20160816IPC to Staff 1-22.pdf

LISA D. NORDSTROM
Lead Counsel
[e-mail]
August 16, 2016
VIA HAND DELIVERY
Jean D. Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington Street
Boise, Idaho 83702
Re: Case No. IPC-E-16-14
An IDACORP company
New Tariff Schedule 63, A Community Solar Pilot Program
Idaho Power Company's Response to the First Production Request of the
Idaho Public Utilities Commission Staff
Dear Ms. Jewell:
Enclosed for filing in the above matter please find an original and three (3) copies of
Idaho Power Company's Response to the First Production Request of the Idaho Public
Utilities Commission Staff ("Staff'').
Also enclosed are four ( 4) copies each of non-confidential and confidential disks
containing information responsive to Staff's production requests. Please handle the
confidential information in accordance with the Protective Agreement executed in this
matter.
LDN:kkt
Enclosures
Very truly yours,
~1)'1_~
Lisa D. Nordstrom
LISA D. NORDSTROM (ISB No. 5733)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
[e-mail]
Attorney for Idaho Power Company
20!fi ; .. ~G 16 PM 2: 15
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
)
IN THE MATTER OF IDAHO POWER )
COMPANY'S APPLICATION TO APPROVE )
NEW TARIFF SCHEDULE 63, A )
COMMUNITY SOLAR PILOT PROGRAM. )
)
)
_______________ )
CASE NO. IPC-E-16-14
IDAHO POWER COMPANY'S
RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
THE COMMISSION STAFF
COMES NOW, Idaho Power Company ("Idaho Power" or "Company"), and in
response to the First Production Request of the Commission Staff to Idaho Power
Company dated July 27, 2016, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF -1
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.
RESPONSE TO REQUEST NO. 1: As described on page 12 of Mr. Larkin's
direct testimony, the proposed solar energy credit is based upon the Company's
embedded energy-related costs as determined by the most recently reviewed class
cost-of-service methodology filed in Case No. IPC-E-11-08 ("2011 Idaho GRC"),
adjusted to reflect revenue requirement changes that were subsequently authorized by
the Idaho Public Utilities Commission ("Commission") which impact the authorized level
of energy-related cost recovery. Each customer class utilizes Idaho Power's system in
a different way and the class cost-of-service study identifies and allocates costs based
on each class' usage characteristics.
If Idaho Power were to credit each class at the same rate, it would incorrectly
assume that each class utilized the system in the same manner.
The response to this Request is sponsored by Matt Larkin, Revenue
Requirement Manager, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 2
REQUEST NO. 2: Please provide manufacturers' data sheets for the specific
panels/modules that Idaho Power plans to use for this project.
RESPONSE TO REQUEST NO. 2: Please see the data sheet provided on the
nonconfidential CD.
The response to this Request is sponsored by David Angell, Customer
Operations Planning Manager, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF -3
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 (RFB). Please explain why 1,563 subscriptions will be offered when
project costs were based on an 1,800 panel RFB.
RESPONSE TO REQUEST NO. 3: There are two reasons for the difference in
the number of panels and subscriptions. The first pertains to the electrical losses. The
Company's RFB was for a 500 kilowatt ("kW") alternating current ("AC") solar array.
Because the energy produced by a solar panel is in the form of direct current ("DC") and
the energy that flows through Idaho Power's system is in the form of AC, the electricity
has to be converted from DC to AC which results in a loss of electricity during the
conversion.
The second is based on the economics of solar plant design. Solar plants are
typically designed with the DC capacity exceeding the AC capacity plus DC system and
inverter losses. Such a design makes use of the increased energy production during the
sun shoulder hours (hours of sunlight before and after solar peak). The successful
bidder determined that the 1,800, 320-watt panels would provide the required 500 kW
AC capacity and optimize the annual energy production for their proposed bid cost.
Idaho Power determined that the number of subscriptions should match the AC capacity
rather than the actual number of solar panels.
