20130607ICEA to IPC 2-5.pdf

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Chas.F.McDevitt
Dean J.(Joe)Miller
Celeste K.Miller
Via Hand Delivery
Jean Jeweli,Secretary
Idaho Public Utilities Comnilssion
472 W.Washington St.
Boise,Idaho 83720
June 7,2013
Re:Case No.IPC-E-12-27
Idaho Clean Energy Association Inc.
Dear Ms.Jewell:
Enclosed for filing in the above matter,please find three (3)copies of Idaho Clean Energy
Association Inc’s Response to the Second Production Request of Idaho Power Company.
Kindly return a file stamped copy to me.
DJM/hh
Enclosures
McDevitt &Miller LLP
LUL
J.Miller
Very Truly Yours,
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Dean J.Miller (ISB No.196$)RECJVf)
Chas.F.McDevift (ISB No.$35)
Celeste K.Miller (ISB No.2590)?fl1]]U —?Ph 12:59
McDEVITT &MILLER LLP
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Attorneyfor Idaho Clean Energy Association Inc.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER Of THE Case No.IPC-E-12-27
APPLICATION Of IDAHO POWER
COMPANY FOR AUTHORITY TO IDAHO CLEAN ENERGY
MODIFY ITS NET METERING ASSOCIATION’S RESPONSE TO THE
SERVICE AND TO INCREASE THE SECOND PRODUCTION REQUEST
GENERATION CAPACITY LIMIT OF IDAHO POWER COMPANY
In response to the Second Production Request of Idaho Power Company (“the
Company”)to the Idaho Clean Energy Association (“ICEA”)dated May 20,2013,ICEA
herewith submits the following:
REQUEST NO.2:Please provide a list of Idaho Clean Energy Association’s
current members as referenced in Mr.Elgethun’s Direct Testimony at page 2,line 19.
RESPONSE TO REQtJEST NO.2:Pursuant to an exchange of email
correspondence between counsel for IECA and counsel for the Company,this request has
been withdrawn.
REQUEST NO.3:On page 2,lines 3 through 5,Mr.Dunay states that benefits
of net metered solar energy systems include “...providing peak power,reducing the need
for new infrastructure (transmission lines and power plants)and making Idaho’s electrical
ifiAHO CLEAN ENERGY ASSOCIATION’S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF IDAHO POWER COMPANY—i
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;:
grid more efficient.”Please provide any analysis that served as the basis for this
statement.
RESPONSE TO REQUEST NO.3:The benefits of solar energy and my
analysis can be confirmed by the following documents:
Page 49 of 2012 Idaho Energy Plan:
“Though solar is an intermittent resource,its intermittency is consistent,and in
general its production potential lines up well with high demand (mid-day).As
control systems continue to improve,there is good likelihood for solar to play an
important role.”
•PagelOof2OllIRP:
“While solar technology continues to be more expensive than other alternatives,
the cost of solar resources continues to decrease while the cost of most other
resource options has increased.In addition to providing RECs,solar resources
typically deliver energy during the time of day when Idaho Power’s customer
demand is high.”
•Page 9 of 2009 IRP:
“In addition to providing RECS,solar resources provide the benefit of delivering
energy during the time of day when Idaho Power’s customer demand is peaking.”
•Page 3-2 of September 2008 “So]ar Generation Technology Assessment”,
performed for Idaho Power by Black &Veatch Corp.:
“Power generation from direct solar energy collection is well correlated with peak
energy demand.”
IDAHO CLEAN ENERGY ASSOCIATION’S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF IDAHO POWER COMPANY—2
•Page 3-7 of Black &Veatch Study:
“Peak energy times tend to be on hot summer afternoons,which are highly
correlated with solar radiation.”
•Idaho Power Sees Brighter Future with Solar Energy—Times-News By
Kimberlee Kruesi
“Solar energy is really unlike wind or natural gas.Unlike wind,our peak energy-
use days are on our hottest days when the wind isn’t blowing.Solar panels could
be critical for adding energy when the wind can’t.”—Mark Stokes,Idaho Power.
•Idaho Power Plans to Build Solar Power Plant—Associated Press August
10th 2011
“The shape of solar’s load has a lot more value to us”—Mark Stokes,Idaho
Power.
