20230523ICL 1 to IPC.pdf

IDAHO PUBLIC UTILITIES COMMISSION, Case No. IPC-E-23-14 Page 1
ICL – First Production Request

Marie Callaway Kellner (ISB No. 8470)
710 N 6th Street
Boise, ID 83701
[phone]
[e-mail]
Attorney for the Idaho Conservation League

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER IDAHO POWER
COMPANY’S APPLICATION FOR
AUTHORITY TO IMPLEMENT
CHANGES TO THE COMPENSATION
STRUCTURE APPLICABLE TO
CUSTOMER ON-SITE GENERATION
UNDER SCHEDULES 6, 8, AND 84 AND
TO ESTABLISH AN EXPORT CREDIT
RATE METHODOLOGY
)
)
)
)
)
)
)
)
)

CASE NO. IPC-E-23-14

FIRST PRODUCTION REQUEST

IDAHO CONSERVATION
LEAGUE

COMES NOW the Idaho Conservation League (“ICL”) and, with the following
production requests for applicant Idaho Power Company (“Idaho Power” or “Company”). Along
with the answer to each question, please provide any supporting documents, workpapers,
calculations, communications, or information sources the Company relies upon to support its
answer. As required by IDAPA 31.01.01.228.02, please indicate the witness who can answer
questions regarding the response and who will sponsor the response at any hearing. If any
responses include Excel spreadsheets or other electronic files, please provide them with all
formulas intact and activated. As allowed by IDAPA 31.01.01.228.01, if the volume of any
response indicates it would be more feasible to do so, ICL agrees to the Company depositing the
response in an electronic depository.
This production request is ongoing. Accordingly, we respectfully ask Avista to provide
additional documents and information that may supplement any initial responses. We ask the
RECEIVED
Tuesday, May 23, 2023 11:12:26 AM
IDAHO PUBLIC
UTILITIES COMMISSION

IDAHO PUBLIC UTILITIES COMMISSION, Case No. IPC-E-23-14 Page 2
ICL – First Production Request

Company to provide responses at earliest convenience if available before the 21-day response
period required by IDAPA 31.01.01.225.

IDAHO PUBLIC UTILITIES COMMISSION, Case No. IPC-E-23-14 Page 3
ICL – First Production Request

Request for Production No. 01
In its Application, the Company proposes that ECR values for the period June 1, 2024
through May 31, 2025 be based upon updated energy and capacity values. Recognizing that final
2023 hourly self-generator export volumes for the weighted averaging and finalized hourly
values for the Energy Imbalance Market Load Aggregation Point (“ELAP”) for the twelve-
month ending December 31, 2023 are not currently available, please provide estimates for the
off-peak energy value (comparable to the $.0491/kWh) and the on-peak energy value
(comparable to the $.0859/kWh) that would be used in the June 1, 2024 through May 31, 2025
period estimated using the following assumptions:
1. For the hourly weighting values used to reflect the distribution of self-generator
exports, use the same 2022 hourly export values used in calculating the $.0491/kWh off-
peak and $.0859/kWh on-peak energy values for use from January 1, 2024 through May
31, 2024.
2. For the division between on-peak and off-peak load hours, maintain the same
definition offered in the application for describing both periods (3-11 pm June 15 –
September 15 excluding Sundays and Holidays as on-peak with all other hours of the
year as off-peak).
3. For estimates of the hourly off-peak hourly energy values during the period January
1, 2023 through May 23, 2023, use the values recorded thus far this year for hourly EIM
locational marginal price nodes within the Idaho Power region, adjusted as necessary to
provide single hourly ELAP values.

IDAHO PUBLIC UTILITIES COMMISSION, Case No. IPC-E-23-14 Page 4
ICL – First Production Request

4. For estimates of all hourly energy values for the period May 24, 2023 (or similar
date) through December 31, 2023, use the forecast of forward market energy prices from
the most current Company Operating plan. If those forward market energy prices are
segmented by heavy load and light load hours during the June 15 through September 15
period, please adjust that heavy-light load segregation as necessary to separate out the on-
peak hourly values as defined in note #2 above.

IDAHO PUBLIC UTILITIES COMMISSION, Case No. IPC-E-23-14 Page 5
ICL – First Production Request

CERTIFICATE OF SERVICE

I hereby certify that on this 23rd day of May 2023, I delivered true and correct copies of
the foregoing FIRST PRODUCTION REQUEST to the following persons via the method of
service noted:

/s/ Marie Callaway Kellner

Marie Callaway Kellner (ISB No. 8470)
Attorney for the Idaho Conservation League
710 N. 6th St.
Boise, Idaho 83702
[e-mail]

Electronic Mail Only (See Order No. 35058)

Idaho Public Utilities Commission
Jan Noriyuki
Commission Secretary
[e-mail]
[e-mail]

Commission Staff
Chris Burdin
Deputy Attorney General
Idaho Public Utility Commission
[e-mail]

Idaho Power Company
Lisa Nordstrom
Megan Goicoechea Allen
Timothy Tatum
Connie Aschenbrenner
Grant Anderson
1221 W. Idaho St., 83702
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]

IDAHO PUBLIC UTILITIES COMMISSION, Case No. IPC-E-23-14 Page 6
ICL – First Production Request

Idaho Irrigation Pumpers Association, Inc.
Eric L. Olsen
Echo Hawk & Olsen, PLLC
P.O. Box 6119
505 Pershing Ave. Ste. 100
Pocatello, ID 83205
[e-mail]

Lance Kaufman
2623 NW Bluebell Place
Corvallis, OR 97330
[e-mail]