20230224IPC to Staff 7-9.pdf

MEGAN GOICOECHEA ALLEN
Corporate Counsel
mgoicoecheaallenidahopower.com

February 24, 2023

Jan Noriyuki, Secretary
Idaho Public Utilities Commission
11331 W. Chinden Boulevard
Building 8, Suite 201-A
Boise, Idaho 83714

Re: Case No. IPC-E-22-30
Application of Idaho Power Company for Authority to Establish Compensation
for the Mandatory Interruption Requirement of Schedule 20 - Speculative
High-Density Load

Dear Ms. Noriyuki:

Attached for electronic filing is Idaho Power Company’s Response to the Second
Production Request of the Commission Staff to Idaho Power Company in the above-
entitled matter.

If you have any questions about the attached documents, please do not hesitate to
contact me.

Sincerely,

Megan Goicoechea Allen

MGA:sg

Enclosure

RECEIVED
Friday, February 24, 2023 2:54:26 PM
IDAHO PUBLIC
UTILITIES COMMISSION
IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 1
MEGAN GOICOECHEA ALLEN (ISB No. 7623)
LISA D. NORDSTROM (ISB No. 5733)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
Attorneys for Idaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
AUTHORITY TO ESTABLISH
COMPENSATION FOR THE MANDATORY
INTERRUPTION REQUIREMENT OF
SCHEDULE 20 - SPECULATIVE HIGH-
DENSITY LOAD.
)
)
)
)
)
)
)
)
CASE NO. IPC-E-22-30
IDAHO POWER COMPANY’S
RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE
COMMISSION STAFF
COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), and in
response to the Second Production Request of the Commission Staff (“IPUC or
Commission”) dated February 3, 2023, herewith submits the following information:

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 2
REQUEST FOR PRODUCTION NO. 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 7: An increased load
factor will likely result in an average daily load shape that does not deviate much in total
requirements from one hour to the next from the peak requirements of the customer.
Conversely, a low load factor customer is just the opposite, resulting in higher variability
from trough to peak requirement. Thus, a high load factor customer has a much higher
probability that their peak requirements, no matter which hour of the day the system
peak falls, will coincide with the system peak. For illustrative purposes the below
graphic shows how this would look on the system when comparing high and low load
factor customers. The likelihood that a high load factor customer could hit their
maximum value coincident to any given hour when the system peaks is much greater
than a low load factor customer.

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 3
The response to this Request is sponsored by Jordan Prassinos, Load Research
and Forecasting Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 4
REQUEST FOR PRODUCTION NO. 8: Please explain if any of the Company's
peer utilities offer compensation for mandatory or voluntary interruption of service for
customers groups similar to Schedule 20. If so, please provide the utility, interruption
compensation, interruption details, rate/tariff, and any other applicable information to the
interruption of service.
RESPONSE TO REQUEST FOR PRODUCTION NO. 8: Idaho Power has not
completed an exhaustive review of all peer utility offerings for customer groups similar
to Schedule 20 but is aware of a few examples. As listed in Idaho Power’s Answer to
GeoBitmine LLC’s Petition for Reconsideration & Objection to Late Intervention in the
case to establish Schedule 20, Case No. IPC-E-21-37, both Black Hills Energy and
Rocky Mountain Power in Wyoming offer interruptible rates that are tailored for high-
density load customers such as cryptocurrency mining operations.1
Please see the respective details for Cheyenne Light, Fuel and Power Company
d/b/a Black Hills Energy Blockchain Interruptible Service Sheet No. 26:
https://www.blackhillsenergy.com/sites/blackhillsenergy.com/files/clfp_electric.pdf
And Rocky Mountain Power’s Interruptible Service Pilot Schedule 30:
https://www.rockymountainpower.net/content/dam/pcorp/documents/en/rockymountainp
ower/rates-regulation/wyoming/rates/030_Interruptible_Service_Pilot.pdf
Additionally, in late 2022 Idaho Power became aware of a recent filing in South
Dakota by Montana-Dakota Utilities Co., a subsidiary of MDU Resources Group, Inc, to
implement an interruptible rate offering for data centers, High Density Contracted

1 In the Matter of the Application of Idaho Power Company for Authority to Establish New Schedule to
Serve Speculative High-Density Load Customers, Case No. IPC-E-21-37, Idaho Power Company’s
Answer to GeoBitmine LLC’s Petition for Reconsideration & Objection to Late Intervention, pg. 11.

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 5
Demand Response Rate 45. However, the approved tariff only outlines infrastructure
upgrade cost responsibility and interruption parameters, not the value of interruption,
which is negotiated separately.
https://www.montana-dakota.com/wp-content/uploads/PDFs/Rates-
Tariffs/SouthDakota/Electric/SDElectric45.pdf
The response to this Request is sponsored by Paul Goralski, Regulatory
Consultant, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 6
REQUEST FOR PRODUCTION NO. 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 9: Please see Response
to Request No. 8 for those peer utility offerings for customer groups similar to Schedule
20 that Idaho Power is aware of; it is not in possession of any studies responsive to this
request that they may have conducted. While not a direct investor-owned peer utility,
Idaho Power has previously reviewed analysis and conclusions outlined in Chelan
Public Utility District’s Cryptocurrency Staff Report, which the Company believes was
issued November 2018, corresponding to public hearings occurring in that utility’s
service area at the time.
https://www.chelanpud.org/docs/default-source/default-document-library/final-
cryptocurrency-staff-report.pdf
The response to this Request is sponsored by Paul Goralski, Regulatory
Consultant, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 7
DATED at Boise, Idaho, this 24th day of February 2023.

MEGAN GOICOECHEA ALLEN
Attorney for Idaho Power Company

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 8
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the 24th day of February 2023, I served a true and
correct copy of Idaho Power Company’s Response to the Second 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:

Commission Staff
Riley Newton
Deputy Attorney General
Idaho Public Utilities Commission
Po Box 83720
Boise, Idaho 83720-0074

Hand Delivered
U.S. Mail
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X E-mail [e-mail]

________________________________
Stacy Gust, Regulatory Administrative
Assistant