20230905IPC to Staff 41-44.pdf

MEGAN GOICOECHEA ALLEN
Corporate Counsel
[e-mail]

September 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 Fifth
Production Request of the Commission Staff in the above-entitled 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
2023 SEPTEMBER 5, 2023 4:43PM
IDAHO PUBLIC
UTILITIES COMMISSION

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

COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), and in
response to the Fifth Production Request of the Commission Staff (“Commission” or
“Staff”) dated August 15, 2023, herewith submits the following information:

IDAHO POWER COMPANY’S RESPONSE TO THE FIFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 2
STAFF REQUEST FOR PRODUCTION NO. 41: The Company proposes valuing
the avoided cost of energy by using a twelve-month weighted average of the Energy
Imbalance Market ("EIM") Load Aggregation Point ("ELAP"). Ellsworth direct at 10.
Please provide the following:
a. Please explain how the Company determines the hourly ELAP value;
b. Please list the nodes the Company uses for its calculation, and the data source
for each node;
c. Please explain the Company's method of combining sub-hourly pricing data from
multiple nodes into a single hourly value; and
d. Please provide representative sample data of this consolidation.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 41: Please see
the below responses regarding ELAP prices:
a. California Independent System Operator (“CAISO”), as the market operator,
derives the ELAP price as explained in Section 3.1.4, 3.1.5, and 3.2 of the CAISO
Business Practice Manual for Market Operations. Each EIM entity has a separate
ELAP price calculated by the market operator. The ELAP price is calculated after
the EIM market clears and is derived from the volumetric weighted average of
the locational marginal prices at the individual load locations (CNodes).
The CAISO Business Practice Manual for Market Operations is available here:
https://bpmcm.caiso.com/BPM%20Document%20Library/Market%20Operation
s/BPM_for_Market%20Operations_V91_Clean.doc
b. CAISO includes load nodes inside the Idaho Power balancing area to calculate
the Idaho Power ELAP price. The Excel file labeled “Attachment – Response to

IDAHO POWER COMPANY’S RESPONSE TO THE FIFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 3
Staff’s Request No. 41” is a list of the load nodes inside the Idaho Power
balancing area in column F and their corresponding load distribution factors in
column G. This data is published on the public CAISO Open Access Same-time
Information System (“OASIS”).
c. Please see the CAISO EIM Business Practice Manual for its method of
combining sub-hourly pricing data from multiple nodes into a single hourly value.
Pages 148 and 149 define the non-participating load settlement and explain the
hourly real-time ELAP price calculation. The 15-minute Locational Marginal Price
(“LMP”) is the difference between the 15-minute demand forecast and the
demand forecast used to calculate the base load to settle the imbalance in the
EIM. The 5-minute LMP is the difference between the 5-minute and 15-minute
demand forecast. The EIM Business Practice Manual is available here:
https://bpmcm.caiso.com/BPM%20Document%20Library/Energy%20Imbalance
%20Market/BPM_for_Energy%20Imbalance%20Market_V30_clean.docx
d. Please see the response to Part C.
The response to this Request is sponsored by Jennifer Gerard, Operations
Settlement Leader, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 4
STAFF REQUEST FOR PRODUCTION NO. 42: Please explain the Company’s
reason(s) for proposing that the Net Billing program become effective January 1, 2024.
Please describe challenges that the Company foresees if the effective date is June 1,
2024, when other annual rate adjustments occur.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 42: The
Company’s rationale for proposing an effective date of January 1, 2024, relied upon a
procedural schedule allowing for the case to be resolved within eight (8) months of filing
the Application.
The Company often implements new service offerings and rates that do not occur
concurrent with June 1, and has not identified a reason to support delaying
implementation to this date. Additionally, the Company proposed a modification to the
project eligibility cap concurrent with the effective date of the proposed successor on-site
generation service offering. Arbitrarily delaying the effective date could be detrimental to
those customers desiring to install larger systems as they would also be delayed in the
ability to interconnect until on or after the effective date.
As described in Supplemental Response to Staff’s Request for Production No. 8,
if the Commission orders a measurement interval other than real-time net billing, the
Company will need time to reconfigure its systems before an effective date would be
feasible.
The response to this Request is sponsored by Connie G. Aschenbrenner, Rate
Design Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 5
STAFF REQUEST FOR PRODUCTION NO. 43: PacifiCorp performs stochastic
analysis of its portfolio costs considering variations in load, hydro output, natural gas
prices, and other factors. It uses the resulting variation in costs to assign an incremental
avoided risk value for any incremental avoided energy. PacifiCorp applies this avoided
risk value to energy efficiency measures and proposes to apply it to customer-generated
exports.
a. Please explain why the Company does not use a similar approach to quantify an
avoided risk value for application to customer-generated exports; and
b. Is it possible for the Company to use this approach? If not, why not.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 43: Please see
the below responses regarding the calculation of an avoided risk value:
a. The Company has proposed that the Export Credit Rate (“ECR”) avoided energy
value be derived from historical actual Energy Imbalance Market (“EIM”) Load
Aggregation Point (“ELAP”) prices – not an energy price forecast. Performing a
stochastic analysis on an energy price forecast could add a risk-based element
if the stochastic shocks are appropriately developed to capture both high-price
and low-price variations, however, because Idaho Power’s proposal does not rely
on a forecast, it would not be appropriate to include.
b. It would not be appropriate to apply this approach with the Company’s proposed
ECR energy value because it is not derived from an energy price forecast. Any
market-based variability is already reflected in actual market prices, such as the
ELAP price used in the Company’s proposal.

