20231115IPC to Staff 1-6.pdf

MEGAN GOICOECHEA ALLEN
Corporate Counsel
[e-mail]

November 15, 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-23-24
Application for Modifications to the Company’s Commercial & Industrial
Demand Response Program, Schedule 82

Dear Ms. Noriyuki:

Attached for electronic filing is Idaho Power Company’s Response to the First
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 NOVEMBER 15, 2023 3:39PM
IDAHO PUBLIC
UTILITIES COMMISSION
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 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
MODIFICATIONS TO THE COMPANY’S
COMMERCIAL & INDUSTRIAL DEMAND
RESPONSE PROGRAM, SCHEDULE 82

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CASE NO. IPC-E-23-24

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

COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), and in
response to the First Production Request of the Commission Staff (“Commission” or
“Staff”) dated October 25, 2023, herewith submits the following information:
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 2
REQUEST FOR PRODUCTION NO. 1: For the 2022 program year, please provide
a blinded list of Flex Peak customers detailing the nominated kW for each week of the
season, maximum potential incentive payment, actual payment, their hypothetical
compensation under the Company's proposed incentive structure, and their hypothetical
compensation under the Energy Efficiency Advisory Group ("EEAG") suggested per event
basis.
RESPONSE TO REQUEST FOR PRODUCTION NO. 1: Please see the
Attachment provided for this response.
The response to this Request is sponsored by Quentin Nesbitt, Customer
Research & Analysis Leader, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 3
REQUEST FOR PRODUCTION NO. 2: Please describe any Company surveys or
customer communications with Flex Peak customers leading to the development of this
proposal.
RESPONSE TO REQUEST FOR PRODUCTION NO. 2: Idaho Power has not
conducted any formal customer surveys on this topic specifically, however the Company
has, via the program specialist and/or energy advisors, received general feedback from
several customers who participated but did not receive an incentive for a demand
response season. This general feedback highlighted that the existing Incentive
Adjustment penalty is not easy to understand and does not always promote customer
participation, particularly in instances where customers ended up with a zero-dollar
incentive despite providing load reduction during some events.
The following is a comment from a past survey, which is representative of typical
customer concerns with the current structure: “For our situation, we can reduce demand
and still not receive an incentive. That doesn’t make the program too attractive.”
The response to this Request is sponsored by Quentin Nesbitt, Customer
Research & Analysis Leader, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 4
REQUEST FOR PRODUCTION NO. 3: Please provide an estimate of the
expected changes to participation under the proposed incentive structure.
RESPONSE TO REQUEST FOR PRODUCTION NO. 3: The Company does not
have an exact estimate of the changes in participation due to the proposed changes in
this filing and has developed its proposal based on customer feedback. As highlighted in
Attachment 1 – Response to Staff’s Production Request No. 1, 43 Flex Peak participants
earned a zero dollar incentive in 2022. With this change, the Company believes updating
the incentive structure will keep current customers engaged with the program to provide
consistent load reduction as well as increase customer satisfaction in cases where the
customer provided load reduction and got nothing for their efforts. The Company also
believes this will be a selling point to prospective customers where it can be definitively
communicated that a customer will receive an incentive if they provide load reduction.
The only way a customer could earn a zero-dollar incentive is if they provide zero load
reduction. The Company believes this will help increase participation from prospective
customers.
The response to this Request is sponsored by Quentin Nesbitt, Customer
Research & Analysis Leader, Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 5
REQUEST FOR PRODUCTION NO. 4: Please explain any functional differences
between the current incentive adjustment waiver and the proposed performance waiver.
RESPONSE TO REQUEST FOR PRODUCTION NO. 4: There is no functional
difference between the current Incentive Adjustment Waiver and the proposed
Performance Waiver. Because the Company is proposing to remove the Nominated kW
Incentive Adjustment definition along with the waiver from the tariff (Definition on page
82-3 and last paragraph of 82-5), it is proposing to add the Performance Waiver so that
customers who participate in the Automatic Dispatch Option continue to not be penalized
if a Load Control Device fails.
The response to this Request is sponsored by Quentin Nesbitt, Customer
Research & Analysis Leader, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 6
REQUEST FOR PRODUCTION NO. 5: Please provide a count of participants that
can nominate 3 MW or more of load reduction.
a. Of these participants, how many does the Company expect to nominate all their
load with the proposed advance notification?
b. Please explain how the Company reached this estimation.
RESPONSE TO REQUEST FOR PRODUCTION NO. 5: From the list of Flex Peak
participants in 2023, 24 participants had a Basic Load Capacity (“BLC”), which is average
of two highest billing demands during a twelve-month period, exceeding 3MW. These
participants had an average nomination as a percentage of their BLC of 14 percent.
a. The Company has had discussions with one customer regarding potentially
nominating the majority of their load, but not all. Idaho Power also believes that
there is an opportunity for these customers to provide more than 14 percent of their
potential load, and that by providing them advanced notice, those customers may
increase their nominations.
b. The 3 MW threshold was selected to target both current and prospective large load
customers that can provide substantial load reduction. When speaking with these
customers, they have consistently mentioned having more than four hours notice
would be better and make it easier for them to participate given the size of their
operations.
The response to this Request is sponsored by Quentin Nesbitt, Customer
Research & Analysis Leader, Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 7
REQUEST FOR PRODUCTION NO. 6: Please explain if the Company considered
any incentive structures other than the proposed structure or the per event structure
proposed in the EEAG.
a. For any potential structures, please explain why they were ultimately not
proposed by the Company.
RESPONSE TO REQUEST FOR PRODUCTION NO. 6: The Company also
considered two other incentive structures. A linear “pay for performance” structure where
there is no penalty and no front-loaded payments, only an incentive for load reduced when
events are called. The second structure considered was similar to what the Company
proposed but had an additional penalty that reduced the incentive even more based on
actual performance.
a. The linear pay for performance model was not chosen because it does not
incentivize accurate nominations from customers, and in years when the program
only runs the three minimum events, customers would not see much benefit even
though they had been willing and ready to reduce all summer. The second
structure was not chosen because it was considered more punitive than the
proposed structure and more complicated for customers to understand.
The response to this Request is sponsored by Quentin Nesbitt, Customer
Research & Analysis Leader, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 8
DATED at Boise, Idaho, this 15th day of November 2023.

MEGAN GOICOECHEA ALLEN
Attorney for Idaho Power Company
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 9
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the 15th day of November 2023, I served a true and
correct Idaho Power Company’s Response to the First Production Request of the
Commission Staff to Idaho Power Company upon the following named parties by the
method indicated below, and addressed to the following:

Commission Staff
Adam Triplett
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

Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email [e-mail]

Stacy Gust, Regulatory Administrative
Assistant

BEFORE THE
IDAHO PUBLIC UTILITIES
COMMISSION CASE NO. IPC-E-23-24
IDAHO POWER COMPANY
REQUEST NO. 1
ATTACHMENT 1
SEE ATTACHED SPREADSHEET