20171011IPC to Staff 1-11.pdf

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LISA D. NORDSTROM
Lead Counsel
[e-mail]
October 11,2017
VIA HAND DELIVERY
Diane Hanian, Secretary
ldaho Public Utilities Commission
472 West Washington Street
Boise, ldaho 83702
Re Case No. IPC-E-17-13
New Schedules for Residential and Small General Service Customers with
On-Site Generation - ldaho Power Company's Response to the First
Production Request of the Commission Staff to ldaho Power Company
Dear Ms. Hanian
Enclosed for filing are an original and three (3) copies of ldaho Power Company's
Response to the First Production Request of the Commission Staff to ldaho Power
Company in the above matter.
Also enclosed are four (4) copies of a disk containing information being produced in
response to Staffs Request No. 8.
lf you have any questions about the enclosed documents, please do not hesitate to
contact me.
Very truly yours,
Lisa
LDN:kkt
Enclosures
P.O. Box 70 (83707)
l22I W. ldaho St.
Boise, lD 83702
LISA D. NORDSTROM (lSB No. 5733)
ldaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83701
Telephone: [phone]
Facsimile: [phone]
I nordstrom@ ida hopower. com
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
AUTHORIry TO ESTABLISH NEW
SCHEDULES FOR RESIDENTIAL AND
SMALL GENERAL SERVICE CUSTOMERS
WITH ON-SITE GENERATION
CASE NO. rPC-E-17-13
IDAHO POWER COMPANY'S
RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
THE COMMISSION STAFF
Dii l. .ir.\I l ii. rl.)
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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COMES NOW, ldaho Power Company ("ldaho Power" or "Company"), and in
response to the First Production Request of the Commission Staff to ldaho Power dated
September 20,2017, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 1
IJ l:: ia r i'r / f I'r
REQUEST NO. 1: ln 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 lnstitute 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. ls it the Company's intent that all IEEE smart meter requirements apply to
new installations? lf not, please specify or list the requirements that the Company
would require of new installations.
RESPONSE TO REQUEST NO. 1:
a. Yes, the Company intends to require that all newly installed inverters
conform with all IEEE-1547 and 1547.1 grid support capabilities and functions, also
known as smart inverter functionality. As explained in Mr. David M. Angell's testimony,
the grid support functions will help to mitigate circuit voltage deviation. To facilitate
inverter installation inspection, the Company inspectors will need an inverter certification
that they can identify. Thus, an IEEE 1547.1 compliant inverter will inherently have all
IEEE 1547 grid support functions which will provide grid support like the ability to
mitigate voltage deviation.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 2
b. Although ldaho Power continues to discuss this request with IEEE, !EEE
has not yet authorized the ldaho Power employee participating on the drafting team to
release this commercially valuable information to other persons or entities.
c. Yes, the Company intends that all IEEE-1547 and 1547.1 grid support
capabilities and functions be applied to all new installations.
The response to this Request is sponsored by David M. Angell, Transmission
and Distribution Planning Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 3
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 ldaho service territory as of June 30, 2017. How
many of these systems are equipped, respectively, with on-grid, off-grid, and grid-
interactive inverters?
RESPONSE TO REQUEST NO. 2: All ldaho Power net metered installations
use either on-grid or grid-interactive inverters. ldaho Power has not conducted an
analysis of which inverters are on-grid or grid-interactive.
The response to this Request is sponsored by David Angell, Transmission and
Distribution Planning Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 4
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?
RESPONSE TO REQUEST NO. 3: To provide context, the full quote from page
19 of Mr. Timothy E. Tatum's testimony stated 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).
Tatum D!, p. 19, lines 14-24.
The Company is currently able to gather the information that is necessary to
study various segments of customers; however, should the Commission decline to
authorize the establishment of the requested new customer classes, the Company
would have no reason to modify its class cost-of-service study or ratemaking processes.
lf the ldaho Public Utilities Commission ("Commission") determines there are
differences that warrant the establishment of new customer classes, the Company will
assign costs to the new customer classes in the class cost-of-service study and design
rates specific to those classes as part of a future rate proceeding. lf the Commission
determines no differences exist that warrant the creation of a new customer class for
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 5
customers with on-site generation, the Company will continue to allocate costs to the
residential and small general service customer classes that exist today.