The response to this Request is sponsored by David Angell, Customer
Operations Planning Manager, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF -4
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.
RESPONSE TO REQUEST NO. 4: If it becomes necessary to use a different
panel, the Company would request revised cost and panel information from the
successful bidder. The revised cost information would be run through the model
provided as Exhibit 2 to Mr. Larkin's testimony, and if the size of the panel were to
change, then the number of available subscriptions would be recalculated based on the
new panel size. The number of available subscriptions is used as the denominator in
calculating the subscription cost in Exhibit 2. The use of a different panel would not
impact the credit rate for the reasons discussed in response to Request No. 1.
The response to this Request is sponsored by Matt Larkin, Revenue
Requirement Manager, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 5
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.
RESPONSE TO REQUEST NO. 5: The estimated cost of $8,000/annum from
the Operations and Maintenance Estimate was taken from the Contractor's bid. Please
refer to page 4 of Attachment 1, Creative Energies' response to Idaho Power's request
for bid, provided on the nonconfidential CD. For a complete description of work and
labor values please see Attachment 2, Creative Energies' Operation and Maintenance
Plan, provided on the nonconfidential CD.
The response to this Request is sponsored by David Angell, Customer
Operations Planning Manager, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF -6
REQUEST NO. 6: Please provide a description of the work activities included in
the Company's 0.5 employee estimate of Administrative expenses.
RESPONSE TO REQUEST NO. 6: The administrative support for the
Community Solar Pilot Program ("Program) will include monitoring and evaluating
Program progress, customer service support with customer agreements, enrollments,
and transfers. The following tasks may be spread among multiple departments and
staff:
Monitoring and Evaluation
• Reporting on enrollment mechanisms: time to subscribe, customer
demographics, marketing results
• Developing construction contracts and monitoring contract deliverables
• Tracking participation and transfers
• Tracking and verification of system output, and allocation among subscribers
• Evaluating participant satisfaction
• Tracking financial variables and budget management
Customer Service Support
• Answering customer questions about the Program and application process
• Marketing the Program including development and implementation of marketing
tactics
• Promoting the Program to customer groups (presentations, meetings)
• Training customer-facing employees
• Processing applications (confirming eligibility, processing payments)
• Processing transfers (confirming eligibility, processing transfers)
• Participant communications (yearly communications and updates)
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 7
• Ongoing employee training
• Addressing ongoing customer issues (billing questions, customer inquiries,
transfers)
The response to this Request is sponsored by Pete Pengilly, Customer Research
and Analysis Leader, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF -8
REQUEST NO. 7: In the event of unexpected, or catastrophic damage, please
describe how repairs would be funded.
RESPONSE TO REQUEST NO. 7: Idaho Power has a large deductible/retention
on its property insurance program of $1,000,000. Therefore, Idaho Power would be
self-insuring the exposure up to this amount. If this project were to experience a loss
above $1,000,000, the Company's insurance would cover the additional amount.
The response to this Request is sponsored by Timothy Tucker,
Property/Casualty Insurance Administrator Audit, Compliance & Security, Idaho Power
Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF -9
REQUEST NO. 8: The Company estimates a 25-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.
RESPONSE TO REQUEST NO. 8: Hanwha Q Cells Co., the manufacturer of
the solar photovoltaic modules, provides a Performance Warranty for 25 years. The
details of the performance warranty can be found on page 2 of the manufacturer's data
sheet provided in response to Request No. 2.
The Operations and Maintenance estimate is envisioned to fund any potential
major repairs to the array not covered under the manufacturer's warranty.
The response to this Request is sponsored by Pete Pengilly, Customer
Research and Analysis Leader, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF -10
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.
RESPONSE TO REQUEST NO. 9: If a subscription were to revert to Idaho
Power, the unsubscribed energy would be assigned zero cost and serve customer loads
or sold as surplus energy to the benefit of all Idaho Power customers.
