20230621Reply Comments.pdf

MEGAN GOICOECHEA ALLEN
Corporate Counsel
[e-mail]

June 21, 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-22-30
Application of Idaho Power Company for Authority to Establish Compensation
for the Mandatory Interruption Requirement of Schedule 20 - Speculative
High-Density Load

Dear Ms. Noriyuki:

Attached for electronic filing is Idaho Power Company’s Reply Comments 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

Enclosure

RECEIVED
Wednesday, June 21, 2023 10:44:35 AM
IDAHO PUBLIC
UTILITIES COMMISSION

IDAHO POWER COMPANY’S REPLY COMMENTS - 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]
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[e-mail]
[e-mail]

Attorneys for Idaho Power Company

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
AUTHORITY TO ESTABLISH
COMPENSATION FOR THE MANDATORY
INTERRUPTION REQUIREMENT OF
SCHEDULE 20 - SPECULATIVE HIGH-
DENSITY LOAD.
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CASE NO. IPC-E-22-30

IDAHO POWER COMPANY’S
REPLY COMMENTS

Idaho Power Company (“Idaho Power” or “Company”) respectfully submits the
following Reply Comments in response to Comments filed by Staff (“Staff”) of the Idaho
Public Utilities Commission (“Commission”) in the matter of the Company’s application to
establish compensation for the mandatory interruption requirement of Schedule 20 –
Speculative High-Density Load (“Schedule 20”).
I. REPLY COMMENTS
Staff Comments – Based on its review of the Company’s proposals to provide
for interruptible compensation for Schedule 20 customers, including comparison to other
existing programs and schedules for context, Staff concluded that the Company’s

IDAHO POWER COMPANY’S REPLY COMMENTS - 2
proposal and method for providing and determining interim compensation was fair, just,
and reasonable for Schedule 20 customers.1
More specifically, Staff reviewed the interim interruption methodology basis of
using Schedule 9 and Schedule 19 cost assignment and found that the resulting proposed
values for interruptible compensation of $0.0734 per kilowatt (“kW”) per hour for Large
General Service and $0.0835 per kW per hour for Large Power Service provide a fair
estimate that reduces the risk of overcompensation that could harm other customers and
can be utilized until data from actual Schedule 20 customers is available. Staff also
agreed it was reasonable for Schedule 20 interruption compensation costs to be 100
percent recoverable through the Company’s Power Cost Adjustment (“PCA”) mechanism,
considering Idaho Power’s inability to negotiate these rates with individual customers and
its obligation to serve.2
Reply Comments - Idaho Power appreciates the review by Staff in consideration
of any interim interruption compensation offered to Schedule 20 for mandatory load
interruption and agrees with its recommendations. The Company also agrees with Staff’s
assessment that Schedule 20 interruption parameters and rates are best reviewed and
determined once Schedule 20 customers are established and data has been collected as
part of a general rate case. While actual Schedule 20 customer data is ultimately the most
appropriate for determining interruptible parameters and rates, the Company does not
currently have any Schedule 20 customers, as noted by the Company in its most recent

1 Staff Comments, p. 5
2 Id.

IDAHO POWER COMPANY’S REPLY COMMENTS - 3
general rate case, Case No. IPC-E-23-11 filed June 1, 2023.3 As a result, the Company
anticipates the analysis would occur in the context of a future general rate case, once
Schedule 20 customers are established and can have cost assignment determined as a
separate rate class. While not specific to the interruption compensation for Schedule 20,
the Company has proposed as part of its pending general rate case to update the
marginal energy component basis of Schedule 20 to align with proposed Schedule 9 and
19 time-of-use periods, and to replace the current Demand-Side Management Avoided
Cost Average-based marginal rates with AURORA-based marginal rates.4 The proposed
change to an AURORA-based marginal energy rate is based on Staff’s recommendation
for the Company to evaluate the pricing basis of marginal energy, and ordered by the
Commission as part of the Company’s case to establish Schedule 20.5
II. CONCLUSION
Idaho Power appreciates Staff’s review and consideration of the issues in this case
and the opportunity to offer these Reply Comments to address Staff’s recommendations.
Idaho Power respectfully requests that the Commission: (1) approve the proposed interim
interruption compensation for Schedule 20 of $0.0734 per kilowatt (“kW”) per hour for
Large General Service and $0.0835 per kW per hour for Large Power Service, and (2)
allow for 100 percent recovery of Schedule 20 interim interruptible compensation costs
through the PCA.

3 In the Matter of the Application of Idaho Power Company for Authority to Increase Its Rates and
Charges for Electric Service in the State of Idaho and for Associated Regulatory Accounting Treatment,
Case No. IPC-E-23-11, Direct Testimony of Pawel Goralski, p. 49-50.
4 Id. at 51.
5 In the Matter of the Application of Idaho Power Company for Authority to Establish a New Schedule to
Serve Speculative High-Density Load Customers, Case No. 21-37, Staff Comments, p. 6 (Apr. 12, 2022)
and Order No 35428, p. 6-7 (Jun. 15, 2022).

IDAHO POWER COMPANY’S REPLY COMMENTS - 4
Respectfully submitted this 21st day of June 2023.

MEGAN GOICOECHEA ALLEN
Attorney for Idaho Power Company

IDAHO POWER COMPANY’S REPLY COMMENTS - 5
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the 21st day of June 2023, I served a true and correct
copy of the foregoing Idaho Power Company’s Reply Comments upon the following
named parties by the method indicated below, and addressed to the following:

Commission Staff
Michael Duval
Deputy Attorney General
Idaho Public Utilities Commission
P.O. Box 83720
11331 West Chinden Blvd, Bldg 8
Suite 201-A
Boise ID 83714

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