20230908IPC to Staff 277-279.pdf

LISA D. NORDSTROM
Lead Counsel
[e-mail]

September 8, 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 Fifteenth Production Request of the Commission Staff 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 attachment
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:sg
Enclosures

RECEIVED
2023 SEPTEMBER 8, 2023 2:48PM
IDAHO PUBLIC
UTILITIES COMMISSION

IDAHO POWER COMPANY’S RESPONSE TO THE FIFTEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 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.
)
)
)
)
)
)
)
)

CASE NO. IPC-E-23-11

IDAHO POWER COMPANY’S
RESPONSE TO THE FIFTEENTH
PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO
POWER COMPANY

COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), and in
response to the Fifteenth Production Request of the Commission Staff (“Commission” or
“Staff”) dated August 28, 2023, herewith submits the following information:

IDAHO POWER COMPANY’S RESPONSE TO THE FIFTEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 2
REQUEST FOR PRODUCTION NO. 277: Regarding the Excel file labeled
"Attachment - Response to Staff Request No. 96" provided by the Company, please
respond to the following:
a. Please explain why the Company used the year 2025 for the analysis;
b. Please provide worksheet that updates all analysis and accompanying tabs for the
forecast year 2024; and
c. Please provide worksheet that updates all analysis and accompanying tabs by
including all existing and contracted BESS Projects for the forecast year 2024.
RESPONSE TO REQUEST FOR PRODUCTION NO. 277:
a. Idaho Power selected 2025 as the load and resource year for the analysis because
it is the furthest point when the Company has contracted upcoming resources as
determined through the Request for Proposal process (i.e., certainty in the
resource buildout). In addition, the 2025 load and resource year includes the
starting ramp period for expected industrial large-load customers.
b. Please see the Excel file labeled “Attachment 1 – Response to Staff Request No.
277” for an updated analysis of the hours of highest risk for the forecast year 2024.
This analysis excludes battery storage resources.
c. Please see the Excel file labeled “Attachment 2 – Response to Staff Request No.
277” for an updated analysis of the hours of highest risk for the forecast year 2024.
This analysis includes all existing and contracted resources. As described in Part
B of Idaho Power’s Response to Staff’s Production Request No. 252, the Company
does not recommend including all resources to define the Time-of-Use hours and
instead proposes to exclude both battery storage and demand response.

IDAHO POWER COMPANY’S RESPONSE TO THE FIFTEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 3
The response to this Request is sponsored by Jared Ellsworth, Transmission,
Distribution, and Resource Planning Director, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIFTEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 4
REQUEST FOR PRODUCTION NO. 278: For rate design, please update the
following workpapers assuming a summer season of June 15th to September 15th:
a. "Anderson_RateDesignWorkpapers_06.01.2023"
b. "Brady Workpaper 2 — Proposed Billing Determinants Workbook".
RESPONSE TO REQUEST FOR PRODUCTION 278: The Company has not
completed the requested analysis and, as more fully explained below, is unable to update
the requested files with a summer season of June 15 to September 15 in the time
requested by Staff. Further, to develop the materials Staff has requested, the Company
would first need to develop a recommendation for how alignment between the sales and
load forecast, revenue forecast, billing determinants, jurisdictional separation study, and
Class Cost-of-Service (“CCOS”) study could be developed and maintained.
For context, a mid-month season convention raises multiple considerations,
notably in how the CCOS model and required inputs would be adjusted to conform from
a calendar month basis. For example, inclusion of a mid-month convention would require
either (1) all months having a mid-month convention, or (2) two months having a 45-day
billing period and two months having a 15-day billing period to maintain data on a calendar
year basis in all other months. Under the first approach, billing data would not align with
the test year revenue and cost basis because this method would require pulling in data
from a prior/subsequent year, as well as excluding half a month of data at the beginning
or end of the year (e.g., the December 16 through January 15 period would span two
years). The second approach results in an uneven cost allocation basis.
Additionally, the load forecast methodology utilized by the Company includes 30
years of normal weather data by month. If using a mid-month convention, those normal

IDAHO POWER COMPANY’S RESPONSE TO THE FIFTEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 5
temperatures would have to be estimated for that non-calendar month period. Further,
the normalization process would require re-specified models to correctly reflect the
weather adjustment using mid-month convention. The Company would need ample time
to build those re-specified weather adjustment models to correctly reflect weather
responsiveness in that period in order to properly synchronize to class cost of service and
rate design. Outside the weather adjustment or normalization process, load forecasting
models also are constructed on a monthly basis, being billing month or calendar month,
not daily. New load forecasting models would be required to be respecified and re-
estimated given the different definition, similarly, to properly synchronize to class cost-of-
service and rate design.
The Company is not aware of other electric utilities that have pursued a mid-month
convention for purposes of a CCOS study.
The response to this Request is sponsored by Jordan Prassinos, Load Forecast
Manager and Principal Economist, and Paul Goralski, Regulatory Consultant, Idaho
Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIFTEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 6
REQUEST FOR PRODUCTION NO. 279: Please provide the following information
for each residential customer with multiple meters for each month over the last 5 years in
Excel with formulas intact:
a. Number of meters;
b. Energy consumption measured by each meter;
c. Exported energy by meter if applicable; and…
RESPONSE TO REQUEST FOR PRODUCTION NO. 279: Please see the Excel
file labeled “Attachment – Response to Staff No. 279.” Each active residential meter is
separately labeled and identified on the “MonthlyEnergy” tab by the service point number
(“servicepointid”). Each meter at the same location is identified by the premise number
(“premise_src_id”) and business partner agreement (“party_src_id”).
a. Please see the “Summary” tab for a count of premises with more than one
residential meter and the number of residential meters at each premise. Less than
one percent of residential meters are located at the same premise.
b. Please see the “Monthly Energy” tab for the energy by month for each meter from
January 1, 2018, to December 31, 2022. The “delivered” column shows the energy
consumption measured by the meter, and the “received” column shows the total
exported energy (note that for 2018 and 2019 data, the “received” column reflects
hourly net energy, versus exported energy measured under real-time. Prior to
2020, the Company’s meters were not configured to measure received and
delivered energy on a real-time basis). The energy data provided for non-interval
meters is from billing data, and for interval meters is from hourly interval data.
There are 31 non-interval meters in the dataset. There will be multiple entries for

IDAHO POWER COMPANY’S RESPONSE TO THE FIFTEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 7
any month where a customer changes rates.
c. Please see the response to Part B.
The response to this Request is sponsored by Jordan Prassinos, Load Forecast
Manager and Principal Economist, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIFTEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 8
DATED at Boise, Idaho, this 8th day of September 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 FIFTEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 9
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the 8th day of September 2023, I served a true and
correct copy of Idaho Power Company’s Response to the Fifteenth 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
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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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 FIFTEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 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 FIFTEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 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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Federal Executive Agencies
Peter Meier
U.S. Department of Energy
1000 Independence Ave., S.W.
Washington, DC 20585

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IDAHO POWER COMPANY’S RESPONSE TO THE FIFTEENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 12
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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Walmart Inc.
Norman M. Semanko
Parsons Behle & Latimer
800 West Main Street, Suite 1300
Boise, Idaho 83702
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Steve W. Chriss
Director, Energy Services
Walmart Inc.
2608 Southeast J Street
Bentonville, Arkansas 72716
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Walmart Inc.
Justina A. Caviglia
Parsons Behle & Latimer
50 West Liberty Street, Suite 750
Reno, NV 89502
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Stacy Gust, Regulatory Administrative
Assistant