20231208Staff 13-21 to IPC.pdf

ADAM TRIPLETT
DEPUTY ATTORNEY GENERAL 90
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE,IDAHO 83720-0074
[phone]
IDAHO BAR NO.10221
Street Address for Express Mail:
11331 W CHINDEN BLVD,BLDG 8,SUITE 201-A
BOISE,ID 83714
Attorneyfor the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
)CASE NO.IPC-E-23-24
IN THE MATTER OF IDAHO POWER )COMPANY'S APPLICATION FOR )MODIFICATIONS TO THE COMPANY'S )THIRD PRODUCTION
COMMERCIAL &INDUSTRIAL DEMAND )REQUESTOF THE
RESPONSE PROGRAM,SCHEDULE 82 )COMMISSION STAFF
)TO IDAHO POWER COMPANY
Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Adam Triplett,Deputy AttorneyGeneral,requests that Idaho Power Company ("Company")
provide the followingdocuments and information as soon as possible,but no later than
FRIDAY,DECEMBER 29,2023.
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 information used 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.
THIRD PRODUCTION REQUEST
TO IDAHO POWER COMPANY l DECEMBER 8,2023
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.13:Please explain the Company's rationale for paying a higher weekly
fixed incentive and then financiallypenalizing a participant for lack of performance during a
called event,in contrast to paying the participant a lower program weekly fixed incentive and
then rewarding the participant for meeting or exceedingtheir nominated load reduction during a
called event.
REQUESTNO.14:Please explain the incremental value to the Company of automatic
dispatch over manual dispatch of events in the Flex Peak program.Please provide a general
description of the incremental value as well as the specific benefits.
REQUESTNO.15:Can nominations occur or be changed within a program week once
the week has started,both historicallyand in the current proposal?Please explain.
REQUESTNO.16:Please provide the followingfor each program participant and each
program week over the past 5 years:
1.The nominated weekly load reduction;
2.The date,time,and duration of each called event;
3.The updated nomination,if nominations can be changed during the
program week;
4.Whether the participant opted out of any events called during each week;
5.The amount of actual load reduction for each event called broken down by
hour and whether dispatched automatically or manually;
6.The participant's hourlyreduction in the incentive amount where the
participant failed to meet the nominated load reduction;and
7.The participant's hourly increase in the incentive amount where the
participant exceeded the nominated load reduction.
THIRD PRODUCTION REQUEST
TO IDAHO POWER COMPANY 2 DECEMBER 8,2023
REQUESTNO.17:Please list all dates,circumstances,and the nominated load
amounts where a load control device failed to operate within the Flex Peak program over the past
5-years.
REQUESTNO.18:Recognizing that a Flex Peak program participant can adjust their
nominated load on a weekly basis,please explain why the requested change is needed?
REQUESTNO.19:Recognizing that a participant within the Flex Peak program can
adjust their nominated load up to 10:00 AM on the Monday within the program week,how can
the Company be assured of the available amount of demand response for the Flex Peak program?
Please explain.
REQUESTNO.20:Given that nominations occur on a weekly basis with little or no
lead time prior to the program week,how will the Company prevent gaming by program
participants that could occur by nominating high load reductions during program weeks that are
not likelyto be called (i.e.weeks when system loads are predicted to be lower due to favorable
weather forecasts)and not nominating as much load reduction during weeks when events are
more likely to be called (i.e.weeks when system loads are predicted to be higher due to
unfavorable weather).
REQUESTNO.21:Why does the Company require nominations for an entire program
season in the Irrigation Load Control Program but allow participants in the Flex Peak Program to
nominate on a weekly basis?In the answer,please provide how it effects the "firmness"of the
capacity contribution to the system of the two programs.
DATED at Boise,Idaho,this day of December 2023.
Adam Triplett
Deputy AttorneyGeneral
i:umisc:prodreq/IPC-E-23-24 PR #3
THIRD PRODUCTION REQUEST
TO IDAHO POWER COMPANY 3 DECEMBER 8,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 8th DAY OF DECEMBER 2023,
SERVED THE FOREGOING THIRD PRODUCTION REQUESTOF THE
COMMISSION STAFF TO IDAHO POWER COMPANY,IN CASE NO.IPC-E-23-
24,BY E-MAILING A COPY THEREOF,TO THE FOLLOWING:
MEGAN GOICOECHEA ALLEN CONNIE ASCHENBRENNER
LISA D NORDSTROM ZACK THOMPSON
IDAHO POWER COMPANY IDAHO POWER COMPANY
PO BOX 70 PO BOX 70
BOISE ID 83707-0070 BOISE ID 83707-0070
E-MAIL:E-MAIL:[e-mail]
[e-mail] [e-mail]
[e-mail]
dockets idaho ower.com
Ida Elmasian
CERTIFICATE OF SERVICE