
Specialist, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 5
REQUEST FOR PRODUCTION NO. 39: For the Green Power program in 2021,
please describe the efforts the Company made tn 2021 to promote initiative, education,
and project opportunities in ldaho.
RESPONSE TO REQUEST FOR PRODUCTION NO. 39: Promoting Solar 4R
Schools is mostly done through the Company's Energy Advisors. The Education and
Outreach Energy Advisors have flyers and slides in their presentations discussing Solar
4R Schools. The residential, commercial and key account energy advisors also discuss
Solar 4R Schools grants during target visits with Iocal schools and when promoting the
Green Power Program to the public.
The 2021 marketing efforts, summarized below, were funded mostly through the
Company's Operations & Maintenance budget. Due to COVID-19 and the ensuing
economic hardship for some customers, the Company balanced 2021 marketing efforts
for the Green Power Program with the priority messaging of safety, flexible bi!!-pay
options, and important operational changes at ldaho Power. Participation in the Green
Power Program still increased compared to 2020. ln fact, the marketing campaign in
October 2021 led to a record-breaking number of enrollments - more than 430 new
signups.
Marketino/Public Relations:
o Bill inserts to customers three months of the year (approximately 910,000 total
inserts)
. Program promotion in April 2021 e-newsletter to celebrate Earth Month
(electronic version sent to approx. 5,U7 customers)
o \Mndow clings promoting individual participation sent to new participants
IDAHO PO\A'ER COMPANY'S RESPONSE TO SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 6
o ldaho Sfafesman article; interview on Green Power Program
. Featured on a homepage card in April2021 on the ldahopower.com website
Advertisino reached:
o 1,325,725 impressions from online digital ads
. Pop-up ad in My Account (ldaho Power's online customer portal) delivering
67,087 impressions in April 2021 and 145,394 in October 2021
The response to this Request is sponsored by Suzanne Smith, Senior Program
Specialist, ldaho Power Company.
IDAHO POVVER COMPANY'S RESPONSE TO SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 7
REQUEST FOR PRODUCTION NO. 40: For the Green Power program, please
provide a list of Solar 4R School projects that were funded during 2021. ln the
response provide a brief description and cost of each project.
RESPONSE TO REQUEST FOR PRODUCTION NO.40: The most recent
project was granted in 2019 to Vallivue Middle School. No schools applied for the Solar
4R Schools grant in 2020,likely due to COVID-19. !n 2021,ldaho Power did not receive
any Solar 4R Schools applications by the application deadline of April 1. One schoo!
applied in Iate 2021, which will be evaluated in2022. The Company anticipates
awarding up to two projects in2022 and up to two additional projects in2023.
The program usually has enough revenue each year to fund one to two schools
per year. Historically, projects have cost $40,000-$45,000 each:
. $12,500 for an all-day in-person teacher training taught by Bonneville
Environmental Foundation. Teachers are also given materials and
classroom experiment kits.
. $30,000 for the solar array, installation costs, data monitoring system, and
project management performed by Bonneville Environmental Foundation.
The response to this Request is sponsored by Suzanne Smith, Senior Program,
Specialist, ldaho Power Company.
IDAHO PO\A'ER COMPANY'S RESPONSE TO SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY. E
REQUEST FOR PRODUCTION NO.41: Please provide annualand cumulative
ldaho 2021 parlicipation results for the Green Power program. Please breakdown
participation by month.
RESPONSE TO REQUEST FOR PRODUCTION NO.41: Participation is counted by
Green Power charges paid each month.
