20230728IPC to CEO 1-6.pdf

LISA D. NORDSTROM
Lead Counsel
[e-mail]

July 28, 2023

VIA ELECTRONIC FILING

Jan Noriyuki, Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg 8,
Suite 201-A (83714)
PO Box 83720
Boise, Idaho 83720-0074

Re: Case No. IPC-E-23-11
Idaho Power Company’s General Rate Case

Dear Ms. Noriyuki:

Enclosed for electronic filing, please find Idaho Power Company’s Response to the
First Production Request of Clean Energy Opportunities for Idaho to Idaho Power
Company.

Due to the collectively voluminous confidential and non-confidential information
provided in response to data requests in this case, the Company is posting the
attachments to these requests to the secure FTP site to allow parties to view the
requested information remotely unless otherwise noted in the response. Because certain
attachments contain confidential information, the FTP site is divided between confidential
and non-confidential information.

The login information for the non-confidential portion of the FTP site has been
provided to all parties that have intervened to date. The login information for the
confidential portion of the FTP site has been provided the parties that have executed the
Protective Agreement in this matter.

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

Very truly yours,
Lisa D. Nordstrom
LDN:cd
Enclosures
RECEIVED
Friday, July 28, 2023 3:47:57 PM
IDAHO PUBLIC
UTILITIES COMMISSION

CERTIFICATE OF ATTORNEY

ASSERTION THAT INFORMATION CONTAINED IN AN IDAHO PUBLIC UTILITIES
COMMISSION FILING IS PROTECTED FROM PUBLIC INSPECTION
Case No. IPC-E-23-11
In the Matter of the Application of Idaho Power Company for Authority to Increase
Its Rates and Charges for Electric Service to Its Customers In the State of Idaho
and For Associated Regulatory Accounting Treatment

The undersigned attorney, in accordance with Commission Rules of Procedure 67,
believes that some of the attachments in Response to Requests Nos. 2 and 3 to Idaho
Power Company’s Response to the First Production Request of the Clean Energy
Opportunities for Idaho to Idaho Power Company dated July 28, 2023, contain information
that Idaho Power Company claims are trade secrets as described in Idaho Code § 74-
101, et seq., and/or § 48-801, et seq. As such, it is protected from public disclosure and
exempt from public inspection, examination, or copying.

DATED this 28th day of July, 2023.

LISA D. NORDSTROM
Counsel for Idaho Power Company

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF CLEAN
ENERGY OPPORTUNITIES FOR IDAHO TO IDAHO POWER COMPANY - 1
LISA D. NORDSTROM (ISB No. 5733)
DONOVAN E. WALKER (ISB No. 5921)
MEGAN GOICOECHEA ALLEN (ISB No. 7623)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[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
INCREASE ITS RATES AND CHARGES
FOR ELECTRIC SERVICE IN THE
STATE OF IDAHO AND FOR
ASSOCIATED REGULATORY
ACCOUNTING TREATMENT.
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CASE NO. IPC-E-23-11

IDAHO POWER COMPANY’S
RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
CLEAN ENERGY OPPORTUNITIES
FOR IDAHO TO IDAHO POWER
COMPANY

COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), and in
response to Clean Energy Opportunities for Idaho’s (“CEO”) First Production Request to
Idaho Power Company dated July 7, 2023, herewith submits the following information:

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF CLEAN
ENERGY OPPORTUNITIES FOR IDAHO TO IDAHO POWER COMPANY - 2
REQUEST FOR PRODUCTION 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

RESPONSE TO REQUEST FOR PRODUCTION NO. 1:
Please see the attachment to this request for hourly generation broken out by the
requested resource groupings. Jim Bridger generation has been provided in one grouping
as all four units operated as coal-fired units for 2022.
The response to this Request is sponsored by Nicole Blackwell, Lead Operations
Analyst, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF CLEAN
ENERGY OPPORTUNITIES FOR IDAHO TO IDAHO POWER COMPANY - 3
REQUEST FOR PRODUCTION 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
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

RESPONSE TO REQUEST FOR PRODUCTION NO. 2:
Please see the confidential attachment to this request for hourly generation broken
out by the requested resource groupings. Storage charging is reflected as a negative
value, and storage discharging is reflected as a positive value.
The response to this Request is sponsored by Jessi Brady, Regulatory Analyst,
Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF CLEAN
ENERGY OPPORTUNITIES FOR IDAHO TO IDAHO POWER COMPANY - 4
REQUEST FOR PRODUCTION 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

RESPONSE TO REQUEST FOR PRODUCTION NO. 3:
Please see the confidential attachment to this request for hourly costs (in
thousands) broken out by the requested resource groupings. Hydro, Oregon Solar, and
storage resources are modeled and accounted for in Base Net Power Supply Expenses
(“NPSE”) as zero-cost resources. As a result, they will show as $0.00 in each hour.
PURPA and demand response will also show as $0.00 in each hour because they
are modeled in AURORA as zero-cost, must-take resources. However, their costs are
added into the monthly Base NPSE total after the modeling process.
The response to this Request is sponsored by Jessi Brady, Regulatory Analyst,
Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF CLEAN
ENERGY OPPORTUNITIES FOR IDAHO TO IDAHO POWER COMPANY - 5
REQUEST FOR PRODUCTION 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), 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

