20230912VS 1-19 to IPC.pdf

VOTE SOLAR’S FIRST SET OF DISCOVERY REQUESTS TO IDAHO POWER COMPANY - 1
Abigail R. Germaine (ISB No. 9231) Elam & Burke, P.A.
251 E. Front St. Suite 300
P.O. Box 1539 Boise, Idaho 83701 [phone] [phone] (fax)
[e-mail]

Attorney for Vote Solar BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

FOR
-SITE 8,

CASE NO. IPC-E-23-14
VOTE SOLAR’S FIRST SET OF DISCOVERY REQUESTS TO IDAHO POWER COMPANY

COMES NOW, Vote Solar, by and through counsel, Elam & Burke, P.A., hereby submits
the attached interrogatories and requests for production of documents to Idaho Power Company
(“Idaho Power”) pursuant to Commission Rule 225. Vote Solar requests that Idaho Power please
respond to these requests no later than October 3, 2023. Please provide answers to each question,
including supporting workpapers that provide pertinent detail or information used in certain
calculations or conclusions. Please also identify the name, title, location, telephone number, and
email of the individual providing such record.
In addition to written copies, please provide all Excel spreadsheets and electronic files with
formulas intact. This discovery request is to be considered as continuing, and Idaho Power is
requested to provide, by way of supplementary responses, additional documents that it may later
obtain that will augment the documents or information produced.

RECEIVED
Tuesday, September 12, 2023 12:55:52 PM
IDAHO PUBLIC
UTILITIES COMMISSION
VOTE SOLAR’S FIRST SET OF DISCOVERY REQUESTS TO IDAHO POWER COMPANY - 2
INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS
REQUEST NO. 1: Please provide Idaho Power’s hourly total system load for every hour
in the years 2018 through 2022. Alternatively, please provide a list of the top 10% of hours during
which Idaho Power experienced the highest electricity demand, ranked by system load, for each
year from 2018 through 2022.
REQUEST NO. 2: Regarding Idaho Power’s customers with rooftop solar:
(a) Please provide the number of customers with rooftop solar who also have battery
storage, broken out by rate schedule;
(b) Please provide the total capacity of battery storage installed by customers with
rooftop solar, broken out by rate schedule.
REQUEST NO. 3: Does Idaho Power currently have any programs or rate schedules
intended to incentivize customers with behind-the-meter battery storage to dispatch their storage
to provide energy to the grid? If so, please describe the relevant programs or rate schedules.
REQUEST NO. 4: Please provide Idaho Power’s total annual retail sales to all customers
for the years 2018, 2019, 2020, 2021, and 2022.
REQUEST NO. 5: Has Idaho Power completed a load forecast more recent than Appendix
A: Sales & Load Forecast, presented as part of Idaho Power’s 2021 Integrated Resource Plan? If
yes, please provide Idaho Power’s most recent forecast of future load.
REQUEST NO. 6: Is Idaho Power aware of any instances where a rooftop solar
installation that met all interconnection requirements resulted in power quality or safety issues to
the grid, or required Idaho Power to complete repair or replacement of any utility grid
infrastructure? If so, please provide the date(s) of each known instance and describe the nature of
the issue(s).
VOTE SOLAR’S FIRST SET OF DISCOVERY REQUESTS TO IDAHO POWER COMPANY - 3
REQUEST NO. 7: Regarding the direct testimony of Connie Aschenbrenner, filed May
1, 2023, page 9 lines 23 through 25, which states “Company representatives continue to hear from
customers who have made investments or who are considering investments that they were unaware
that the structure could change:”
(a) In what manner has Idaho Power learned that customers are unaware that the
structure could change? For example, are customers contacting the Company?
(b) Has Idaho Power conducted any surveys of, or outreach to, non-legacy solar
customers to determine the number or percentage of customers who are aware that their rate may
change?
(c) Has Idaho Power provided any information to non-legacy solar customers
indicating how their rate may change in the future? If so, please describe.
REQUEST NO. 8: Regarding the direct testimony of Connie Aschenbrenner, filed May 1,
2023, page 36:
(a) Please provide copies of all communication materials referenced in Table 3.
(b) Does Table 3 include all communication materials the Company has sent to non-
legacy customers addressing the potential for changes to their rates?
(c) If Table 3 does not include all communication materials sent to non-legacy
customers addressing the potential for changes to their rates, please provide copies of any materials
that are not included in Table 3.
(d) Has Idaho Power provided any materials to non-legacy customers that include
information about factors the customer should consider in light of the guidance that rates may
change in the future? For example, has Idaho Power provided recommendations about how
VOTE SOLAR’S FIRST SET OF DISCOVERY REQUESTS TO IDAHO POWER COMPANY - 4
customers may want to size their system, or orient their system to maximize value under a new
rate?
REQUEST NO. 9: Regarding the direct testimony of Grant Anderson, filed May 1, 2023,
page 26, lines 12 through 15 which states: “For residential and small general service customers,
Idaho Power plans to provide its customers access to a third-party calculator tool on Idaho Power’s
website.”
(a) Does Idaho Power intend to develop the calculator itself, or through a third-party?
(b) If Idaho Power intends to engage a third-party, has that entity been selected?
(c) When does Idaho Power expect that the calculator will be operational and available
to customers?
REQUEST NO. 10: Regarding Idaho Power’s “Time of Day” Plan:
(a) What types of customers are eligible to participate in the Time of Day plan?
(b) How many customers are currently participating in the Time of Day plan? Please
provide the number of customers participating from each rate schedule, if applicable.
(c) How many customers have enrolled in the Time of Day plan and subsequently
requested to return to the Residential Standard Plan?
(d) What outreach or education has Idaho Power provided to customers to help them
understand how the Time of Day Plan works?
REQUEST NO. 11: Regarding Idaho Power’s 2023 Integrated Resource Plan:
(a) On what date does the Company anticipate filing the 2023 Integrated Resource
Plan?
(b) On what date does the Company anticipate regulators will rule on the 2023
Integrated Resource Plan?
VOTE SOLAR’S FIRST SET OF DISCOVERY REQUESTS TO IDAHO POWER COMPANY - 5
REQUEST NO. 12: Do Idaho Power customers currently have access to information
about their own hourly energy usage? If so, please describe what data is available to customers
and how customers are able to access their hourly energy usage data.
REQUEST NO. 13: Please describe the cost methodology and components used to
calculate avoided costs in Idaho Power’s recently filed general rate case, IPC-E-23-11, as
compared to the avoided cost methodology and components used in the export credit rate (“ECR”)
and this Application.
REQUEST NO. 14: Does the cost of service study in Idaho Power’s recently filed
general rate case, IPC-E-23-11, include any assumptions related to the value of the ECR? If so,
please describe.
REQUEST NO. 15: Is Idaho Power aware of any other utilities that have an ECR value
that is updated annually? If so, which utilities?
REQUEST NO. 16: Is Idaho Power aware of any other utilities that have an ECR that
updates annually, and where the updated ECR applies to both new and existing customers? If so,
which utilities?
REQUEST NO. 17: Please provide all load research data available for Idaho Power’s
non-legacy solar customers including hourly usage data for 2021 and 2022. For each customer,
please identify the rate schedule on which the customer takes service, use a unique identifier and
avoid providing any personally identifying information. If available, please provide information
on the installed solar capacity associated with each non-legacy solar customer.
REQUEST NO. 18: Please provide hourly exports, in kilowatt-hours, for each non-legacy
solar customer for all hours in 2021 and 2022. For each customer, please identify the rate schedule
on which the customer takes service, use a unique identifier and avoid providing any personally
VOTE SOLAR’S FIRST SET OF DISCOVERY REQUESTS TO IDAHO POWER COMPANY - 6
identifying information. If available, please provide information on the installed solar capacity
associated with each non-legacy solar customer.
REQUEST NO. 19: Please identify all fuel hedging activities and expenditures (if any) by
Idaho Power during each of the last ten years. For each hedging product purchased in the last ten
years, please provide the trade date, start date, end date, price, volume, and any other information
available regarding the hedging product purchased.
DATED this 12th day of September, 2023.
ELAM & BURKE, P.A.
_______________________________ Abigail R. Germaine
Attorney for Vote Solar

