20220711IPC to ICIP 1-5.pdf

,'r''.\l-!\I:':-1
:: -' ',- i i PIi ':: 05
STHffi.
Lisa D. Nordstrom
AnnACOlPOomFny
P.O. Box 70 (8:t707)
rZlt W. HlhoSt.
Bolsc. lD &1702
LISA D. NORDSTROM
Lead Counsel
[e-mail]
July 1 1,2022
Jan Noriyuki, Secretary
ldaho Public Utilities Commission
11331 W. Chinden Boulevard
Building 8, Suite 201-A
Boise, ldaho 83714
Re: Case No. IPC-E-214O
Application to Expand Optional Customer Clean Energy Offerings Through
the CIean Energy YourWay Program
Dear Ms. Noriyuki:
Attached for electronic filing is Idaho Power Company's Response to the First
Production Request of lndustrial Customers of ldaho Power in the above-entitled matter.
lf you have any questions about the attached document, please do not hesitate to
contact me.
Sincerely,
X* !.(^1.+r,-*,
LDN:sg
Enclosure
LISA D. NORDSTROM (1SB No. 5733)
ldaho Power Company
1221 West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
!n ordstrom@ ida hopower. com
Attorney for Idaho Power Company
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. |PC-E-2140
IDAHO POWER COMPANY'S
RESPONSE TO FIRST
PRODUCTION REQUEST OF THE
INDUSTRIAL CUSTOMERS OF
IDAHO POWER
)
)
)
)
)
)
)
)
COMES NOW, Idaho Power Company ("ldaho Powe/' or "Company'), and in
response to the First Production Request of the lndustrial Customers of Idaho Power
('ICIP') dated June 20, 2022, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE INDUSTRIAL
CUSTOMERS OF IDAHO POWER - 1
REQUEST FOR PRODUCTION NO. 1:
At page 43 of Ms. Wlliams' prefiled testimony she states that, "ln simple terms,
Clean Energy Your Way - Construction ('Gonstruction Customef) offers large customers
a tailored way to cover 100 percent of their energy use with a new renewable resource(s)."
\Mllthe Company consider including new cogeneration resources in its proposal? Please
explain why or why not. Would it make a difference if the cogeneration facility were a
topping cycle facility or a bottoming cycle facility?l
RESPONSE TO REQUEST FOR PRODUCTION NO. 1:
No, unless the co-generation is from a renewable resource. The intent of the
program is to support customers' and their clean energy goals and initiatives, therefore
any proposed resource for the Construction option would need to be a renewable
resource.
The response to this Request is sponsored by Alison \M!!iams, Regulatory Policy
and Strategy Leader, ldaho Power Company.
t Topping cycle plants generate electricity first and utilize'waste' heat in the industrial process. Bottoming
cycle plants first use the heat in the industrial process and then use the remaining 'waste' heat to
generate electricity.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE INDUSTRIAL
CUSTOMERS OF IDAHO POWER - 2
REQUEST FOR PRODUCTION NO. 2:
Will ldaho Power charge Construction Customers a standby or back up charge for
the capacity and energy that they have contracted to receive from the REF? Please
reconcile your answer with the Commission's findings in Order No. 22887 at page 6
wherein the Commission made the following findings.
The Commission finds that Partia! Requirements Service for standby or backup
power for customers with self generation capability is distinguishable from underlying
basic Schedule 19 service in that it requires the Company to reserve a block of generation
and transmission capacity in addition to the distribution capacity covered by the standby
charge without a reasonable expectation of usage or related revenue.
RESPONSE TO REQUEST FOR PRODUGTION NO. 2:
No. The CIean Energy Your Way (.'CEYV1fl) Construction option is a billing
construct and ldaho Power continues to provide full energy and capacity service to
participating customers.