RESPONSE TO REQUEST FOR PRODUCTION NO. 4:
Please see the attachment to this request for hourly Megawatt (“MW”) load data
for 2022 for all customers with interval meters. Rate schedules are grouped into classes
according to the “RateClassLookup” tab within the attachment.
Individual class data does not include losses, company use, cogeneration, non-
AMI or monthly read meters, nor unmetered customers. However, the system total will
include these items, with losses representing the majority of the difference between the
sum of the classes and system. In addition, when applicable, the classes and system total
have been adjusted to include demand response events.
In addition, the attachment contains two tabs: “Net” and “Delivered”. For customers
with onsite generation, the “Net” tab contains the net hourly load data and the “Delivered”
tab contains total energy delivered by hour. Customers without onsite generation will not
differ between the two tabs.
The response to this Request is sponsored by Jordan Prassinos, Manager Load
Forecast and Principal Economist, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF CLEAN
ENERGY OPPORTUNITIES FOR IDAHO TO IDAHO POWER COMPANY - 6
REQUEST FOR PRODUCTION 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

RESPONSE TO REQUEST FOR PRODUCTION NO. 5:
Please see the attachment to this request for the forecasted hourly Megawatt
(“MW”) load by the requested customer groupings for 2023. Individual class data does
not include losses, company use, or cogeneration. In addition, demand response events
are not forecasted hourly, and are therefore not included.
Hourly data by jurisdiction (Idaho and Oregon) is not available. However, for
reference, Oregon sales represented approximately 4.4 percent of total 2023 test year
sales.
The response to this Request is sponsored by Jordan Prassinos, Manager Load
Forecast and Principal Economist, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF CLEAN
ENERGY OPPORTUNITIES FOR IDAHO TO IDAHO POWER COMPANY - 7
REQUEST FOR PRODUCTION 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
d. Irrigation
e. Special contract customers

RESPONSE TO REQUEST FOR PRODUCTION NO. 6:
Please see the attachment to this request for the maximum monthly hourly load
(Megawatts) for the requested customer groupings, as well as the day and time when it
occurred. All times are hour ending mountain prevailing time.
The response to this Request is sponsored by Jordan Prassinos, Manager Load
Forecast and Principal Economist, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF CLEAN
ENERGY OPPORTUNITIES FOR IDAHO TO IDAHO POWER COMPANY - 8
DATED at Boise, Idaho, this 28th day of July 2023.

LISA D. NORDSTROM
Attorney for Idaho Power Company

DONOVAN E. WALKER
Attorney for Idaho Power Company

MEGAN GOICOECHEA ALLEN
Attorney for Idaho Power Company

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF CLEAN
ENERGY OPPORTUNITIES FOR IDAHO TO IDAHO POWER COMPANY - 9
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the 28th day of July 2023, I served a true and correct
copy of Idaho Power Company’s Response to the First Production Request of Clean
Energy Opportunities for Idaho to Idaho Power Company upon the following named
parties by the method indicated below, and addressed to the following:

Commission Staff
Dayn Hardie
Chris Burdin
Deputy Attorney General
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg No. 8
Suite 201-A (83714)
PO Box 83720
Boise, ID 83720-0074

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[e-mail]

Clean Energy Opportunities for Idaho
Kelsey Jae
Law for Conscious Leadership
920 N. Clover Dr.
Boise, ID 83703
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Courtney White
Mike Heckler
Clean Energy Opportunities for Idaho
3778 Plantation River Drive, Suite 102
Boise, ID 83703

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Industrial Customers of Idaho Power
Peter J. Richardson
Richardson Adams, PLLC
515 N. 27th Street
Boise, Idaho 83702

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IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF CLEAN
ENERGY OPPORTUNITIES FOR IDAHO TO IDAHO POWER COMPANY - 10
Dr. Don Reading
280 Silverwood Way
Eagle, Idaho 83616

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Idaho Irrigation Pumpers Association,
Inc.
Eric L. Olsen
ECHO HAWK & OLSEN, PLLC
505 Pershing Avenue, Suite 100
P.O. Box 6119
Pocatello, Idaho 83205

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Lance Kaufman, Ph.D.
2623 NW Bluebell Place
Corvallis, OR 97330
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Micron Technology, Inc.
Austin Rueschhoff
Thorvald A. Nelson
Austin W. Jensen
Holland & Hart, LLP
555 Seventeenth Street, Suite 3200
Denver, Colorado 80202

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Jim Swier
Micron Technology, Inc.
8000 South Federal Way
Boise, Idaho 83707
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IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF CLEAN
ENERGY OPPORTUNITIES FOR IDAHO TO IDAHO POWER COMPANY - 11
City of Boise
Ed Jewell
Darrell Early
Boise City Attorney’s Office
150 N. Capitol Blvd.
Boise, ID 83701
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Wil Gehl
Boise City Dept. of Public Works
150 N. Capitol Blvd.
P.O. Box 500
Boise, Idaho 83701-0500

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Idaho Conservation League
Marie Callaway Kellner
Idaho Conservation League
710 N. 6th Street
Boise, Idaho 83702

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Brad Heusinkveld
Idaho Conservation League
710 N. 6th Street
Boise, Idaho 83702
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IdaHydro
C. Tom Arkoosh
Arkoosh Law Offices
913 W. River Street, Suite 450
P.O. Box 2900
Boise, Idaho 83701

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IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF CLEAN
ENERGY OPPORTUNITIES FOR IDAHO TO IDAHO POWER COMPANY - 12
Federal Executive Agencies
Peter Meier
Paige Anderson
Tanner Crowther
U.S. Department of Energy
1000 Independence Ave., S.W.
Washington, DC 20585

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Dwight Etheridge
Exeter Associates
5565 Sterrett Place, Suite 310
Columbia, MD 21044
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NW Energy Coalition
F. Diego Rivas
1101 8th Ave
Helena, MT 59601
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Christy Davenport,
Legal Administrative Assistant