20220915IPC to Staff Supplemental Response.pdf

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An IDACORP CompenY
LISA D. NORDSTROM
Lead Counse!
I [e-mail]
Septembet 15,2022
VIA ELECTRONIC FILING
Jan Noriyuki, Secretary
ldaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg 8,
Suite 201-A (83714)
PO Box 83720
Boise, fdaho 83720-0074
Re Case No. IPC-E-22-22
ln the Matter of ldaho 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 lmplement Changes to
Schedules 6, 8 and 84 for Non-Legacy Systems
Dear Ms. Noriyuki
Attached for electronic filing is ldaho Power Company's Second Supplemental
Response the First Production Request of the Commission Staff in the above-referenced
matter.
Based on consultation with Commission Staff, the Company provides these
second supplementa! responses to the First Production Request of Staff dated August 3,
2022, pursuant to Staffs request for additional information on Request Nos. 5, 6, 13, and
24.
lf you have any questions about the documents referenced above, please do not
hesitate to contact me.
Verv trulv vours.
^'l-__ 4
X*!fl"u^^,
Lisa D. Nordstrom
LDN:sg
Attachments
LISA D. NORDSTROM (lSB No. 5733)
MEGAN GOICOECHEA ALLEN (lSB No. 7623)
Idaho Power Company
1221 West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
lnordstrom@ida hopower. com
mqoicoecheaa llen@ida hopower.com
Attorneys for ldaho Power Company
BEFORE THE !DAHO 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
oASE NO. |PC-E-22-22
IDAHO PO\A/ER COMPANY'S
SECOND SUPPLEMENTAL
RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO
POWER COMPANY
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COMES NOW, ldaho Power Company ('ldaho Powe/' or "Company") hereby
provides these second supplemental responses to the First Production Request of the
Commission Staff ("Commission" or "StafP') dated August 3,2022.
IDAHO POWER COMPANY'S SECOND SUPPLEMENTAL RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POVVER COMPANY - 1
REQUEST FOR PRODUCTION NO.5: Please provide a histogram (10 kW
intervals) showing the number of non-solar residential customers with demand peaks
greater than 25 kW.
:
Please see Figure 1 below for the histogram of non-solar residential customer service
points. This information is based on billing data over the calendar year 2021.|t excludes
mobile home parks, RV parks, and large master metered customers. The customers
included in this histogram with demand 25 kilowatts ('kW') and greater represent 2.1
percent of non-solar residential customers.
Customer counts and demand are reported by service point, or Point of Delivery,
where the retail customer takes Electric Service from ldaho Power.l This method for
counting customers is consistent with how the Company reports customer counts and
how the existing project eligibility cap is applied. Pursuant to Rule C, Service and
Limitations, meter readings will not be combined or aggregated for any purpose except
for determining if the Customer's total power requirements exceed 20,000 kW for
determining special contract arrangements.
1 Point of Delivery and Eleclric Service are defined in Rule B, Definitions of |.P.U.C. No. 29, Tariff No. 101
IDAHO PO\'\'ER COMPANY'S SECOND SUPPLEMENTAL RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POVVER COMPANY - 2
Figure I
Non-Solar Residential Customer Service Point Histogram
600,000
495,1325m,000
000
000
000
400,
300,
200,
o
g
oo:,o
o
o
€)z
100,000
25 or
less
1,904
25-34
30
75-84
29
85 plus
7,059 1,269 2gT 64
3544 45-54 55€4 65-74
Annual Peak Demand (kW)
The response to this Request is sponsored by Grant T. Anderson, Regulatory
Consultant, ldaho Power Company.
IDAHO POVVER COMPANY'S SECOND SUPPLEMENTAL RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 3
REQUEST FOR PRODUCTION NO. 6: Flease provide a histogram (100 kW
intervals) showing the number of non-solar Commercial, lndustrial, and !rrigation ('Cl&l')
customers with demand peaks greater than 100 kW.
