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Home My WebLink About20171027Vote Solar 49-57 to IPC.pdfDavid Bender, WI Bar # 1046102 (Pro Hac Vice) Earthjustice 3916 Nakoma Road Madison, WI537l I (4rs) e77-s727 db ender(@ earthj usti c e. or e IN THE MAITER OF THE APPLICATION OF IDAHO POWER COMPANY FOR AUTHORITY TO ESTABLISH NEW SCHEDULES FOR RESIDENTIAL AND SMALL GENERAL SERVICE CUSTOMERS WITH ON-SITE GENERATION RECEIVED 20llOCT 27 Pll S: 02 tillltic PUilLlc ri'l li-ll IES CCI'IMlSSlON BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION ) ) ) ) ) ) ) CASE NO. IPC-E-17-13 THIRD SET OF DATA REQUESTS BY VOTE SOLAR TO TDAHO POWER COMPANY Vote Solar hereby serves its third 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 November 17 ,2017 . INSTRUCTIONS l. Please provide copies of responses to the following contacts: Briana Kobor Vote Solar 360 22"d Street, Suite 730 Oakland, CA946l2 bri ana(ru v ot e so I ar. or g 2. Whenever possible, Vote Solar prefers to receive electronic copies of data responses either by email or on CD. Third 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: (208) 345-5183 Fax: (208) 906-8663 Email: kahlc(okah lebeckerlaw.com David Bender Earthjustice 3916 Nakoma Road Madison, WI 53711 dbender(a earthj ustice. or g 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 ldaho Power Company is requested to supplement its responses as necessary and as additional information becomes available. 5. [n 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, identifu 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. tf 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 ifnecessary to the understanding ofthe 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. 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. 2 Third 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 49. Reference your response to Vote Solar Request No. 4. a. Please identify the nameplate capacity and generation resource (i.e., solar PV, wind, hydro, etc.) for each generator interconnected on Jamieson circuit 012. b. For the seven substations identified as having customer-sited distributed generation that contributed to reverse power flow conditions, please provide the nameplate capacity, interconnection date, and generation resource for each generator served by that substation and, separately for each generator, the tariff(s) and/or contracts pursuant to which it takes service from, and sells electricity to, Idaho Power Company. 50. Please identify each substation on your system and, for each, please provide: a. The total number of connected distribution circuits; b. The total number of residential customers served on each circuit; c. The total number of small general service customers served on each circuit; d. The total number of distribution transformers (line transformers) serving residential customers on each circuit; Third Set of Data Requests by Vote Solar to Idaho Power Company J e. The total number of distribution transformers (line transformers) serving small general service customers on each circuit; and f. The total number, nameplate capacity, and generation type of residential and small commercial class, customer-sited, net metered, distributed generation connected to each circuit. 5l. Reference your response to Vote Solar Request No. 5(a). a. Please identify, by date, time, and substation, each instance when excess energy from customer-sited distributed generation flowed to the transmission system. b. Please identify, for each instance identified in response to 3(a), above, the amount of generation from net-metered, customer-sited distributed generation, and the amount from other interconnected generation (e.g., PURPA QF generation). 52. Reference your response to Vote Solar Request No. s(cXi). Please identify the date, time, and volume of energy from customer-sited distributed generation that was sold in the wholesale market since January 1,2015. 53. Reference Angell Direct at 12 and your response to Vote Solar Data Request No. 6. Please identify the distribution substation that the "Net Zero Net Metering Customer" and the "Standard Service Residential Customer" are served from and, for each substation, the hourly loads for each hour on June 29,2016. 54. Reference your response to Vote Solar Data Request No. 13, Aschenbrenner Direct at 2,line 15,7 ,line 16, 16,lines 6-8, 17, line 6, 27 ,line I 5, : If the Company is not proposing a cost assignment methodology in this case, is the Company basing its contentions in this case that customers with on-site distributed generation are causing a "cost shift" and receiving a "subsidy'' on the methodology used in the 2017 Report to the Commission, Aschenbrenner Direct Exhibit 9 and as described in response to Vote Solar Data Request No. 17? If not, please explain the methodology used to determine a "cost shift" and "subsidy." 55. Please provide the date, hour, and magnitude of each monthly system peak during each ofthe last ten (10) years. 