20230828IPC to IIPA 1-8.pdf

MEGAN GOICOECHEA ALLEN
Corporate Counsel
[e-mail]
August 28, 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 Idaho
Irrigation Pumpers Association, Inc.’s First Set of Data Requests 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.
If you have any questions about the attached documents, please do not hesitate
to contact me.
Sincerely,
Megan Goicoechea Allen
MGA:sg
Enclosures
RECEIVED
Monday, August 28, 2023 4:28:09 PM
IDAHO PUBLIC
UTILITIES COMMISSION
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 Attachment No. 2 to Request No. 1-1 of Idaho Power Company’s
Response to Idaho Irrigation Pumpers Association, Inc.’s First Set of Discovery Requests
to Idaho Power, dated August 28, 2023, contains information that Idaho Power Company
and a third party claim is a trade secret or a business records of a private enterprise
required by law to be submitted to or inspected by a public agency 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 August 28, 2023.
Megan Goicoechea Allen
Counsel for Idaho Power Company
IDAHO POWER COMPANY’S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S
FIRST SET OF DATA REQUESTS - 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 IDAHO
IRRIGATION PUMPERS
ASSOCIATION, INC.’S FIRST SET
OF DATA REQUESTS TO IDAHO
POWER COMPANY
COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), and in
response to Idaho Irrigation Pumpers Association, Inc.’s (“IIPA”) First Set of Data
Requests to Idaho Power Company dated August 7, 2023, herewith submits the following
information:
IDAHO POWER COMPANY’S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S
FIRST SET OF DATA REQUESTS - 2
REQUEST FOR PRODUCTION NO. 1-1: Please refer to the VODAR study page
8, figure 2.5.
a. Please provide the annual hourly generation expected for the Jackpot PPA.
b. Please provide all calculations underlying the $0.02175 rate for the Jackpot
PPA.
c. Please provide all calculations underlying the $0.03456 rate for Sch 86.
RESPONSE TO REQUEST FOR PRODUCTION NO. 1-1: Please see the
following responses to the request:
a. Please see the Excel file labeled “Attachment 1 – Response to IIPA Request
No. 1-1” for the annual hourly generation expected for the Jackpot PPA. The
calculations underlying the hourly generation are scaled estimates for the
Jackpot project based on the hourly shape of utility-scale solar on Idaho
Power’s system for 2020, 2021, and 2022.
b. The rate for the Jackpot PPA was proposed by the project owner in negotiations
and was not the result of calculations by Idaho Power.
c. Please see the Excel file labeled “Confidential Attachment 2 – Response to
IIPA Request No. 1-1.” The calculations underlying the 2021 annual average
market-based rate for Schedule 86, Cogeneration and Small Power Production
Non-Firm Energy (“Schedule 86”) can be found under the definition of “Avoided
Energy Cost” and the “Purchase Price” section of Schedule 86.
The response to this Request is sponsored by Jared Hansen, Resource Planning
Leader, and Camille Christen, Resource Acquisition, Planning and Coordination
Manager, Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S
FIRST SET OF DATA REQUESTS - 3
REQUEST FOR PRODUCTION NO. 1-2: Please refer to 20230501Exhibit 2.xlsx,
tab “Energy Hourly”.
a. Please provide this data for 2021 and 2023 to date.
b. Please provide the hourly load by hour and customer class for 2022 for all
customers contributing to exports on this tab.
c. Does the EIM price include any environmental adders or components?
RESPONSE TO REQUEST FOR PRODUCTION NO. 1-2: Please see the
following responses regarding Exhibit 2 to the Direct Testimony of Jared Ellsworth and
the “Energy Hourly” tab:
a. Please see the Excel files labeled “Attachment 1 – Response to IIPA Request
No. 1-2” for 2021 and “Attachment 2 – Response to IIPA Request No. 1-2” for
June 30, 2023, year-to-date.
b. Please see the Excel file labeled “Attachment 3 – Response to IIPA Request
No. 1-2” for 2022 hourly delivered energy by customer class for all customers
included in the dataset on the “Energy Hourly” tab of Exhibit No. 2.
c. Yes. The weighted average Energy Imbalance Market Load Aggregation Point
(“ELAP”) prices provided in Exhibit 2 include a Greenhouse Gas (“GHG”)
component. The GHG component is the marginal cost of providing the next
megawatt (“MW”) of energy to serve load in the California Independent System
Operator (“CAISO”) load from an Energy Imbalance Market (“EIM”) Balancing
Authority Area outside of California. EIM participating resources submit energy
bids into the EIM market and can choose to offer a bid with a flat GHG price
adder to allow that energy to be sent to serve load in California. The GHG
IDAHO POWER COMPANY’S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S
FIRST SET OF DATA REQUESTS - 4
component of the price is based on the marginal unit that set the energy price
and the GHG bid adder offered on the marginal unit.