The response to this Request is sponsored by Matt Larkin, Revenue
Requirement Manager, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF -11
REQUEST NO. 10: Please provide the RFB the Company issued for the
community solar project.
RESPONSE TO REQUEST NO. 10: Please see the RFB and supporting bid
documents provided as confidential Attachments 1-6 on the confidential CD. The
confidential attachments will only be provided to those parties that have executed the
Protective Agreement in this matter.
The response to this Request is sponsored by Pete Pengilly, Customer Research
and Analysis Leader, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF -12
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.
RESPONSE TO REQUEST NO. 11: Idaho Power is currently exploring
electronic registration and payment options that customers can use to participate in the
Program.
The response to this Request is sponsored by Pete Pengilly, Customer Research
and Analysis Leader, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF -13
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.
RESPONSE TO REQUEST NO. 12: No. The transfer of subscriptions would be
a complex manual transaction involving two or more accounts and customers of record.
Due to the complexity of this process and potential cost, the Company determined that
the electronic transfer of subscriptions is not a feasible option.
The response to this Request is sponsored by Pete Pengilly, Customer Research
and Analysis Leader, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF -14
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.
RESPONSE TO REQUEST NO. 13: The Company used the resources listed
below:
"Solar Electric Power Association Community Solar Handbook: Utility, Private, and Non­
profit Project Development": http://www.solarelectricpower.org/media/71959/solarops­
community-solar-handbook.pdf
• "A Guide to Community Solar": http://www.nrel.gov/docs/fy11 osti/49930.pdf
• Flathead Electric: http://www.flatheadelectric.com/energy/sun/sun.html
• Missoula Electric Cooperative:
http://missoulaelectric.com/0ur%20Community%20Solar%20Program
Idaho Power researched other utility offerings in designing its Program. Please
see the 2015 research provided as Attachment 1 and the Environmental Protection
Agency webinar from March 9, 2016, provided as Attachment 2 on the nonconfidential
CD.
• Utilities consulted were:
o Avista
o Flathead Electric
o Missoula Electric Cooperative
o Rocky Mountain Power
The response to this Request is sponsored by Pete Pengilly, Customer Research
and Analysis Leader, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF -15
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.
RESPONSE TO REQUEST NO. 14: The Company did 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. Although the Company did
not single out this issue in the filing, the provisions within the enrollment phase, as
discussed in Mr. Pete Pengilly's testimony, would still allow for this scenario to occur.
As discussed on page 10 of Mr. Pengilly's testimony, "the first 60 days of the initial
enrollment window will reserve 70 percent of the project for residential customers and
30 percent for non-residential customers. After the 60-day timeframe, if there is
unsubscribed capacity that was reserved for residential customers it may be opened up
to non-residential customers and vice versa."
The response to this Request is sponsored by Pete Pengilly, Customer Research
and Analysis Leader, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF -16
REQUEST NO. 15: Page 20 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 kilowatts ("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).
RESPONSE TO REQUEST NO. 15: It is the intent of the kWh credit to provide
participating customers an opportunity to offset the embedded variable cost of providing
service and not the embedded fixed costs recovered through the FCA.
The response to this Request is sponsored by Matt Larkin, Revenue
Requirement Manager, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF -17
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.
RESPONSE TO REQUEST NO. 16: The PCA portion of a participant's monthly
bill will be calculated by subtracting solar energy production from total gross usage,
multiplied by the PCA rate. Please see the spreadsheet containing a sample bill
calculation, assuming total gross consumption of 1,008 kWh and solar energy
production of 55 kWh provided on the nonconfidential CD.
The response to this Request is sponsored by Pete Pengilly, Customer Research
and Analysis Leader, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF -18
REQUEST NO. 17: In the Company's most recent FCA filing (IPC-E-16-02),
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 $239,660,982
($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.
RESPONSE TO REQUEST NO. 17: The class cost-of-service study from the
2011 Idaho GRC used to determine the proposed Solar Energy Credit in this case is the
same study used to determine the energy/fixed components of the Company's retail
rates within the FCA mechanism. However, there are a number of reasons why the
calculation detailed above results in a variable energy rate that differs from the
proposed Solar Energy Credit in the Company's filing.
