20220323IPC to Staff 44.pdf

LISA D. NORDSTROM
Lead Counsel
[e-mail]
March 23, 2022
VIA ELECTRONIC FILING
Jan Noriyuki, Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg 8,
Suite 201-A (83714)
PO Box 83720
Boise, Idaho 83720-0074
Re: Case No. IPC-E-21-42
In the Matter of Idaho Power Company’s Application for Approval of Special
Contract and Tariff Schedule 33 to Provide Electric Service to Brisbie, LLC’s
Data Center Facility
Dear Ms. Noriyuki:
Attached for electronic filing, pursuant to Order No. 35058, is Idaho Power
Company’s Response to the Third Production Request of the Commission Staff in the
above entitled matter.
Please feel free to contact me directly with any questions you might have about
this filing.
Sincerely,
Lisa D. Nordstrom
LDN:sg
Enclosures
RECEIVED
2022 MAR 23 PM 4:21
IDAHO PUBLIC
UTILITIES COMMISSION

IDAHO POWER COMPANY’S RESPONSE TO THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 1
DONOVAN E. WALKER (ISB No. 5921)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
[e-mail]

Attorney for Idaho Power Company

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF IDAHO POWER
COMPANY’S APPLICATION FOR
APPROVAL OF SPECIAL CONTRACT AND
TARIFF SCHEDULE 33 TO PROVIDE
ELECTRIC SERVICE TO BRISBIE, LLC’S
DATA CENTER FACILITY.
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CASE NO. IPC-E-21-42

IDAHO POWER COMPANY’S
RESPONSE TO THIRD
PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO
POWER COMPANY

COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), and in
response to the Third Production Request of the Commission Staff (“IPUC or
Commission”) dated March 16, 2022, herewith submits the following information:

IDAHO POWER COMPANY’S RESPONSE TO THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 2
REQUEST FOR PRODUCTION NO. 44: Please explain how the Company will
allocate the cost of both Excess Generation credits and the Renewable Capacity credits
between its jurisdictions in future base rates and in the Power Cost Adjustment.
RESPONSE TO REQUEST FOR PRODUCTION NO. 44: For base rate and the
Power Cost Adjustment (“PCA”) rate determinations, Idaho Power will allocate the costs
of the Excess Generation credits between jurisdictions and customer classes using an
energy-based allocation factor. In the PCA, these costs will be allocated to Idaho based
on its share of total system billed sales, and should not be subject to the 95/5 sharing
provision. As noted in the Company’s Response to Staff’s Request No. 36(a),
Renewable Capacity credits for Brisbie will not be reflected in the PCA. These credits
are intended to appropriately recognize that the renewable resources supporting Brisbie
will provide a portion of their capacity needs, which must be recognized in the rate
design to ensure they are not double-charged for their capacity needs. Because
Brisbie’s demand-related revenue will be directly assigned to the Idaho jurisdiction in a
general rate case, the cost of the renewable capacity credit should be directly assigned
to Idaho to ensure a proper matching of costs and revenues. The cost of the Renewable
Capacity credit should be allocated between classes of Idaho customers using a
demand-based allocation factor. Idaho Power envisions its 12 coincident peak demand
allocation factor, “D10,” as being the appropriate method of class-level allocation.
The response to this Request is sponsored by Matt Larkin, Revenue
Requirement Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 3
Respectfully submitted this 23rd day of March 2022.

for
DONOVAN E. WALKER
Attorney for Idaho Power Company

IDAHO POWER COMPANY’S RESPONSE TO THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 4
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the 23rd day of March 2022, I served a true and
correct copy of the foregoing Idaho Power Company’s Response to Third Production
Request of the Commission Staff to Idaho Power Company upon the following named
parties by the method indicated below, and addressed to the following:

Taylor Brooks
Deputy Attorney General
Idaho Public Utilities Commission
Po Box 83720
Boise, Idaho 83720-0074

Emailed to:
[e-mail]
Clean Energy Opportunities for Idaho
Michael Heckler
Courtney White
CLEAN ENERGY OPPORTUNITIES
FOR IDAHO INC.
3778 Plantation River Drive, Suite 102
Boise, Idaho 83703

Emailed to:
[e-mail]
[e-mail]

Kelsey Jae
Law for Conscious Leadership
920 N. Clover Dr.
Boise, ID 83703

Emailed to:
[e-mail]

________________________________
Stacy Gust, Regulatory Administrative
Assistant