IDAHO POWER COMPANY’S RESPONSE TO THE FIFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 6
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 THE FIFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 7
STAFF REQUEST FOR PRODUCTION NO. 44: Please explain how the Company
recovers the cost of one-to-one credits given to Net Metering customers.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 44: For residential
and small general service customer-generators taking service under Net Energy
Metering, the one-to-one kilowatt-hour (“kWh”) credits are partially recovered through the
Fixed Cost Adjustment (“FCA”) mechanism. For all customers, the Power Cost
Adjustment (“PCA”) indirectly recovers a portion of the kWh credit. Both mechanisms are
described in more detail below.
The current FCA, derived from customer statistics at the time of the Company’s
2011 general rate case, calculates use per customer (“UPC”) on a combined basis for
Schedule 1 and Schedule 6, and a combined basis for Schedule 7 and 8. The FCA
recovers the authorized fixed cost portion of the volumetric energy rate for reductions to
UPC for customers subject to the FCA (including reductions resulting from one-to-one
kWh credits). The Company is proposing to derive UPC for Schedule 6 and 8 separately
for FCA rates proposed to become effective January 1, 2024; however, any over or under
collection of fixed costs is effectuated through a volumetric credit or assessment
determined on the combined residential, or small general service class, thus reductions
in UPC for either Schedules 6 or 8 will continue to impact other classes subject to the
FCA. There is no similar fixed cost recovery mechanism for commercial, industrial, and
irrigation customers.
The PCA mechanism adjusts kWh rates annually to reflect variations in power
supply costs. The PCA rate is calculated with total kWh sales as the denominator, and as
a result, will be higher for all customers classes if kWh sales are lower. Under net

IDAHO POWER COMPANY’S RESPONSE TO THE FIFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 8
metering, the customers reported kWh consumption is understated with a monthly
measurement interval, resulting in lower reported sales and a higher PCA rate per kWh.
The response to this Request is sponsored by Paul Goralski, Regulatory
Consultant, and Jessi Brady, Regulatory Analyst, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 9

DATED at Boise, Idaho, this 5th day of September 2023.

MEGAN GOICOECHEA ALLEN
Attorney for Idaho Power Company

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

I HEREBY CERTIFY that on the 5th day of September, 2023, I served a true and
correct copy of Idaho Power Company’s Response to the Fifth 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 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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IDAHO POWER COMPANY’S RESPONSE TO THE FIFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 11
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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Jim Swier
Micron Technology, Inc.
8000 South Federal Way
Boise, Idaho 83707
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IDAHO POWER COMPANY’S RESPONSE TO THE FIFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 12
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

BEFORE THE

IDAHO PUBLIC UTILITIES COMMISSION

CASE NO. IPC-E-23-14

IDAHO POWER COMPANY

REQUEST NO. 41

ATTACHMENT NO. 1
SEE ATTACHED SPREADSHEET