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Home My WebLink About20130521IPC 1-5 to Boise City.pdfSffi*. An IDACORP Company ar, n n ni! l - rr1ii:.:t-lr'rl IU rll 11: 3D LISA D. NORDSTROM Lead Gounsel lnordstrom@idahopower.com May 20,2013 VIA HAND DELIVERY Jean D. Jewell, Secretary ldaho Public Utilities Commission 472 W est Washington Street Boise, ldaho 83702 Re: Case No. IPC-E-12-27 Net Metering Service - ldaho Power Company's First Production Request to the City of Boise. Dear Ms. Jewel!: Enclosed for filing in the above matter are an original and three (3) copies of ldaho Power Company's First Production Request to the City of Boise. Very truly yours, ?. n -,f Ch,r- lt.7/^uh"h- Lisa D. Nordstro\m LDN:evp Enclosures LISA D. NORDSTROM (!SB No. 5733) JULIA A. HILTON (lSB No. 7740) ldaho Power Company 1221West ldaho Street (83702) P.O. Box 70 Boise, ldaho 83707 Telephone: (208) 388-5825 Facsimile: (208) 388-6936 I no rd stro m @ id a ho power. co m i h i lton @ idahopower. com Attorneys for ldaho Power Company IN THE MATTER OF IDAHO POWER COMPANY'S APPLICATION FOR AUTHORITY TO MODIFY lTS NET METERING SERVICE AND TO INCREASE THE GENERATION CAPACITY LIMIT BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-12-27 IDAHO POWER COMPANY'S FIRST PRODUCTION REQUEST TO THE CITY OF BOISE. COMES NOW, ldaho Power Company ("Company"), by and through its attorneys, and hereby requests that the City of Boise answer the following production request and provide the following information and documents in accordance with the ldaho Public Utilities Commission's ("Commission") Rules of Procedure and applicable scheduling orders and notices issued by the Commission in this proceeding. !n anticipation of hearing please provide information that is responsive to this request no Iater than June 7,2013. IDAHO POWER COMPANY'S FIRST PRODUCTION REQUEST TO THE CITY OF BOISE - 1 REQUEST NO. 1: On page 6, line 4, Mr. Woods states, "lt appears that this rate design would in fact create a subsidy for a subset of net metering customers." Please in detail describe the potential subsidy referenced by Mr. Woods. lf possible, please provide a numerical example. REQUEST NO. 2: On page 3, line 26, Mr. Gilliam states, "The actions and changes proposed by IPCO in this case are individually and collectively designed to make customer-sited generation more difficult to install or more expensive to utilize, or both." Does the City of Boise possess any statement from the Company regarding the intent of this filing as being designed to accomplish the objective of making "customer- sited generation more difficult to install or more expensive to utilize, or both?" REQUEST NO. 3: On page 24,line 10, Mr. Gilliam states, "A number of studies have been performed around the country which compare the benefits provided by distributed solar generation behind the meter with the costs incurred by the host utility. ln virtually all cases, the benefits have exceeded the costs." Please provide the studies referenced by Mr. Gilliam that substantiate this claim. REQUEST NO. 4: On page 26, line 4, Mr. Gilliam states, "lf the benefits here in ldaho are at all similar to those determined in other jurisdictions, it means that lPCo's current retail rates are Iikely a fair approximation of the value of distributed generation, and potentially under-compensating solar system owners. More specifically, it means that any perceived cost shift from solar adopters to non-solar customers is more than compensated by the benefits of adding new incrementa! energy sources with the attributes derived from solar energy." Has the City of Boise performed any analysis to IDAHO POWER COMPANY'S FIRST PRODUCTION REQUEST TO THE CITY OF BOISE - 2 substantiate this claim, or the applicability of Mr. Gilliam's statement to ldaho Powe/s service area? lf so, please provide this analysis. REQUEST NO. 5: On page 27,line 2, Mr. Gilliam states, "lf IPCO's proposals are approved, current net-metering customers will be paying substantially more than they had planned." Please provide any analysis performed to substantiate this claim. DATED at Boise, ldaho, this 20th day of May 2013. IDAHO POWER COMPANY'S FIRST PRODUCTION REQUEST TO THE CITY OF BOISE - 3 Attorney for Idaho Power Company CERTIFICATE OF SERVICE ! HEREBY CERTIFY that on this 20th day of May 2013 I served a true and correct copy of IDAHO POWER COMPANY'S FIRST PRODUCTION REQUEST TO THE CITY OF BOISE upon the following named parties by the method indicated below, and addressed to the following: Gommission Staff Hand Delivered Karl T. Klein Deputy Attomey General ldaho Public Utilities Commission 47 2 W est Washi ngton (83702 ) P.O. Box 83720 Boise, ldaho 83720-007 4 ldaho Conservation League Benjamin J. Otto ldaho Conservation League 710 North Sixth Street (83702) P.O. Box 844 Boise, ldaho 83701 PowerWorks LLG Chris Aepelbacher, Project Engineer PoweMorks LLC 5420 West Wicher Road Glenns Ferry, ldaho 83623 Pioneer Power, LLG Peter J. Richardson RICHARDSON & O'LEARY, PLLC 515 North 27th Street (83702) P.O. Box 7218 Boise, ldaho 83707 John Steiner 24597 Collett Road Oreana, ldaho 83650-5070 IDAHO POWER COMPANY'S FIRST PRODUCTION REQUEST TO THE CIry OF BOISE - 4 U.S. Mail Overnight Mail FAXX Email Karl.Klein@puc.idaho.qov Hand Delivered U.S. Mai! Overnight Mail FAXX Email botto@idahoconservation.orq Hand Delivered U.S. Mai! Overnight Mail FAXX Email ca@powenruorks.com Hand Delivered U.S. Mail Overnight Mail FAXX Email peter@richardsonandolearv.com Hand Delivered U.S. Mail Overnight Mail FAXX Email isteiner@rtci.net City of Boise R. Stephen Rutherford Chief Deputy City Attorney Boise City Attorney's Office 150 North Capital Boulevard P.O. Box 500 Boise, ldaho 83701 -0500 John R. Hammond, Jr. BATT FISHER PUSCH & ALDERMAN, LLP U.S. Bank Plaza, Tth Floor 101 South Capitol Boulevard, Suite 701 P.O. Box 1308 Boise, ldaho 83701 ldaho Clean Energy Association lnc. Dean J. Miller McDEVITT & MILLER LLP 420 West Bannock Street (83702) P.O. Box 2564 Boise, ldaho 83701 Board of Directors ldaho Clean Energy Association !nc. P.O. Box 1212 Boise, ldaho 83701 Snake River Alliance Ken Miller, Clean Energy Program Director Snake River Alliance P.O. Box 1731 Boise, ldaho 83701 IDAHO POWER COMPANY'S FIRST PRODUCTION REQUEST TO THE CITY OF BOISE - 5 Hand Delivered U.S. Mail Overnight Mail FAXX Email BoiseCitvAttornev@citvofboise.orq Hand Delivered U.S. Mail Overnight Mail FAXX Email irh@battfisher.com Hand Delivered U.S. Mail Overnight Mail FAXX Email ioe@mcdevitt-miller.com _Hand DeliveredX U.S. Mail _Overnight Mail _FAX Email Hand Delivered U.S. Mail Overnight Mail FAX Email kmiller@snakeriveralliance.orq