20230707CEO 1-6 to IPC.pdf

Kelsey Jae (ISB No. 7899)
Kelsey Jae LLC
920 N. Clover Dr.
Boise, ID 83703
Phone: (208) 391-2961
[e-mail]
Attorney for Clean Energy Opportunities for Idaho
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO
POWER COMPANY’S
APPLICATION FOR AUTHORITY
TO INCREASE ITS RATES AND
CHARGES FOR ELECTRIC
SERVICE IN THE STATE OF
IDAHO AND FOR ASSOCIATED
REGULATORY ACCOUNT
TREATMENT
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CASE NO. IPC-E-23-11
CLEAN ENERGY OPPORTUNITIES
FOR IDAHO’S FIRST 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, and requests that Idaho Power
Company (“the Company” or “Idaho Power”) provide the following documents within 21 days
or sooner if possible.
This Production Request is 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 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 - FIRST PRODUCTION REQUEST - 1
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RECEIVED
Friday, July 7, 2023 10:04:43 AM
IDAHO PUBLIC
UTILITIES COMMISSION
hearing if need be. As allowed by IDAPA 31.01.01.228.01, CEO agrees to the Company
depositing the response in an electronic depository.
CONTEXT/BACKGROUND
In IPC-E-23-11, the Commission confirmed that the scope of appropriate review includes
“every component of every existing and proposed rate” as well as the “proposed relationships
among and between customer classes or rate groupings” and that “classifications . . . are at issue”
(see Order No. 35825 at 6-7).
In the classification and allocation portions of its Class Cost of Service (CCOS) analysis,
the Company has “used the Electric Utility Cost Allocation Manual, published January 1992, as
(its) primary guide to cost classification (see Goralski Direct at 6) as well as a 12CP/4CP method
for cost allocation to customer classes.
CEO believes that substantive technological changes have taken place since such
classification and allocation methods were used in the 2008 and 2011 rate cases. In light of such
technological changes, the DOE suggests that the traditional 1992 manual approach is no longer
persuasive and that “Changes in technology and regulation necessitate a change in cost allocation
process” (see on Emerging Trends in Utility Cost Allocation by the Grid Modernization Lab
Consortium).
With near universal availability of Idaho Power customer load data in hourly increments
via AMI, similar hourly (or finer) resolution of market prices via EIM, dramatically higher levels
of “must-run” variable energy resource generation added since 2011 and new storage
technologies employed in the test year data, CEO believes it is worthwhile to review a time
CLEAN ENERGY OPPORTUNITIES FOR IDAHO - FIRST PRODUCTION REQUEST - 2
IPC-E-23-11
based cost assignment in addition to the Company’s proposed process of distinguishing costs by
demand and energy and allocation to customer classes on a 12CP basis. For those reasons, CEO
makes the following data requests.
REQUEST NO 1.
For each hour of 2022 please provide the actual quantity of Megawatt-hours (if any) each
resource supplied to meet that hour’s load. Please provide such hourly detail broken out by the
following resource groupings:
1. Company-owned hydro generation
2. Jim Bridger units 1 & 2
3. Jim Bridger units 3 & 4
4. Valmy
5. Langley
6. Bennett
7. Danskin
8. Market purchases
9. Market sales
10. Wind (from either PPA or PURPA sources)
11. Solar (from either PPA or PURPA sources)
12. Other PURPA
13. Demand response programs
REQUEST NO 2.
