20230616Staff 1-10 to IPC.pdf

MICHAEL DUVAL
DEPUTY ATTORNEYS GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NOS.11714
Street Address for Express Mail:
11331 W CHINDEN BLVD,BLDG 8,SUITE 201-A
BOISE, ID 83714
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER )COMPANY'S APPLICATION FOR )CASE NO.IPC-E-23-18APPROVALOFASPECIALCONTRACT)UNDER TARIFF SCHEDULE 34 TO )FIRST PRODUCTIONPROVIDEELECTRICSERVICETOLAMB)REQUESTOF THEWESTON,INC.)COMMISSION STAFF
)TO IDAHO POWER COMPANY
Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Michael Duval,Deputy AttorneyGeneral, requests that Idaho Power Company ("Company"or
"Idaho Power")provide the followingdocuments and information as soon as possible,but no
later than FRIDAY,JULY 7,2023.
This Production Request is to be considered as continuing,and the Company is requested
to provide,by way of supplementaryresponses,additional documents that it,or any person
acting on its behalf,may later obtain that will augment the documents or information produced.
Please provide answers to each question,supporting workpapers that provide detail or are
the source of informationused in calculations,and the name,job title,and telephonenumber of
the person preparing the documents.Please also identify the name,job title,location,and
telephonenumber of the record holder.
FIRST PRODUCTION REQUEST
TO IDAHO POWER 1 JUNE 16,2023
RECEIVED
2023 June 16, PM 1:36
IDAHO PUBLIC
UTILITIES COMMISSION
In addition to the written copies provided as response to the requests,please provide all
Excel spreadsheets and electronic files with formulas intact and enabled.
REQUESTNO.1:Please provide all workpapers used to derive the two-block pricing
structure discussed on pages 7-10 of the Application in electronic format with formula enabled.
REQUESTNO.2:In reference to the proposed Block 2 Demand and Block 2 Energy
Charges,please respond to the following:
a.Please provide all workpapers used to determine the Block 2 Demand rates in
electronic format with formula enabled.
b.Please provide all model runs and workpapers used to determine the Block 2
Energy Charge.For the model runs,please provide the assumptions used for each
model run.Please provide all files in electronic format with formula enabled.
c.Please explain if the Company considered any other methods to determine the
Block 2 Energy Charge for Schedule 34 besides the marginal cost method
discussed in the Application.If other methods were considered,please explain
the method(s)considered and why these method(s)were not selected.If no other
method(s)were considered,please explain why no other methods were
considered.
d.Please explain if the Company evaluatedthe proposed Block 2 Energy Charge
differentiated by season and by On,Mid,and Off-peak hour pricing similar to
Demand-Side Management Avoided Cost Averages.If the Company did evaluate
the time periods,please explain why the time periods were not used and provide
the Company's workpapers from the evaluation.If the Company did not evaluate
these time periods,please explain why these time periods were not evaluated.
e.Please provide a proposal for Block 2 Energy Charges differentiated by season
and by On,Mid,and Off-peak hours with electronic workpapers documenting the
method.
FIRST PRODUCTION REQUEST
TO IDAHO POWER 2 JUNE 16,2023
REQUESTNO.3:In reference to the option under Section 6.4 to reevaluatethe source
of the Block 2 Energy Charge discussed on page 11 of the Application,please respond to the
following:
a.Please explain the rationale for the "at least five years"requirement.
b.Please explain if other Idaho Power Special Contracts have had and/or do include
a similar option.
c.Please provide examples of when the Company would consider pricing Lamb
Weston at its embedded cost instead of the proposed marginal cost.
REQUESTNO.4:Please provide all annual and hourly load forecasts for the years
2023,2024,and 2025 the Company has for Lamb Weston that include the expected increase in
energy and demand discussed in this case.For hourly load forecasts,please include the amount
of Block 2 energy in each hour.Please provide files in electronic format with formula enabled.
REQUESTNO.5:Please explain how or if the Company incorporated Lamb Weston's
expected increase in energy and demand represented in this case into the General Rate Case
(Case No.IPC-E-23-l l)filed on June 1,2023.
REQUESTNO.6:Please explain how the Company plans to incorporate the
Commission's decision in this case into the General Rate Case (Case No.IPC-E-23-11)filed on
June 1,2023.
REQUESTNO.7:Please provide a copy of the Construction Agreement dated
September 20,2022,discussed on page 8 of the Special Contract.
REQUESTNO.8:Please explain if Lamb Weston's Contract Demand Ramp projection
shown on page 5 of the Special Contract is still accurate based on any changes that have
occurred in their schedule for expanding operations.
FIRST PRODUCTION REQUEST
TO IDAHO POWER 3 JUNE 16,2023
REQUESTNO.9:In reference to the Initial Power Factor ("P.F.")Adjustment
discussed on page 7 of the Application,please respond to the following:
a.Please explain how the Company will measure the P.F.,given the requirement is
90%P.F.below 20,000 kW and 95%P.F.above 20,000 kW.
b.Please provide an example of the proposed Initial P.F.Adjustment calculation in
electronic format with formula enabled when Lamb Weston's demand is:(1)
under 20,000 kW and the P.F.is under 90%,and (2)over 20,000 kW and the P.F.
is under 95%.
REQUESTNO.10:The Company stated that the Contract Demand will be 34,000 kW
for Lamb Weston.Please explain if Lamb Weston expects its demand to exceed 34,000 kW.
Please provide a 5-year forecast for Lamb Weston's load demand.
DATED at Boise,Idaho,this i day of June 2023.
Michael Duval
Deputy AttorneyGeneral
i:umise:prodreq/ipce23.18mdme prod req l
FIRST PRODUCTION REQUEST
TO IDAHO POWER 4 JUNE 16,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 16th DAY OF JUNE 2023,SERVEDTHEFOREGOINGFIRSTPRODUCTIONREQUESTOFTHECOMMISSIONSTAFFTOIDAHOPOWERCOMPANY,IN CASE NO.IPC-E-23-18,BY E-MAILING ACOPYTHEREOF,TO THE FOLLOWING:
MEGAN GOICOECHEA ALLEN CONNIE ASCHENBRENNERLISADNORDSTROMPAWELGORALSKI
IDAHO POWER COMPANY IDAHO POWER COMPANY
PO BOX 70 PO BOX 70
BOISE ID 83707-0070 BOISE ID 83707-0070E-MAIL:E-MAIL:[e-mail]
[e-mail] [e-mail]
[e-mail]
[e-mail]
SECRETARY
CERTIFICATE OF SERVICE