20170920Staff 1-11 to IPC.pdf

SEAN COSTELLO
DEPUTY ATTORNEYS GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NOS.8743
IN THE MATTER OF THE APPLICATION OF
IDAHO POWER COMPANY FOR AUTHORITY
TO ESTABLISH NEW SCHEDULES FOR
RESIDENTIAL AND SMALL GENERAL
SERVICE CUSTOMERS WITH ON-SITE
GENERATION
,/ED
i0li I[r 20 A]l 9: 3l
Street Address for Express Mail:
472W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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CASE NO. IPC.E.I7.I3
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
IDAHO POWER COMPANY
The Staff of the Idaho Public Utilities Commission requests that Idaho Power Company
(Idaho Power; Company) provide the following documents and information as soon as possible, and
no later than WEDNESDAY, OCTOBER 11,2017.
This Production Request is continuing, and the Company 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. The Company 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. Reference IDAPA
31.01.01.228.
FIRST PRODUCTION REQUEST
TO IDAHO POWER 1 SEPTEMBER20,2Ol7
tit,:.1,,'r.
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: In its Application, the Company requests that the Commission order the
Company to amend its applicable tariff schedules to require the installation and operation of smart
inverters for all new customer-owned generator interconnections within 60 days following the
adoption of an industry standard definition of smart inverters as defined by the Institute of Electrical
and Electronic Engineers.
a. Does the Company intend to require that all newly installed inverters conform with all
IEEE smart inverter requirements? Please explain.
b. Please provide copies of the proposed standard definition and all applicable IEEE smart
meter requirements.
c. Is it the Company's intent that all IEEE smart meter requirements apply to new
installations? [f not, please specify or list the requirements that the Company would
require of new installations.
REQUEST NO.2: On page 8 of his testimony, Mr. Angell describes the differences
between on-grid and off-grid inverters. Mr. Angell's testimony does not discuss grid-interactive
inverters, which can function either as on-grid or as off-grid inverters. On page 12 of her testimony,
Ms. Aschenbrenner states that the Company had 1,468 net metering systems in its Idaho service
territory as of June 30,2017. How many of these systems are equipped, respectively, with on-grid,
off-grid, and grid-interactive inverters?
REQUEST NO.3: On page 9 of its Application, the Company states that "Establishing
separate customer classes now will position the Company to study this segment of customers,
providing the data necessary to understand how this customer segment utilizes this system." What
information will the Company be able to gather that is not currently available for these customers?
REQUEST NO. 4: On pages 9 and 10 of its Application, the Company states that "The
data quantifying the usage of the system will inform what costs and benefits (revenue requirement)
are appropriately allocated to the newly established customer classes in a future rate making process
FIRST PRODUCTION REQUEST
TO IDAHO POWER 2 SEPTEMBER20,2Ol7
(class cost-of-service process)". Given that the Company's proposed Schedules 6 and 8 would
initially have zero customers, how many years will be required before there are sufficient customers
in these new classes to develop accurate cost-of-service allocators?
REQUEST NO. 5: The Company's proposed tariffs would apply to generation facilities
fueled by solar, wind, biomass, geothermal, hydropower, and fuel cell technology. In Exhibit 9 of
its Application (Charts 3,4, and 5), the Company discusses the unique patterns of energy use by net
metered solar facilities. Please provide similar charts for net metering customers who generate
energy using wind, biomass, geothermal, hydropower, and fuel cell technology.
REQUEST NO. 6: The Company's proposed tariffs would apply to generation facilities
fueled by solar, wind, biomass, geothermal, hydropower, and fuel cell technology. In Exhibit 9 of
its Application, the Company discusses cost shifting that occurs from solar net metered customers to
non-net metering customers. Please explain how costs might be shifted to non-net metering
customers from net metering customers who generate energy using wind, biomass, geothermal,
hydropower, and fuel cell technology.
REQUEST NO. 7: On page 4 of its Application, the Company states that it has deployed
Advanced Metering Infrastructure (AMI) in its service area enabling the Company to achieve more
precise usage measurement and facilitate more sophisticated, cost-based rate designs. Please
explain how AMI might be used to achieve more sophisticated, cost-based rate designs for its net
metering customers. Does the Company also propose updating rate designs for its non net metering
classes?
REQUEST NO. 8: In Exhibit 9, the Company states that, as of December 31, 20l6,Idaho
Power's net metering service consisted of 1,067 active systems. For each system that was connected
to Idaho Power for the entire period between January 1,2016 through December 31,2016, please
provide the following information:
a. The schedule under which the net metering customer takes power.
b. The County in which the customer is located.
c. Net hourly power consumption/production data for the 2016 calendar year.
