20230705IPC to Staff 1-5.pdf

MEGAN GOICOECHEA ALLEN
Corporate Counsel
[e-mail]

July 5, 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-23-14
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

Dear Ms. Noriyuki:

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

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 is being
provided to all parties that have intervened to date. The login information for the
confidential portion of the FTP site will be provided to the parties that execute the
Protective Agreement in this matter.

RECEIVED
2023 JULY 5, 2023 3:45PM
IDAHO PUBLIC
UTILITIES COMMISSION
Jan Noriyuki
Idaho Public Utilities Commission
July 5, 2023
Page 2

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

Sincerely,

Megan Goicoechea Allen

MGA:sg
Enclosures

CERTIFICATE OF ATTORNEY

ASSERTION THAT INFORMATION CONTAINED IN AN IDAHO PUBLIC UTILITIES
COMMISSION FILING IS PROTECTED FROM PUBLIC INSPECTION

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

The undersigned attorney, in accordance with Commission Rules of Procedure 67,
believes that the Attachments Nos. 4, 5, 6, 7, 8, 9, and 10 to DR 1 of Idaho Power
Company’s Response of Staff’s First Set of Production Requests, dated July 5, 2023,
contain information that Idaho Power Company claims is a trade secret or a public record
exempt from disclosure by federal law (Critical Energy/Electric Infrastructure Information
under Federal Energy Regulatory Commission Order Nos. 630 and/or 662) 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 July 5, 2023.

Megan Goicoechea Allen
Counsel for Idaho Power Company

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

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CASE NO. IPC-E-23-14

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

COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), and in
response to the First Production Request of the Commission Staff (“Commission” or
“Staff”) dated June 14, 2023, herewith submits the following information:

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 2
REQUEST FOR PRODUCTION NO. 1: Please provide all workpapers, in Excel
format with formulas intact and enabled.
RESPONSE TO REQUEST FOR PRODUCTION NO. 1: In addition to the
workpapers previously provided in Excel format for Exhibit Nos. 2 and 3 in this docket,
following workpapers supporting Exhibit Nos. 6 – 8 are provided as Excel files labeled:
 “Attachment 1 – Response to Staff Request No. 1 – Residential”
 “Attachment 2 – Response to Staff Request No. 1 – Small General”
 “Attachment 3 – Response to Staff Request No. 1 – Large General”
Attachment 1 – 3 to this response each contain six tabs. Below is a brief description
of each tab, going from right to left within the workbook:
(1) The “Data” tab includes all non-legacy customers with 12 months of
billing data in 2022.
(2) The “NEM” tab calculates the monthly billed energy under a monthly net
energy metering compensation structure.
(3) The “NB.RT” tab calculates the monthly billed energy under a real-time
net billing compensation structure.
(4) The “Summary” tab summarizes, by service point, the total annual energy
delivered, energy exported, and the amount billed for energy under net
energy metering and net billing. This tab also calculates the total bill,
including the monthly service charge.
(5) The “Charts” tab is the output leveraged for the respective exhibit (Exhibit
Nos. 6-8).

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 3
(6) The “Inputs” tab contains the prices, or rates, used for the service charge,
energy charge, and export credit rate.
For the workpapers to Exhibit No. 4, please see seven confidential Excel files
labeled:
 “Confidential Attachment 4 – Response to Staff Request No. 1 – Total
System Losses”: Includes final loss coefficient calculations and compiles
data calculated in Attachment 6-10 for a summary of total system losses.
 “Confidential Attachment 5 – Response to Staff Request No. 1 – VODER
Summary”: Includes final loss coefficient calculations and compiles data
calculated in Attachment 6-10 for a summary of total system losses avoided
by distributed energy resources. The primary difference between
Attachment 4 and 5 is the exclusion of “non-avoidable” losses. Non-
avoidable losses include secondary distribution losses and transformer core
losses.
 “Confidential Attachment 6 – Response to Staff Request No. 1 – Line
Losses”: The line losses are calculated separately for each voltage level
within this workpaper.
 “Confidential Attachment 7 – Response to Staff Request No. 1 –
Transformer Losses”: The transformer losses are calculated separately for
each voltage level within this workpaper.
 “Confidential Attachment 8 – Response to Staff Request No. 1 – 138kV
Calculations”: Due to the complexity of the 138 kilovolt (“kV”) transmission
system, the calculations used rely on calculating net inputs and outputs