VOTE SOLAR’S FIRST SET OF DISCOVERY REQUESTS TO IDAHO POWER COMPANY - 7
CERTIFICATE OF SERVICE
I HEREBY certify that I have on this 12th day of September, 2023, I served the foregoing
Vote Solar’s First Set of Discovery Requests to Idaho Power Company by electronic mail to the following:
Commission Staff
Idaho Public Utilities Commission 11331 W. Chinden Blvd., Ste. 201-A Boise, ID 83714 [e-mail] [e-mail] Chris Burdin Deputy Attorney General
Idaho Public Utilities Commission 1131 W. Chinden Blvd., Ste. 201-A Boise, ID 83714
[e-mail]
Brad Heusinkveld Idaho Conservation League, Energy Associate Attorneys for Idaho Conservation
League 710 N. 6th St. Boise, ID 83702 [e-mail] [e-mail]

Megan Goicoechea Idaho Power Company PO Box 70 Boise, ID 83707 [e-mail] [e-mail] [e-mail]
Idaho Irrigation Pumpers Association Echo Hawk & Olsen, PLLC 505 Pershing Ave., Ste. 100 P.O. Box 6119 Pocatello, Idaho 83205 [e-mail]
Micron Technology, Inc. 8000 South Federal Way Boise, ID 83707 [e-mail]
2623 NW Bluebell Place Corvallis, OR 97330 [e-mail]
Law for Conscious Leadership Clean Energy Opportunities for Idaho
920 N. Clover Dr. Boise, ID 83703 [e-mail]

Attorneys for IdaHydro Arkoosh Law Offices
913 W. River Street, Suite 450 Boise, ID 83701 [e-mail]
[e-mail]
VOTE SOLAR’S FIRST SET OF DISCOVERY REQUESTS TO IDAHO POWER COMPANY - 8
Timothy E. Tatum Connie Aschenbrenner
Grant Anderson Idaho Power Company PO Box 70 Boise, ID 83707 [e-mail] [e-mail] [e-mail]
Mike Heckler
Clean Energy Opportunities for Idaho 3778 Plantation River Dr. Suite 102 Boise, ID 83703 [e-mail] mike@cleanenergyopportuni
Thorvald A. Nelson
Austin W. Jensen
Micron Technology, Inc. Holland & Hart, LLP
555 17th St. Suite 3200 Denver, CO 80202 [e-mail]
[e-mail] [e-mail] [e-mail] [e-mail]
Boise City Attorney’s Office
150 N. Capitol Blvd. Boise, ID 83701 Boise City Attorney
[e-mail] [e-mail]
Boise City Dept. of Public Works 150 N Capitol Blvd. Boise, ID 83701 [e-mail]

_____________________________________ Abigail R. Germaine