As noted by the Commission in Order No. 22887, the need to reserve a block of
generation and transmission capacity is due to a partial requirements customer with self-
generation who may need to utilize the Company's system capacity. The Company will
continue to charge CEYW customers a Demand and Basic Load Capacity charge at the
full capacity requirement of the customer's load. Further, the CEYW Construction option
includes collection of any fixed costs embedded in the standard energy rate, thus al!
capacity costs in customer rates will be collected at the custome/s fu!l capacity utilization.
The response to this Request is sponsored by Connie Aschenbrenner, Rate
Design Senior Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE INDUSTRIAL
CUSTOMERS OF IDAHO POWER.3
REQUEST FOR PRODUCTION NO. 3:
Wil! ldaho Power, in fact, be reserving a "block of generation and transmission
capacity" that is equivalent to the REF's output for the account of its Construction
Customers in the event their REFs experience an outage? lf not please explain how the
Company will ensure compliance with its fundamental obligation to serve in the event of
a REF outage?
RESPONSE TO REQUEST FOR PRODUCTION NO. 3:
No. ldaho Power will continue to provide, and plan for, full capacity service to
CEYW Construction option customers.
As part of the determination of the "REF Credit," ldaho Power wi!! evaluate the
capacity value the renewable resource provides to ldaho Power's system consistent with
the lntegrated Resource Plan ('lRP") most-recently acknowledged by the Commission at
the time of Construction option contract negotiation. As an example, once the 2021 IRP
is acknowledged, ldaho Power will utilize Effective Load Carrying Capability ('ELCC")
methodology to determine a renewable resource's capacity contribution, which would
inform potential changes to ldaho Power's required resources at the time of system
planning, The ELCC is a reliability-based metric used to assess the contribution to peak
of any given power plant, and the resulting ELCC includes probabilities of renewable
resource outages. Through use of the ELCC, or other IRP capacity contribution
methodology, ldaho Power will incorporate renewable resource system dynamics when
determining the necessary resources to meets its obligation to serve.
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 FIRST PRODUCTION REQUEST OF THE INDUSTRIAL
CUSTOMERS OF IDAHO POWER - 4
REQUEST FOR PRODUCTION NO.4:
Does the Company recommend that Schedule 19 customers who participate in the
Clean Energy Your Way - Construction option also subscribe to Tariff Schedule 45 in
order to ensure that they will not be subject to service interruptions in the even the
renewable resource procured through the Clean Energy Your Way process experiences
unplanned outages? Please explain why or why not.
RESPONSE TO REQUEST FOR PRODUGTION NO.4:
No. As noted by the Company in Response to Requests for Production No. 3 and
No. 4, ldaho Power will continue to provide full capacity service to CEYW Construction
option customers.
The response to this Request is sponsored by Connie Aschenbrenner, Rate
Design Senior Manager, ldaho Power Company.
IDAHO POVVER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE INDUSTRIAL
CUSTOMERS OF IDAHO POWER - 5
REQUEST FOR PRODUCTION NO. 5:
The Company's Application at page 14 provides that, "Construction resources
must connect to ldaho Power as system resources..." Will a Construction resource that
is physically located 'inside the fence'2 at an industrialfacitity be considered connected to
ldaho Powe/s system for eligibility purposes? Would your answer be different if the
Construction resource is located directly adjacent to the industria! customers plant but is
on the ldaho Power side of the customer's revenue meter? lf the treatment is different
please explain the rationale for the difference.
RESPONSE TO REQUEST FOR PRODUCTION NO. 5:
As outlined in the Application, the renewable resource must connect to ldaho
Power as a system resource. The resource may be located at the customer's site or
adjacent, but interconnection must be directly to ldaho Power's system.
The CEYW Construction Option does not contemplate behind-the-meter resource
installation. Customers are eligible to install behind-the-meter resources under the terms
governed by ldaho Power's Schedule 68 - Interconnections to Customer Distributed
Energy Resources, and Schedule 84 - Customer Energy Production Net Metering.
The response to this Request is sponsored by Connie Aschenbrenner, Rate
Design Senior Manager, ldaho Power Company.
