20230822Reply Comments.pdf

MEGAN GOICOECHEA ALLEN
Corporate Counsel
[e-mail]

August 22, 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-23-18
Application for Approval of Special Contract and Tariff Schedule 34 to Provide
Electric Service to Lamb Weston, Inc.

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
Enclosures
RECEIVED
Tuesday, August 22, 2023 11:02:34 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]
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
APPROVAL OF SPECIAL CONTRACT AND
TARIFF SCHEDULE 34 TO PROVIDE
ELECTRIC SERVICE TO LAMB WESTON,
INC.
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CASE NO. IPC-E-23-18

IDAHO POWER COMPANY’S
REPLY COMMENTS

COMES NOW, Idaho Power Company (“Idaho Power” or “Company”) and,
pursuant to Idaho Public Utilities Commission’s (“Commission”) Rule of Procedure1
203, and the Notice of Modified Procedure, Order No. 35822, hereby respectfully submits
the following Reply Comments in response to Comments of the Commission Staff (“Staff”)
in this case dated August 15, 2023.

1 Hereinafter cited as RP.

IDAHO POWER COMPANY’S REPLY COMMENTS - 2
Idaho Power appreciates Staff’s thorough review and assessment of the proposed
Special Contract for electric service between Idaho Power and Lamb Weston, Inc. (“Lamb
Weston”) for electric service at the Lamb Weston manufacturing facility located in
American Falls, Idaho, and rates proposed in tariff Schedule 34, “Idaho Power Company
Electric Service Rate for Lamb Weston, Inc.” (“Schedule 34”). Staff’s supportive
Comments include the following recommendations:
1. Approve the Special Contract provided as Attachment 1 of the Application;
2. Approve the proposed annual update to the marginal energy price effective
June 1;
3. Approve the proposed Schedule 34 tariff provided as Attachment 2 of the
Application with the modification to replace Original Sheet No. 34-4 included
with Attachment 2 with the Original Sheet No. 34-4 included in the Errata to
Application provided as Revised Attachment 2; and
4. Approve the proposed PCA accounting treatment.
The Company agrees with Staff’s recommendations and appreciates the
opportunity to offer these brief Reply Comments to provide clarification on two points
included in Staff’s Comments as follows:
(1) Discussing the Special Contract provisions, page 3 of Staff’s Comments states:
The Special Contract outlines Lamb Weston's gradual contract demand
ramp projection beginning July 2023 of 23 MW to March 2024, when it
expects to reach a steady state of production. Lamb Weston has an initial
annual contract demand of 34,000 kW starting in March 2024, which is
consistent with the Company's request for the Agreement to be effective
on March 1, 2024.

 As indicated by Staff, the Special Contract provides that initial levels of
Contract Demand through February 2024 will be based on the Contract

IDAHO POWER COMPANY’S REPLY COMMENTS - 3
Demand ramp projection (set forth in Section 5.1(a) of the Special Contract),
which starts at 23 MW in July 20232 and steadily increases until March
2024, when it expects to reach a steady state of production at which point
Contract Demand will be 34,000 kW.
 The Company clarifies, however, that the effective date requested for the
Special Contract, which was executed on May 5, 2023, is “upon the
approval by the IPUC of all terms and provisions hereof without change or
condition.” See Application at paragraph 8 and Special Contract at Section
14.2.
(2) Discussing the Errata filed by the Company on July 14th in order to correct an error
regarding Block 2 charges, page 6 of Staff’s Comments states:
In preparing the Company's response to Staff Production Requests, the
Company found an error in the calculation of the Monthly Contract
Demand Charge and provided Staff with corrected workpapers Staff
reviewed the corrected workpapers and believes the updated Block 2
Monthly Contract Demand provided by the Company in the Original
Sheet No. 34-4 included with the Errata to Application is the appropriate
demand charge to be used for Lamb Weston.

 The Company clarifies that the Errata related to the Block 2 Monthly
Billing Demand Charge, not the Contract Demand Charge.
Idaho Power again notes its appreciation for Staff’s review and consideration of
the issues in this case. The Company supports Staff’s recommendations and provides
these Reply Comments to clarify the items noted above to ensure accuracy, consistency,
and clarity of the record.

2 Please note that Lamb Weston’s energy requirements have not, to date, exceeded 20,000 kW, and Lamb Weston
has indicated they are approximately 3 months behind in their load ramping timing.

IDAHO POWER COMPANY’S REPLY COMMENTS - 4
DATED at Boise, Idaho, this 22nd day of August 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 22nd day of August 2023, I served a true and
correct copy of 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
11331 W. Chinden Blvd., Bldg No. 8
Suite 201-A (83714)
PO Box 83720
Boise, ID 83720-0074

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