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Home My WebLink About20171031IPC to Auric Solar 1-4.pdf3E$Uffi* October 31,2017 VIA HAND DELIVERY Diane Hanian, Secretary ldaho Public Utilities Commission 47 2 W est Wash i ngton 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 Auric Solar's First Production Requests to ldaho Power Company Dear Ms. Hanian: Enclosed for filing are an original and three (3) copies of ldaho Power Company's Response to Auric Solar's First Production Requests to ldaho Power Company in the above matter. lf you have any questions aboutthe enclosed documents, please do not hesitate to contact me. Very truly yours, LISA D. NORDSTROM Lead Counsel I nordstrom@idahooower.com LDN:kkt Enclosures RECEIVED l0llOCT 3l Plt hr 32 ID r"rTlt"lT Lisa D. Nordstrom Hn''Cilif,h18*'o* An loAcoRP company P.O. Box 70 (837Oi) 1221 W. ldaho 5t. Boise, lD 83702 LISA D. NORDSTROM (lSB No. 5733) ldaho Power Company 1221West ldaho Street (83702) P.O. Box 70 Boise, ldaho 83707 Telephone: (208) 388-5825 Facsimile: (208) 388-6936 I n ord strom @ id a h opowe r. com 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 GENERAT]ON RECEIVED ?0llOCT 3l Pll lr: 32 lLlAli0 PUBLIC, IT:I.ITIES COMMISSION Attorney for ldaho Power Company BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION ) ) ) ) ) ) ) ) CASE NO. IPC-E-17-13 IDAHO POWER COMPANY'S RESPONSE TO AURIC SOLAR, LLC'S FIRST PRODUCTION REQUESTS TO IDAHO POWER COMPANY COMES NOW, ldaho Power Company ("ldaho Power" or "Company"), and in response to Auric Solar, LLC's First Production Requests to ldaho Power dated October 10,2017, herewith submits the following information: IDAHO POWER COMPANY'S RESPONSE TO AURIC SOLAR, LLC'S FIRST PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 1 REQUEST NO. 1: Please identify and specifically describe any changes in ldaho Power's net metering service since July 3, 2013 that have materially affected ldaho Power's system, including (without limitation) ldaho Power's generation, transmission, or distribution systems. RESPONSE TO REQUEST NO. 1: ldaho Power has experienced significant grovuth in the number of customers taking net metering service. The growth has contributed to the challenges listed in the Company's responses to Vote Solar's Request Nos.21 and 39. The response to this Request is sponsored by Dave M. Angell, Transmission and Distribution Planning Manager, ldaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO AURIC SOLAR, LLC'S FIRST PRODUCTION REQUESTS TO IDAHO POWER COMPANY.2 REQUEST NO. 2: For all changes identified in response to Request No. 1, please identify and specifically describe the material effects on ldaho Power's system. Please include in your response the approximate date on which the material effects first occurred; the nature of the material effects; the steps ldaho Power has taken to address the effects; the cost of the steps ldaho Power has taken to address the effects; and when ldaho Power provided notice to the Commission of the material effect. RESPONSE TO REQUEST NO. 2: Please see the Company's response to Request No. 1. The response to this Request is sponsored by Dave M. Angell, Transmission and Distribution Planning Manager, ldaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO AURIC SOLAR, LLC'S FIRST PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 3 REQUEST NO. 3: ln paragraph 15 of the Application, speaking about residential and small general service ("R&SGS") customers with on-site generation, ldaho Power states that "[e]stablishing 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 the Company's system." Please identify and specifically describe al! efforts or attempts ldaho Power has made, in the past ten years, to study R&SGS customers with on-site generation. Please include in your response the efforts or attempts ldaho Power has made to study these customers; the approximate start and end dates for each effort or attempt; and the results of such efforts or attempts to study these customers, including any data from any such effort or attempt to study these customers. RESPONSE TO REQUEST NO. 3:ldaho Power performed an analysis of customers with on-site generation in its application to modify net metering service filed with the ldaho Public Utilities Commission ("Commission") in 2012. This publicly available analysis is detailed in Case No. IPC-E-12-27. Since then, ldaho Power has performed analyses of the residential and small general service customers with on-site generation in preparation of the 2016 Net Metering Status Report ("2016 Report"), the 2017 Net Metering Status Report ("2017 Report"), and for this case. Please see the response to Vote Solar's Request No. 34 for all workpapers supporting the analyses performed for the 2016 Report. The analysis for the 2016 Report was performed in Q1 and Q2 2016. IDAHO POWER COMPANY'S RESPONSE TO AURIC SOLAR, LLC'S FIRST PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 4 Please see the response to Vote Solar's Request No. 33 for all workpapers supporting the analyses performed for the 2017 Report. The analysis for the 2017 Report was performed in Q1 and Q2 2017. Please see the response