SECOND SUPPLETI'IENTAL RESPONSE TO REQUEST FOR PRODUCTION
NO. 6: Please see Figure 2 below for the histogram of non-solar Cl&l customer service
points. This information is based on billing data over the calendar year 2021. The
customers included in the histogram with demand 100 kW and greater represent 6.10/o ot
non-solar Cl&l customers.
Customer counts and demand are reported in the same method as explained in
more detail in Second Supplemental Response to Request for Production No. 5.
Figure 2
Non-Solar Cl&l Customer Service Point Histogram
1oo'mo 90.781
90,000
80.000
70.000
60.000
50.000
40.0m
30.000
20.0m
10.000
Annual Peak Demand (kW)
The response to this Request is sponsored by Grant T. Anderson, Regulatory
Consultant, ldaho Power Company.
IDAHO POWER COMPANY'S SECOND SUPPLEMENTAL RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 4
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REQUEST FOR PRODUCTION NO. 13: Pages 101 and 102 of the VODER study
discuss changes in the system ownership and provides an example where a business
owner could have a maximum hourly demand of 50 kW when s/he installs a generation
system, but a new owner may only operate with a maximum hourly demand of 25 kW.
Please respond to the following.
a. Please explain whether this situation could increase the exported amount.
b. Please explain whether this situation could cause any safety or reliability
issues to the Company's system.
c. Please explain what mechanism(s) is(are) necessary to sufficiently address
issues caused by change of ownership.
d. Please provide the estimated costs of implementing the mechanism(s).
SUPPLEMENTAL RESPONSE TO REQUEST FOR PRODUCTION NO. 13:
Please see the following responses regarding project eligibility cap:
a. There would likely be an increase in exports based on the reduced peak
demand. However, this isn't definitive and would depend on the original load
factor compared to the new load factor.
b. It is not likely that this situation would cause a safety or reliability issue. The
risk that could occur would be a match on the distribution line between the
minimum load with the coincident generation that could result in the system
operating in an island condition. The decrease in load while maintaining the
generation level, if occurring often, could lead to this islanding potential.
However, the singular example presented of a 25kW load reduction is not
likely to result in this scenario.
IDAHO POWER COMPANY'S SECOND SUPPLEMENTAL RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 5
c. The Company believes this is both a policy and administrative issue - not a
safety or reliability issue. A solution could be that the new customer must
curtailthe generation to match the new peak load.
d. Curtailing the generation could require an inverter maximum output settings
change, if possible, or disconnecting a portion of the array. The Company has
not yet evaluated other potential administrative costs necessary for
incremental personnel to monitor and follow up with the new customer to
adjust the inverter.
The response to this Request is sponsored by Jared L. Ellsworth, Distribution &
Resource Planning Director, ldaho Power Company.
IDAHO POVVER COMPANY'S SECOND SUPPLEMENTAL RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 6
REQUEST FOR PRODUCTION NO. 24: Please explain why the Nameplate
Capacity value of 64.11 MW was used to calculate the Avoided Capacity Cost. Please
provide any workpapers supporting this value.
SUPPLEMENTAL RESPONSE TO REQUEST FOR PRODUCTION NO. 24: The
cumulative nameplate capacity of active projects installed at the end of 2020 was 64.11
MW. By selecting the operational projects at the end of 2020, data for at least one full
year was available. The Effective Load Carrying Capacity ('ELCC') and the National
Renewable Energy Laboratory ("NREL') 8,760-based methods provide capacity
contribution results as percentages whose calculations utilize a nameplate capacity of the
resource under review and can be used for different amounts of penetration levels in the
system. The attached Excel spreadsheet provides the data supporting the nameplate
capacity value of 64.1 1 MW.
The company considered the impact of including projects added throughout the
calendar year 2021. Customer loads and customer generation output vary from season
to season; the resulting exported energy also varies by season. lncluding projects added
throughout the year would skew the resulting data and not provide a representative
annual exported energy to use in the Study.
The response to this Request is sponsored by Jared L. Ellsworth, Distribution &
Resource Planning Director, ldaho Power Company.
DATED at Boise, ldaho, this 1Sth day of September 2022.