FIRST PRODUCTION REQUEST
TO IDAHO POWER aJ SEPTEMBER 20, 2OI7
REQUEST NO. 9: Schedule 84 includes a one meter option for customers who take
service under schedules other than 1,4,5, and7, and whose generation facilities have a total
nameplate capacity rating of 25 kW or smaller, or whose generation facilities have a total nameplate
capacity that is no more thar2o/o of their BLC. Under the Company's proposal, how would these
customers be able to receive net metering service?
REQUEST NO. 10: Schedule 84 includes a two meter option for customers who take
service under schedules other than l, 4, 5, and 7 , and whose generation facilities have a total
nameplate capacity rating of 100 kW or smaller. Under the Company's proposal, how would these
customers be able to receive net metering service?
REQUEST NO. 11: Would the Company's proposal apply to customers who use on-site
generation to reduce their own power consumption, but who eliminate their ability to export power
to the Company's grid by means of a Grid Tie Limiter, Grid Inverter with Export Control, or similar
device? If so, please explain how customers receiving power on schedules other than Schedules 6
and 8 might be able to use on-site generation to reduce their power consumption.
DATED at Boise, Idaho, this Z*day of September 2017 .
Technical Staff: Michael Morrison/l-1 1
i:umisc:prodreq/ipcel 7. I 3scmm prod req I
FIRST PRODUCTION REQUEST
TO IDAHO POWER 4 SEPTEMBER2O,2OIT
Sean Costello
Deputy Attorney General
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 2OTH DAY OF SEPTEMBER 2017,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY, IN CASE NO.
IPC-E-17-I3, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
LISA D NORDSTROM
REGULATORY DOCKETS
IDAHO POWER COMPANY
PO BOX 70
BOrSE rD 83707-0070
E-MAIL: [e-mail]
dockets@ idahopower. com
C TOM ARKOOSH
ARKOOSH LAW OFFICES
802 W BANNOCK ST STE 9OO
PO BOX 2900
BOISE ID 83701
E-MAIL: [e-mail]
[e-mail]
ELIAS BISHOP
AURIC SOLAR LLC
2310 S 1300 W
W VALLEY CITY UT 84119
E-MAIL : [e-mail]
ANTHONY YANKEL
I27OO LAKE AVENUE
LINIT 2505
LAKEWOOD OH 44107
E-MAIL: [e-mail]
ZACK WATERMAN
IDAHO SIERRA CLUB
503 W FRANKLIN STREET
BOISE TD 83702
E-MAIL : [e-mail]
TIMOTHY E TATUM
CONNIE ASCHENBRENNER
IDAHO POWER COMPANY
PO BOX 70
BOrSE ID 83707-0070
E-MAIL: [e-mail]
sacs h enblel1qe r@. i daho p ower. c o m
MATTHEW A NYKIEL
ID CONSERVATION LEAGUE
102 S EUCLID #207
PO BOX 2308
SANDPOINT ID 83864
E-MAIL: [e-mail]
ERIC L OLSEN
ECHO HAWK & OLSEN PLLC
PO BOX 6119
POCATELLO ID 83205
E-MAIL: [e-mail]
KELSEY JAE NLINEZLLC
920 N CLOVER DR
BOISE ID 83703
E-MAIL: kelsey@kelseyj aenunez.com
ELECTRONIC ONLY
MICHAEL HECKLER
michael.p.heckler@ gmail.com
CERTIFICATE OF SERVICE
ABIGAIL R GERMAINE
DEPUTY CITY ATTORNEY
BOISE CITY ATTORNEY'S
PO BOX 500
BOISE rD 83701-0500
E-MAIL: [e-mail]
DAVID BENDER
EARTHJUSTICE
3916 NAKOMA ROAD
MADISON WI 53711
E-MAIL: [e-mail]
JOHN R HAMMOND JR
FISHER PUSCH LLP
PO BOX 1308
BOISE ID 83701
E-MAIL: i rh@fi sherpusch.com
RYAN B FRAZIER
BRIAN W BURNETT
KIRTON McCONKIE
PO BOX 45t20
SALT LAKE CITY UT 8411 1
E-MAIL: [e-mail]
bburnett@,kmclaw.com
DAVID H ARKOOSH
LAW OFFICE OF DAVID ARKOOSH
PO BOX 2817
BOISE ID 83701
E-MAIL: [e-mail]
BRIANA KOBOR
VOTE SOLAR
360 22ND STREET STE 730
OAKLAND CA946I2
E-MAIL: [e-mail]
ELECTRONIC ONLY
SNAKE RIVER ALLIANCE
wwilson@ snakeriveralliance. org
NW ENERGY COALITION
[e-mail]
INTERMOLTNTAIN WIND AND
SOLAR LLC
1952 WEST 2425 SOUTH
WOODS CROSS UT 84087
E-MAIL: [e-mail]
dale@imwindandsolar. com
-J- /)d--l-
SECRETARY ,/
CERTIFICATE OF SERVICE