20231221IPC to Staff 7-12.pdf

MEGAN GOICOECHEA ALLEN
Corporate Counsel
[e-mail]

December 21, 2023

Commission 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 Commission Secretary:

Attached for electronic filing is Idaho Power Company’s Response to the Second
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 DECEMBER 21, 2023 2:57PM
IDAHO PUBLIC
UTILITIES COMMISSION
IDAHO POWER COMPANY’S RESPONSE TO THE SECOND 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 SECOND
PRODUCTION REQUEST OF
THE COMMISSION STAFF TO
IDAHO POWER COMPANY

COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), and in
response to the Second Production Request of the Commission Staff (“Commission” or
“Staff”) dated November 30, 2023, herewith submits the following information:
IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 2
REQUEST FOR PRODUCTION NO. 7: Please describe the maximum possible
advanced notice participants can receive under the advance notification option. Please
describe how the Company will determine this lead time when evaluating potential
participants.
RESPONSE TO REQUEST FOR PRODUCTION NO. 7: The Company has initially
aligned on providing advance notification in the 8 AM to 9 AM hour on the day of an event.
Therefore, the maximum possible advanced notification would be between 7 and 12 hours
depending on the event start time. The Company believes keeping the advance
notification consistent for all customers that elect and qualify to participate will ensure
consistent program operations, execution, and customer experience for participants.
The response to this Request is sponsored by Quentin Nesbitt, Customer
Research & Analysis Leader, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 3
REQUEST FOR PRODUCTION NO. 8: Please describe what additional risks the
advance notification presents in terms of the reliability of the associated load reduction.
Please describe what options the Company would consider as part of its case-by-case
evaluation to mitigate these risks.
RESPONSE TO REQUEST FOR PRODUCTION NO. 8: Idaho Power proposes
offering the advance notification option to attract very large customers where the advance
notice would make it easier for them to participate, provide more reliable load reduction,
and align more with their facility’s needs and operations. In evaluating the advance
notification option, which included discussions with customers, Idaho Power does not
believe there are additional risks in obtaining reliable load reduction from qualifying
customers. The Company believes the proposal would help provide more reliable load
reduction, and that the additional time provided by the advance notification option will
make it easier for qualifying customers to reliably meet their nominations when demand
response events are called.
The response to this Request is sponsored by Quentin Nesbitt, Customer
Research & Analysis Leader, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 4
REQUEST FOR PRODUCTION NO. 9: Please explain if the Company considered
a different incentive structure for the proposed advanced notification option. If so, please
provide the details and documentation.
RESPONSE TO REQUEST FOR PRODUCTION NO. 9: As described below in
Response to Request for Production No. 10, the Company will evaluate potential
participants based on certain criteria and whether the option is in the customer’s best
interest. The Company does not view advance notification as a new option in terms of the
hours a customer would participate. It is only new in terms of when qualifying customers
would receive notice a demand response event was occurring. Because the hours in
which customers are participating are not changing, the Company believes the value of
the load reduction does not change. Therefore, Idaho Power did not evaluate or consider
a different incentive structure for the proposed advance notification option.
The response to this Request is sponsored by Quentin Nesbitt, Customer
Research & Analysis Leader, Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 5
REQUEST FOR PRODUCTION NO. 10: Please explain any other criteria and
metrics the Company will consider when evaluating potential advance notification option
participants.
RESPONSE TO REQUEST FOR PRODUCTION NO. 10: For customers that
desire to pursue the advance notification option, the Company will evaluate these
potential large customers (3 MW or more) on a case-by-case basis to determine if their
load profiles and/or operations would warrant advance notification. The size and shape
of a customer’s load profile will be the main factor considered; a large customer with a
consistent load profile/shape and/or a very flat load would likely be a good candidate for
the advance notification option. Other factors that will be analyzed on a case-by-case
basis include the customer’s history participating in the Flex Peak Program (“Program"),
the customer’s operating practices, and whether the customer has other sites
participating in the Program that could be considered under the Program’s Aggregated
Option. The Company will also discuss with the customer in detail on how the baseline
and incentive calculations work, the weekly nomination process, and discuss the incentive
impacts for not providing their nominated load reduction before determining if the advance
notification option would be in the customer’s best interest.
The response to this Request is sponsored by Quentin Nesbitt, Customer
Research & Analysis Leader, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 6
REQUEST FOR PRODUCTION NO. 11: For each participant listed in Attachment
1 to the Company's response to Staff Production Request No. 1, please provide the
nominated and actual load reduction for each event called in the 2022 demand response
season.
RESPONSE TO REQUEST FOR PRODUCTION NO. 11: 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.
REQUEST FOR PRODUCTION NO. 12: The data provided in response to
Production Request No. 1 suggests that the majority of participants do not adjust their
nominations on a weekly basis.
Please explain how the Company encourages participants to actively manage their
nomination and load reduction performance.
RESPONSE TO REQUEST FOR PRODUCTION NO. 12: Idaho Power sends out
load reduction performance data to participants after every event. This data includes each
participating service location’s nomination, its achieved load reduction, and a graph
showing the load along with the calculated baseline over the course of the event. It is not
the Company’s goal to incentivize customers to change their nomination on a weekly
basis. Rather, the Company’s goal has been to try and find a consistent nomination
amount that works for the customer while also providing flexibility for a customer to adjust
their nomination or opt out of a week if needed. Following an event, the Program
Specialist identifies participants that had poor performance in meeting their nomination,
and then an Energy Advisor engages with each of these customers to discuss any
nomination adjustments or identify ways a customer could reduce load given their current
operations. The Company also provides engineering support to help customers identify
load reduction opportunities.
The response to this Request is sponsored by Quentin Nesbitt, Customer
Research & Analysis Leader, Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 7
IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 8
DATED at Boise, Idaho, this 21st day of December 2023.

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

I HEREBY CERTIFY that on the 21st day of December 2023, I served a true and
correct Idaho Power Company’s Response to the Second 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. 11
ATTACHMENT NO. 1
SEE ATTACHED SPREADSHEET