20240102IPC to Staff 13-21.pdf

MEGAN GOICOECHEA ALLEN
Corporate Counsel
[e-mail]

January 2, 2024

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 Third
Production Request of the Commission Staff in the above-entitled matter. While the
response was initially due on December 29, 2023, the Commission Staff granted the
Company a one-day extension of the due date to January 2, 2024.

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

Sincerely,

Megan Goicoechea Allen
MGA:sg
Enclosures
RECEIVED
Tuesday, January 2, 2024 3:36:06 PM
IDAHO PUBLIC
UTILITIES COMMISSION
IDAHO POWER COMPANY’S RESPONSE TO THE THIRD 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 THIRD
PRODUCTION REQUEST OF
THE COMMISSION STAFF TO
IDAHO POWER COMPANY

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 December 8, 2023, herewith submits the following information:
IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 2
REQUEST FOR PRODUCTION NO. 13: Please explain the Company's rationale
for paying a higher weekly fixed incentive and then financially penalizing 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
exceeding their nominated load reduction during a called event.
RESPONSE TO REQUEST FOR PRODUCTION NO. 13: The basis for the
existing payment structure is to attract customers to the program and incentivize
customers to achieve their nomination. A lower fixed incentive and a higher variable
incentive for events has the potential to result in highly variable annual incentive payouts
based on the number of events, which could impact future participation in the program
and ultimately load reduction potential.
The response to this Request is sponsored by Quentin Nesbitt, Customer
Research and Analysis Leader, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 3
REQUEST FOR PRODUCTION NO. 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 14: The incremental value
of the automatic dispatch is the potential for increased participation in the program and
more consistent load reduction from some customers. Though this is not an option that is
appealing to all potential participants, the automatic dispatch option allows customers
another participation option that requires less labor involvement and potentially lessens
the variability of the load reduction during events once the load control device is set up.
One example of an actual scenario demonstrating the potential benefits associated
with the automatic dispatch option involved a situation in which knowledge of what to do
when an event is called rested with one employee of the Flex Peak participant, such that,
if that employee was not present at the time an event was called, the participant did not
perform during that event. The automatic dispatch option can help alleviate problems like
this and provide more consistent load reduction. The participant has elected to enroll in
the automatic dispatch option which removes the need for employee intervention to
participate in events.
The response to this Request is sponsored by Quentin Nesbitt, Customer
Research and Analysis Leader, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 4
REQUEST FOR PRODUCTION NO. 15: Can nominations occur or be changed
within a program week once the week has started, both historically and in the current
proposal? Please explain.
RESPONSE TO REQUEST FOR PRODUCTION NO. 15: Under the existing
program parameters, participants must notify the Company before 10:00 A.M. Thursday
of changes to their nomination for the following week. In preparation of the Company’s
Responses to the Third Production Request of Staff in this matter, the Company became
aware it had inadvertently included a proposed change to the tariff moving the notification
deadline to 10:00 A.M. on Monday of the program week, which is being contemplated by
the Company but not requested at this time and, therefore, was not described or justified
for inclusion in its application. The Company is not proposing a change to the timing of
the nomination changes as part of this case and regrets the oversight of including the
incorrect tariff sheets as part of its application. If the Company believes this change is
appropriate in the future, it will make such proposal in a later filing setting forth the
rationale behind it. Upon becoming aware of this issue, the Company reviewed all
remaining redlines and can confirm those changes are all necessary to implement the
program changes requested in the application. The Company is very appreciative of
Staff’s thorough review in highlighting the proposed change and seeking to understand
the justification for it. Unless Staff prefers a different procedural resolution, the Company
intends to make the Commission aware of the oversight by filing the corrected tariff sheets
as part of its Reply Comments in this case.
The response to this Request is sponsored by Connie Aschenbrenner, Rate
Design Senior Manager, Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 5
REQUEST FOR PRODUCTION NO. 16: Please provide the following for 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 hourly reduction 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 16: Please see the attached
excel spreadsheet, Attachment 1 – Response to Request for Production No. 16, and a
further explanation as follows.
1. The weekly nominations are shown on each year’s “Weekly Nomination” tab.
2. The event dates and times are listed on each year’s “Weekly Nomination” tab (to
assist in review, the weeks where events were called are highlighted in blue in
the worksheet).
3. Weekly nomination changes can be found on each year’s “Weekly Nomination”
tab.
IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 6
4. If a participant opted out for any week, or if they were no longer enrolled in the
program, their nomination is “0” in each year’s “Weekly Nomination” tab.
5. Hourly load reduction can be found on each year’s “Adjustment” tab in the
“Event” columns. This is broken down for each participant’s load reduction each
hour of the event as well as their average for each event (the event average is
capped at 120% of the nomination of any week).
6. The incentive adjustment associated with each hour can be found on each year’s
“Adjustment” tab in the “HR Adjustment” columns. Both the incentive adjustment
as well as the summed total of incentive adjustment for each event is shown in
the righthand columns of each “Adjustment” tab.
7. Participants earn an incentive on the average load reduction per event so there is