2 On the custome/s side of ldaho Powe/s revenue meter
IDAHO PO\A'ER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE INDUSTRIAL
CUSTOMERS OF IDAHO POWER - 6
DATED at Boiee, ldaho, this 1Ith day of July 2022.
"(; fr.Y/^*r*-*,
LISA D. NORDSTROM
Attorney for ldaho Polrer Company
IDAHO POVT'ER COMPAhIY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE INDUSTRIAL
CUSTOMERS OF IDAHO POWER.T
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 11th day of July 2022,1 served a true and correct
copy of ldaho Power Company's Response to First Production Request of the lndustrial
Customers of ldaho Power upon the following named parties by the method indicated
below, and addressed to the following:
Commission Staff
Dayn Hardie
Deputy Attorney General
ldaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg No.8,
Suite 2O1-A (83714)
PO Box 83720
Boise, lD 83720-0074
lndustrial Gustomers of ldaho Power
Peter J. Richardson
Richardson Adams, PLLC
515 N. 27th Street
P.O. Box 7218
Boise, !D 83702
Dr. Don Reading
6070 Hill Road
Boise, ldaho 83703
ldaho Conseryation League
Benjamin J. Otto
Emma E. Sperry
ldaho Conservation League
710 N. 6th Street
Boise, lD 83702
Walmart, lnc.
Norman M. Semanko
Parsons Behle & Latimer
800 W. Main Street, Suite 1300
Boise, lD 83702
_Hand Delivered
_U.S. Mail
Overnight Mail
-FAX
FTP SiteX Email: [e-mail]
_Hand Delivered
_U.S. Mail
Overnight Mail
-FAX
FTP SiteX Emai!: [e-mail]
_Hand Delivered
_U.S. Mail
Overnight Mail
_FAX
FTP SiteX Email: [e-mail]
_Hand Delivered
_U.S. Mail
_Overnight Mail
_FAX
FTP SiteX Email:[e-mail]
esoerry@ ida hoconservation.orq
_Hand Delivered
_U.S. Mail
_Overnight Mail
_FAX
FTP SiteX Email: [e-mail]
IDAHO PO\A'ER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE INDUSTRIAL
CUSTOMERS OF IDAHO POWER - 8
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 Jewel!
Deputy City Attorney's Office
150 N. Capitol Blvd.
P.O. Box 500
Boise, !D 83701-0500
WilGeh!
Energy Program Manager
Boise City Department of Public Works
150 N. Capitol Blvd.
P.O. Box 500
Boise, ID 83701-0500
Clean Energy Opportunities for ldaho
Kelsey Jae
Law for Conscious Leadership
920 N. Clover Dr.
Boise, lD 83703
Courtney White
Mike Heckler
Clean Energy Opportunities for ldaho
3778 Plantation River Drive, Suite 102
Boise, ID 83703
_Hand Delivered
_U.S. Mail
Overnight Mail
_FAX
FTP SiteX Email: [e-mail]
_Hand Delivered
_U.S. Mail
Overnight Mail
_FAX
FTP SiteX Email:[e-mail]
_Hand Delivered
_U.S. Mai!
Overnight Mail
_FAX
FTP SiteX Email: [e-mail]
bo isecitvatto rnev@citvofboise. orq
_Hand Delivered
_U.S. Mail
Overnight Mail
_FAX
FTP SiteX Email:[e-mail]
_Hand Delivered
_U.S. Mail
Overnight Mail
_FAX
FTP SiteX Email: [e-mail]
_Hand Delivered
_U.S. Mail
Overnight Mail
-FAX
FTP Site
-[Email:cou rtnev@clea ne ne rqvop po rtu n ities. com
mike@cleanenerovopportu n ities.com
IDAHO PO\A/ER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE INDUSTRIAL
CUSTOMERS OF IDAHO POWER - 9
\fu""+ &-.d=
Stacy Gust, Regulatory Administrative
Assistant
IDAHO POV\ER COMPAI.IYS RESPONSE TO FIRST PRODUCTION REQUEST OF THE INDUSTRIAL
CUSTOMERS OF IDAHO POVT'ER. 10