20220419ICL 1-6 to IPC.pdf

.- I i i :- i t:..:tairj
Benjamin J. Otto (ISB No. 8292)
Emma E. Sperry
710 N 6ft Street
Boise,ID 83701
Ph: (208) 286-44s2
[e-mail]
e [e-mail]
IN THE MATTER OF IDAHO )
POWER COMPAI\IY'S )
APPLICATION TO EXPAND )
OPTIONAL CUSTOMER CLEAI\I )
ENERGY OFFERINGS THROUGH )
THE CLEAI\{ ENERGY YOUR WAY )PROGRAM )
CASE NO. IPC.E.2I.4O
FIRST PRODUCTION REQUEST OF
THE IDAHO CONSERVATION
LEAGUE
i.;," , *a F:! C' :1,-i:rr i..J f::i r'l^l
.- '1il::r-l-lt/lri-,,,. it.r \-rt\.tt i
Attorney for the ldaho Conservation League
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
COMES NOW the Idaho Conservation League, with the following production requests.
Along with the answer to each question, please provide any supporting documents, workpapers,
calculations, or information sources Idaho Power relies upon to support its answer. As required
by IDAPA 31.01.01.228.02, please indicate the witness who can answer questions regarding the
response and who will sponsor the response at any hearing. If any responses include Excel
spreadsheets or other electronic files, please provide them with all formulas intact and activated.
As allowed by IDAPA 3 I .01 .01 .228.01, if the volume of any response indicates it would be
more feasible to do so, ICL agrees to the Company depositing the response in an electronic
depository.
This production request is ongoing. Accordingly, we respectfully ask Idaho Power to
provide additional documents and information that may supplement any initial responses.
Request No l:
Ms. Williams' Direct Testimony, page 39, lines 8-14, states that the Program Charge for
the Subscription option will include "administration and marketing costs to advertise and
maintain the offering" and, separately a'oterm adjustment charge" applied to subscriptions for
less than 20 years. Then, on page 40, lines 7-9, Ms. Williams states that the term adjustment
IPC-E-21-40
ICL FIRST PRODUCTION REQUEST I
April19,2022
charge will cover "ongoing advertising and marketing." How is Idaho Power distinguishing
between these two sources of funding for the advertising and marketing to avoid double
collection of these costs?
Request No 2:
Ms. William's Direct Testimony, page 4l,line l3 states that any unsubscribed power
from the subscriber option resource will dispatch into the grid and be included in "broader
customer rates." However, Ms. Williams also states on page 40,line 5 of her Direct Testimony
that the 'oterm adjustment charge" will cover "any unexpected under-collection of program costs
due to early customer exit from the Subscription." Since Idaho Power will be charging its rate
base for any power that is not subscribed, how will Idaho Power assure that it does not double
recover program costs through both the term adjustment charge and including unsubscribed
power in broader customer rates?
Request No 3:
Please refer to Williams direct testimony at 39, lines 15-18 describing the Subscription
option Program Credit.
a. Please clarifu how Idaho Power intends to determine the energy and capacity value of
the program resource for the CEYW Subscription option.
b. Will the Company use the Value of Solar study currently underway?
Request No 4:
In response to Request No. 28(a) from Commission Staff, Idaho Power states that the
Program Credit for the Subscription option cannot exceed the Program Cost. Explain why there
is no scenario in which the energy and capacity components of the subscription credit could
exceed the program costs.
Request No 5:
In response to Request No. 47 from Commission Staff, Idaho Power provides an
estimated timeline for the Subscription option. Although the resource procurement is estimated
IPC-E-21-40 April19,2022
ICL FIRST PRODUCTION REQUEST 2
to be finalized by April of 2023, the Subscription option is not expected to commence until
November of 2024. Why does Idaho Power anticipate such a lengthy timeline for the start of this
option?
Request No 6:
ln Response to Request No. I from Commission Staff, Idaho Power states that one
advantage of the cuffent proposed Subscription option over the previous Community Solar pilot
is that the larger resource provides greater "economies of scale." Please provide all analysis
showing that the proposed 50 MW resource is the optimal size to achieve these economies of
scale.
a. Did ldaho Power compare the benefits of one 50 MW resource with the benefits of
multiple smaller (for example,25 MW) resources?
b. Did ldaho Power compare the benefits of one 50 MW resource with the benefits of a
larger resource in the current economic environment?
Respectfully submitted this lfth day of April2022.
6^tr
Benjamin J. Otto
Idaho Conservation League
IPC-E-21-40
ICL FIRST PRODUCTION REQUEST 3
April19,2022
CERTIFICATE OF SERYICE
I hereby certiff that on this 1fth day of April2022,l delivered true and correct copies of
the foregoing FIRST PRODUCTION REQUEST to the following persons via the method of
service noted:f^F
Electronic mail only (See Order 35058):
Idaho Public Utilities Commission
Jan Noriyuki, Secretary
sec retar.v @puc. i daho. gov
Dayn Hardie,
Deputy Attorney General
Dayn.hardie@puc. idaho. gov
Idaho Power
Lisa D. Nordstrom
Allison Williams
[e-mail]
awi I [e-mail]
[e-mail]
dockets@ idahopower.com
Industrial Customers of ldaho Power
Peter J. Richardson
Richardson, Adams, PLLC
[e-mail]
Dr. Don Reading
dread in g@mi ndsprins.com
Clean Energt Opportunityfor ldaho
Michael Heckler
Courtney White
m ike@c I eanenerg),opportun it),.com
Courtney@c leanenergyopportunity.com
Kelsey Jae
Law for Conscious Leadership
[e-mail]
IPC-E-21-40
ICL FIRST PRODUCTION REQUEST
Benjamin J. Otto
City of Boise
Ed Jewell, Deputy City Attorney
ej ewel [e-mail]
boi sec ityattornev@c itvofbo i se.ore
Wil Gehl, Energy Program Managaer
[e-mail]
ll'almart
Norman M. Semanko
Parsons Behle & Latimer
[e-mail]
Vicki M. Baldwin
Parsons Behle & Latimer
[e-mail]
Steve W. Chriss, Director Energy Services
Walmart,Inc.
Stephen. [e-mail]
4
April19,2022