20220902Staff 56-61 to IPC.pdf

RILEY NEWTON
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BARNO. II2O2
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 GE,NERATION & FOR
AUTHORITY TO IMPLEMENT CHANGES
TO SCHEDULES 6, 8, AI\D 84
CASE NO.IPC.E-22.22
THIRD PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO IDAHO POWER COMPANY
ia; .i l r ; t
Street Address for Express Mail:
1I33I W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE,ID 837I4
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Riley Newton, Deputy Attomey General, requests that Idaho Power Company ("Company" or
"Idaho Power") provide the following documents and information as soon as possible, but no later
than MONDAY, SEPTEMBER 12, 2022.1
This Production Request is to be considered as continuing, and the Company 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 or information produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name, job title, and telephone number of
I Stuff ir requesting an expedited response. If responding by this date will be problematic, please call StafPs
attorney at [phone].
THIRD PRODUCTION REQUEST
TO IDAHO POWER 1 SEPTEMBER2,2022
the person preparing the documents. Please also identiff the name, job title, location, and
telephone number of the record holder.
In addition to the written copies provided as response to the requests, please provide all
Excel spreadsheets and electronic files on CD with formulas intact and enabled.
REQUEST NO. 56: To evaluate the monetary value of the accumulated excess kWh
credits, the Value of Distributive Energy Resources ("VODER") Study used each customer
class's average energy rate and stated "[t]he average energy rate was selected because the
accumulated kwh credits can only be used to offset the energy components of a customer bill."
VODER Study at 105. Please explain why the Export Credit Rate ("ECR") is not used to
evaluate the monetary value of the accumulated excess kWh credits. In your explanation, please
reconcile with the statement in the VODER Study at 105 "the use of non-time variant export
credit rates is appropriate."
REQUEST NO. 57: The VODER Study states that "[i]n recognition that excess
accumulated kWhs benefitted the system at the time they were created, the accumulated kWhs
could be compensated at the Export Credit Rate and recovered through the PCA similar to how
the study anticipates the cost of export credits would be recovered." Voder Study at 105. Please
clarifu whether the ECR used to compensate for the excess accumulated kWhs is the ECR at the
time when the excess accumulated kWhs were created or when the excess accumulated kWhs are
"cashed out". Please explain why.
REQUEST NO. 58: The VODER Study states "[i]f the excess kWh credits were expired
and not used to offset customer usage, Idaho Power would benefit by collecting the average
energy rate for the usage not offset." VODER Study at 106. Please explain why the benefit is not
measured based on the avoidance of the ECR payments.
REQUEST NO. 59: Please respond to the following regarding the Tab Summary in
Appendix 10.1.
a- Please confirm Cell B20 should have been "Residential", instead of
"Commercial".
THIRD PRODUCTION REQUEST
TO IDAHO POWER 2 SEPTEMBER2,2022
b. To calculate "Transfers as a % of KWH Balance", why is "Excess Net Energy
Credit Transfers - Actuals" of one year divided by "Net Excess - KWH" of the
previous year? For example, why is "Excess Net Energy Credit Transfers -
Actuals" as of l2l3ll20l8 divided by "Net Excess - KWH" as of l2l3ll20l7,
instead of using the same year's data?
c. Please explain why the formula used to calculate "Transfers as ao/o of KWH
Balance" for Irrigation customers is different than that for Residential and
Commercial classes?
d. Why does this analysis not include Schedule 6 customers and the industrial
customers of Schedule 84?
REQUEST NO. 60: Please respond to the following regarding the Tab Average Energy
Rate in Appendix 10.1.
a. Please define "APCU - March Forecast".
b. Please explain why Idaho's PCA and Oregon's PCAM and APCU - March
Forecast should be summed together to arrive at the total system value.
REQUEST NO. 61: Please explain whether all the scenarios below are possible.
a. For non-legacy systems, accumulated excess kWh credits could be exchanged for
financial credits, after ECRs are approved.
b. For non-legacy systems, accumulated excess kWh credits could still be used as
kWh credits, after ECRS are approved.
c. For legacy systems, accumulated excess kWh credits could be exchanged for
financial credits, after ECRs are approved.
d. For legacy systems, accumulated excess kWh credits could still be used as kWh
credits, after ECRs are approved.
THIRD PRODUCTION REQUEST
TO IDAHO POWER J SEPTEMBER2,2022
IIATED at Boise, Id,aho, *, Z t day of Septembo 2A22.
Riley Neirton
DWUBAttorney General
i:umisc:pro&cq/ipce22.22rntne god rcq 3
TIIIRD PRODUCTION REQI.JEST
TO IDATIO POSTER 4 SEPTEN{BER 2,2022
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 2Nd DAY OF SEPTEMBER 2022,
SERVED THE FOREGOING THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY, IN CASE NO. IPC-E-22-22,
BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
LISA NORDSTROM
MEGAN GOICOECHEA ALLEN
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL:rdstrom
[e-mail]
[e-mail]
C TOM ARKOOSH
AMBER DRESSLAR
ARKOOSH LAW OFFICES
PO BOX 2900
BOISE ID 83701
E-MAIL: [e-mail]
ambe r. dres s lar(d,arkoo sh. co m
KELSEY JAE
LAW FOR CONSCIOUS LEADERSHIP
920 N CLOVER DR
BOISE ID 83703
E-MAIL: kelsev@k rae.com
ERIC L OLSEN
ECHO HAWK & OLSEN PLLC
PO BOX 6l 19
POCATELLO ID 83205
E-MAIL: [e-mail]
TIMOTHY TATUM
CONNIE ASCHENBRENNER
GRANT ANDERSON
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: [e-mail]
[e-mail]
sanderson@ idahooorver.com
MICHAEL HECKLER
COURTNEY WHITE
CLEAN ENERGY OPPORTUNITIES
3778 PLANTATION RIVER DR
SUITE IO2
BOISE ID 83703
E-MAIL:
m i ke(0 c I eanenerg)'o pport u n i t ies. com
[e-mail]
ELECTRONIC ONLY
ERIN CECIL
E-MAIL: [e-mail]
LANCE KAUFMAN PhD
4801 W YALE AVE
DENVER CO 80219
E-MAIL: [e-mail]
-A t-2^"-.
SECRETrif '/-
CERTIFICATE OF SERVICE