20171010Vote Solar 20-48 to IPC.pdf

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Second Set of Data Requests by Vote Solar to Idaho Power Company
J. Kahle Becker (ISB No. 7408)
223 N. 6th St., Suite 325 Boise, Idaho 83702 Phone: [phone] Fax: [phone]
Email: [e-mail]
David Bender, WI Bar # 1046102 (Pro Hac Vice) Earthjustice 3916 Nakoma Road
Madison, WI 53711
[phone] [e-mail]
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF IDAHO POWER COMPANY FOR AUTHORITY T
WITH ON-SITE GENERATION
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CASE NO. IPC-E-17-13 SECOND SET OF DATA
REQUESTS BY VOTE SOLAR TO
IDAHO POWER COMPANY
Vote Solar hereby serves its second 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 21 days, which is October 31,
2017.
INSTRUCTIONS 1. Please provide copies of responses to the following contacts: David Bender Briana Kobor
Earthjustice Vote Solar 3916 Nakoma Road 360 22nd Street, Suite 730 Madison, WI 53711 Oakland, CA 94612 [e-mail] [e-mail]
2. Whenever possible, Vote Solar prefers to receive electronic copies of data
responses either by email or on CD.
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Second Set of Data Requests by Vote Solar to Idaho Power Company
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. In 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.
11. 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.
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Second Set of Data Requests by Vote Solar to Idaho Power Company
12. All references to electricity load during a specific hour are assumed to be the
hour ending at the indicated time, unless you state otherwise in your response.
13. “You” “your”, and “Company” used herein refer to Idaho Power Company, its
agents, employees, and affiliates.
14. When load data are provided in response to these data requests, please anonymize
the data so that personally identifiable information is omitted from the data provided.
Where feasible, please include a consistent customer reference for each customer so that
data from the same customer can be matched from different data sources and/or groups
without disclosing the identity of any customer.
Data Requests
20. Please provide work papers to support your application and all witness testimony
including all underlying data and analyses to support any numerical calculations, tables,
and figures presented in the application and testimony. Please provide work papers in
native format with formulas and links intact. Please consider this an ongoing request and
timely provide any additional work papers supporting additional testimony filed in this
proceeding.
21. Reference the following quote from page 12 of your Application: “High DER
penetration amounts create distribution circuit operation challenges, such as voltage
management, short circuit detection, and islanding.”
a. Please quantify the level of DER penetration that you consider “high,” as
used in the above-quoted statement.
b. Please provide documentation regarding each operation challenge you
experienced as a result of current levels of DER penetration.
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Second Set of Data Requests by Vote Solar to Idaho Power Company
c. Please provide documentation regarding each voltage management
challenge you experienced as a result of current levels of DER penetration.
d. Please provide documentation regarding each short circuit detection
challenge you experienced as a result of current levels of DER penetration.
e. Please provide documentation regarding each islanding challenge you
experienced as a result of current levels of DER penetration.
22. Reference the following quote from page 12 of the Application: “To reduce these
operational challenges, Idaho Power first replaces the controllers and optimizes their
settings for reduction of voltage deviation without substantially increasing the device
wear.”
a. Please identify each controller you replaced as a result of DER
penetration, by year, for each of the last ten (10) years.
b. For each controller identified in response to subsection a, above, please
provide:
i. The total expenditure;
ii. The amount of expenditure that was capitalized;
iii. The remaining book life and undepreciated balance of the controller that
was replaced and the salvage value, if any.
23. Please provide Idaho Power's Response to Staff's Production Request Nos. 6 and
7 in Case No. IPC-E-01-39.
24. Please provide the following information regarding Figure 3 on page 28 of Ms.
Aschenbrenner’s direct testimony:
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Second Set of Data Requests by Vote Solar to Idaho Power Company
a. Please identify the methodology used to develop the figure, including but
not limited to the source of data used.
b. If the figure was developed from sampled customer load data, please
describe the sampling methodology and specify the size of the samples employed.
c. Please provide all data used in the development of Figure 3.
d. Please indicate whether a similar analysis has been conducted for small
general service (“SGS”) customers and, if so, please provide the result, underlying
work papers, and data.
25. Please provide the following information regarding Figure 4 on page 30 of Ms.
Aschenbrenner’s direct testimony:
a. Please identify the methodology used to develop the figure, including but
not limited to the source of data used.
b. If the figure was developed from sampled customer load data, please
describe the sampling methodology and specify the size of the samples employed.
c. Please provide all data used in the development of Figure 4.
d. Please indicate whether a similar analysis has been conducted for SGS
customers and, if so, please provide the result, underlying work papers, and data.
26. Please provide, separately by customer class, individual customer load data from
the Company’s residential and SGS customers with on-site generation for 2015 and 2016
in the following categories:
a. Non-netted deliveries from the Company to the customer (i.e., all
delivered energy over the shortest time period over which energy flows are
recorded without accounting for flows of energy you received from the customer)
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Second Set of Data Requests by Vote Solar to Idaho Power Company
b. Non-netted receipt of energy exports from the customer to the Company
on the same time basis as deliveries.
