20170927Vote Solar 1-19 to IPC.pdf

J. Kahle Becker (ISB No. 7408)
223 N. 6th St., Suite 325
Boise,Idaho 83702
Phone: [phone]
Fax: [phone]
Email : kahle@kahlebeckerlaw. com
David Bender, WI Bar # 1046102 (Pro Hac Vice)
Earthjustice
3916 Nakoma Road
Madison, WI537l I
(4ts) 977-s727
db end er@earthj ustice. org
TN 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
1 Ati l0: ?0
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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CASE NO. IPC-E-17-13
FIRST SET OF DATA REQUESTS
BY VOTE SOLAR TO IDAHO
POWER COMPANY
Vote Solar hereby serves its first set of data requests regarding the above-mentioned
docket. Vote Solar requests that Idaho Power Company provide responses as expeditiously as
possible, but not later than the deadline of 2l days, which is October 18,2017 .
INSTRUCTIONS
L Please provide copies of responses to the following contacts:
David Bender
Earthjustice
3916 Nakoma Road
Madison, WI 53711
db ender@ earthj usti c e. ors
Briana Kobor
Vote Solar
360 22d Street, Suite 730
Oakland, Cl.94612
[e-mail]
First Set of Data Requests by Vote Solar to Idaho Power Company
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2. Whenever possible, Vote Solar prefers to receive electronic copies of data responses
either by email or on CD.
3. Responses to any and all of Vote Solar's data requests should be supplied to Vote Solar as
soon as they become available to Idaho Power Company.
4. The requests herein shall be deemed to be continuing in nature and Idaho Power Company
is requested to supplement its responses as necessary and as additional information becomes
available.
5. ln responding to each data request, please consult every document source which is in your
possession, custody, or control, including all documents in the possession of experts or
consultants.
6. For each response, identify the person who prepared the answer to the data request as well
as his or her position with Idaho Power Company or any Idaho Power Company affiliate or
parent company.
7. Please reproduce the data request being responded to before the response.
8. If the responses include computer modeling input and output files, please provide those
data files in electronic machine-readable or txt format.
9. If the responses include spreadsheet files, please provide those spreadsheet files in usable
electronic Excel-readable format.
10. In responses providing computer files, list the file names with the cross-reference to the
data request, and if necessary to the understanding of the data, provide a record layout of the
computer files, Computer files provided with a response must be in or compatible with the
current version, or the immediately prior version, of Microsoft Office.
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First Set of Data Requests by Vote Solar to Idaho Power Company
I 1. For each dollar amount provided in response to a discovery request please state if the
amount is in nominal or constant dollars and what years' dollars.
12. All references to elechicity load during a specific hour are assumed to be the hour
ending at the indicated time, unless you state otherwise in your response.
DATA REQUESTS
l. Please produce your responses to all discovery requests served on you by any other party
and your responses to each such request.
2. Reference Application, page 4, paragraph 4. Please describe and quantify an on-site
generation customer's "respective share for... grid-related services," including but not limited to
how the "respective share" relates to the customer's actual contribution to class loads used to
allocate costs in a cost-of-service-study.
3. Reference Application, page 5, paragraph 7. Please provide all analyses showing,
confirming, or in any way supporting your assertion that net metering service acts as a regressive
wealth transfer from lower-income to higher-income customers in your service territory,
including your definitions of "lower-income" and "higher-income" as used in this paragraph, and
all income data for the residential customers taking service under Schedule 84, Customer Energy
Production Net Metering, that you relied on to make the assertion regarding the transfer of
wealth from lower-income to higher-income customers.
4. Please identiff, by date, time and substation, each instance when customer-sited
distributed generation connected to your distribution system caused a backflow at a distribution
substation.
5. Reference Angell Direct at I 1-13.
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First Set of Data Requests by Vote Solar to Idaho Power Company
(a) Please confirm that the negative loads for the "Net Zero Net Metering Customer" flow
to, and serve the load of, another customer on the distribution system.
(b) Please confirm that by serving the load of another customer on the distribution
system, the "Net Zero Net Metering Customer" negative loads reduce the cumulative load placed
on the distribution substations and all equipment upstream of the substation, including the
substation distribution transformers, the transmission system, and generation.
(c) Please confirm that (i) the "Exported Net Excess" energy depicted in Figure 2
represents electricity that is delivered to another customer and is, therefore, also contained in that
customer's delivered load for the same "Hour Ending" and (ii) some or all of the kW depicted as
"Exported Net Excess" in Figure 2 is also contained in the kW depicted as load for the "Standard
Service" customer.
6. Reference Angell Direct at l2 lines 9-10. Please confirm that: (l) "daily absolute demand
requirements of the two customers are similar" refers to the individual customer's maximum
daily peak, not to the demand during the system peak hour; and (2) that the "Net Zero Net
Metering Customer" had a lower demand during the system peak hour on June 29,2016, than the
"Standard Service Residential Customer".
7. Reference Angell Direct page 15, line 5 to page 18, line 2 and Exhibit 14.
(a) Please provide the date and hour of the Company's system peak during each of the
last ten (10) years.
