20240207IPC to Staff Supplemental 67.pdf

LISA NORDSTROM
Lead Counsel
[e-mail]

February 7, 2024

VIA ELECTRONIC EMAIL

Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg. 8,
Suite 201-A (83714)
P.O. Box 83720
Boise, Idaho 83720-0074

Re: Docket No. IPC-E-23-23
Idaho Power Company’s 2023 Integrated Resource Plan

Dear Commission Secretary:

Enclosed for electronic filing, please find Idaho Power Company’s Second
Supplemental Response to the Third Production Request of the Commission Staff.

If you have any questions about the attached filing, please do not hesitate to
contact me.

Very truly yours,

Lisa Nordstrom
LDN:cd
Attachments
RECEIVED
Wednesday, February 7, 2024 4:38PM
IDAHO PUBLIC
UTILITIES COMMISSION
IDAHO POWER COMPANY’S SECOND SUPPLEMENTAL RESPONSE TO THE THIRD 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]
[e-mail]
[e-mail]

Attorney for Idaho Power Company

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF IDAHO POWER
COMPANY’S 2023 INTEGRATED
RESOURCE PLAN.
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CASE NO. IPC-E-23-23

IDAHO POWER COMPANY’S
SECOND SUPPLEMENTAL
RESPONSE TO THE THIRD
PRODUCTION REQUEST OF THE
COMMISSION STAFF

COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), and in
response to the Third Production Request of the Commission Staff (“Commission” or
“Staff”) dated January 17, 2024, herewith submits the following supplemental
information:

IDAHO POWER COMPANY’S SECOND SUPPLEMENTAL RESPONSE TO THE THIRD PRODUCTION
REQUEST OF THE COMMISSION STAFF- 2
STAFF REQUEST FOR PRODUCTION NO. 67: In response to Production
Request No. 59, the Company states that Schedule 33 would experience a rate change
related to changes in energy load forecast percentile because the special contract relies
on Demand-Side Management ("DSM") avoided cost averages. Please answer the
following:
a. Please describe the relationship between the load forecast percentile and
DSM avoided cost averages;
b. Please explain the effect that moving from a 50th percentile load forecast
to a 70th percentile load forecast has had on each avoided cost component
(e.g., avoided cost of energy, avoided cost of capacity, etc.); and
c. Please explain the effect that moving from a 50th percentile load forecast
to a 70th percentile load forecast has had on demand response and energy
efficiency selections.
SUPPLEMENTAL RESPONSE TO STAFF’S REQUEST FOR PRODUCTION
NO. 67:
a & b. Based on the Company’s discussion with Staff on January 24, 2024, Idaho
Power agreed to provide Staff with an analysis of the average avoided cost differences
between a 50th percentile load and a 70th percentile load, which was used in the 2023
Integrated Resource Plan (“IRP”).
The analysis, provided in the attachment to this supplemental response, was
conducted by re-running the Preferred Portfolio using the 50th percentile load forecast
(energy and capacity or “P50/50”) and comparing the resulting avoided costs to those in
the 2023 IRP, as published in Appendix C. The price comparison—both in dollar values

IDAHO POWER COMPANY’S SECOND SUPPLEMENTAL RESPONSE TO THE THIRD PRODUCTION
REQUEST OF THE COMMISSION STAFF- 3
and percentages—can be found in the “P5050” tab. The table with dollar value
comparisons begins at cell N25 and the percentage differences table begins at cell N50.
Please note that avoided cost averages are compared annually across the seven time
periods used by the Company in the IRP (summer super-peak, summer mid-peak,
summer off-peak, winter super-peak, winter mid-peak, winter off-peak, and off season off-
peak).
In general, using a P70 load forecast increases avoided costs by approximately 1
percent compared to using a P50 load forecast, but actual variance changes by year and
time period.
c. Please reference the Supplemental Response to Staff’s Production
Request No. 59 for the impacts on energy efficiency selection and cost-effectiveness. The
selection or valuation of demand response does not rely on the energy portion of DSM
avoided costs.
The response to this Request is sponsored by Jared Hansen, Resource Planning
Leader, Idaho Power Company.

DATED at Boise, Idaho, this 7th day of February 2024.

Lisa Nordstrom
Attorney for Idaho Power Company

IDAHO POWER COMPANY’S SECOND SUPPLEMENTAL RESPONSE TO THE THIRD PRODUCTION
REQUEST OF THE COMMISSION STAFF- 4
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the 7th day of February 2024, I served a true and
correct copy of Idaho Power Company’s Second Supplemental Response to the Third
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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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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________________________________
Christy Davenport
Legal Administrative Assistant