c. From these data, please provide a census of customer data or, if a census is
unavailable, a statistically significant sample of individual customer data. If
neither a census nor a statistically significant sample of individual customer data
is available, please provide aggregate class data.
27. Please provide, separately by class, individual customer load data from the
Company’s residential and SGS customers without on-site generation for 2015 and 2016
on the same time basis as the load data produced in response to the preceding request.
From these data, please provide a census of customer data or, if a census is unavailable, a
statistically significant sample of individual customer data. If neither a census nor a
statistically significant sample of individual customer data is available, please provide
aggregate class data.
28. Please provide all load research data you collected, or that was collected on your
behalf, in support of your Application in this docket for the following groups of
customers:
a. Residential customers with on-site generation;
b. Residential customers without on-site generation;
c. Small commercial customers with on-site generation; and
d. Small commercial customers without on-site generation
29. Please indicate the average percentage of on-site monthly energy use that is offset
by solar net energy generation among the Company’s residential customers with on-site
generation. Please provide the data used to develop the calculation.
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Second Set of Data Requests by Vote Solar to Idaho Power Company
30. Please indicate the average percentage of on-site monthly energy use that is offset
by solar net energy generation among the Company’s small commercial customers with
on-site generation. Please provide the data used to develop the calculation.
31. Please indicate, by year, the number of your residential customers with on-site
generation who were net zero customers in each of the last five (5) calendar years.
32. Please indicate, by year, the number of your small commercial customers with on-
site generation who were net zero customers in each of the last five (5) calendar years.
33. Please provide all work papers supporting the 2016 Net Metering Status Report
attached to Ms. Aschenbrenner’s direct testimony as Exhibit No. 9. Please provide work
papers in executable native format with formulas and links intact.
34. Please provide all work papers supporting the 2016 Net Metering Status Report.
Please provide work papers in executable native format with formulas and links intact.
35. Please provide all work papers supporting the presentation attached to Ms.
Aschenbrenner’s direct testimony as Exhibit No. 10. Please provide work papers in
executable native format with formulas and links intact.
36. Reference the statement by Mr. Angell on page 11, lines 21 to 23 of his direct
testimony that: “To illustrate this, the Company selected a single residential net metering
customer who netted their usage to zero during 2016.”
a. Please provide all available usage data for the calendar year 2016 for the
two customers depicted in Figure 1, separating energy used by the customer
coincident to its production by the customer (self-consumed customer generation)
and energy you delivered to the customer.
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Second Set of Data Requests by Vote Solar to Idaho Power Company
b. Please indicate the number of residential and small general service
(“R&SGS”) customers for which you have data comparable to the data depicted
for the selected customer in Figure 3. If you do not have such data for all
customers, please describe why you have such data for some, but not all
customers.
c. Please provide all available load data for R&SGS customers with on-site
generation for 2016, separating energy used by the customer coincident to its
production by the customer (self-consumed customer generation) and energy you
delivered to the customer if available.
d. Please provide all available load data for R&SGS customers without on-
site generation for 2016.
37. Reference Figure 3 on page 17 of Mr. Angell’s direct testimony:
a. Please indicate the standardized unit value for the Load curve at time of
peak.
b. Please indicate the standardized unit value for the Load-irradiance curve at
the time the Load curve peaks.
c. Please provide all underlying data used to support this figure in Excel
format with formulas and links intact.
38. Reference Figure 4 on page 18 of Mr. Angell’s direct testimony:
a. Please indicate the standardized unit value for the Load curve at time of
peak.
b. Please indicate the standardized unit value for the Load-irradiance curve at
the time the Load curve peaks.
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Second Set of Data Requests by Vote Solar to Idaho Power Company
c. Please provide all underlying data used to support this figure in Excel
format with formulas and links intact.
39. Reference page 20 lines 13 to 15 of Mr. Angell’s direct testimony:
a. Please define “high DER penetration” as used in the referenced section.
b. Please identify each time you experienced a voltage violation as a result of
current DER penetration levels.
c. Please identify each time you experienced a short circuit detection as a
result of current DER penetration levels.
d. Please identify each time you experienced islanding as a result of current
DER penetration levels.
e. Please provide documentation of all events identified in response to
subparts b through d, above.
f. Please identify the costs incurred to address each of the events, and their
underlying cause, for each of the events identified in response to subparts b
through d, above.
40. Reference page 22 lines 1 to 2 of Mr. Angell’s direct testimony:
a. Please define the “peak load” referred to in the description “15 percent of
peak load,” including but not limited to whether this refers to peak system load,
peak load on the relevant circuit, or the peak at some other point of measurement.
b. Please indicate the date at which the Company expects DER penetration to
reach 15 percent of peak load and provide all work papers and analyses
supporting that calculation in Excel format with formulas and links intact.
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Second Set of Data Requests by Vote Solar to Idaho Power Company
41. Please clarify whether the Companies’ proposal regarding the requirement for
