20220819CEO 4 to IPC.pdf

Kelsey Jae (ISB No. 7899)
Law for Conscious Leadership
920 N. Clover Dr.
Boise, ID 83703
Phone: (208) 391-2961
[e-mail]
Attorney for the Clean Energy Opportunities of Idaho
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
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CASE NO. IPC-E-22-22
CLEAN ENERGY OPPORTUNITIES
FOR IDAHO’S SECOND
PRODUCTION REQUEST TO
IDAHO POWER COMPANY
COMES NOW Clean Energy Opportunities for Idaho (CEO), by and through its attorney
of record, Kelsey Jae of the firm Kelsey Jae LLC, request that Idaho Power Company (“Idaho
Power” or “the Company”) provide the following documents within 21 days.
This Production Request is continuing, and Idaho Power is requested to provide, by way
of supplementary responses, additional documents that it or any person acting on its behalf may
later obtain that will augment the documents produced. Please provide answers to each question
with supporting workpapers that provide detail or are the source of information used in
calculations. Please provide any Excel files with formulas active. Additionally, please include the
name and phone number of the person preparing the document, and the name, location, and
phone number of the record holder and, if different, the witness who can sponsor the answer at
CLEAN ENERGY OPPORTUNITIES FOR IDAHO - SECOND PRODUCTION REQUEST - 1
IPC-E-22-22
RECEIVED
2022 AUG 19 PM 4:40
IDAHO PUBLIC
UTILITIES COMMISSION
hearing if need be. As allowed by IDAPA 31.01.01.228.01, CEO agrees to Idaho Power
depositing the response in an electronic depository.
REQUEST NO 4. Within Appendix 3.4 – 2021 Metering data – Schedule 84, the draft
VODER study provided kWhs of generation and consumption for multiple Commercial and
Irrigation service points. Within the Commercial customer data set in the Appendix, for each of
the approximately 127 service points (84L0001 to 84L0127) generation and consumption data
was aggregated by service point by month. Data was similarly presented on a separate worksheet
for the approximately 79 Irrigation service points (84A0001 to 84A0079).
Please provide for the sum of all 127 Commercial customers data sets, and separately for
the sum of all 79 Irrigation customers data sets, the hourly generation and consumption in kWhs
recorded for each hour of 2021.
Thus, we request four data sets, each showing 8760 entries:
● one showing hourly customer generation for the sum of all 127 Commercial
customer service points,
● one for the sum of Commercial customer consumption each hour,
● one for the sum of Irrigation customer generation each hour, and
● a fourth for the sum of Irrigation customer consumption each hour.
Dated this 19th day of August, 2022.
Respectfully submitted,
___________________________________
Kelsey Jae, Attorney for CEO
CLEAN ENERGY OPPORTUNITIES FOR IDAHO - SECOND PRODUCTION REQUEST - 2
IPC-E-22-22
CERTIFICATE OF SERVICE
I hereby certify that on this 19th day of August, I delivered true and correct copies of the
foregoing PRODUCTION REQUEST to the following persons via the method of service noted:
Electronic Mail Delivery (See Order No. 34602)
Idaho Public Utilities Commission
Jan Noriyuki
Commission Secretary
[e-mail]
Idaho PUC Staff
Riley Newton
Chris Burdin
Deputy Attorneys General
Idaho Public Utilities Commission
[e-mail]
[e-mail]
Idaho Power Company
Lisa D. Nordstrom
Megan Goicoechea Allen
Timothy Tatum
Connie Aschenbrenner
Grant Anderson
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
ABC Power Company
Ryan Bushland
[e-mail]
[e-mail]
City of Boise
Mary Grant, Deputy City Attorney
Boise City Attorney's Office
[e-mail]
[e-mail]
Wil Gehl, Energy Program Manager
Boise City Dept. Of Public Works
[e-mail]
Idaho Conservation League
Emma E. Sperry
[e-mail]
IdaHydro:
C. Tom Arkoosh
Amber Dresslar
Arkoosh Law Offices
[e-mail]
[e-mail]
[e-mail]
Idaho Irrigation Pumpers Association :
Eric L. Olsen
ECHO HAWK & OLSEN, PLLC
[e-mail]
Lance Kaufman, Ph.D.
[e-mail]
Idaho Solar Owners Network
Joshua Hill
[e-mail]
[e-mail]
CLEAN ENERGY OPPORTUNITIES FOR IDAHO - SECOND PRODUCTION REQUEST - 3
IPC-E-22-22
Industrial Customers of Idaho Power
Peter J. Richardson Richardson Adams,
[e-mail]
Dr. Don Reading
[e-mail]
Richard E. Kluckhohn
Wesley A. Kluckhohn
[e-mail]
[e-mail]
Micron Technology, Inc.
Jim Swier
[e-mail]
Austin Rueschhoff
Thorvald A. Nelson
Austin W. Jensen
Holland & Hart, LLP
[e-mail]
[e-mail]
[e-mail]
[e-mail]
_____________________________
Kelsey Jae
Attorney for CEO
CLEAN ENERGY OPPORTUNITIES FOR IDAHO - SECOND PRODUCTION REQUEST - 4
IPC-E-22-22