The response to this Request is sponsored by Tim Tatum, Vice President of
Regulatory Affairs, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 6
REQUEST I{Q.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 (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?
RESPONSE TO REQUEST NO. 4: The Company cannot determine how many
years will be required before there are sufficient customers in Schedules 6 and 8 to
perform a stand-alone cost-of-service study. However, all customers with on-site
generation will be used to develop cost-of-service allocators for the new customer
classes, those who remain on Schedule 84 and those taking service under Schedules 6
and 8. The Company has proposed that existing residential and small general service
net metering customers remain on Schedule 84 for a period of time, where the term of
the transition period be determined by the Commission as part of a future rate
proceeding; however, they will transition to Schedules 6 and 8 at the end of the
transition period. Their usage characteristics accurately represent the segment of
customers with on-site generation, regardless of which tariff schedule they take service
under during the transition period.
The response to this Request is sponsored by Tim Tatum, Vice President of
Regulatory Affairs, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 7
REQUEST NO. 5: The Company's proposed tariffs would apply to generation
facilities fueled by solar, wind, biomass, geothermal, hydropower, and fuel cell
technology. ln 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.
RESPONSE TO REQUEST NO. 5: Chart 3 in Exhibit 9 of Ms. Connie G.
Aschenbrenner's testimony compares the average load profile calculated from the
Company's residential standard service customer class to the average load profile
calculated from the Company's entire residential net metering customer segment on the
day of the 2016 adjusted peak. That load profile for the residential net metering
customer segment included all generation types allowed under Schedule 84 and was
not limited to net metered solar facilities.
The discussion accompanying Charts 4 and 5 on pages 10-11 of Exhibit 9, as
well as on pages 11-14 of Mr. Angell's testimony, was not intended to illustrate the load
profile of a customer with solar generation but rather it was intended to illustrate that a
net zero customer utilizes all aspects of ldaho Power's grid during the hours they are
consuming energy and during the hours they are exporting energy to the grid. To
illustrate the utilization of the grid by a net zero customer, the Company selected a
single residential net metering customer who netted their usage to zero during 2016.
ln order to provide similar charts for net zero customers with generation sources
other than solar, the Company selected customers who had netted their usage to zero
during 2016 using wind and hydropower generation. The hourly usage was not
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 8
compared to the usage of a customer whose home was on the same street, as was
done in Charts 4 and 5 in Exhibit 9, because the wind and hydropower installations are
not on a residence. Thus, the wind and hydropower load profiles are not comparable to
the load of a residential standard service customer. Please see the charts included
below for the load profile of one customer with wind generation and the load profile for
one customer with hydropower generation. As with Charts 4 and 5 in Exhibit 9, there are
two graphs for each customer. The first graph is of the net hourly usage on the day of
the Company's 2016 adjusted system peak day (June 29) and the second graph,
represents the same day but uses the absolute value for any hour where the customer
generated excess energy.
The Company does not have any net metering customers, in any of its customer
segments, who generate energy using biomass, geothermal, or fuel cell technology, and
therefore, no charts were included for these generation types.
Wind Generation for Single Customer
-
2
1
0B.Y
(1)
(2)
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 9
T rrr r rII T rI
1 2 3 4 5 5 7 8 9 101112L3 14151617 18192021222324
Hour Ending
I ResidentialWind
IITIII
II
I
I
Wind Generation for Single Customer (absolute value)
7
=-Y 1
0
3
T I rlt I II T I tt
12 4 5 6 7 8 9 1011t213 141576L7 1819202t222324
Hour Ending
I Residential Wind O Exported Net Excess
Hydro Generation for Single Customer
2
1 I II,l rlll rl
=o
I I II
I
(1)
(2)
L 2 3 4 5 5 7 8 9 1011L273 14151517 18192021222324
Hour Ending
I Residential Hydro
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 1O
III l
Hydro Generation for Single Customer (absolute value)
2
=J 1
0
L 2 3 4 5 6 7 8 9 101112131415L617 18192421222324
Hour Ending
f Residential Hydro tr Exported Net Excess
The response to this Request is sponsored by David Angell, Transmission and
Distribution Planning Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 11
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REQUEST NO. 6: The Company's proposed tariffs would apply to generation
facilities fueled by solar, wind, biomass, geothermal, hydropower, and fuel cell
technology. ln 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.