smart inverters would apply only to new customers seeking interconnection or whether
existing customers who may not have smart inverters in place would be subject to the
requirement.
42. Reference the statement by Mr. Tatum on page 5, lines 17-20 of his direct
testimony, that: “The existing R&SGS rate design does not reflect the costs and benefits
of the transaction between Idaho Power and its customers with on-site generation.”
a. Please provide all analyses that the Company has conducted that quantify
the cost to serve customers with on-site generation and all data relied upon. If
applicable, please provide supporting work papers in their native format with
formulas and links intact.
b. Please provide all analyses that the Company has conducted that quantify
the benefits associated with serving customers with on-site generation and all data
relied upon. If applicable, please provide supporting work papers in their native
format with formulas and links intact.
43. Reference the statement by Mr. Tatum on page 8 line 21 to page 9 line 2 of his
direct testimony that: “Under this proposal, the rates under Schedule 6 and Schedule 8
would continue to mirror the rates contained in Schedule 1 and Schedule 7 until the
Commission determines the proper rate design and/or compensation structures for
Schedule 6 and Schedule 8 based upon appropriate cost of service studies and other
applicable generation valuation studies.”
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Second Set of Data Requests by Vote Solar to Idaho Power Company
a. Please describe in detail what cost of service studies and other application
generation valuation studies are “appropriate” to support a “proper” rate design
and/or compensation structure for customers with on-site generation.
b. Please indicate whether you have completed any of the studies referred to
in the preceding subpart and, if so, please provide all relevant studies and
associated work papers in Excel format with formulas and links intact.
44. Reference the statement by Mr. Tatum on page 19 lines 14 to 24 of his direct
testimony that: “The establishment of similarly situated customers or customer classes
has been a long-standing and important first step in the ratemaking process. Taking this
important first ratemaking step now will position the Company to study this segment of
customers, providing the data necessary to understand how this customer segment utilizes
the Company's system. The data quantifying the usage of the system will inform what
costs (revenue requirement) are appropriately allocated to the newly established customer
classes in a future rate proceeding (class cost-of-service process).”
a. Please indicate whether you contend that Idaho law requires that
customers with on-site generation be designated as a separate rate class before
they can be analyzed in a class cost-of-service analysis for a future general rate
case. If so please provide references to the controlling statute(s), regulation(s),
and/or case(s).
b. Please identify the most recent five (5) instances when a new class was
established and, for each such instance, please identify the Commission order
approving the new class.
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Second Set of Data Requests by Vote Solar to Idaho Power Company
c. Please identify the most recent five (5) instances when you proposed to
create a new class but the Commission did not approve such proposal and, for
each such instance, please identify the Commission order or other decision
rejecting the proposal.
d. Please identify each instance when you included a proposed class of
customers in a cost-of-service study filed with the Commission, prior to the
Commission approving the creation of a new class for such customers.
45. Refer to the statement by Mr. Tatum on page 22 lines 1 to 6 of his direct
testimony that: “The Company requests that the Commission open a generic docket at the
conclusion of this case with the purpose of establishing a compensation structure for
customer-owned DERs that reflects both the benefits and costs that DER interconnection
brings to the electric system.”
a. Please explain how the proposed generic docket differs from a general rate
case proceeding (if at all).
b. Please confirm that the Company does not propose to modify rates for any
customers outside of a general rate case proceeding.
46. Reference the statement by Mr. Tatum on page 22 lines 14-16 of his direct
testimony that: “The Company anticipates that it will request to modify the pricing
structure and compensation methodology as part of a future rate proceeding.”
a. Please indicate whether the “future rate proceeding” is the same as, or
distinct from, the generic docket referred to on page 22 lines 1-6 of Mr. Tatum’s
direct testimony.
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Second Set of Data Requests by Vote Solar to Idaho Power Company
b. Please explain whether the “future rate proceeding” is the same as a
general rate case proceeding. If different, please explain.
47.
a. Please confirm that proposed Schedule 6 combines the substantive
provisions from existing Schedule 1 and Schedule 84 and adds a provision that
“Compensation for the balance of generation and usage by the Customer is
subject to change upon Commission approval.”
b. If proposed Schedule 6 makes any substantive changes—whether addition
or omission—from existing Schedules 1 and 84, other than that identified in
subpart a, above, please fully describe each such substantive change.
c. If you contend that including the statement “Compensation for the balance
of generation and usage by the Customer is subject to change upon Commission
approval” has any legal significance and/or provides any information to the
customer beyond that described by Mr. Tatum on page 23 lines 5 to 22 of his
direct testimony, please set forth the full basis for your contention.
48. Please provide all work papers supporting the payback period calculation set forth
on page 24 lines 11 to 17 of Mr. Tatum’s direct testimony. Please provide work papers in
Excel format with formulas and links intact.
DATED: October 10, 2017 Respectfully submitted, _s/ David C. Bender_______
David C. Bender
Earthjustice 3916 Nakoma Road Madison, WI 53711 [phone]
[e-mail]
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Second Set of Data Requests by Vote Solar to Idaho Power Company

