20220812ICL 1-21 to IPC.pdf

IPC-E-22-22 August 12, 2022
ICL FIRST PRODUCTION REQUEST 1
Emma E. Sperry (Indiana Bar No. 37224-84)
710 N 6th Street
Boise, ID 83701
Ph: 208-537-7993, ext. 230
[e-mail]
Attorney for the Idaho Conservation League
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY’S APPLICATION TO COMPLETE
THE STUDY REVIEW PHASE OF THE
COMPREHENSIVE STUDY OF COSTS AND
BENEFITS OF ON-SITE CUSTOMER
GENERATION & FOR AUTHORITY TO
IMPLEMENT CHANGES TO SCHEDULES 6,
8 AND 84 FOR NON-LEGACY SYSTEMS
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CASE NO. IPC-E-22-22
FIRST PRODUCTION REQUEST
OF THE IDAHO
CONSERVATION LEAGUE
COMES NOW the Idaho Conservation League, with the following production requests
for Idaho Power Company. 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 heari ng. If
any responses include Excel spreadsheets or other electronic files, please provide them with all
formulas intact and activated. As allowed by IDAPA 31.01.01.228.01, 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.
ICL has engaged an expert witness to provide an analysis of the VODER Study which we
will use to inform our formal comments. Given the potential short time frame upon which to
comment on the Study and thus the short time frame for our expert to conduct its analysis, ICL
respectfully requests that, if possible, Idaho Power provide responses to Requests 1 – 5, 14, and
18 – 21 within 14 days. For the remaining Requests, the normal 21-day turnaround is fine for our
purposes.
RECEIVED
2022 AUG 12 PM 4:01
IDAHO PUBLIC
UTILITIES COMMISSION
IPC-E-22-22 August 12, 2022
ICL FIRST PRODUCTION REQUEST 2
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 1:
Please provide the following natural gas price forecasts discussed at page 105 of Idaho Power
Company’s (IPC) 2021 Integrated Resource Plan (2021 IRP):
a. Platts’ 2021 Henry Hub long-term forecast, after applying a basis differential and
transportation costs from Sumas, Washington.
b. The EIA Low Oil & Gas Supply forecast from the Energy Information Administration’s
Annual Energy Outlook 2021.
Request No. 2:
If IPC has a more recent gas price forecast than used in the 2021 IRP, please provide it. Also, if
IPC used a different gas price forecast for the VODER study than the 2021 IRP forecast, please
provide that forecast.
Request No. 3:
Please provide the gas transportation rates assumed in the gas forecast in page 106 of the 2021
IRP:
a. The rates that were applied for transportation from Stanfield, and the years in which they
apply (i.e. what were any discounted rate and the years in which they apply, and what
were any full tariff rates and the years they apply).
b. Please provide the basis differential assumed in each year for Stanfield, or at whatever
point commodity gas supplies are transported from, versus the benchmark Henry Hub
market.
Request No. 4:
Please provide the annual (nominal $/ton) values for the 2021 Carbon Price Forecasts (the High
Carbon Case/SCC and the Planning Case) shown in Figure 9.3 of the 2021 IRP.

IPC-E-22-22 August 12, 2022
ICL FIRST PRODUCTION REQUEST 3
Request No. 5:
Appendix 4.3 of the VODER study provides Energy Imbalance Market (EIM) locational
marginal prices (LMPs), in the EIM markets administered by the California Independent System
Operator (CAISO).
a. Are these the CAISO LMPs for the “ELAP_IPCO-APND” node?
b. Please explain why they appear to be significantly lower than the LMPs posted on the
CAISO OASIS site for that node (i.e. for 8/1/21 Hour 1, $35.53 per MWh VODER value
vs. $62.7 per MWh for the ELAP_IPCO-APND node).
c. Are the “Date” and “hour ending” values in Pacific or Mountain time? For example, is
the price of $35.53 per MWh for 8/1/2021 Hour 1 labeled in terms of Pacific Standard
Time (PST) or Mountain Standard Time (MST)?
Request No. 6:
Regarding IPC hourly loads:
a. Please provide FERC Form 714 data for 2021.
b. Please explain why FERC Form 714 data for 2020 shows different loads than in the
VODER study Appendix 4.10. For example, total load is 1,557 MW for 1/1/20, Hour 1,
in the VODER study appendix, whereas it is 1,743 MW in FERC Form 714 for Idaho
Power (Respondent ID = 180). Are the two datasets comparable?
Request No. 7:
Regarding IPC annual peak hourly loads in 2020:
• FERC Form 1, page 401b, for 2020 indicates a maximum hourly load of 3,723
MW, occurring on August 18, 2020, hour 20.
• Form 714 for 2020 shows an annual peak of 3,723 MW, occurring on August 18,
2020, hour 18 (MST).
• The VODER study, appendix 4.10, shows 2020 peak load equal to 3,392 MW,
occurring at on August 18, 2020, hour 17.
• FERC Form 1, page 400, indicates that the 2020 transmission system peak loads
shown below occurred on August 18, 2020, hour 17.