Total Participants Throughout Z;OZL- !daho only (includes mid-year cancellations)
Customer GP - 1OO% OPTION GP. BTOCK OPTION Grand Total
lrrigation
Commercial
lndustrial
Residential
L
2033
97
4
50
2
47
4
2081
3
4LL4
Grand Total 2984
Participant Count by Month - ldaho only
202L GP- 1oo%OPT|ON
2t?4 4218
GP. BTOCK OPTION Grand Total
January
February
March
April
May
June
July
August
September
October
November
December
1258
Lt70
1500
1359
L26L
L487
1388
1518
t496
L567
1745
1839
1738
t493
L976
1766
1516
t9t4
t7t4
1856
L748
L84L
L857
L962
2996
2663
3476
3125
2877
3401
3toz
3374
3244
3408
3502
3801
The response to this Request is sponsored by Suzanne Smith, Senior Program
Specialist, ldaho Power Company.
IDAHO PO\A'ER COMPANY'S RESPONSE TO SEGOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 9
REQUEST FOR PRODUCTION NO. 42: For the Green Power program in2021,
please provide tota! blocks and k\Mt purchased by Green Power customers for ldaho
and for the Company's system
RESPONSE TO REQUEST FOR PRODUCTION NO.42:
Total revenue and kWh by participation option - ldaho only
(Participant pricing is 50.01 per kWh, 1 btock = S1)
Customertype 9P: 100%OPTION
lrrigation - lD $248.59
Commercial- lD 522,565.02
lndustrial - lD
Residential - lD s146,158.89
Grand Total $16&s72.s0
GP - BTOCK OPTION
s2o4.oo
s21,259.58
s4,200.00
s99r137:52
s124301.10
s4s2.se
s43,824.60
Sa,zoo.oo
5241?2q4-1
5293,773.60
Totalkwh
45,259
4,382,460
420,000
24,529,ilo
29,177,160
TotalkWh
45,259
4,382,460
420,000
24,529,64L
304,390
29,681,75O
Total
Total revenue and kWh by participation option - ldaho and Oregon
(Participant pricing is 50.01 per kWh, t block = S1)
CustomerType
lrrigation - lD
Commercial- lD
lndustrial- lD
Residential - lD
Residential - OR
Grand Total
GP. 1OO% OPTION GP. BTOCK OPNON
S248.s9
Szz,sos.oz
s146,158.89
s1,805.14
iLto,7tt.64
s2o4.oo
S21,2s9.58
s4,200.00
S99,137.52
sL,238.76
$120,039.s6
Total
s4s2.s9
S43,824.G0
s4,200.00
s245,296.41
s3,043.90
s296,817.50
The response to this Request is sponsored by Suzanne Smith, Senior Program
Specialist, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 1O
REQUEST FOR PRODUCTION NO.43: For the Green Power program, please
provide program REC purchase detai! including: generator, location, quantity, total
price, price per REC, date purchased, and weighted average price on behalf of ldaho
customers in2021.
RESPONSE TO REQUEST FOR PRODUCTION NO.43: The table below
represents RECs for both ldaho and Oregon participants combined. The contract with
the Program's REC supplier has a fixed cost of $7.10 per REC. Actual REC orders are
placed in July for January through June sales, and in January the following year for the
prior July through December period. ln 2021, the invoices were paid in November 2021
and January 2022.
Generator CounW State RECs Price /REC Total Price Date Purchases
Meadow Creek Wind
Farm - Five Pine Project
Old MillSolar, LLC
Rockland Wind Farm
Woodline Solar, LLC
Bonneville lD 2341 s7.10 s16,621.10 LL(2O2L&0L12O22
Klamath
Power
Klamath
4262
12500
10579
s30,250.20
S88,750.00
S75,110.90
OR
ID
OR
10
10
10
St
$t
Sz
LLlzOzt&OL/2O22
Lu2021&0L12O22
LLl2Ozt&0t12022
Totals 29,682 52,10,7N.4?*
*Participants total REC needs were 29,681.75 RECs. Only whole RECs can be
transferred. The vendor transferred 29,682 RECs to ldaho Power but only charged a
partial amount for 1 REC.
The response to this Request is sponsorqd by Suzanne Smith, Senior Program
Specialist, ldaho Power Company.
