20160705ICL 1-19 to IPC.pdf

i{ECEIVED
Benjamin I. Otto (ISB No. 8292)
710 N 6m Street
Boise,ID 83701
Ph: [phone] x12
Fax [phone]
[e-mail]
Attorneyfor the Idaho Conservation League
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER ) CASE NO. IPC-E-16-14
COMPANY'S APPLICATION FOR )
APPROVAL OF NEW TARIFF ) FIRST PRODUCTION RTQUEST OF
SCHEDLTLE 63, A COMMUNTTY ) THE IDAHO CONSERVATTON
SOLAR PILOT PROGRAM. ) LEAGUE
The Idaho Conservation League (ICL) and the Sierra Club requests the following
information from Idaho Power. Please provide any documents, workpapers, calculations, or
information sources that support any answer. 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. This production request is
ongoing. Accordingly, we ask Idaho Power to provide additional documents and information
that may supplement any initial responses.
Larkin Testimony
Request No. 1: Please provide a complete copy of the "most recently reviewed class cost-of-
service methodology filed in Case No IPC-E-11-08, adjusted to reflect revenue requirement
changes that were subsequently authorized by the Commission which impact the authorized level
of energy related cost recovery" referred to on Page 12 of Mr. Larkin's direct testimony.
Request No. 2: For the "revenue requirement changes [to the IPC-E-11-08 class cost-of-service
study] that were subsequently authorized by the Commission" referred to on page 12 of Mr.
Larkin's direct testimony, please identiff each subsequent adjustment and the associated
Commission order approving such change.
Request No. 3: Please refer to page 12 of Mr. Larkin's direct testimony referencing the point of
measurement as the "generator source". Please provide a precise definition of where the power
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FIRST PRODUCTION REQUEST OF ICL I |uly 5, 2016
production will be measured relative to the power project and any associated transformers or
substation interconnection points.
Request No. 4: Please refer to Exhibit No. 2 of Mr. Larkin's direct testimony. Please provide the
associated workbooks, formulas, and sources for input assumptions used in that analysis.
Request No. 5: Please refer to page 15 of Mr. Larkin's direct testimony where he explains the
"year-round [solar energy credit] rates were appropriately adjusted to reflect the summer/non-
summer weighting of solar production." Please provide all documentation of this appropriate
adjustment, including both the methodology and the data.
Request No. 6: Please refer to page 14 of Mr. Larkin's direct testimony where he explains Idaho
Power's proposed Solar Energy Credit "will be reflective of the seasonal differences in the cost of
energy" but the actual rate will not adjust seasonally. Please explain how, under this proposal,
subscribers will see the seasonal differences in the cost of energy on their monthly electric bill.
Request No 7: Please refer to Mr. Larkin's Direct Testimony at pages 10 - 11.
a. Please describe in detail the monthly payment option considered by Idaho Power.
b. Please provide all analysis quantifring the "financial risk for non-participants and the
Company would be too great under the monthly payment option if panels went
unsubscribed throughout the life of the program."
Request No. 8: Please refer to Mr. Larkin's Direct Testimony at page 11, where he states "if there
is interest by a third-party lender, the Companywill make this offering known to prospective
subscribers during the recruitment period."
a. Please define what the Company means by "interest by a third-party lender". Does this
mean the financial institution has a specific product, or is merely willing to talk with a
subscriber?
b. B. Please define what the Company means by "make known to prospective subscribers".
Does the Company intend to include financing options in the marketing materials, or
separately?
Request No. 9: Please refer to Mr. Larkin's Direct Testimony at 12 regarding using embedded
energy related costs as the basis of the solar energy credit. Please provide any analytical or poliry
FIRST PRODUCTION REQUEST OF ICL 2 luly 5,2016
basis relied on to assign embedded energy related costs as the appropriate means of valuing
power produced from the project.
Request No. l0: Please refer to Mr. Larkin's Direct Testimony at 18 where he states "participation
through a Company-sponsored renewable energy program provides for better consumer
protection through Idaho Power' s regulated business practices as compared to third-party
installations or leasing of rooftop solar installations." Please provide all objective evidence or
analysis relied on by Mr. Larkin to make this claim.
Angell Testimony
Request No. 11: Please refer to Mr. Angell's Direct Testimony at2 regarding the selection process
and categories for candidate sites. Please provide the specific criteria used as the basis for site
selection, including "current infrastructure" considerations used.
Request No. 12: Please refer to Mr. Angell's Direct Testimony at 9 - 10 where he explains how the
Company calculated the expected production of the pilot solar project.
a. Please explain why the Company used the "Tlpical Meteorological Year 3" instead of the
Idaho Power's solar generation profile developed for the 2016 Solar Integration Study.
b. Please provide a comparison of expected project output using the Typical Meteorological
Year 3 and the solar generation profile developed for the 2016 Solar Integration Study.
Request No. 13: Please refer to Mr. Angell's Direct Testimony at 11, regarding line loss
accounting. Please provide all analysis of effects on transmission and distribution system line
loadings for candidate locations.
Request No. 14: Please refer to Mr. Angell's Direct Testimony at 11 regarding line loss
accounting. Please provide all analytical support for line losses deriving from delivery to
community solar subscribers.
Request No. 15: Please refer to Mr. Angell's Direct Testimony at 11 regarding line loss
accounting. Please provide any analysis relied on to quantifr and value losses accruing from
transmission, substation, and primary distribution line system components.
FIRST PRODUCTION REQUEST OF ICL 3 fuly 5, 2016
Request No. 16: Please refer to Mr. Angell's Direct Testimony at 11 regarding line loss
accounting. Please provide any accounting of how offset transmission, substation, and primary
distribution line losses are credited to community solar subscribers.
Pengilly Testimony
Request No. l7: Please refer to Mr. Pengilly's Direct Testimony at l1 regarding Idaho Power
ownership of RECs and carbon emission reduction credits. Please provide any analysis, poliry
objectives, or computation of Idaho Power benefits supporting ownership of RECs and carbon
emission credits.
Request No. 18: Please refer to Mr. Pengilly's_Direct Testimony at 10-11 regarding the $25
transfer fee. Please provide any analysis relied on to establish a cost basis for the proposed fee.
Request No. 19: Please refer to Mr. Pengilly's Direct Testimony at 12-13 regarding "learning
objective" benefits. Please provide any analysis of the value of such benefits and any estimates of
the expected reductions in production from the facility from providing voltage control services to
Idaho Power.
DATED this 5'h day of luly 2016.
Respectfully submitted,
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Benjamin I. Otto
Idaho Conservation League
CERTIFICATE OF SERVICE
certifr that on this 5th day of fuly, 2016,I delivered true and correct
copies of the foiegoing FIRST PRODUCTION REQUEST to the following persons:
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Hand delivery:
Jean Iewell
Commission Secretary (Original and 3
copies provided)
Idaho Public Utilities Commission
427 W. Washington St.
Boise, lD 83702-5983
Electronic Mail:
Lisa D Nordstrom
Matt Larkin
Peter Pengilly
Idaho Power Company
1221 West Idaho St
PO Box 70
Boise, ID 83707
[e-mail]
dockets@idahopower. com
mlarkin@idahopower. com
ppen [e-mail]
FIRST PRODUCTION REQUEST OF ICL 4 luly 5,2016