(b) For each of the date and hours of system peak for the last ten ( I 0) years, provide the
solar irradiance in "Standardized Units" and the "Load - Irradiance" in "Standafiized Units"
similar to that used in Figures 3 and 4,
First Set of Data Requests by Vote Solar to Idaho Power Company
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(c) Provide the date and hour of peak load, and the load, during the last five (5) years for
each distribution substation in your system that serves residential and small general service
("R&SGS") customers.
8. Reference Angell Direct, page 19,lines 4-7. Please produce the Integrated Resource Plan
analysis for on-site generation additions for the service areas for the most recent three (3)
Integrated Resource Plans.
9. Reference Aschenbrenner Direct at 15. Please produce the2016 Annual Net Metering
Status Report and all similar reports for the years 2012 through present except for the document
filed as Exhibit 9 with your testimony in this case.
10. Reference Aschenbrenner Direct at 28 note 14.
(a) Please produce the cost-of-service study from the Company's last general rate case.
(b) Please produce the workpapers for the cost-of-service study from the Company's last
general rate case in native, unlocked, electronic format with formulas intact.
(c) To the extent the Company's last cost-of-service study allocated costs based on
system peak (at any level of the system), multiple coincident peaks (i.e., 3CP, 4CP or lzCP),
and/or class noncoincident peaks, please provide the date and time (hour ending) of each such
peak and noncoincident peak for each class.
I I . Reference Aschenbrenner Direct at 31, lines 17 -24. Please provide all studies and other
evidence that supports your contention that energy efficiency measures are called upon at all
hours and are, therefore, "always delivering energy reduction."
12. Reference Aschenbrenner Direct at 33, lines l-2.
(a) Please identifu each distribution system component that you contend net metering
customers utilize when they o'are exporting energy to the grid."
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First Set of Data Requests by Vote Solar to Idaho Power Company
(b) State whether you contend that a net metering customer's utilization of the grid to
export electricity is separate from, and in addition to, the nearby customer's use of the
distribution system to receive a net metering customer's export electricity.
(c) If a net metered customer's export electricity flow is used to serve a nearby
customer's load, and is, therefore, part of the nearby customer's import flow of electricity, please
explain how you propose to assign costs to that flow of electricity to avoid double counting the
same flow of electricity as both the net metering customer's export flow and the non-net
metering customer's import flow.
13. Reference Aschenbrenner Direct at 33, lines 16-21. Please provide the methodology that
you contend should be applied to determine a net metering customer's "appropriate amount of
costs" and the methodology you contend should be applied to determine the amount of billing
that would reflect a net metering customer's "utilization of the grid."
14. Reference Aschenbrenner Direct at34-35 and Table 3. Please provide the 2016 hourly
load data, in native, unlocked, electronic format with formulas intact, for the net zero residential
customer and the "Nearby Residential" customer used for the comparison of rates paid in Table
J.
15. Reference Aschenbrenner Direct at 36, lines 8-17.
(a) Please identify where in Mr. Tatum's testimony intra-class subsidies other than the
one you contend exists for net metered customers are discussed.
(b) Please identify all intra-class subsidies that exist within the R&SGS customer classes.
16. Reference Aschenbrenner Exhibit 9 at pp 5-6 of 18. Please define an "inappropriate cost
shifting," including but not limited to:
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First Set of Data Requests by Vote Solar to Idaho Power Company
(a) Whether you contend that any reduction in volumetric energy use by a customer
since the last rate case test year constitutes an "inappropriate cost shift";
(b) Whether you contend that revenue collection from an individual customer should
match that customer's contribution to the class loads at the peak periods used for allocating
revenue requirement to the class; and
(c) The qualities and attributes of a near-term "cost shift" that make it an "inappropriate
cost shift" rather than an appropriate o'cost shift."
17. Reference Aschenbrenner Exhibit 9 at 6 of 18.
(a) Please provide the methodology, assumptions, calculations, and workpapers
supporting the "estimated cost shift" as of the end of 2015 and as of the end of 2016. Please
provide all responsive calculations and workpapers in native, unlocked, electronic format with
formulas intact.
(b) Please describe the basis for, and how you calculated, that the 366 residential net
metered customers were responsible for a total annual revenue requirement of $464,266.67 and
that the 566 residential net metered customers were responsible for a total annual revenue
requirement of $665,969.
18. Reference Tahrm Direct at l3,lines 15-25.
(a) Please explain the difference between reduction in customer usage that results in
"unduly reduc[ing] collection of class revenue" and reduction in customer usage that results in
acceptable reduction of collection of class revenue.
(b) Please confirm that "fixed" costs are "transfer[red]" to other residential customers
after a reduction in class revenue collection due to net metering, as described on lines 2l-25,
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First Set of Data Requests by Vote Solar to Idaho Power Company
only when rates are reset in subsequent general rate cases, and only to the extent that the
residential class's allocated revenue requirement is not reduced by the same or greater amount.
19. Reference Tatum Direct at 18, lines l1-18. Please identify Idaho's policies on cost
causation and how you contend net metering rates should be structured to provide price signals
that reflect those policies.