First, the $272,407,352 used in the calculation above is the result of applying the
currently-approved Fixed Cost per Customer ("FCC") to current actual customer counts.
The FCC currently in effect for the FCA mechanism was last updated in the 2011 Idaho
GRC. By contrast, the costs used to determine the Solar Energy Credit in this filing
began with the same cost-of-service study from the 2011 Idaho GRC, but include
adjustments to base rates that have occurred subsequent to the conclusion of that
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF -19
case.1 These adjustments were necessary to ensure that the proposed Solar Energy
Credit appropriately reflects all costs currently approved for recovery through rates.
Second, the calculation above utilizes actual 2015 residential sales and energy
as reported in Idaho Power's 2015 Form 10-K, while the proposed Solar Energy Credit
calculation utilized normalized test year information from each corresponding
ratemaking proceeding. The sales and energy reported in the 10-K are actual
sales/energy reported on a system-wide basis, not Idaho jurisdictional, while Idaho
Power utilizes Idaho jurisdictional normalized sales/energy when computing retail rates
for customers. Using actual sales/energy to calculate the embedded energy-related
costs and the subsequent rate per kWh creates an additional disconnect between the
way base rates are determined by the Company and the manner in which the credit rate
is calculated in this request.
To summarize, the underlying cost-of-service methodology utilized by the
Company to determine the Solar Energy Credit in this filing is the same as that utilized
to determine the fixed and variable portions of revenue requirement within the context of
the FCA mechanism. However, to ensure that the Solar Energy Credit reflects all
currently-approved costs, and to maintain consistency with approved ratemaking
practices, the proposed Solar Energy Credit differs from the rate calculated above due
to the reasons detailed in this response.
The response to this Request is sponsored by Matt Larkin, Revenue
Requirement Manager, Idaho Power Company.
1 The list of each case and Commission order approving such change was provided in response
to the Idaho Conservation League's Request No. 2.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF -20
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 internal rate of return of -3.0%.
RESPONSE TO REQUEST NO. 18: The Company does not have information
that shows residential customers are willing to invest in the Program at an internal rate
of return of -3.0 percent. One of the stated learning objectives of the proposed Program
is to assess customer commitment in this type of program with the proposed structure.
The response to this Request is sponsored by Matt Larkin, Revenue
Requirement Manager, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF -21
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. Lark.in'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.
RESPONSE TO REQUEST NO. 19: The statements in Mr. Lark.in's Direct
Testimony were made in regard to the Company's proposed treatment of ongoing
program expenses in future ratemaking proceedings. On pages 17-18 of Mr. Larkin's
Testimony, he states the Company will make:
[A] test year adjustment will be made based on the annual
amortization of the deferred revenue account. The result of
the adjustment will effectively offset the ongoing incremental
costs of the program in the Company's revenue requirement
determination in future rate cases. However, it should be
noted that because the annual amortization amount will be
based on estimated costs, the actual costs may differ from
that estimate. The Company does not believe these
differences will result in material costs or benefits being
assigned to non-participating customers in the future.
These statements were not intended to indicate that the Company will not
monitor the costs of administering and operating the Program, but rather to indicate that
the Company is not proposing to true-up actual expenses with estimated expenses in a
future ratemaking proceeding. To achieve the stated learning objectives, the Company
fully intends to monitor actual expenses of the Program.
The response to this Request is sponsored by Matt Larkin, Revenue
Requirement Manager, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF -22
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.
RESPONSE TO REQUEST NO. 20: The project will not result in any deferred
transmission or distribution cost. The project's 500 kW array is 0.01 percent of the
Company's peak load of 3,407 megawatts which will not defer any transmission costs.
It is proposed to be constructed next to an existing Idaho Power substation and connect
to an existing distribution circuit. This configuration will not defer distribution costs
associated with this or other distribution circuits.