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 4
rather than making equipment specific calculations. This workpaper
includes these calculations.
 “Confidential Attachment 9 – Response to Staff Request No. 1 – Distribution
Losses”: The distribution line losses are calculated in this workpaper.
Similar to Attachment 8, the distribution losses are calculated by comparing
overall inputs to outputs of the system.
 “Confidential Attachment 10 – Response to Staff Request No. 1 – Input
Output Data”: Includes relevant FERC Form 1 data and customer billing
data separated by system level.
The response to this Request is sponsored by Jared L. Ellsworth, Transmission,
Distribution & Resource Planning Director, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 5
REQUEST FOR PRODUCTION NO. 2: Please explain where line losses are
accounted for in the calculation of avoided generation capacity.
RESPONSE TO REQUEST FOR PRODUCTION NO. 2: Line losses are
accounted for in the capacity contribution portion of the avoided generation capacity value
equation by increasing the exported amount by the loss factor. Please see the Excel file
labeled “Attachment – Response to Staff Request No. 2” for the hourly customer-
generator exported energy values and the corresponding line loss factor calculation. This
calculation is also described on page 58 of the October 2022 Value of Distributed Energy
Resources (“VODER”) Study, which is provided as Attachment 1 to the Company’s
Application.
The response to this Request is sponsored by Jared L. Ellsworth, Transmission,
Distribution & Resource Planning Director, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 6
REQUEST FOR PRODUCTION NO. 3: Please explain why Sundays and holidays
are excluded from on-peak hours during the Jun-Sep window and provide data that
supports that position.
RESPONSE TO REQUEST FOR PRODUCTION NO. 3: In general, Sundays and
holidays do not comprise the highest Loss of Load Probability (“LOLP”) values. As
described on page 16 of Company witness Mr. Jared L. Ellsworth’s direct testimony, the
highest LOLP hours are from 3 to 11 p.m., June 15 through September 15, Monday
through Saturday, excluding holidays. Please see the PDF file labeled “Attachment –
Response to Staff Request No. 3,” which illustrates the LOLP for the “on-peak” period
with Sundays and holidays outlined in white – Sundays and holidays have a lower LOLP
than weekdays and non-holidays.
The response to this Request is sponsored by Jared L. Ellsworth, Transmission,
Distribution & Resource Planning Director, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 7
REQUEST FOR PRODUCTION NO. 4: Please explain and provide worksheets
showing how the Effective Load Carrying Capacity ("ELCC") Megawatt ("MW") values
were determined for customer generation exports in 2020-2022. See Exhibit 2,
"Gen_Capacity" tab.
RESPONSE TO REQUEST FOR PRODUCTION NO. 4: The ELCC of the
customer-generator exports, adjusted for losses, is determined by calculating the
generation required to achieve a reliability target of 0.1 event-days per year with and
without the resource being evaluated (in this case, the customer-generator exports). The
ELCC of customer-generator exports, in megawatts, equals the difference between the
generation required to achieve the reliability target without the customer-generator
exports and the generation required to achieve the reliability target with the customer-
generator exports. This method is also described on page 58 of the October 2022 VODER
Study, which is provided as Attachment 1 to the Company’s Application.
Idaho Power created a tool to maximize computational efficiency for modeling the
Company’s existing and potential resource stack and calculate ELCCs. Idaho Power
utilizes MathWorks® computing environment and programming language MATLAB® to
develop the reliability and capacity assessment tool (which comprises many scripts and
functions that allow for detailed modeling and representation of the Company’s system).
The 2020-2022 customer-generator exports ELCC MW values provided in Exhibit 2 are
direct outputs from the described tool and the scripts are included in the text file labeled
“Attachment – Response to Staff Request No. 4.”
The response to this Request is sponsored by Jared L. Ellsworth, Transmission,
Distribution & Resource Planning Director, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 8
REQUEST FOR PRODUCTION NO. 5: Utilities are shifting to seasonal ELCC
values for their variable energy resources. Please calculate and provide worksheets
showing "on-peak" and "off-peak" seasonal ELCC values for customer generation exports
for the years 2020-2022.
RESPONSE TO REQUEST FOR PRODUCTION NO. 5: ELCC is primarily driven
by the timing of the highest risk hours, or Loss of Load Probability (“LOLP”) hours. The
“on-peak” period is derived from the LOLP analysis, meaning it was designed to maximize
capacity avoidance during the company’s highest-risk hours. There is little to no capacity
avoidance during the “off-peak” period for the years 2020-2022. As a result, there is no
seasonal ELCC value to calculate.
An ELCC for the “off-peak” period cannot be calculated if there is no capacity value
to avoid. The amount of risk, as measured by the Loss of Load Expectation (“LOLE”), is
concentrated in the defined “on-peak” period by nearly 95 percent:
Year LOLE (On-Peak) LOLE (All hours) LOLE Ratio
2020 0.0974 0.1 97.6%
2021 0.0944 0.1 94.9%
2022 0.0919 0.1 92.2%
Average 0.0946 0.1 94.9%
The response to this Request is sponsored by Jared L. Ellsworth, Transmission,
Distribution & Resource Planning Director, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 9
DATED at Boise, Idaho, this 5th day of July 2023.

Megan Goicoechea Allen
Attorney for Idaho Power Company

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 10
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the 5th day of July, 2023, I served a true and correct
copy of Idaho Power Company’s Response to the First Production Request of the
Commission Staff upon the following named parties by the method indicated below, and
addressed to the following:

Commission Staff
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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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 Conservation League
Marie Callaway Kellner
Idaho Conservation League
710 North 6th Street
Boise, Idaho 83702

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Brad Heusinkveld
Idaho Conservation League
710 North 6th Street
Boise, Idaho 83702

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IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 11
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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Clean Energy Opportunities for Idaho
Kelsey Jae
Law for Conscious Leadership
920 N. Clover Dr.
Boise, Idaho 83703
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Michael Heckler
Courtney White
Clean Energy Opportunities for Idaho
3778 Plantation River Dr., Suite 102
Boise, ID 83703

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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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IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 12
Jim Swier
Micron Technology, Inc.
8000 South Federal Way
Boise, Idaho 83707
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City of Boise
Darrell G. Early
Deputy City Attorney
Boise City Attorney’s Office
150 N. Capitol Blvd.
PO Box 500
Boise, Idaho 83701-0500
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Wil Gehl
Energy Program Manager
Boise City Dept. of Public Works
150 N. Capitol Blvd.
Boise, Idaho 83701-0500

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Vote Solar
Abigail R. Germaine
Elam & Burke, PA
251 E. Front Street, Suite 300
PO Box 1539
Boise, ID 83701
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Kate Bowman
Regulatory Director
Vote Solar
299 S. Main Street, Suite 1300
PMB 93601
Salt Lake City, UT 84111
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Stacy Gust, Regulatory Administrative
Assistant