IDAHO PO\A'ER COMPANY'S RESPONSE TO SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 11
REQUEST FOR PRODUCTION 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 1 and 2 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 1 and 2 for the Flexible offering. lf so, please provide accounts and
details. lt not, please explain why not.
d. \Mll customers have an opportunity to purchase Company owned RECs?
a. Administration costs for all options (1, 2 and 3) are treated as genera!
operations and maintenanc€ expenses and are not directly assigned to the
Flexible offering. As a result, there is no risk of cost shifting within the Flexible
option. Participant funds are only used for REC purchases REC certification,
and (if extra funds are available) Solar 4R Schools and marketing.
b. RECs are sold in a competitive market and prices change regularly based on
demand. A REC's value can vary greatly based on the resource type,
location, individualstate Renewable Portfolio Standard ("RPS') eligibility, and
other characteristics. ldaho Power receives daily REC pricing sheets from
multiple REC brokerage firms. The daily report shows asking prices and
current bids for available RECs across the nation. To ensure a fair market
IDAHO POVVER COMPANY'S RESPONSE TO SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 12
price when selling Company-owned RECs, ldaho Power utilizes these pricing
sheets, REC brokerage firms, and may reach out directly to known wholesale
REC buyers to solicit bids. Seven business customers have purchased
Company-generated hydro RECs. ldaho Power's hydro RECs are not Green-
e eligible, but they are eligible for Oregon's RPS. Although hydro REC
characteristics are less common, ldaho Power found comparable offerings in
Oregon's RPS to use as a reference point when determining the loca! market
value of hydro RECs. !f ldaho Power were to buy third-party RECs, we could
utilize the daily pricing sheets and REC brokerages to gauge an appropriate
price for the RECs.
c. Yes, REC sales for Option 3 are differentiated from Options 1 and 2 by using
different accounting. Options 1 and 2 share a232 Accounts Payable account,
which collects the participant payments. This same account is used to record
payment for the purchase of RECs and any approved program expenses,
which are reviewed monthly. Currently, ldaho Power only sells Company-
owned RECs through Option 3. All Company-owned REC sales and broker
fees are recorded to 182.3 Regulatory Assets to ensure the net revenue flows
through the Power Cost Adjustment mechanism. Should the Commission
approve ldaho Power to purchase third-party RECs for Option 3, a third
accounting option would be created to keep the REC purchases and
offsetting collections from customers separate from Options '1,2 and
Company-owned REC sales, by creating a new 143 OtherAccounts
Receivable account. The purchase of third-parg RECs and any broker fees
IDAHO POWER COMPANY'S RESPONSE TO SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 13
will debit this new account and will be ofbet by the payments received from
customers. ldaho Power intends to sellthird-party RECs to customers for the
amount purchased, Iess any broker fees, and have no impact on other
customers. Pricing and REC composition will be individually negotiated in a
manner that ensures that the full cost of the REC contract is borne by the
participating Customer(s).
d. Yes, customers purchasing a minimum 750 M!ryh of RECs per year can
purchase Company-owned RECs at the current market value. REC sales to
customers follow ldaho Power's REC Management Plan.
The response to this Request is sponsored by Suzanne Smith, Senior Program
Specialist, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 14
REQUEST FOR PRODUCTION NO.45: ln response to Production Request No.
9a, which states "the Large Purchase Option was first offered following the 2016
modifications to Schedule 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 Purchase Option. ln 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 ldaho'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.
IDAHO PO\A'ER COMPANY'S RESPONSE TO SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO ]DAHO POWER COMPANY- 15
RESPONSE TO REQUEST FOR PRODUGTION NO.45:
a. On June 11,2010, the Commission issued Order No.32002 approving the
Company's REC Management Plan ("Management Plan"), which governs the
sale and proceeds of ldaho Power-owned RECs. The Management Plan is
attached to this response. As noted in Wlliams Direct on p.27, the Company
has since executed all REC transactions according to the Management Plan.