The response to this Request is sponsored by Pete Pengilly, Customer Research
& Analysis Leader, and David Angell, Customer Operations Planning Manager, Idaho
Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF -23
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.
RESPONSE TO REQUEST NO. 21: The Company did not perform this analysis
because crediting participants at the retail rate would fundamentally result in the same
cost shift occurring under the current net metering rate design.2 Page 13 of Mr.
Larkin's testimony addresses the Company's rationale for the proposed Solar Energy
Credit: "This methodology will ensure that participating customers are able to offset the
energy-related portion of base rates, while still contributing to the recovery of fixed costs
related to infrastructure needed to serve all customers."
The response to this Request is sponsored by Matt Larkin, Revenue
Requirement Manager, Idaho Power Company.
2 In the Company's annual net metering report filed on April, 29, 2016, Section II discusses and
quantifies the cost shift occurring between net metering customers and standard service customers.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF -24
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
RESPONSE TO REQUEST NO. 22: To assess the perceived impact on nearby
residents, Idaho Power hand-delivered 144 letters to residences in the area and to one
business adjacent to the proposed solar array property. This does not include the letters
sent out from the City of Boise prior to the neighborhood meeting as part of the
conditional use permitting process. Idaho Power does not have income data for its
customers.
In a one-mile radius from the project location, there are about 3,300 residences,
104 commercial/industrial business, and 52 other properties including vacant land.
To market the Program, the Company will create awareness through the
utilization of direct marketing, niche marketing, and database marketing. Community
solar may also be bundled with other renewable offering messages so customers can
choose the program that is right for them. Currently, awareness is being generated by
earned media and owned media. A July press release regarding the filing generated
media coverage. Owned media such as the Company website, Company newsletters,
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF -25
and bill inserts may be used. Idaho Power currently has set up a Program webpage
through which customers can sign up to receive Program information updates. To date,
the Company has received over 70 sign-ups for more information.
The response to this Request is sponsored by Pete Pengilly, Customer Research
& Analysis Leader, Idaho Power Company.
DATED at Boise, Idaho, this 16th day of August 2016.
~j}~ ISA D.NORDS OM
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF -26
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 15th day of August 2016 I served a true and
correct copy of IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF upon the following named
parties by the method indicated below, and addressed to the following:
Commission Staff
Daphne Huang
Deputy Attorney General
Idaho Public Utilities Commission
472 West Washington (83702)
P.O. Box 83720
Boise, Idaho 83720-007 4
Idaho Conservation League
Benjamin J. Otto
Idaho Conservation League
710 North Sixth Street
Boise, Idaho 83702
Industrial Customers of Idaho Power
Peter J. Richardson
Gregory M. Adams
RICHARDSON ADAMS, PLLC
515 North 2?1h Street (83702)
P.O. Box 7218
Boise, Idaho 83707
Dr. Don Reading
6070 Hill Road
Boise, Idaho 83703
Idaho Irrigation Pumpers Association, Inc.
Eric L. Olsen
ECHO HAWK& OLSEN, PLLC
505 Pershing Avenue, Suite 100
P.O. Box 6119
Pocatello, Idaho 83205
Anthony Yankel
12700 Blake Avenue, Unit 2505
Lakewood, Ohio 44107
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IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF -27
Snake River Alliance
Ken Miller, Energy Program Director
Snake River Alliance
223 North Sixth Street, Suite 317
P.O. Box 1731
Boise, Idaho 83701
Sierra Club
Zack Waterman
Director, Idaho Sierra Club
503 West Franklin Street
Boise, Idaho 83702
Michael Heckler
3606 North Prospect Way
Garden City, Idaho 83714
City of Boise City
Elizabeth A. Koeckeritz
Deputy City Attorney
Boise City Attorney's Office
150 North Capitol Boulevard
P.O. Box 500
Boise, Idaho 83701-0500
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IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF -28