20160727Staff 1-22 to IPC.pdf

DAPHNE HUANG
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 8370
Street Address for Express Mail:
472W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION TO APPROVE
NEW TARIFF SCHEDULE 63, A COMMUNITY
SOLAR PILOT PROGRAM.
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E.16-14
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
IDAHO POWER
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Daphne Huang, Deputy Attorney General, request that Idaho Power Company (Idaho Power or
Company) provide the following documents and information as soon as possible, by TUESDAY,
AUGUST 16,2016.
This Production Request is continuing, and Idaho Power is requested to provide, by way
of supplementary responses, additional documents that it or any person acting on its behalf may
later obtain that will augment the documents produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations. Idaho Power is reminded that responses pursuant
to Commission Rules of Procedure must include the name and phone number of the
person preparing the document, and the name, location and phone number of the record holder
and if different the witness who can sponsor the answer at hearing if need be. IDAPA
31.0r.0t.228.
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY JULY 27,2016
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. 1: The Company proposes to charge the same per-panel subscription
fee to community solar project subscribers from each class. Please explain the Company's
rationale for crediting each class at a different rate.
REQUEST NO. 2: Please provide manufacturers' data sheets for the specific
panels/modules that Idaho Power plans to use for this project.
REQUEST NO. 3: In its Application, the Company states that it plans to offer a total of
1,563 subscriptions, and that project costs were based on an 1,800 panel Request for Bid (RIB).
Please explain why 1,563 subscriptions will be offered when project costs were based on an
1,800 panel RFB.
REQUEST NO. 4: If it becomes necessary to use a different panel, please describe how
Idaho Power would re-compute the subscription fee and credit rate.
REQUEST NO. 5: Please provide a breakdown of the specific costs and a description of
the work for labor costs included in the Company's $8,000/annum Operations and Maintenance
Estimate.
REQUEST NO. 6: Please provide a description of the work activities included in the
Company's 0.5 employee estimate of Administrative expenses.
REQUEST NO. 7: In the event of unexpected, or catastrophic damage, please describe
how repairs would be funded.
REQUEST NO. 8: The Company estimates a25-year project life; however, the
manufacturers only warrant major equipment items (inverters and solar panels) for 12 years.
Please describe how major repairs will be funded during the remaining 13 years.
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 2 JULY 27,2016
REQUEST NO. 9: The Company proposes that when participants move outside the
Company's service area, and do not request a subscription transfer, the subscription will revert to
Idaho Power. Please describe how Idaho Power plans to book the value of credits obtained from
such subscriptions.
REQUEST NO. 10: Please provide the RFB the Company issued for the community
solar project.
REQUEST NO. 11: Will customers be able to register and pay for community solar
subscriptions electronically using myAccount in addition to paper application and check? If not,
please explain why not.
REQUEST NO. 12: Will customers be able to transfer their community solar
subscriptions electronically, using myAccount, rather than "in writing"? If not, please explain
why not.
REQUEST NO. 13: Please provide all community solar program literature and best
practices Idaho Power used to develop its proposal, including the bill credits and subscription
structure.
REQUEST NO. 14: Did Idaho Power discuss the possibility of a large commercial or
industrial customer committing to subscribe to the remaining program capacity if the program
was not fully subscribed within 120 days? If so, please explain why this possibility was not
included in the program design.
REQUEST NO. 15: Page20 of Mr. Larkin's Direct Testimony indicates that the
participant's share of the monthly output from the solar array will be applied as a kWh credit
towards billed kWh subject to the annual Power Cost Adjustment rate (PCA). Please explain
why a participant's share of the monthly output will not be applied as a kWh credit towards
billed kWh subject to the Fixed Cost Adjustment (FCA).
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY JULY 27,20T6
REQUEST NO. 16: Page 15 of Mr. Larkin's Direct Testimony states the Company
proposes to apply the participant's share of the monthly output as a kWh credit toward billed
kWh subject to the annual PCA rate. However, Exhibit No. 4 to Mr. Pengilly's Direct
Testimony does not show that this credit has been applied. Does the Company plan to credit the
monthly energy production per subscription multiplied by the PCA rate? If not, please explain
how such a credit will be applied.