no direct hourly relationship to incentive. There is a breakdown of nomination per
event compared to event average load reduction, showing the incentive that was
credited above nomination per event. This can be found on each year’s “Event
Average” tab.
Note, certain Idaho Power sites participate in the Flex Peak program and load reduction
is tracked for the Company’s participation. Because the Company does not earn
incentives for its participation, there is no incentive adjustment associated with these
sites. The Idaho Power participant data is found on row 45 of the 2019 tabs, row 43 of
the 2020 tabs, row 42 of the 2021 tabs, row 92 of the 2022 tabs, and row 58 of the 2023
tabs.
The response to this Request is sponsored by Quentin Nesbitt, Customer
Research and Analysis Leader, Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 7
REQUEST FOR PRODUCTION NO. 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 17: 2023 was the first year
the Company offered the automatic dispatch option and there are currently 4 load control
devices at sites participating in the program. There have been no load control device
failures within the Flex Peak program to date.
The response to this Request is sponsored by Quentin Nesbitt, Customer
Research and Analysis Leader, Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 8
REQUEST FOR PRODUCTION NO. 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?
RESPONSE TO REQUEST FOR PRODUCTION NO. 18: Please see the
Company’s Response to Request for Production No. 15.
The response to this Request is sponsored by Quentin Nesbitt, Customer
Research and Analysis Leader, Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 9
REQUEST FOR PRODUCTION NO. 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 19: Please see the
Company’s Response to Request for Production No. 15.
The response to this Request is sponsored by Quentin Nesbitt, Customer
Research and Analysis Leader, Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 10
REQUEST FOR PRODUCTION NO. 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 likely to 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).
RESPONSE TO REQUEST FOR PRODUCTION NO. 20: Please see the
Company’s Response to Request for Production No. 15 on nomination lead times.
However, the Company does not believe potential gaming is likely with the proposed
structure. Only nominations during weeks where events are called, and most importantly,
a customer’s performance during those events, will be factored into the incentive
calculation. Weeks where events are not called will no longer guarantee a participant
receives an incentive as under the Company’s proposed program parameters, a
participant would now be required to perform during event weeks. The Company believes
this will incentivize participants to maintain a consistent nomination as well as eliminate
any benefit from having a high nomination in weeks when events are not called.
The response to this Request is sponsored by Quentin Nesbitt, Customer
Research and Analysis Leader, Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 11
REQUEST FOR PRODUCTION NO. 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 21: While the Flex Peak
Program available to commercial and industrial customers and the Irrigation Peak
Rewards Program offering for irrigation customers are similar in some respects, there are
differences between the two programs based on the particular characteristics and usage
of these customer classes. Both programs allow customers the option of participating with
either a manual or automatic dispatch option though the specific parameters of the
interruption options vary and are intended to maintain consistency within each of the
respective programs rather than between them. For example, the manual dispatch option
of the Irrigation Peak Rewards program was designed to have a structure akin to the
automatic dispatch option under the Irrigation Peak Rewards for the sake of customer
consistency. The Irrigation Peak Rewards automatic option is designed to have a simple
calculation of load reduction that requires all the pumps at the service location to be under
control, which then eliminates the need for customers to nominate load reduction. Rather,
the Company uses past demand for a customer’s nomination. Similarly, for the Irrigation
Peak Rewards manual option, the Company uses past demand but allows customers to
nominate based on what pumps they will not turn off during load control events. The
Company estimates and calculates load reduction from what was on prior to the event.
This type of nomination is generally suitable for irrigation customers but does not work as
IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 12
well for commercial or industrial customers, because irrigation load is much more uniform
in that pumps are on or off and do not have the degree of variation over the course of a
day as what is typical for commercial or industrial customers. The Company estimates
the capacity of the Irrigation Peak Rewards program using interval metering data from
previous days and historical trends. For either the manual or automatic interruption option
under the Flex Peak program, the Company estimates load reduction from customer
nominations.
The “firmness” of the Irrigation Peak Rewards program load reduction is affected
by a customer’s operational needs and whether pumps are actually on prior to load control
events being called. The firmness of the Flex Peak program is affected by customers not
performing to their nominations to the degree that would give the Company a better load
reduction estimate. Therefore, the “firmness” in the Flex Peak program is made better by
having more accurate customer nominations where the current nomination method in the
Irrigation Peak Rewards program is currently providing the Company adequate estimation
of the load reduction potential of Irrigation Peak Rewards participants.
The response to this Request is sponsored by Quentin Nesbitt, Customer
Research and Analysis Leader, Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 13
DATED at Boise, Idaho, this 2nd day of January 2024.

MEGAN GOICOECHEA ALLEN
Attorney for Idaho Power Company
IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 14
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the 2nd day of January 2024, I served a true and
correct Idaho Power Company’s Response to the Third 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. 16
ATTACHMENT NO. 1
SEE ATTACHED SPREADSHEET