The Large Renewable Energy Purchase Option ("Large Purchase Option")
was developed to give customers a way to purchase larger amounts of
Company-owned RECs to be retired on the customer's behalf as an
alternative to the Green Power Program. The Green Power Program cannot
support many large purchases due to the limited number of RECs available
annually through the program. When the first REC sale/retirement under the
Large Purchase Option was executed in December 2019 (for RECs in the
2020 calendar year), it was determined that a formalfiling with the
Commission was not necessary, as the transactions would involve ldaho
Power-owned RECs and be executed in a manner consistent with the
approved Management Plan. That is, the Company would sell RECs in a
manner that would maximize revenue from these sales, and any proceeds
would be passed back to customers through the Power Cost Adjustment
mechanism. These transactions have been and will continue to be subject to
Staff audit in the Company's annual PCA filings.
ln the current filing, the Company has included the Large Purchase Option
in the proposed Schedule 62tarilt for two reasons: 1) The Company is now
IDAHO POVVER COMPANY'S RESPONSE TO SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 16
seeking approvalto procure unbundled third-partv RECs for retirement on
behalf of participating customers, an action not contemplated by the current
Management Plan, and 2) the list of clean energy offerings for customers is
expanding under Clean Energy Your Way, and the Company considers it
important to have all customer clean energy options represented in the tariff.
b. The individual customer contracts and invoices are provided as a confidential
attachment to this request. The RECs transferred to the PCA are provided as
an Excelworkbook attached to this request.
c. The Large Renewable Energy Purchase Option and the Large Purchase
Option are the same. The name of the option was shortened to "Large
Purchase Option' in the proposed Schedule 62 in recognition that the new
overall program name of Clean Energy Your Way would be sufficient to imply
"renewable energy" under the Large Purchase Option. The Large Purchase
Option will continue to operate as it always has, with any proceeds associated
with the sale of Company-owned RECs passing through the PCA.
d. RECs are sold on a first-come, first-served basis. The first customer to let
ldaho Power know that they would like to purchase RECs at the quoted price
will get the RECs. While many customers have requested information on REC
options and pricing, only seven have decided to purchase ldaho Power-
owned RECs, and a few chose to join the Green Power Program (option 1 or
2). Some other businesses are still exploring options and some have bought
RECs from third-party sellers.
IDAHO POVI/ER COMPANY'S RESPONSE TO SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 17
e. RECs are sold in a competitive market and prices change regularly based on
demand. ldaho Power consutts with brokers and references multiple broker
pricing sheets to gauge cunent value of RECs.
The response to this Request is sponsored by Suzanne Smith, Senior Program
Specialist, ldaho Power Company.
IDAHO POWER COMPAT.IYS RESPONSE TO SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY. 18
REQUEST FOR PRODUCTION 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. lf so, please explain the
Company's accounting process for ensuring revenue for Company-owned RECs are
passed through the PCA.
RESPONSE TO REQUEST FOR PRODUCTION NO. 46: ldaho Power does not
intend to use company-owned RECs to support Options 1 and 2. Currently, Company-
owned REC sales and associated broker fees are recorded to 182.3 Regulatory Assets
to ensure the net revenue flows through the Power Cost Adjustment mechanism. ldaho
Power uses Company-owned RECs for Option 3, and those sales/retirements follow the
current accounting process for net REC proceeds that is already in place. Assuming
Commission approval of Option 3, accounting for third-pafi REC purchases under
Option 3 would involve a new 143 Other Accounts Receivable account that would be
created to ensure no expenses or proceeds flow through to the Power Cost Adjustment
mechanism.
The response to this Request is sponsored by Suzanne Smith, Senior Program
Specialist, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 19
REQUEST FOR PRODUCTION 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 47: ldaho Power has
developed an estimated timeline for phase two, however notes that the timeline relies
on a series of uncertain assumptions about the processing of the current case and
developments in preparation of the next phase, including the timing/logistics of resource
procurement.
IDAHO PO\A'ER COMPANY'S RESPONSE TO SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY.20
Estimated Subscription Option Timeline
tuLY 2022 ldaho Power receives Commission approvalto offer Clean Energy Your Way,
including the Subscription option.
AUGUST 2022 ldaho Power identifies/selects a potential resource (type, size, and price) to
serve as the Subscription resource.
ldaho Power updates customers on Commission approval and the future
availability of the Subscription.
ocroBER 2022 ldaho Power submits the phase two filing to the Commission, including
identification of a prospective resource, proposed program pricing, mock
customer contract/terms and conditions, and accounting treatment for the
Subscription.
APRIT 2023 ldaho Power receives Commission approval on the Subscription phase two
filine.
ldaho Power finalizes resource procurement.
MAY.JUNE 2023 ldaho Power advertises Subscription details and participant pricing to
customers.
ldaho Power introduces logistics of Subscription sign-up process and phases
JUNE 2023 Residential call to action: sign-up opens (four-week sign up window for
residential customers onlv).
JULY 2023 Open enrollment call to action: sign-up open and available to all customers --
residential, commercial, industrial, irrigation.
AUGUST 2023 lf Subscription fills, establish a wait list for Subscription participants.
lf Subscription does not fill, continue to advertise to customers
NOVEMBER 2024 Resource comes online; Subscription commences
DECEMBER 2024 Subscription customers see program participation reflected on their bill
The response to this Request is sponsored by Alison Williams, Regulatory Policy
and Strategy Advisor, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 21
REQUEST FOR PRODUCTION NO. 48: Page 41 of Ms. Williams direct
testimony describes assigning unsubscribed energy cost at or below reasonable
avoided cost. \Mrat avoided cost is the Company referencing and what method(s) does
the Company plan on using for determining the avoided cost?
RESPONSE TO REQUEST FOR PRODUCTION NO.48: ldaho Power has not
yet identified its recommended method for determining the avoided cost that will be
applied to unsubscribed energy from the subscription option. The Company has two
open cases (IPC-E-21-42 and IPC-E-22-06) where it has proposed to rely on a non-firm
AuRORA-generated hourly avoided cost. The Company has also been directed to file a
case studying various potential methods for valuing excess energy provided to ldaho
Power's system from on-site generation customers during 2022. Finally, the Company
also anticipates filling a case related to PURPA compensation this year. The Company
expects to rely on these cases as it develops its recommended avoided cost related to
the Subscription option prior to filing the second phase.
The response to this Request is sponsored by Alison Williams, Regulatory Policy
and Strategy Advisor, ldaho Power Company.
IDAHO PO\A'ER COMPANY'S RESPONSE TO SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 22
REQUEST FOR PRODUCTION NO.49: !n response to Production Request No.
19, the Company states that "ldaho Power has filed phase one which seeks approva! of
the foundational concepts of program design and structure." \Mllthe Company alter
these foundational concepts of the program 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 2filing?
RESPONSE TO REQUEST FOR PRODUCTION NO. 49: ln the Phase Two
filing, ldaho Power intends to maintain the same Program Charges and Credits
identified in the current filing. However, should the Commission order as part of this
case that modified or different Program Charges and Credits should be implemented,
the Company will incorporate those revisions into its subsequent filing.
The response to this Request is sponsored by Alison Williams, Regulatory Policy
and Strategy Advisor, ldaho Power Company.
IDAHO PO\A'ER COMPANY'S RESPONSE TO SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 23
Given that each IRP is acknowledged
and not authorized, what is the approva! process for values that will be determine in
future lRPs 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 50: The proposed
Schedule 62 requires customers electing the Construction option to negotiate a
Renewable Construction Agreement with the Company. That Renewable Construction
Agreement will be subject to Commission approval and will contain the proposed rates
and methodology for Excess Generation or a REF Credit (if applicable).