to Vote Solar's Request No. 20 for all workpapers supporting the analyses performed for this case. The response to this Request is sponsored by Connie Aschenbrenner, Rate Design Manager, ldaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO AURIC SOLAR, LLC'S FIRST PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 5 REQUEST NO. 4: In paragraph 15 of the Application, speaking about R&SGS customers with on-site generation, ldaho Power states that "[e]stablishing 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 the Company's system." Please identify and specifically describe why a separate customer class is needed to study R&SGS customers with on-site generation. Please include in your response a description of any information or data that is not currently available, but that would become available by establishing a new customer class. Please also identify and specifically describe in your response all impediments to studying R&SGS customers with on-site generation under the current net metering schedule. RESPONSE TO REQUEST NO. 4: 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 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 that those classes as part of a future rate proceeding. If the Commission determines no differences exist that warrant the creation of a new customer class for customers with on-site generation, the Company will continue to allocate costs to the residential and smal! general service customer classes that exist today. IDAHO POWER COMPANY'S RESPONSE TO AURIC SOLAR, LLC'S FIRST PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 6 The response to this Request is sponsored by Tim Tatum, Vice President of Regulatory Affairs, ldaho Power Company. DATED at Boise, ldaho, this 31st day of October 2017. LISA D Attorney for ldaho Power Company IDAHO POWER COMPANY'S RESPONSE TO AURIC SOLAR, LLC'S FIRST PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 7 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 31't day of October 2017 I served a true and correct copy of IDAHO POWER COMPANY'S RESPONSE TO AURIC SOLAR, LLC'S FIRST PRODUCTION REQUESTS TO IDAHO POWER COMPANY 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 472 West Washington (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 Conseruation League Matthew A. Nykiel ldaho Conservation League 102 South Euclid #207 P.O. Box 2308 Sandpoint, ldaho 83864 Benjamin J. Otto ldaho Conservation League 710 N. 6th st. Boise, ldaho 83702 ldaho lrrigation Pumpers Association, lnc. Eric L. Olsen ECHO HAWK & OLSEN, PLLC 505 Pershing Avenue, Suite 100 P.O. Box 6119 Pocatello, ldaho 83205 _Hand Delivered _U.S. Mail _Overnight Mail _FAXX Email sean.costello@puc.idaho.qov _Hand Delivered _U.S. Mail _Overnight Mail _FAXX Email tom.arkoosh@arkoosh.com eri n. cecil@arkoosh.com _Hand Delivered _U.S. Mail _Overnight Mail _FAXX Email mnvkiel@idM _Hand Delivered _U.S. Mail _Overnight Mail _FAXX Email botto@idahoconservation.orq _Hand Delivered _U.S. Mai! _Overnight Mail _FAXX Email elo@echohawk.com IDAHO POWER COMPANY'S RESPONSE TO AURIC SOLAR, LLC'S FIRST PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 8 Anthony Yankel 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 1 1 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 _Hand Delivered _U.S. Mail _Overnight Mail _FAXX Email tqny@yankel,net _Hand Delivered _U.S. Mail _Overnight Mail _FAXX Email prestoncarter@qivenspurslev.com den@qivenspursley. com _Hand Delivered _U.S. Mail _Overnight Mail _FAXX Email elias.bishop@auricsolar.com _Hand Delivered_U.S. Mail _Overnight Mail _FAXX Email dbender@earthiustice.oro _Hand Delivered _U.S. Mail _Overnight Mail _FAXX Email briana@votesolar org _Hand Delivered _U.S. Mail _Overnight Mail _FAXX Email aqermaine@citvofboise.org _Hand Delivered _U.S. Mail _Overnight Mail _FAXX Email tom.arkoosh@arkoosh.com eri n. ceci l@a rkoosh. com IDAHO POWER COMPANY'S RESPONSE TO AURIC SOLAR, LLC'S FIRST PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 9 David H. Arkoosh Law Office of David Arkoosh P.O. Box 2900 Boise, ldaho 8370'1 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 AIIiance NW Energy Goalition 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 _Hand Delivered _U.S. Mail _Overnight Mail _FAXX Email david@arkooqhlalu.cann _Hand Delivered _U.S. Mail _Overnight Mail _FAXX Email _Hand Delivered _U.S. Mail _Overnight Mail _FAXX Email zack.waterman@sierraclub.orq _Hand Delivered _U.S. Mail _Overnight Mail _FAXX Email michael.p.heckler@qmail.com _Hand Delivered _U.S. Mail _Overnight Mail _FAXI Email irh@fisherpusch.com wwi lson@snakeriveral I ia nce. org dieqo@nwenerqv.org _Hand Delivered _U.S. Mail _Overnight Mail _FAXX Email rfrazier@kmclaw.com bburnett@kmclaw.com IDAHO POWER COMPANY'S RESPONSE TO AURIC SOLAR, LLC'S FIRST PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 1O Doug Shipley Dale Crawford lntermountain Wind and Solar, LLC 1952 West2425 South Woods Cross, Utah 84087 _Hand Delivered _U.S. Mail _Overnight Mail _FAXX Email douq@imwindandsolar.com dale@imwindandsolar.com Towell Assistant IDAHO POWER COMPANY'S RESPONSE TO AURIC SOLAR, LLC'S FIRST PRODUCTION REQUESTS TO IDAHO POWER COMPANY - 11