4 Third Set of Data Requests by Vote Solar to Idaho Power Company 56. Reference your response to Vote Solar Data Request Nos. l5(a) and l6 and Mr. Tatum's Direct at pp. 4-5. a. Please explain how costs incurred and prices paid by individual customers would be "perfectly align[ed]." For example, would aligning costs within the mean of Mr. Tatum's testimony mean that the individual customer's contribution to class cost allocation in the cost of service study would match revenues collected from that customer? If not, please explain how perfectly aligned costs and prices paid would be determined. b. Please state whether you contend that the existing retail rate results in inappropriate cost shifting and intra class subsidy to customers with distributed generation who do not export (i.e., do not net meter) but instead use all generation to offset load served from the Company (i.e., through battery storage or by sizing generation to never exceed load). 57. Reference your response to Vote Solar Data Request l7(b). a. Please identify each way in which the methodology used to quantify the estimated cost shifts in 2015 and2016 were different from the methodology used to assign costs during the Company's last general rate case. b. Please identify the date and hour of the system coincident demand and residential class non-coincident demand that was used to determine "the residential customer class's functionalized and classified revenue requirement authorized in the Company's 201I GRC" and the date and hour of the system coincident demand and the residential net metering segment's non-coincident demand used to estimate the net metering segment's revenue requirement. c. Please define "the absolute value ofthe average usage in that hour" as used on page 23 of your response to Vote Solar Data Request l7(b) and how it differs from "the average of each customer's positive consumption." Third Set of Data Requests by Vote Solar to Idaho Power Company 5 DATED: October 27,2017 Respectfu lly submitted. s/ David C. Bender David C. Bender Earthjustice 3916 Nakoma Road Madison, WI 53711 (202\ 667-4s00 dbcndcr(rq carlhj usti cc. org J. Kahle Becker (ISB No. 7408) 223 N. 6s St., Suite 325 Boise,Idaho 83702 Phone: (208) 345-5183 Fax: (208) 906-8663 Email: kahle(gukahlebeckerlaw.com 6 Third Set of Data Requests by Vote Solar to Idaho Power Company CERTIFICATE OF SERVICE I HEREBY CERTIFY that I have this 27ft day of October 2017, served the foregoing THIRD SET OF DATA REQUESTS BY VOTE SOLAR TO IDAHO POWER COMPAI\Y upon all parties of record in this proceeding, via the manner indicated: FedEx and Electronic Mail Diane Hanian Commission Secretary Idaho Public Utilities Commission 47 2 W est Washington Street Boise, lD 83702 Diane. holt(ri)puc. idaho. gov (Three copies) Electronic Mail Lisa D. Nordstrom Idaho Power Company 1221 West Idaho Street (83702) P.O. Box 70 Boise, D 83707 I nordstrom(rD i dahopo wer. 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@i dahopower. com caschenbrenner(didahopower. com Sean Costello Deputy Attorney General Idaho Public Utilities Commission 47 2 West Washington (837 02\ PO Box 83720 Boise, D 83720-0074 Sean.costel lo(rqpuc. idaho. gov 7 Third Set of Data Requests by Vote Solar to Idaho Power Company MatthewA. Nykiel Idaho Conservation League P.O. Box 2308 102E,. Euclid, #207 Sandpoint, ID 83864 mnyk i c I (ru i dahoconser.vation.org Abigail R. Germaine Deputy CityAttomey BOISE CITY ATTORNEY'S OFFICE 150 N. Capitol Blvd. P.O. Box 500 Boise, Idaho 83701-0500 a germai nc(ac i tyo fbo i se. org David Bender Earthjustice 3916 Nakoma Road Madison, WI53711 dbender@)earthj ustice. org Briana Kobor Vote Solar 360 22"d Street, Suite 730 Oakland, CA946l2 bri ana(g) v o tes o I a r. org Idaho Irrigation Pumpers Association, [nc. Eric L. Olsen ECHO HAWK & OLSEN, PLLC 505 PershingAve., Ste. 100 P.O. Box 6119 Pocatello, Idaho 83205 elo(ruechclhawk.com AnthonyYankel 12700 Lake Ave., Unit 2505 Lakewood, OH44107 tonlu (rDlzankel.net Elias Bishop Auric Solar, LLC 23r0 s. 1300 w. West Valley City, UT 84119 El i as. bi shop(gtauricso I ar. com 8 Third 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 prestoncarter(@ givenspursley. com den@ givenspursley.com Idahydro clo C. TomArkoosh, and Idaho Clean Energy Association c/o C. Tom Arkoosh Arkoosh Law Offrces 802 W. Bannock Street, Suite 900 P.O. Box 2900 Boise,ID 83701 Tom. arkoosh@arkoosh. com E ri n. cec i I (g)arkoo sh. com David H. Arkoosh Idaho Clean EnergyAssociation c/o Law Office of DavidArkoosh P.O. Box 2817 Boise, ID 83701 dav i d (d arkoo sh I aw. c om Zack Waterman IDAHO SIERRA CLUB 503 W. Franklin St. Boise, ID 83702 Zach. waterman(d si erracIub. org Kelsey Jae Nunez KELSEY JAE NUNEZLLC 920 N. Clover Dr. Boise,ID 83703 ke I sev(ra)ke I sevi aenunez. com Afforney for Sierra Club Michael Heckler 3606 N. Prospect Way Garden City,ID 83714 M i chael. p. heck I er(rD gmai l.com 9 Third Set of Data Requests by Vote Solar to Idaho Power Company John R. Hammond Jr. Fisher Pusch LLP l0l South Capitol Blvd., Suite 701 PO Box 1308 Boise,Idaho 83702 irh(r0fisherpusch.com Snake RiverAlliance wwi lson(a,,snaleriveralliance.org NW Energy Coalition diegoGDnwenergy.org Intermountain Wind and Solar, LLC Ryan B. Frazier Brian W. Burnett KIRTON MoCONKIE 50 East South Temple, Suite 400 P.O. Box 45120 Salt Lake City, UT 84111 rfiaz i er(glkmc I a w. com bb u rn ct t (/Dkn r c I aw.q eur Intermountain Wind and Solar, LLC 1952 West 2425 South Woods Cross, UT 84087 dou q(D imwindandso I ar. com dal e@imwindandsolar. com s/ Al Luna Al Luna, Litigation Assistant Earthjustice Third Set of Data Requests by Vote Solar to Idaho Power Company l0