20230925IPC to Staff 51-53.pdf

MEGAN GOICOECHEA ALLEN
Corporate Counsel
[e-mail]
September 25, 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 Eighth
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 25, 2023 4:38PM
IDAHO PUBLIC
UTILITIES COMMISSION
IDAHO POWER COMPANY’S RESPONSE TO THE EIGHTH 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 EIGHTH
PRODUCTION REQUEST OF
THE COMMISSION STAFF TO
IDAHO POWER COMPANY
COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), and in
response to the Eighth Production Request of the Commission Staff (“Commission” or
“Staff”) dated September 12, 2023, herewith submits the following information:
IDAHO POWER COMPANY’S RESPONSE TO THE EIGHTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 2
STAFF REQUEST FOR PRODUCTION NO. 51: Please provide the formula for
calculating the average retail energy rate that may be applied to customers' excess
accumulated kilowatt-hours thru 2024. In your explanation, please explain if each
customer will have their own average retail energy rate and if the Fixed Cost Adjustment
and Power Cost Adjustment rates may be an input factor.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 51: The Company
proposes the average retail energy rate from the respective schedule will be calculated
for Residential, Small Commercial, Large Commercial, and Irrigation customer segments,
and will include the then current Fixed Cost Adjustment (“FCA”) and Power Cost
Adjustment (“PCA”) rate. The formula would be as follows for rates in effect on December
31, 2023:
Customer test year Energy Charges + FCA collection + PCA Collection
Test Year kWh forecast
Please see the Excel file labeled “Attachment 2 – Response to Staff Request No.
52” for an illustrative example of the calculation of the Average Energy Rate. Please note
that in this particular example the Average Energy Rate is a blended average of Idaho
and Oregon rates as the 4.7 million accumulated kWh credits is the combined total for
Idaho and Oregon.
The response to this Request is sponsored by Paul Goralski, Regulatory
Consultant, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE EIGHTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 3
STAFF REQUEST FOR PRODUCTION NO. 52: Please provide the workpaper
that calculated the value of non-legacy accumulated kWh credits using a blended average
energy rate to be approximately $496,000. Anderson Direct 24, Line 4.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 52: Please refer
to the Excel file labeled “Attachment 1 - Response to Staff Request No. 52” for the
workpaper that calculated the non-legacy accumulated kWh credits by customer class as
of December 31, 2022. Please refer to the Excel file labeled “Attachment 2 - Response
to Staff Request No. 52” for the workpaper that calculated the average energy rates as of
June 1, 2022.
The response to this Request is sponsored by Tami White, Budget and Revenue
Manager, Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO THE EIGHTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 4
STAFF REQUEST FOR PRODUCTION NO. 53: The Company has proposed to
perform system upgrades for customer generators who install battery storage with
generation that can exceed the safety limits of their interconnection as long as the
customer pays the upfront cost. However, the Company has also stated there are ongoing
costs associated with the upgrades (including maintenance, replacement, property taxes,
and other ancillary costs) that are paid for by all customers. Please provide an estimate
for the ongoing cost of these upgrades on a per kilowatt basis and a potential surcharge
for these ongoing costs also on a per kilowatt basis that could be added to the upfront
cost of the upgrade.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 53: The Company
has not performed an analysis for the ongoing cost of system upgrades on a per kilowatt
basis or a potential surcharge for these ongoing costs that could be added to the upfront
cost of the upgrade. As outlined in Schedule 68, customers whose interconnection of a
non-exporting system that is three megavolt-ampere (“MVA”) or larger pay a Facilities
Charge for ongoing maintenance costs associated with the investment in System
Protection, metering, and communication equipment installed to interconnect those
systems. While the Company has not evaluated the possibility of administering this type
of a charge for the types of upgrades outlined in the Request for Production No. 53, a
similar charge may be reasonably considered.
The response to this Request is sponsored by Grant T. Anderson, Regulatory
Consultant, Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO THE EIGHTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 5
DATED at Boise, Idaho, this 25th day of September 2023.
MEGAN GOICOECHEA ALLEN
Attorney for Idaho Power Company
IDAHO POWER COMPANY’S RESPONSE TO THE EIGHTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 6
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 25th day of September, 2023, I served a true
and correct copy of Idaho Power Company’s Response to the Eighth 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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[e-mail]
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 EIGHTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 7
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 EIGHTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 8
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. 52
ATTACHMENT NO. 1
SEE ATTACHED SPREADSHEET

BEFORE THE

IDAHO PUBLIC UTILITIES COMMISSION

CASE NO. IPC-E-23-14

IDAHO POWER COMPANY

REQUEST NO. 52

ATTACHMENT NO. 2
SEE ATTACHED SPREADSHEET