RESPONSE TO REQUEST NO. 6: The discussion around cost shifting in
Exhibit 9 of the Company's Application, and also on pages 13-18 in Mr. Tatum's
testimony, references the cost shift from all existing net metering customers to non-net
metering customers. Neither the discussion, nor the analysis, was limited to solar net
metering customers.
The response to this Request is sponsored by Tim Tatum, Vice President of
Regulatory Affairs, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 12
REQUEST NO. 7: On page 4 of its Application, the Company states that it has
deployed Advanced Metering lnfrastructure (AMl) 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?
RESPONSE TO REQUEST NO. 7: Prior to the de ployment of Advanced
Metering lnfrastructure ("AMl"), ldaho Power used mechanical and solid-state meters to
measure consumption for residential and small general service customers. These
meters measured only the kilowatt-hour ("kwh") consumption, and the Company
retrieved this data monthly according to the meter read date of the customer's billing
cycle. ldaho Power's AMI system collects additional data from the AMI meters that
enables the Company to better develop cost-based rate designs. The additional data
provided by the AMI system is listed below:
. 1S-minute max demand - ldaho Power's AMI meters record the 1S-minute
maximum demand. The 15-minute maximum demand enables the Company
to implement demand rates for residential and small general service
customers using a 1S-minute maximum demand.
o Hourly kwh - ldaho Power's AMI meters record the net hourly energy
consumption and/or generation. The hourly energy data enables the
Company to implement time-of-use rates for residential and small general
service customers with on-site generation.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 13
. Hourly kilowatt ('kW') - The hourly kWh can be used as a 60-minute
maximum demand. The 60-minute maximum demand enables the Company
to implement demand rates for residential and small general service
customers using a 60-minute maximum demand.
One of ldaho Power's objectives regarding rate design is to establish prices that
primarily reflect the cost of the services provided. While the Company is not currently
proposing pricing changes for net metering or standard service customers as part of its
proposal, ldaho Power will continue to evaluate and propose modifications to the rate
design of all customer classes in future rate case proceedings.
The response to this Request is sponsored by Tim Tatum, Vice President of
Regulatory Affairs, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 14
REQUEST NO. 8: ln Exhibit 9 , the Company states that, as of December 31,
2016, ldaho Power's net metering service consisted of 1,067 active systems. For each
system that was connected to ldaho 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.
RESPONSE TO REQUEST NO. 8: Please see the attached Excel file which
includes the hourly net energy consumption for all net metered customers who had an
AMI meter and who were taking net metering service for the entire period between
January 1,2016, through December 31,2016. The Company has provided the schedule
under which the net metering customer was taking service and the county in which the
customer was located.
It is important to note that the attached data is net hourly energy
consumption/production data by customer, not by svstem. A customer may have
multiple systems, possibly with different generation sources, attached to a service point
(meter). ln that case, each generation source is considered a different system;
however, because the energy consumption is metered at a single point, a customer with
multiple systems is one customer. Please reference footnote No. 3 in Exhibit g.
The response to this Request is sponsored by David Angell, Transmission and
Distribution Planning Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 15
REQUEST NO. 9: Schedule 84 includes a one meter option for customers who
take service under schedules other than 1 , 4, 5, and 7, 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 than 2o/o of their BLC. Under
the Company's proposal, how would these customers be able to receive net metering
service?
RESPONSE TO REQUEST NO. 9: Under the Company's proposal, they will
continue to take service under the existing net metering schedule (Schedule 84). The
Company is requesting that Schedule 84 be closed to new service for only residential
and small general service customers.
The response to this Request is sponsored by Connie Aschenbrenner, Rate
Design Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 16
REQUEST NO. 10: Schedule 84 includes a two meter option for customers who
take service under schedules other than 1 , 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?
RESPONSE TO REQUEST NO. 10: Under the Company's proposal, they will
continue to take service under the existing net metering schedule (Schedule 84). The
Company is requesting that Schedule 84 be closed to new service for only residential
and small general service customers with on-site generation.
The response to this Request is sponsored by Connie Aschenbrenner, Rate
Design Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 17
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
lnverter with Export Control, or similar device? lf 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.
RESPONSE TO REQUEST NO. 11: Yes.Customers with on-site generation
systems that are connected in parallel with the ldaho Power system will be required to
take service under the new schedules. An on-site generation system is connected in
parallel if it is connected to and receives voltage from ldaho Power's system. A
customer using a Grid Tie Limiter, a Grid lnverter with Export Control, or a similar
device is still connected in parallel with the system.
A customer may use on-site generation to reduce their power consumption and
take service on schedules other than Schedules 6 and 8 if their system is not connected
in parallel to ldaho Power's system. For example, a customer could use a mechanical
transfer switch such that they either consume energy from ldaho Power or consume
energy from their on-site generation system with no ability to feed power from the on-
site generation back onto ldaho Power's system. This system would not be connected
in parallel to the electric grid.
The response to this Request is sponsored by David Angell, Transmission and
Distribution Planning Manager, ldaho Power Company.
DATED at Boise, ldaho, this 11th day of October 2017.
D M
Attorney for ower Company
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 18
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 11th day of October 2017 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
Sean Costello
Deputy Attorney General
ldaho Public Utilities Commission
47 2 W est Wash i ngton (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
ldahydro
C. Tom Arkoosh
ARKOOSH LAW OFFICES
802 West Bannock Street, Suite 900
P.O. Box 2900
Boise, ldaho 83701
ldaho Gonservation League
Benjamin J. Otto
ldaho Conservation League
710 N.6th st.
Boise, ldaho 83702
Matthew A. Nykiel
ldaho Conservation League
102 South Euclid #207
P.O. Box 2308
Sandpoint, Idaho 83864
Idaho lrrigation Pumpers Association, lnc.
Eric L. Olsen
ECHO HAWK & OLSEN, PLLC
505 Pershing Avenue, Suite 100
P.O. Box 6119
Pocatello, Idaho 83205
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IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 19
Anthony Yanke!
12700 Lake Avenue, Unit 2505
Lakewood, Ohio 44107
Auric Solar, LLC
Preston N. Carter
Deborah E. Nelson
GIVENS PURSLEY LLP
601 W. Bannock Street
Boise, ldaho 83702
Elias Bishop
Auric Solar, LLC
2310 S. 1300 W.
West Valley City, Utah 84119
Vote Solar
David Bender
Earthjustice
3916 Nakoma Road
Madison, Wisconsin 537 11
Briana Kobor
Vote Solar
360 22nd Street, Suite 730
Oakland, California 94612
City of Boise
Abigail R. Germaine
Deputy City Attorney
Boise City Attorney's Office
150 N. Capitol Blvd.
P.O. Box 500
Boise, ldaho 83701-0500
ldaho Clean Energy Association
C. Tom Arkoosh
ARKOOSH LAW OFFICES
P.O. Box 2900
Boise, ldaho 83701
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IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 20
David H. Arkoosh
Law Office of David Arkoosh
P.O. Box 2900
Boise, ldaho 83701
Sierra Club
Kelsey Jae Nunez
KELSEY JAE NUNEZLLC
920 North Clover Drive
Boise, ldaho 83703
Zack Waterman
Director, ldaho Sierra Club
503 West Franklin Street
Boise, ldaho 83702
Michael Heckler
3606 North Prospect Way
Garden City, ldaho 83714
Snake River Alliance
NW Energy Coalition
John R. Hammond, Jr.
FISHER PUSCH LLP
101 South Capitol Boulevard, Suite 701
Boise, ldaho 83702
lntermountain 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, Utah 84111
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[e-mail]
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 21
Doug Shipley
Dale Crawford
lntermountain Wind and Solar, LLC
1952 West2425 South
Woods Cross, Utah 84087
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dale@ imwindandsolar.com
Ki T , Executive Assistant
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 22