20230203Staff 7-9 to IPC.pdf

RILEY NEWTON
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE,IDAHO 83720-0074
[phone]
IDAHO BAR NO.11202
Street Address for Express Mail:
11331 W CHINDEN BLVD,BLDG 8,SUITE 201-A
BOISE,ID 83714
Attorneyfor the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER )COMPANY'S APPLICATION FOR )CASE NO.IPC-E-22-30
AUTHORITY TO ESTABLISH )COMPENSATION FOR THE MANDATORY )INTERRUPTION REQUIREMENTOF )SECOND PRODUCTION
SCHEDULE 20 --SPECULATIVE HIGH-)REQUESTOF THE
DENSITY LOAD )COMMISSION STAFF
)TO IDAHO POWER COMPANY
Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Riley Newton,Deputy AttorneyGeneral,requests that Idaho Power Company ("Company")
provide the followingdocuments and information as soon as possible,but no later than
FRIDAY,FEBRUARY 24,2023.
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 telephonenumber of
the person preparing the documents.Please also identify the name,job title,location,and
telephone number of the record holder.
SECOND PRODUCTION REQUEST
TO IDAHO POWER l FEBRUARY 3,2023
RECEIVED
2023 February 3, 1:27PM
IDAHO PUBLIC
UTILITIES COMMISSION
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.
REQUESTNO.7:Please explain how an increase in load factor increases the
probability that that load will be coincident with system peak.Please provide any relevant
examples or documents supporting the correlation.
REQUESTNO.8:Please explain if any of the Company's peer utilities offer
compensation for mandatory or voluntaryinterruption of service for customers groups similar to
Schedule 20.If so,please provide the utility,interruptioncompensation,interruption details,
rate/tariff,and any other applicable information to the interruption of service.
REQUESTNO.9:Please provide any studies conducted or referenced by the Company
that evaluate load characteristics of customers under peer utilities for customer groups that are
similar to Schedule 20.
DATED at Boise,Idaho,this day of February 2023.
Riley wton
Deput AttorneyGeneral
i:umisc:prodreq/ipce22 30rnme prod req 2
SECOND PRODUCTION REQUEST
TO IDAHO POWER 2 FEBRUARY 3,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 3rd DAY OF FEBRUARY 2023,
SERVED THE FOREGOING SECOND PRODUCTION REQUESTOF THE
COMMISSION STAFF TO IDAHO POWER COMPANY,IN CASE NO.IPC-E-22-30,
BY E-MAILING A COPY THEREOF,TO THE FOLLOWING:
MEGAN GOICOECHEA ALLEN CONNIE ASCHENBRENNER
LISA NORDSTROM PAUL GORALSKI
IDAHO POWER COMPANY IDAHO POWER COMPANY
PO BOX 70 PO BOX 70
BOISE ID 83707-0070 BOISE ID 83707-0070
E-MAIL:[e-mail] E-MAIL:[e-mail]
[e-mail] peoralski idahopower.com
[e-mail]
SECRE ARY
CERTIFICATE OF SERVICE