The response is sponsored by Jared L. Ellsworth, Transmission, Distribution and
Resource Planning Director, Idaho Power Company, and Jennifer Gerard, Operations
Settlement Leader.
IDAHO POWER COMPANY’S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S
FIRST SET OF DATA REQUESTS - 5
REQUEST FOR PRODUCTION NO. 1-3: Please reconcile the value in
20230501Exhibit 2.xlsx Summary tab, cell G24 with the corresponding value in Exhibit
No. 1 Case No. IPC-E-23-14 J. Ellsworth, IPC Page 1.
RESPONSE TO REQUEST FOR PRODUCTION NO. 1-3: Jared L. Ellsworth’s
direct testimony (“Ellsworth Testimony”) includes Exhibit Nos. 1 - 5. Page 3 of Ellsworth
Testimony states that Exhibit No. 2 is an Excel copy of Exhibit No. 1. Therefore, the 20.42
cents per kilowatt-hour (“kWh”) on the “Summary” tab of Exhibit No. 2 in cell G24 is the
same as the 20.42 cents per kWh listed on Exhibit 1, Page 1.
The response to this Request is sponsored by Jared L. Ellsworth, Transmission,
Distribution and Resource Planning Director, Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S
FIRST SET OF DATA REQUESTS - 6
REQUEST FOR PRODUCTION NO. 1-4: Please provide IPC’s most recent long
term hourly electricity price forecast or forward curve.
RESPONSE TO REQUEST FOR PRODUCTION NO. 1-4: Idaho Power does not
develop electricity price forecasts, but market prices are an output of the Integrated
Resource Plan (“IRP”) modeling process. Please see the Excel file labeled “Attachment
– Response to IIPA Request No. 1-4” for the 20-year zonal market prices from the 2021
IRP model, which are the most recent and granular long-term forecast available.
The response to this Request is sponsored by Jared Hansen, Resource Planning
Leader, Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S
FIRST SET OF DATA REQUESTS - 7
REQUEST FOR PRODUCTION NO. 1-5: Please provide IPC’s most recent
20year electricity price forecast at its most granular level.
RESPONSE TO REQUEST FOR PRODUCTION NO. 1-5: Please see the
response to Request for Production No. 1-4.
The response to this Request is sponsored by Jared Hansen, Resource Planning
Leader, Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S
FIRST SET OF DATA REQUESTS - 8
REQUEST FOR PRODUCTION NO. 1-6: Please provide all models used to
calculate the ELCC in 20230501Exhibit 2.xlsx.1
RESPONSE TO REQUEST FOR PRODUCTION NO. 1-6: Please see the coding
files used to calculate the referenced Effective Load Carrying Capability (“ELCC”) values
in the folder labeled “Attachment 1-11 – Response to IIPA Request No. 1-6.” Idaho Power
calculates resource ELCC values using an internally developed Reliability and Capacity
Assessment Tool (“RCAT”) which is coded in MathWorks® computing environment and
programming language MATLAB®. The RCAT is comprised of many MATLAB® scripts
and functions which have been converted to text files for convenience.
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 IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S
FIRST SET OF DATA REQUESTS - 9
REQUEST FOR PRODUCTION NO. 1-7: Please provide the current draft of IPC’s
2023 IRP.
RESPONSE TO REQUEST FOR PRODUCTION NO. 1-7: The Company does not
currently have a draft 2023 IRP available. Please see IPUC Case No. IPC-E-23-17 for
anticipated timing for public review and filing of the 2023 IRP.
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 IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S
FIRST SET OF DATA REQUESTS - 10
REQUEST FOR PRODUCTION NO. 1-8: Does IPC expect the ELCC of net
metering to increase or decrease over time?
RESPONSE TO REQUEST FOR PRODUCTION NO. 1-8: The Effective Load
Carrying Capability (“ELCC”) of on-site customer generation is dependent on several
factors including load and load shape, penetration of variable energy resources, and the
Company’s resource mix, particularly storage. Because the future ELCC for on-site
customer generation will depend on these variables, Idaho Power does not have an
expectation as to whether the ELCC will increase or decrease over time.
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 IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S
FIRST SET OF DATA REQUESTS - 11
DATED at Boise, Idaho, this 28th day of August 2023.
MEGAN GOICOECHEA ALLEN
Attorney for Idaho Power Company
IDAHO POWER COMPANY’S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S
FIRST SET OF DATA REQUESTS - 12
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 28th day of August, 2023, I served a true and
correct copy of Idaho Power Company’s Response to Idaho Irrigation Pumpers
Association, Inc.’s First Set of Data Requests 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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[e-mail]
Idaho Conservation League
Marie 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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X Email [e-mail]
IDAHO POWER COMPANY’S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S
FIRST SET OF DATA REQUESTS - 13
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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[e-mail]
IDAHO POWER COMPANY’S RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S
FIRST SET OF DATA REQUESTS - 14
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