IPC-E-22-22 August 12, 2022
ICL FIRST PRODUCTION REQUEST 4
August 2020 Idaho Power Company Transmission System Peak Load (MW)
Peak
MW
Firm Network
Service for Self
Firm Network
Service for Others
Long-Term Firm
Point-to-point
Reservations
Short-Term Firm
Point-to-point
Reservation
4,695 3,064 341 973 363

a. In FERC Form 1, was the maximum load of 3,723 MW reported on page 401b computed
as the approximate sum of 3,064 MW firm network service for self, 341 MW firm
network service for others, and 317 MW short-term firm point-to-point reservation (i.e.
3,723 ~= 3,064 + 341 + 317)?
b. Please explain why the 3,392 MW system peak load listed in the VODER study differs
from the 2020 peak loads indicated in FERC Form 1 and FERC Form 714.
Request No. 8:
Please provide the IPC’s most recent forecast of future transmission system investments (i.e.
additions to plant in service as reported on page 206 of FERC Form 1 in FERC Accounts 350-
359), by year, for the future period over which IPC plans such investments. To the extent
available, this information should include:
a. A list of transmission lines and substations planned to be added or upgraded, their voltage
level, and the principal reason for each addition or upgrade.
b. The expected capital cost and in-service date of each planned transmission addition or
upgrade.
Request No. 9:
Please provide IPC’s most recent forecast of future distribution system investments (i.e.
additions to plant in service as reported on page 206 of FERC Form 1 in FERC Accounts 360-
374), by year, for the future period over which the IPC plans such investments. To the extent
available, this information should include:
a. A list of distribution circuits and substations planned to be added or upgraded, their
voltage level, and the principal reason for each addition or upgrade.
b. The expected capital cost and in-service date of each planned transmission addition or
upgrade.
IPC-E-22-22 August 12, 2022
ICL FIRST PRODUCTION REQUEST 5
Request No. 10:
Provide the IPC’s most recent forecast of future annual system peak loads, as reported in FERC
Form 1, page 401b, over the same forecast period as the T&D investment forecasts in Requests 8
and 9.
Request No. 11:
Please provide the IPC’s most recent forecast of transmission system peak loads, as reported in
FERC Form 1, page 400, over the same forecast period as the T&D investment forecasts in
Requests 8 and 9, if those peak loads differ from the system peak loads requested in Request 10.
Request No. 12:
Please provide 8,760 hourly substation loads for a recent calendar year (e.g. 2020 or 2021) in
Excel spreadsheet format for each of IPC’s Idaho distribution substations. For each substation,
please also provide its maximum capacity. Note: IPC has previously provided such data for
2016 in response to a Sierra Club data request in Docket IPC-E-17-13.
Request No. 13:
Please provide 8,760 hourly substation loads for a recent calendar year (e.g. 2020 or 2021) in
Excel spreadsheet format for each of the IPC’s Idaho transmission substations. Please also
include, for each substation, its maximum capacity.
Request No. 14:
Please provide all of IPC’s marginal cost studies completed in the last five years, and all
associated workpapers in Excel spreadsheet format. These can be, for example, a marginal cost
study used in rate design in a general rate case in Idaho, or a marginal cost of service study used
for filings such as the Oregon Resource Value of Solar (RVOS). In particular, please provide
any recent study (in the last five years) that calculates marginal capacity-related transmission and
distribution costs.
Request No. 15:
Please provide information on the IPC’s currently approved capital cost structure used to set
rates in Idaho, including return on debt, return on equity, return on preferred stock, percentages
for each, and IPC’s weighted average cost of capital.

IPC-E-22-22 August 12, 2022
ICL FIRST PRODUCTION REQUEST 6
Request No. 16:
Please provide, if available, any Real Economic Carrying Cost (RECC) factors used by IPC, as
well as the workpapers used to derive them.
Request No. 17:
Please provide the following load data:
a. Please provide in Excel spreadsheet format the monthly retail peak demands (in MW) for
the most recent calendar year for which data is available, (i) for all IPC customers and (ii)
broken down by customer class, as well as the date and time on which each of those
Idaho system and class peaks occurred.
b. Please provide in Excel spreadsheet format representative hourly load profiles (8,760
hourly loads in a year) for the following IPC customer classes: (1) residential, (2) small
commercial or small general service, and (3) large commercial / large general service /
industrial customers.
Request No. 18:
Please provide the IPC’s most recent cost-effectiveness analyses of its demand-side resources,
including energy efficiency (EE) and demand response (DR) programs that it has submitted to
the Idaho Public Service Commission. Please include all workpapers for these cost-effectiveness
analyses, including the alternate or avoided costs that IPC used, in Excel spreadsheet format.
Request No. 19:
Please provide:
a. The IPC’s current system average line loss factors, for both its transmission and
distribution systems, which it uses to set rates. Please provide these line loss factors by
voltage level if you have that level of disaggregation.
b. Please also provide the source documents or line loss study used to produce these factors.
Request No. 20:
Please provide the following data on any purchases or sales of Renewable Energy Credits
(RECs) that IPC has made in the 5 years 2017-2021 plus 2022 to date:
a. Volume of RECs (MWh) bought and sold, by month
IPC-E-22-22 August 12, 2022
ICL FIRST PRODUCTION REQUEST 7
b. Average purchase and sales prices, by month
c. Any study, report, or forecast that IPC has conducted or used to understand the market
for RECs in the WECC.
Request No. 21:
Please provide IPC’s most recent filing at the Oregon Public Utilities Commission of its
Resource Value of Solar (RVOS), as directed in Oregon PUC Order No. 19-022 in Docket UM
1911 and any subsequent orders. Please provide all workpapers for the calculations in this
RVOS filing.
Respectfully submitted this 12th day of August 2022.

/s/ Emma E. Sperry
Emma E. Sperry
Idaho Conservation League

IPC-E-22-22 August 12, 2022
ICL FIRST PRODUCTION REQUEST 8
CERTIFICATE OF SERVICE
I hereby certify that on this 12th day of August, 2022, I delivered true and correct copies
of the foregoing FIRST PRODUCTION REQUEST OF THE IDAHO CONSERVATION
LEAGUE to the following persons via the method of service noted:
/s/ Emma E. Sperry
Emma E. Sperry

Electronic mail only (See Order 35058):

Idaho Public Utilities Commission
Jan Noriyuki
Riley Newton
[e-mail]
[e-mail]
[e-mail]

IdaHydro
Tom Arkoosh
Amber Dresslar
[e-mail]
[e-mail]
[e-mail]

Idaho Power
Lisa Nordstrom
Megan Goicoechea Allan
Timothy E. Tatum
Connie G. Aschenbrenner
Grant Anderson
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
Idaho Irrigation Pumpers Associations, Inc.
Eric L. Olsen
Lance Kaufman, Ph.D.
[e-mail]
[e-mail]

Industrial Customers of Idaho Power
Peter J. Richardson
Don Reading
[e-mail]
[e-mail]

Clean Energy Opportunities for Idaho
Courtney White
Mike Heckler
Kelsey Jae
[e-mail]
[e-mail]
[e-mail]

City of Boise
Mary Grant
Wil Gehl
[e-mail]
[e-mail]
[e-mail]

IPC-E-22-22 August 12, 2022
ICL FIRST PRODUCTION REQUEST 9
Idaho Solar Owners Network
Joshua Hill
[e-mail]
[e-mail]

Kluckhohns
Richard E. Kluckhohn
Wesley A. Kluckhohn
[e-mail]
[e-mail]

Micron Technology, Inc.
Austin Rueschhoff
Thorvald A. Nelson
Austin W. Jensen
Jim Swier
[e-mail]
[e-mail]
[e-mail]
[e-mail]

ABC Power Co. LLC
Ryan Bushland
[e-mail]
[e-mail]