DATED: September 27, 2017
Respectfully submitted,
s/ David C. Bender
David C. Bender
Earthjustice
3916 Nakoma Road
Madison, WI537l I
(202) 667-4s00
dbender@ earthj ustice. or g
J. Kahle Becker (lSB No. 7408)
223 N. 6'h St., Suite 325
Boise,Idaho 83702
Phone: [phone]
Fax: [phone]
Email: [e-mail]
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First Set of Data Requests by Vote Solar to Idaho Power Company
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that I have this 27th day of September 2017, served the foregoing
FIRST SET OF DATA REQUESTS BY VOTE SOLAR TO IDAHO POWER COMPANY
upon allparties of record in this proceeding, via the manner indicated:
FedEx and Electronic Mail
Diane Hanian
Commission Secretary
Idaho Public Utilities Commission
47 2 West Washington Street
Boise, ID 83702
Diane.holt@puc. idaho. gov
(Three copies)
Electronic Mail
Lisa D. Nordstrom
Idaho Power Company
l22l West Idaho Street (83702)
P.O. Box 70
Boise, ID 83707
lnordstrom@idahopower. com
dockets@ idahopower.com
Timothy E. Tatum
Connie Aschenbrenner
Idaho Power Company
l22l West Idaho Street (83702)
P.O. Box 70
Boise, ID 83707
ttatum@ id ahopower.com
caschenbrenner@ idahopower.com
Sean Costello
Deputy Attorney General
Idaho Public Utilities Commission
47 2 W est Wash in gton (837 02)
PO Box 83720
Boise, ID 83720-0074
Sean.costel lo@puc. idaho. gov
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First Set of Data Requests by Vote Solar to Idaho Power Company
MatthewA. Nykiel
Idaho Conservation League
P.O. Box 2308
102 E. Euclid, #207
Sandpoint, ID 83864
mnykiel@,idahoconservation.org
AbigailR. Germaine
Deputy City Attorney
BOISE CITY ATTORNEY' S OFFICE
150 N. Capitol Blvd.
P.O. Box 500
Boise, Idaho 83701 -0500
agerma i ne@c ity ofbo i se. org
David Bender
Earthjustice
3916 Nakoma Road
Madison, WI 5371I
dbender@earthj ustice. org
Briana Kobor
Vote Solar
360 22d Street, Suite 730
Oakland, CA94612
[e-mail]
Idaho Irrigation Pumpers Association, Inc.
Eric L. Olsen
ECHO HAWK & OLSEN, PLLC
505 PershingAve., Ste. 100
P.O. Box 6l19
Pocatello, Idaho 83205
[e-mail]
Anthony Yankel
12700 Lake Ave., Unit 2505
Lakewood, OH 44107
[e-mail]
Elias Bishop
Auric Solar, LLC
2310 s. 1300 w.
West Valley City, UT 84119
El [e-mail]
First Set of Data Requests by Vote Solar to Idaho Power Company
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Preston N. Carter
Deborah E. Nelson
Givens Pursley LLC
601 West Bannock Street
Boise, ID 83702
prestoncarter@ given spursley. com
den@ givenspursley.com
Idahydro clo C. Tom Arkoosh, and
Idaho Clean Energy Association c/o C, Tom Arkoosh
Arkoosh Law Offices
802 W. Bannock Street, Suite 900
P.O. Box 2900
Boise, ID 83701
Tom.arkoo sh@arkoosh. com
Erin.ceci [e-mail]
David H. Arkoosh
Idaho Clean Energy Association c/o Law Office of David Arkoosh
P.O. Box 2817
Boise, ID 83701
[e-mail]
Zack Waterman
IDAHO SIERRA CLUB
503 W, Franklin St.
Boise, ID 83702
Zach.waterman @s ierrac lub. org
Kelsey Jae Nunez
KELSEY JAE NI.JNEZLLC
920 N. Clover Dr.
Boise, ID 83703
kel sey@ke lseyj aenunez.com
Attorney for Sierra Club
Michael Heckler
3606 N. Prospect Way
Garden City, ID 83714
Michael.p.heckler@ gmail.com
First Set of Data Requests by Vote Solar to Idaho Power Company
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John R. Hammond Jr.
Fisher Pusch LLP
l0l South Capitol Blvd., Suite 701
PO Box 1308
Boise, Idaho 83702
[e-mail]
Snake RiverAlliance
wwilson@snaleriveral I iance. org
NW Energy Coalition
[e-mail]
Intermountain Wind and Solar, LLC
Ryan B. Fruzier
Brian W. Burnett
KIRTON MoCONKIE
50 East South Temple, Suite 400
P.O. Box 45120
Salt Lake City, UT 841I I
rfrazier@kmclawcom
[e-mail]
Intermountain Wind and Solar, LLC
1952 West 2425 South
Woods Cross, UT 84087
doug@ imwindandso lar.com
dale@,imwindand so I ar.com
s/ Al Luna
Al Luna, Litigation Assistant
Earthjustice
First Set of Data Requests by Vote Solar to Idaho Power Company
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