20130130ICL 1-33 to IPC.pdf

Benjamin Otto (ISB No. 8292)
710 N 6th Street
Boise, ID 83701
Ph: [phone] x 12
Fax: [phone]
[e-mail]
RE CE f V
17013JAN3O r;i I: is
jT!LTf c.
Attorney for the Idaho Conservation League
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE
APPLICATION OF IDAHO POWER ) CASE NO. IPC-E-12-27
COMPANY FOR AUTHORITY TO )
MODIFY ITS NET METERING ) FIRST PRODUCTION REQUEST OF
SERVICE AND TO INCREASE THE ) THE IDAHO CONSERVATION
GENERATION CAPACITY LIMIT. ) LEAGUE TO IDAHO POWER
)
The Idaho Conservation League (ICL) requests the following information. Along with the
answer to each question, please provide any supporting documents, workpapers, calculations, or
information sources. As required by IDAPA 31.01.01.228.02, please indicate the witness who can
answer questions regarding the response and who will sponsor the response at any potential
hearing. If any responses include Excel spreadsheets or other electronic files, please provide them
with all formulas intact and activated. As allowed by IDAPA 31.01.01.228.01, if any response is
voluminous ICL agrees to Idaho Power depositing the response in an electronic depository.
This production request is ongoing. Accordingly, we respectfully ask Idaho Power to
provide additional documents and information that may supplement any initial responses.
REQUEST NO 1: Please provide the most recently used alternate costs for analyzing demand
side resources. Please provide these costs for each hour of the year and for the future 20 years.
Please provide these costs in excel spreadsheet or other digital format.
IPC-E- 12-27
ICL'S 1' Production Ràquest 1 January 30, 2013
to Idaho Power
REQUEST NO 2: For the alternate cost data requested above, please identify and quantify the
following components. If Idaho Power has not identified or quantified any of the following,
please explain why.
a.Energy
b.Capacity
c.Transmission
d.Distribution
e.Operations and maintenance
f.Avoided line losses identified and quantified separately for the transmission and
distribution systems.
g.Any other components Idaho Power includes in alternate costs not specifically referred to
in a - f.
REQUEST NO 3: Page 23 of Mr. Larkin's testimony discusses the complexity in using time-
differentiated rates for net metering service. Please provide the following:
a.When does Idaho Power plan to complete "implementing a new customer information
and billing system"?
b.Will this new system have the capability to apply time-differentiated rates for net
metering service?
c.When does Idaho Power plan to determine whether applying time-differentiated rates is
feasible for net metering usage and generation?
d.Describe in further detail the complexity of the calculations to implement time-
differentiated rates for net metering customers.
REQUEST NO 4. Does Idaho Power admit or deny that the Fixed Cost Adjustment mechanism
addresses the recovery of fixed costs that are affected by any change in customer energy
consumption.
REQUEST NO 5. Please explain how Idaho Power arrived at a capacity limit of 5.8 MW. Please
include any documents, analysis, or data used in setting this limit.
REQUEST NO 6. Mr. Larkin, on page 18, states the current net metering program creates a
"potential inequity between net metering customers and standard service customers, as net
metering customers rate provided the opportunity to unduly reduce collection of revenue
requirement by receiving credit for generation at the full retail rate while standard service
customers are left to compensate for the revenue shortfall."
IPC-E- 12-27
ICL'S V Production Request 2 January 30, 2013
to Idaho Power
a.Please quantify any current inequity between current program participants and current
customers in terms of any shift in revenue collections between participants and non-
participants.
b.Based on the Company's forecast of net metering program growth, please quantify the
cc potentialinequity" annually for the next three years.
REQUEST NO 7. The energy rates for Residential and Small General Service customers currently
include multiple blocks. Please explain which energy block a net metering customer's excess
energy is credited at.
REQUEST NO 8. Please explain how Idaho Power choose the December billing period to
eliminate accrued excess net energy credits.
REQUEST NO 9. Please refer to Exhibit 4 at page 40, which is a legislative format of the
proposed revisions to Schedule 72. Please document how Idaho Power calculated the $100
application fee for new Net Metering customers.
REQUEST NO 10. Please refer to Exhibit 5, which is Idaho Power proposed Schedule 84. Please
document why the one meter option is limited to generation facilities with a total name plate
capacity rating of 25 kW or less and a "total nameplate capacity rating no more than 2% of the
Customer's Basic Load Capacity (BLC) or comparable average maximum monthly Billing
Demands."
REQUEST NO 11. Please provide the hourly load curves and data for the most recent calendar
year period for the Idaho jurisdiction of Idaho Power's system for the following customer classes:
a.Residential
b.Small General Service
REQUEST NO 12. Please provide the monthly Idaho jurisdiction retail peak demands and
consumption for the most recent calendar year by customer class.
REQUEST NO 13. Please provide the average monthly consumption per customer for the
residential and small general service classes for calendar years 2003 through 2012.
REQUEST NO 14. Please provide the full set of production requests and responses that include
the response referenced in Mr. Larkin's testimony page 8, lines 18-21.
REQUEST NO 15. Does the Company still believe the retail rate may be higher than the value of
generation produced under the net metering program? If so, please provide any analysis, data, or
any other documentation supporting this position.
REQUEST NO 16. Please reference Mr. Larkin's testimony on page 8, line 26 through page 9,
line 5. Please provide any analyses performed by or for the Company addressing the
administrative costs and benefits of applying the retail rate for both consumption and generation
by net metering customers.