The Company envisions it will submit a separate filing concurrent with each
lntegrated Resource Plan ('lRP") for approval of charges or credits contained within any
Renewable Construction Agreement that relies on IRP inputs.
The response to this Request is sponsored by Connie Aschenbrenner, Rate
Design Senior Manager, ldaho Power Company.
IDAHO PO\A'ER COMPANY'S RESPONSE TO SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 24
REQUEST FOR PRODUCTION 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? lf so, please provide the specific language that
allows such change(s) in the proposed Schedule 62.
RESPONSE TO REQUEST FOR PRODUCTION NO. 51: The Company intends
that all rates contained in the schedules of each customer class will be subject to
update in future revenue requirement proceedings, which in the context of a Clean
Energy Your Way - Construction arrangement, includes rates paid for standard service
(i.e., the Service, Billing Demand, On-Peak Billing Demand, Basic Load Capacity, and
Energy Charges applicable to Net Consumption) and rates related to the REF On-Site
Usage. As more fully described on page 47 in Williams Direct, the methodology for
determining the rate to be applied to the REF On-Site Usage is based on the
Company's most recently reviewed class cost-of-service study.
The Company's proposed Schedule 62 does not contain a prescriptive
methodology for establishing the credits a Clean Energy Your Way - Construction
participant may be eligible to receive. While the Company will endeavor to apply a
consistent framework across these Renewable Construction Agreements, there may be
differing circumstances that would need to be taken into consideration as part of the
holistic evaluation of the individual arrangement. The Company intends for these
elements, including any credit for Excess Generation or capacity benefits and whether
those elements are subject to modification, to be contained within the Renewable
IDAHO PO\A'ER COMPANY'S RESPONSE TO SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 25
Construction AgreemenUEnergy Services Agreement, which would be subject to
Commission approva!.
While none of the Company's standard service schedules (inclusive of the
proposed Schedule 62) highlight that rates paid for ldaho Power-provided services are
subject to change in a future Commission proceeding, the Company believes customers
understand rates will vary over time, subject to Commission approval. If determined
necessary by the Commission, the Company can include clariffing language in
Schedule 62, or any of its standard service schedules, highlighting that future
Commission decisions can alter the rates paid for or the rate design applied to ldaho
Power provided service.
The response to this Request is sponsored by Connie Aschenbrenner, Rate
Design Senior Manager, ldaho Power Company.
IDAHO POVVER COMPANY'S RESPONSE TO SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 26
REQUEST FOR PRODUCTION NO.52: lf 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? lf so, please provide
the specific language that allows such change(s) in the proposed Schedule 62.
RESPONSE TO REQUEST FOR PRODUCTION NO. 52: Yes. \MiIe nonE of the
Company's standard service schedules (inclusive of the proposed Schedule 62)
highlight that rates paid for ldaho Power provided services are subject to change in a
future Commission proceeding, the Company believes customers understand rates wil!
vary over time, subject to Commission approval.
lf determined necessary by the Commission, the Company can include clariffing
language in Schedule 62, or any of its standard service schedules, highlighting that
future Commission decisions can alter the rates paid for ldaho Power provided service.
The response to this Request is sponsored by Connie Aschenbrenner, Rate
Design Senior Manager, ldaho Power Company.
IDAHO POVVER COMPANY'S RESPONSE TO SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 27
REQUEST FOR PRODUCTION NO. 53: lf rate design for all Schedules is
subject to change in the Company's general rate case, or filings that adjust base rates,
will the CIean Energy Your Way Construction rate design(s) also change? If so, please
provide the specific Ianguage that allows such change(s) in the proposed Schedule 62.
The Company intends
for the Clean Energy Your Way - Construction structure to continue to mirror the rate
design structure contained within Schedule 19. While none of the Company's standard
service schedules (inclusive of the proposed Schedule 62) highlight that rates paid for
or the rate design applied to ldaho Power-provided services are subject to change in a
future Commission proceeding, the Company believes customers understand rates will
vary over time, subject to Commission approval. lf determined necessary by the
Commission, the Company can include clariffing language in Schedule 62, or any of its
standard service schedules, highlighting that future Commission decisions can alter the
rates paid for or the rate design applied to ldaho Power provided service.
The response to this Request is sponsored by Connie Aschenbrenner, Rate
Design Senior Manager, ldaho Power Company.
IDAHO POVVER COMPANY'S RESPONSE TO SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 28
REQUEST FOR PRODUCTION 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?
RESPONSE TO REQUEST FOR PRODUCTION NO. 54: RECs are created
based on generation from a renewable resource. More specifically, one Megawatt-hour
of renewable energy generation produces one REC.IRECs are earned by customers
through one of two means-payment for the RECs themselves or payment for the
renewable resource(s).
The determining factor in all REC transactions is how many RECs the customer
would like to purchase, not how much energy the individual customer consumes. In all
REC markets and exchanges, a customer's individualconsumption has no bearing on
whether they can earn or claim the environmental attributes/RECs of a renewable
resource.
Under the Clean Energy Your Way - Subscription option, RECs associated with
Subscription participation wil! be based entirely on each customer's subscriber
amount-which reflects how much they wil! pay to participate in the program. As
proposed by ldaho Power, the RECs associated with the Subscription will be retired on
participating customers' behalf.
Similarly, under the CIean Energy Your Way - Construction option, individual
Construction customers will pay for the total cost of renewable resource(s) and, in
exchange, will receive allthe environmental attributes associated with those resources.
I Green-e, an organization that certifies official REC generation and transactions, defines RECs in its
g lossary: https:/Arttwvrt. green-e.org/glossary
IDAHO POWER COMPANY'S RESPONSE TO SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 29
ln both options, RECs/environmentral attributes are eamed based on payment for
renewable resour@ generation, not on any custome/s consumption of energy.
The response to this Request is sponsored by Alison Wlliams, Regulatory Policy
and Strategy Advisor, ldaho Power Company.
IDAHO POVITER COMPANYS RESPONSE TO SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POVVER COMPAI.IY. SO
REQUEST FOR PRODUCTION NO. 55: Please explain why ldaho 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?
RESPONSE TO REQUEST FOR PRODUCTION NO. 55: Please refer to the
response to Staffs Request No. 54 for information on the way in which bundled and
unbundled RECs are created.
With respect to the Clean Energy Your Way - Construction option, each
arrangement will require the Construction customer to pay for the total cost of the
renewable resource(s) and, in exchange, receive allthe environmentalaftributes/RECs
associated with those resource(s). Environmental attributes/RECs of Construction
resources are only awarded based on each Construction custome/s payment for those
resources. As a result, other ldaho Power customers do not get to claim renewable
energy attributes based on their potential consumption of *excess generation.' Other
customers can only earn RECs by purchasing them. And, in the case Construction
arrangements, all the RECs will be earned (paid for) by each individual Construction
customer, leaving no amount of environmenta! attributes/RECs available to be assigned
to other customers.
With respect to the Glean Energy Your Way - Subscription option, there will not
be any "excess generation,' as the program concept does not involve reconciling
participating customer load against the output of the Subscription resource. Excess
generation is only created in the Construction option when the generation from the
assigned renewable resource exceeds the Construction customer's Ioad. ln contrast,
Subscription participants will subscribe to a certain amount of generation, but that
IDAHO POIA'ER COMPANY'S RESPONSE TO SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 31
amount will not interac* with their personal load.
The response to this Request is sponsored byAlison Wlliams, Regulatory Poliry
and Strategy Advisor, ldaho Porer Company.
IDAHO POWER COMPANYS RESPONSE TO SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POVI'ER COMPAT.IY- 32
DATED at Boise, ldaho, this 25th day of March 2022.
&; !.7("*t*-*,
LISA D. NORDSTROM
Attorney for ldaho Power Company
IDAHO POVVER COMPANY'S RESPONSE TO SECOND PRODUCTION REQUESTOF THE
COMMISSION STAFF TO IDAHO POVT'ER COMPANY.33
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 25th day of March 2022, ! served a true and
correct copy of ldaho Power Company's Response to Second Production Request of the
Commission Staff to ldaho Power Company upon the following named parties by the
method indicated below, and addressed to the following:
Gommission Staff
Dayn Hardie
Deputy Attorney General
ldaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg 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.27h Street
P.O. Box 7218
Boise, lD 83702
Dr. Don Reading
6070 Hill Road
Boise, ldaho 83703
ldaho Conservation League
Benjamin J. Otto
Emma E. Sperry
ldaho Conservation League
710 N. 6th Street
Boise, lD 83702
Walmart, Inc.
Norman M. Semanko
Parsons Behle & Latimer
800 W. Main Street, Suite 1300
Boise, lD 83702
_Hand Delivered
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Overnight Mail
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FTP SiteX Email: [e-mail]
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Overnight Mail
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FTP SiteX Email: [e-mail]
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FTP SiteX Email: [e-mail]
esperry@ida hoconservation.orq
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FTP SiteX Email: [e-mail]
IDAHO PO\A'ER COMPANY'S RESPONSE TO SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 34
Walmart, lnc.
Vicki M. Baldwin
Parsons Behle & Latimer
201 South Main Street, Suite 1800
Salt Lake City, UT 84111
Steve W. Chriss
Director, Energy Services
Walmart, lnc.
City of Boise
Ed Jewell
Deputy City Attorney's Office
150 N. Capitol Blvd.
P.O. Box 500
Boise, lD 83701-0500
WilGehl
Energy Program Manager
Boise City Department of Public Works
150 N. Capitol Blvd.
P.O. Box 500
Boise, !D 83701-0500
Clean Energy Opportunities for ldaho
Kelsey Jae
Law for Conscious Leadership
920 N. Clover Dr.
Boise, lD 83703
Courtney Write
Mike Heckler
Clean Energy Opportunities for ldaho
3778 Plantation River Drive, Suite 102
Boise, lD 83703
_Hand Delivered
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FTP SiteX Email: [e-mail]
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FTP SiteX Email:[e-mail]
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FTP SiteX Email:[e-mail]
bo isecitvatto rnev@citvofboise. oro
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FTP SiteX Email:[e-mail]
_Hand Delivered
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FTP SiteX Email: [e-mail]
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FTP Site
-[Email:cou rtnev@cleanenerqvopportu nities. com
mike@cleanenerovoooortu n ities. com
IDAHO PO\A'ER COMPANY'S RESPONSE TO SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 35
\tu-*e flr,nr*
Stacy Gust, Regulatory Administrative
Assistant
IDAHO POI/T'ER COIIPAT.IYs RESPONSE TO SECOND PRO'DUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POVI/ER COMPAT$T. 36
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
GASE NO. IPC-E-2140
IDAHO POWER COMPANY
REQUEST NO.38
ATTACHMENT NO. 1
SEE ATTACH ED SPREADSHEET
BEFORE THE
IDAHO PUBLIC UTILITIES COMMIS
GASE NO. IPC-E-2140
IDAHO POWER COMPANY
REQUEST NO.45B
S NIO
ATTAGHMENT NO. 1
SEE ATTAGHED SPREADSHEET
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
GASE NO. !PC-E-21-4A
IDAHO POWER COMPANY
CONFIDENTIAL
REQUEST NO. 45b (Gontracts)
ATTAGHMENT NO. 1
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPG.E.214A
IDAHO POWER COMPANY
CONFIDENTIAL
REQUEST NO. 45b (lnvoices)
ATTACHMENT NO.2