REQUEST NO. 17: In the Company's most recent FCA filing (IPC-E-l6-02), Idaho
Power's Regulatory Analyst, Zachary Harris, calculates in Exhibit No. 2 the fixed cost per
Customer at $650.63 with 418,682.43 residential customers, for a total authorized recovery
amount of $272,407,352. The remaining$239,660p82 ($512,068,335-$272,407,352) represents
the variable energy portion of the average residential rate. This figure, when divided by the
4,977,176 MWh of residential sales confirms the variable energy portion of rates at
$0.0482/kwh. Please explain why the Company chose the adjusted embedded energy-related
cost and not the energy portion of rates calculated through the 2016 FCA Mechanism, to be the
Solar Energy Credit.
REQUEST NO. 18: At the current $740 subscription rate, the Company would collect
$808,820 (1093 residential subscriptions x $740 per subscription) in upfront subscription fees
from residential participants, and would credit $527,289 (1093 subscriptions x $0.030246 x 638
kWh/subscription-year x 25 years) back to residential participants at the proposed Solar Energy
Credit. Given the current pricing structure, please provide any information showing residential
customers' willingness to invest in the community solar project at an intemal rate of return of -
3.0%.
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY JULY 27,2016
REQUEST NO. 19: Page 4 of Mr. Pengilly's Direct Testimony explains that the
Company intends to treat this initial offering as a pilot program so the Company can learn about
the complexities associated with offering community solar programs, including customer
commitment, construction, contracting, interconnection, maintenance and billing. However,
page 18 of Mr. Larkin's Direct Testimony states that the Company will not track the differences
between estimated and actual costs through the life of the program. Given the Company's stated
learning objectives, please provide a rationale for not tracking the differences between estimated
costs embedded in the upfront subscription fee and actual costs incurred throughout the life of
the program.
REQUEST NO. 20: Please estimate the project's deferred transmission and distribution
costs in cents-per-kWh. Please provide an executable workbook showing all calculations used to
produce the estimates.
REQUEST NO. 21: Please estimate the yearly cost shift that would occur to non-
participants, the Company, or shareholders if the Solar Energy Credit would be set at the full
retail rate for energy. Please include the breakeven point in years for participants if they were to
be credited at the full retail rate of electricity. Please provide an executable workbook with links
enabled showing all calculations used to produce the estimate.
REQUEST NO. 22: Page 8 of Mr. Pengilly's Direct Testimony states that Idaho Power
visited the neighborhood near the location of the proposed array, including 13 residences and one
business, Additionally, Mr. Pengilly states that the Company circulated information to the
neighborhoods adjacent to the project through personal hand-delivered letters or their respective
homeowners associations. How many letters were delivered during this process? If possible,
please provide the number of total households, median household income, and total businesses
within a one-mile radius of the proposed location. Please describe the Company's plan for
marketing the program if the program is approved
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY JULY 27,2016
Dated at Boise, Idaho, this Z7 )\day of July 2016.
Technical Staff: Mike Morrison (1-10)
Stacey Donohue (11-16)
Johnathan Farley (17)
Mark Rogers (1,8-24)
i:umisc:prodreq/ipoel6. l4djhsdmrmmdejf prod reql
Daphne Huang
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY JULY 27,2016
CERTIFICATE OF SERYICE
I HEREBY CERTIFY THAT I HAVE THIS 27Ih DAY OF JULY 2016,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY IN CASE NO. IPC.E.I6.I4,
BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
LISA D NORDSTROM
REGULATORY DOCKETS
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-mail : [e-mail]
dockets@ idahopower. com
PETER J RICHARDSON
GREGORY M ADAMS
RICHARDSON ADAMS PLLC
PO BOX 7218
BOISE TD 83702
E-mail : [e-mail]
sre sfari chardsonadams. com
MATT LARKIN
PETER PENGILLY
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-mail : [e-mail]
[e-mail]
DR DON READING
6070 HILL ROAD
BOISE ID 83703
E-mail: [e-mail]
CERTIFICATE OF SERVICE