IPC-E- 12-27
ICL'S 1' Production Request 3 January 30, 2013
to Idaho Power
REQUEST NO 17. Please reference Mr. Larkin's testimony on page 12, lines 8 — 9. To what
circumstances does IPC attribute the sharply increased growth since 2010 (page 12, lines 8-9)?
REQUEST NO 18. Please provide any and all studies, analyses, polling, information from focus
groups, or any other support for Mr. Larkin's statement (starting on page 14, line 23) that the
pricing proposal balances the interests of net metering customers and standard service customers.
REQUEST NO 19. Please provide any and all studies, analyses, or any other support for Mr.
Larkin's statement (on page 15, line 1-2) that the proposed changes will achieve the objective of
"applying charges to net metering customers that accurately reflect the cost to serve them."
REQUEST NO 20. Please reference the questions an answers in Mr. Larkin's testimony
beginning on page 15, line 3 through page 18, line 16. Is the core issue being identified the total
sales reductions due to on-site generation, the exports of electricity (net energy leaving the
customer's premises on a moment by moment basis), or the non-simultaneous netting of excess
generation with consumption?
REQUEST NO 21. Please refer to Mr. Larkin's testimony at page 22, line 19-22. Please
separately identify and quantify the benefits provided to IPC by the installation of customer-sited
generation that were considered in developing the charges.
REQUEST NO 22. Please provide a list of all generating resources and the associated capacity
used by IPC to serve its retail load, whether each is owned in whole or in part by IPC, and for
those from which IPC purchases energy whether the purchase is firm or non-firm.
REQUEST NO 23. Does IPC dispatch its generating resources on an economic basis?
REQUEST NO 24. Are the retail rates of IPC cost-based? Is the basis long term or short term
costs?
REQUEST NO 25. Please identify and quantify each cost category (both expenses and return on
capital) the Company considers appropriately included in the current monthly service charges.
REQUEST NO 26. For the proposed $20.92 and $22.49 customer charges for schedules 6 and 8,
please identify what portion of fixed costs attributable to the residential and small general service
customers will be recovered through these charges. Also, please identify the portion of fixed
charges for the residential and small general service classes that will be recovered from the
proposed basic load charge for Schedules 6 and 8.
REQUEST NO 27. Please reference Mr. Larkin's testimony on page 21 line 21 through page 22,
line 5. Please explain in detail why the cents-per-kwh figure for the distribution related costs
collected through the energy rate for Schedule 7 is nearly twice as high as that for Schedule 1.
REQUEST NO 28. In connection with the "two-meter solution" discussed by Mr. Larkin on at
page 23, line 12, did the Company perform any studies that might be used for the generation-
specific rate? If so, please provide the studies and any related data.
IPC-E- 12-27
ICL'S i' Production Request 4 January 30, 2013
to Idaho Power
REQUEST NO 29. Please refer to Mr. Larkin's testimony on page 25 lines 14 - 21. Please
identify the portion of fixed cost recovery excluded from the energy rates applied to Schedules 9,
19, and 24. Please compare this result to Schedules 1, 7 and the proposed 6, and 8.
REQUEST NO 30. Please reference Mr. Larkin's testimony on page 26, line 23 through page 27
line 3. Please provide the determination of the "generation-related revenue requirement"
embedded in rates, and the cost/kWh or cost/kW included in each rate schedule 1, 6, 7, and 8.
REQUEST NO 31. Does IPC consider net-metered customers to be wholesale generators?
REQUEST NO 32. Is it IPC's position that net-metered systems are not qualifying facilities
under PURPA?
REQUEST NO 33. Please reference Mr. Larkin's testimony on page 32, line 15. Which planning
process(es) are being referenced?
DATED the 30th day of January 2013.
Benjamin J. Otto
Idaho Conservation League
IPC-E- 12-27
ICL'S Vt Production Request 5 January 30, 2013
to Idaho Power
CERTIFICATE OF SERVICE
I hereby certify that on this 30th day of January 2013,! delivered true and correct copies
of the foregoing FIRST PRODUCTION REQUEST TO IDAHO POWER to the following persons
via the method of service noted:
Hand delivery:
Jean Jewell
Commission Secretary (Original and three copies provided)
Idaho Public Utilities Commission
427 W. Washington St.
Boise, ID 83702-5983
Electronic Mail:
Lisa D. Nordstrom
Regulatory Dockets
Idaho Power Company
P.O. Box 70
Boise, Idaho 83707
[e-mail]
[e-mail]
Matt Larkin
Greg Said
Idaho Power Company
P.O. Box 70
Boise, Idaho 83707
[e-mail]
[e-mail]
Pioneer Power, LLC
do Peter J. Richardson
Richardson & O'Leary
515N.27' St
P.O. Box 7218
Boise, Idaho 83702
[e-mail]
John Steiner
24597 Collett RD
Oreana, Idaho 83650-5070
[e-mail]
PowerWorks, LLC
C/o Chris Aepelbacher, Project Engineer
5420 W. Wicher Road
Glenns Ferry, Idaho 83623
[e-mail]
City of Boise
R. Stephen Rutherford
City of Boise City, Idaho
P.O. Box 500
Boise, ID 83701-0500
[e-mail]
Idaho Clean Energy Association
Dean J. Miller
McDEVIIT & MILLER LLP
P.O. BOX 2564-83701
Boise, Idaho 83702
[e-mail]
Snake River Alliance
Ken Miller
Clean Energy Program Director
Snake River Alliance
P.O. Box 1731
Boise, ID 83701
[e-mail]
'44'.
Benjamin J. Otto
Certificate of Service 6 January 30, 2013