J. Kahle Becker (ISB No. 7408) 223 N. 6th St., Suite 325 Boise, Idaho 83702 Phone: [phone]
Fax: [phone]
Email: [e-mail]
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Second Set of Data Requests by Vote Solar to Idaho Power Company
CERTIFICATE OF SERVICE I HEREBY CERTIFY that I have this 10th day of October 2017, served the foregoing SECOND SET OF DATA REQUESTS BY VOTE SOLAR TO IDAHO POWER COMPANY upon all parties of record in this proceeding, via the manner
indicated:
FedEx and Electronic Mail Diane Hanian
Commission Secretary
Idaho Public Utilities Commission 472 West Washington Street Boise, ID 83702 [e-mail]
(Three copies)
Electronic Mail Lisa D. Nordstrom
Idaho Power Company
1221 West Idaho Street (83702) P.O. Box 70 Boise, ID 83707 [e-mail]
[e-mail]
Timothy E. Tatum Connie Aschenbrenner Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70 Boise, ID 83707 [e-mail] [e-mail]

Sean Costello Deputy Attorney General Idaho Public Utilities Commission 472 West Washington (83702)
PO Box 83720
Boise, ID 83720-0074 [e-mail]

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Second Set of Data Requests by Vote Solar to Idaho Power Company
Matthew A. Nykiel
Idaho Conservation League P.O. Box 2308 102 E. Euclid, #207 Sandpoint, ID 83864
[e-mail]
Abigail R. Germaine Deputy City Attorney BOISE CITY ATTORNEY’S OFFICE
150 N. Capitol Blvd.
P.O. Box 500 Boise, Idaho 83701-0500 [e-mail]
David Bender
Earthjustice 3916 Nakoma Road Madison, WI 53711 [e-mail]

Briana Kobor Vote Solar 360 22nd Street, Suite 730 Oakland, CA 94612
[e-mail]
Idaho Irrigation Pumpers Association, Inc. Eric L. Olsen ECHO HAWK & OLSEN, PLLC
505 Pershing Ave., Ste. 100
P.O. Box 6119 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 [e-mail]

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Second Set of Data Requests by Vote Solar to Idaho Power Company

Preston N. Carter Deborah E. Nelson Givens Pursley LLC 601 West Bannock Street
Boise, ID 83702
[e-mail] [e-mail] Idahydro c/o 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
[e-mail]
[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 [e-mail]
Kelsey Jae Nunez
KELSEY JAE NUNEZ LLC 920 N. Clover Dr. Boise, ID 83703 [e-mail]
Attorney for Sierra Club
Michael Heckler 3606 N. Prospect Way Garden City, ID 83714
[e-mail]

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Second Set of Data Requests by Vote Solar to Idaho Power Company
John R. Hammond Jr.
Fisher Pusch LLP 101 South Capitol Blvd., Suite 701 PO Box 1308 Boise, Idaho 83702
[e-mail]
Snake River Alliance [e-mail]
NW Energy Coalition
[e-mail] Intermountain Wind and Solar, LLC Ryan B. Frazier
Brian W. Burnett
KIRTON McCONKIE 50 East South Temple, Suite 400 P.O. Box 45120 Salt Lake City, UT 84111
[e-mail]
[e-mail] Intermountain Wind and Solar, LLC 1952 West 2425 South
Woods Cross, UT 84087
[e-mail] [e-mail]
s/ Al Luna
Al Luna, Litigation Assistant Earthjustice