REQUEST NO.4:On page 3,line 11,Mr.Dunay states,“Based on my own
analysis,submitted comments and discussions with the public,I believe these proposed
rate requests will have a dramatic declining effect on the amount of installed solar energy
systems.”Please provide Mr.Dunay’s analysis referenced in this statement.
RESPONSE TO REQUEST NO.4:Case IPC-E-l2-27 proposes to increases
monthly fees for net metering customers and to devalue the electricity placed back on the
grid.These requests would penalize current net metering customers and reduce the
financial benefits of new solar energy systems.By reducing the benefits of investing in
solar,the application reduces demand for new systems from what it would otherwise be
in the absence of these changes.
IDAHO CLEM ENERGY ASSOCIATION’S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF IDAHO POWER COMPANY—3
REQUEST NO.5:On page 3,line 15,Mr.Dunay states,They are paying for
the infrastructure to connect their homes and businesses to the grid through the current
fixed fees charged by the Company.”Please provide any analysis performed that
indicates that current fixed fees charged by the Company “{payJ for the infrastructure to
connect”these homes and businesses to the Company’s electrical system.
RESPONSE TO REQUEST NO.5:The Company does not have to improve or
increase the existing infrastructure to accommodate net metering customers.Regardless
of whether the customer is a net metering customer or a standard rate-payer,the electrical
infrastructure remains the same.
The response to this request was prepared by Matthew Dunay in consultation with
Dean J.Miller.
DATED this 4 day of June,2013.
IDAHO CLEAN ENERGY ASSOQATION INC.
By:_________
Dean J.Miller
Attorneyfor Idaho Clean Energy Association Inc.
IDAHO CLEAN ENERGY ASSOCIATION’S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF IDAHO POWER COMPANY—4
CERTIFICATE OF SERVICE
I hereby certify that on the day of June,2013,I caused to be served,via the
method(s)indicated below,true and correct copies of the foregoing document,upon:
Jean Jewell,Secretary Hand Delivered
Idaho Public Utilities Commission U.S.Mail
472 West Washington Street fax
P.O.Box $3720 fed.Express
Boise,ID 83720-0074 Email
[e-mail]
Karl Klein,Deputy Attorney General Hand Delivered
Idaho Public Utilities Commission U.S.Mail J
472 West Washington Street Fax J
P.O.Box 83720 fed.Express
Boise,ID 83720-0074 Email
[e-mail]
Lisa D.Nordstrom Hand Delivered
Maft Larkin U.S.Mail J
Greg Said Fax J
Idaho Power Company fed.Express J
1221 West Idaho Street (83702)Email
P.O.Box 70
Boise,Idaho $3707
[e-mail]
[e-mail]
[e-mail]
gsaid(2idahopower.com
Benjamin J.Otto Hand Delivered J
710N.6thStreet U.S.Mail J
Boise,Idaho 83701 Fax J
botto(idahoconservation.org Fed.Express Li
Email
Peter J.Richardson Hand Delivered
Richardson &O’Leary,PLLC U.S.Mail
P0 Box 7218 fax J
Boise,ID 83702 fed.Express
[e-mail] Email
IDAHO CLEAN ENERGY ASSOCIATION’S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF IDAHO POWER COMPANY—5
Chris Aepelbacher,Project Engineer Hand Delivered
5420 W.Wincher Road U.S.Mail
Glemis Ferry Idaho 83623 Fax
[e-mail] Fed.Express
Email
R.Stephen Rutherford Hand Delivered
Boise City Attorney’s Office U.S.Mail
150 N.Capital Blvd.Fax
P.O.Box 500 Fed.Express
Boise,Idaho 83701-0500 Email
BoiseCityAttomeytcitvofboise.org
John R.Hammond,Jr.Hand Delivered Li
Batt Fisher Pusch &Alderman,LLP U.S.Mail J
U.S.Bank Plaza7th1 Floor Fax J
101 S.Capital Blvd.,Suite 701 Fed.Express
P.O.Box 1308 Email
Boise,Idaho 83701
[e-mail]
Ken Miller,Clean Energy Director Hand Delivered
Snake River Alliance U.S.Mail
P.O.Box 1731 Fax
Boise,Idaho 83701 Fed.Express
kmiller(snakeriveralliance.org Email
BY:_________
McDEvITT &ILLER LLP
IDAHO CLEAN ENERGY ASSOCIATION’S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF IDAHO POWER COMPANY—6