For each hour of the 2023 test year please provide the forecast quantity of
Megawatt-hours (if any) each resource supplied to meet that hour’s load. Please provide such
hourly detail broken out by the following resource groupings:
1. Company-owned hydro generation
2. Jim Bridger units 1 & 2
3. Jim Bridger units 3 & 4
4. Valmy
5. Langley
6. Bennett
CLEAN ENERGY OPPORTUNITIES FOR IDAHO - FIRST PRODUCTION REQUEST - 3
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7. Danskin
8. Market purchases
9. Market sales
10. Wind (from either or both PPA & PURPA sources)
11. Solar (from either or both PPA & PURPA sources)
12. Other PPA and/or PURPA
13. Demand response programs
14. Storage charging
15. Storage discharging
REQUEST NO 3
For each hour of the 2023 test year please provide the forecast cost for the quantity of
Megawatt-hours (if any) each resource supplied to meet that hour’s load. Please provide such
hourly detail broken out by the following resource groupings:
1. Company-owned hydro generation
2. Jim Bridger units 1 & 2
3. Jim Bridger units 3 & 4
4. Valmy
5. Langley
6. Bennett
7. Danskin
8. Market purchases
9. Market sales
10. Wind (from either or both PPA & PURPA sources)
11. Solar (from either or both PPA & PURPA sources)
12. Other PPA and/or PURPA
13. Demand response programs
14. Storage charging
15. Storage discharging
REQUEST NO 4 .
For each hour of 2022 please provide the actual quantity of Megawatt-hours, (adjusted as
needed to reflect losses and/or hours where demand response programs were employed),
CLEAN ENERGY OPPORTUNITIES FOR IDAHO - FIRST PRODUCTION REQUEST - 4
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required to serve each customer grouping. Please provide such hourly detail broken out by the
following major customer groupings:
1. Residential
2. Commercial
3. Industrial
4. Irrigation
5. Special contract customers
REQUEST NO 5 .
For each hour of 2023 test year please provide the forecast quantity of Megawatt-hours,
(adjusted as needed to reflect losses and/or hours where demand response programs are forecast
being employed), required to serve each customer grouping. Please provide such hourly detail
broken out by the following major customer groupings:
1. Residential
2. Commercial
3. Industrial
4. Irrigation
5. Special contract customers
REQUEST NO 6 .
From the 2022 actual load data, please provide the following information for each of the
12 monthly coincident peaks:
1. On what day of the month and hour ending did each of the 12 monthly coincident peaks
occur?
2. On each of those twelve coincident peak hours, please show the quantity of
Megawatt-hours, (adjusted as needed to reflect losses and/or hours where demand
response programs are forecast being employed), required to serve each of the following
major customer groupings:
a. Residential
b. Commercial
c. Industrial
CLEAN ENERGY OPPORTUNITIES FOR IDAHO - FIRST PRODUCTION REQUEST - 5
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d. Irrigation
e. Special contract customers
DATED this 7th day of July, 2023.
Respectfully submitted,
______________________________
Kelsey Jae
Attorney for CEO
CLEAN ENERGY OPPORTUNITIES FOR IDAHO - FIRST PRODUCTION REQUEST - 6
IPC-E-23-11
CERTIFICATE OF SERVICE
I hereby certify that on this 7th day of July, 2023. I delivered true and correct copies of
the foregoing FIRST PRODUCTION REQUEST to the following persons via the method of
service noted:
Electronic Mail Delivery
Idaho Public Utilities Commission
Jan Noriyuki
Commission Secretary
[e-mail]
Idaho PUC Staff
Chris Burdin
Deputy Attorney General
Idaho Public Utilities Commission
[e-mail]
Idaho Power Company
Megan Goicoechea Allen
Lisa D. Nordstrom
Donovan E. Walker
[e-mail]
[e-mail]
[e-mail]
[e-mail]
City of Boise
Ed Jewell
Darrell Early
Deputy City Attorney
[e-mail]
[e-mail]
[e-mail]
Wil Gehl, Energy Program Manager
[e-mail]
Industrial Customers of Idaho Power
Peter J. Richardson
Richardson Adams
[e-mail]
CLEAN ENERGY OPPORTUNITIES FOR IDAHO - FIRST PRODUCTION REQUEST - 7
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Idaho Conservation League
Marie Callaway Kellner
Brad Heusinkveld
[e-mail]
[e-mail]
IdaHydro
Tom Arkoosh
[e-mail]
[e-mail]
Idaho Irrigation Pumpers Association, Inc.
Eric L. Olsen
Lance Kaufman
[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]
[e-mail]
_____________________________
Kelsey Jae
Attorney for CEO
CLEAN ENERGY OPPORTUNITIES FOR IDAHO - FIRST PRODUCTION REQUEST - 8
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