X;!.ff""ut **,
LISA D. NORDSTROM
Aftorney for ldaho Power Company
IDAHO POVER COMPANY'S SECOND SUPPLEMENTAL RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POVVER COMPANY - 7
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 1Sth day of September 2022, ! served a true and
correct copy of ldaho Power Company's Second Supplemental Response to the First
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:
IDAHO PO\A'ER COMPANY'S SECOND SUPPLEMENTAL RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO PO\A'ER COMPANY - 8
Commission Staff
Riley Newton
Chris Burdin
Deputy Attorney General
ldaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg No. 8
Suite 201-A (83714)
PO Box 83720
Boise, lD 83720-0074
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Chris.burdin@ouc. idaho.qov
IdaHydro
C. Tom Arkoosh
Amber Dresslar
Arkoosh Law Offices
913 W. River Street, Suite 450
P.O. Box 2900
Boise, ldaho 83701
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Amber.d resslar@a rkoosh. com
erin. cecil@a rkoosh.com
ldaho Conseryation League
Marie Kellner
Idaho Conservation League
710 North 6th Street
Boise, ldaho 83702
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ldaho lrrigation Pumpers Association, lnc.
Eric L. Olsen
Echo Hawk & Olsen, PLLC
505 Pershing Avenue, Suite 100
P.O. Box 61 19
Pocatello, ldaho 83205
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Lance Kaufman, Ph.D
4801 W. Yale Ave.
Denver, CO 80219
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Gity of Boise
Mary Grant
Deputy City Attorney
Boise City Aftorney's Office
150 North Capitol Boulevard
P.O. Box 500
Boise, ldaho 83701 -0500
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bo isecitvatto rnev@ citvofboise. o ro
Wi! Geh!
Energy Program Manager
Boise City Dept. of Public Works
150 N. Capitol Blvd.
PO Box 500
Boise, ldaho 83701 -0500
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lndustrial Customers of ldaho Power
Peter J. Richardson
Richardson Adams, PLLC
515 North 27th Street (83702)
P.O. Box 7218
Boise, ldaho 83707
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Dr. Don Reading
6070 Hill Road
Boise, ldaho 83703
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Micron Technology, lnc.
Austin Rueschhoff
Thorvald A. Nelson
Austin W. Jensen
Holland & Hart, LLP
555 Seventeenth Street, Suite 3200
Denver, Colorado 80202
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[e-mail]
awiensen@hol la nd hart.com
Jim Swier
Micron Technology, lnc.
8000 South FederalWay
Boise, ldaho 83707
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aclee@holland ha rt. com
IDAHO PO\A'ER COMPANY'S SECOND SUPPLEMENTAL RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO PO\A'ER COMPANY - 9
Clean Energy Opportunities for ldaho
Kelsey Jae
Law for Conscious Leadership
920 N. Clover Dr.
Boise, ldaho 83703
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Ovemight Mail
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Michael Heckler
Courtney \Nhite
Clean Energy Opportunities for ldaho
3778 Plantation River Dr., Suite 102
Boise, lD 83703
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mike@cleanenerovopportu n ities.com
cou rtnev@cleanenerqvopoortu n ities.com
Richard E. Kluckhohn, pro se
Wesley A. Kluckhohn, pro se
2564 W. Parkstone Dr.
Meridian, lD 83646
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ldaho Solar Owners Network
Joshua Hill
ldaho Solar Owners Network
1625 S. Latah
Boise, lD 83705
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[e-mail]
ABC Power Gompany, LLC
Ryan Bushland
ABC Power Company, LLC
184 W. Chrisfield Dr.
Meridian, lD 83646
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[e-mail]
&rsj=
Stacy Gust, Regulatory Administrative
Assistant
IDAHO POWER COMPANY'S SECOND SUPPLEMENTAL RESPONSE TO THE FIRST PRODUCT]ON
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 1O
BEFORE THE
IDAHO PUBLIC UTILITIES GOMMISS]ON
CASE NO. IPG-E-22-22
IDAHO POWER COMPANY
REQUEST NO.24
ATTACHMENT NO. 1
SEE ATTACHED SPREADSHEET