20171031IPC to Vote Solar 20-48.pdf

SEffi*.
An IDACORP Companv
LISA D. NORDSTROM
Lead Counsel
I [e-mail]
RECE IVED
?0lI CICT 3l Pll tr: 3t+
.,,', l?#{'Cdi,ffi i 8u, or,,
October 31,2017
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 Vote Solar's
Second Set of Data 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 Vote Solar's Second Set of Data Requests to ldaho Power Company in the
above matter.
Also enclosed are four (4) copies of a disk containing information being produced in
response to Vote Solar's Request Nos. 20, 23-25,27 ,33-39 and 48.
lf you have any questions about the enclosed documents, please do not hesitate to
contact me.
Very truly yours,
bo--e.fl*,Lt*
Lisa D. Nordstrom
LDN:kkt
Enclosures
P.O. Box 70 (83707)
1221 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 83707
Telephone: [phone]
Facsimile: [phone]
I n ord strom @ id a h opower. com
RECEIVED
?01? 0CT 3l Pl,l trr Blr
ur t1?#sccffiflhl8r,o*
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILIT!ES COMMISSION
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
AUTHORITY TO ESTABLISH NEW
SCHEDULES FOR RESIDENT]AL AND
SMALL GENERAL SERVICE CUSTOMERS
WITH ON-SITE GENERATION
)
)
)
)
)
)
)
)
CASE NO. !PC-E-17-13
IDAHO POWER COMPANY'S
RESPONSE TO VOTE SOLAR'S
SECOND SET OF DATA
REQUESTS TO IDAHO POWER
COMPANY
COMES NOW, ldaho Power Company ("ldaho Power" or "Company"), and in
response to Vote Solar's Second Set of Data Requests to ldaho Power dated October
10,2017, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
SECOND SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 1
REQUEST NO. 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.
RESPONSE TO REQUEST NO. 2Ol. Please see the Attachment to the
Company's response to Request No. 24 for the workpapers to support Figure 1 in the
Company's Application.
Please see the Attachment to the Company's response to Request No. 48 for the
workpapers to support the payback period calculation in Mr. Tatum's testimony.
Please see Attachment 1 for the workpapers to support Table 1, Table 2, and
Figure 1 in Ms. Aschenbrenner's testimony.
Please see Attachment 2 for the workpapers to support Table 3 in Ms.
Aschenbrenner's testimony.
Please find all other workpapers to support Ms. Aschenbrenner's testimony in the
following responses:
. Aschenbrenner Direct - Figure 2. Please see Attachment 2 to the
Company's response to Request No. 33.
o Aschenbrenner Direct - Figure 3: Please see the Attachment to the
Company's response to Request No. 24
o Aschenbrenner Direct - Figure 4. Please see the Attachment to the
Company's response to Request No. 25
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
SECOND SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 2
Please see Attachment 3 for the workpapers to support Figure 1 and Figure 2 in
Mr. Angell's testimony.
Please find all other workpapers to support Mr. Angell's testimony in the following
responses:
. Angell Direct - Figure 3: Please see the Attachment to the Company's
response to Request No. 37.
. Angell Direct - Figure 4: Please see the Attachment to the Company's
response to Request No. 38.
The response to this Request is sponsored by Connie Aschenbrenner, Rate
Design Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
SECOND SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 3
REQUEST NO. 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.
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.
RESPONSE TO REQUEST NO. 21:
a. ldaho Power agrees with the National Renewable Energy Laboratory's
("NREL") definition of high penetration photovoltaic ("PV") published in the High-
Penetration PV lntegration Handbook for Distribution Engineers on January 2016. The
NREL defines high penetration PV as the level at which the distribution network has a
high likelihood of experiencing voltage, thermal, and/or protection criteria violations.
Every feeder has a unique topology and the level of distributed energy resources
("DER") penetration at which each feeder will experience voltage management, short
circuit detection and/or islanding will be different.
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
SECOND SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 4
b. ldaho Power has experienced operational challenges as a result of current
levels of DER penetration. The following are descriptions of the operational challenges:
o The generation output of DER has created challenges for providing
alternate service to customers through distribution circuit tie-switches,
normally open switches between distribution circuit that are used to
supply customers during circuit maintenance and outage. This has
required the replacement of single-phase switches with gang-operated
three-phase switches and additional switching procedures, shown in
Figure 1.
Figure 1. Distribution Circuit map notification of additional operating
procedures.
. The potential of closing into an out-of-synchronism generator.
c. ldaho Power has experienced the following voltage management
challenges due to current levels of DER penetration:
. DER connected to the Blue Gulch substation caused high voltage
issues on the distribution circuit due to control challenges among
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
SECOND SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 5
P7
--4^_..-" I/elt4
g
ait
G.l
roo /4toExr
-Tl
r18\ itIT
e
>t
ffi*(
5
o.tt$
T
CA
MLNR_043
MAP 1
multiple voltage regulating devices and capacitors, as illustrated in
Figure 2.
Figure 2. Capacitor Operation
25
127 r
"20
ooo-o
IoNr
o)o)o=o
1 26 'l15
125 10
0)
=o(L
2
1 /5
12 0
\,
-5
Jul 19,00:00 Jul 19, 06:00 Jul 19, 12:00
Date
Jul 19, 18:00 Jul20, 00:00
2017
1 Capacitor goes off, rapidly decreasing the voltage
2 Capacitor turns on, increasing the voltage at the substation
beyond the acceptable upper bound
a The Mora substation experienced high voltage at the low side of the
substation transformer due to reverse power flow at the substation.
The Load Tap Changer ("LTC") was unable to quickly adjust to the
change in the power direction, causing high voltage. Figure 3 provides
an illustration.
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
SECOND SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 6
-
Feeder Voltage
-Feeder
MW
-DER
MW
-Feeder
MVAR
I
I
t
Figure 3. LTC operation at Mora Substation
't29
128
5<_l
0
e
.l ^ =
o,;o
,-fO 1(Ec)tr
ooo-o
?oN
oo)o=o
126
125
124
123
122
121
127 -
00:00 02:00 04:00 06:00 08:00 10:00 12:00 14:00
Date
5
-2016:00 '18:00
Ma( '11,2017
a
a
a
I Due to the fast ramp rate of the DER, the LTC at the substation
was not able to react fast enough, causing high voltage, above
128 Vol ("V"), at the substation.
Distribution circuits may experience high voltage when high
penetration of DER occur on the circuits with substation transformer
based circuit capacitor controls. High voltage was experienced near
the generation site of a DER on the Gary substation due to the
operation of the Company's capacitors.
High voltage conditions occur when the Cairo distribution circuits with
DER are being sourced from Ontario substation for maintenance or
repair.
Jamieson substation experiences high voltage at multiple locations on
the feeder. Figure 4 illustrates the voltage reads at Jamieson above
126V on a 120-V base.
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
SECOND SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 7
-
Substation Voltage
-Substation
Power
Figure 4. High Voltage at Jamieson Substation
High Voltage JMSN
120Feb Mar Apr May Jun Jul
Date
Aug Sep Oct Nov
2017
o The Company experiences high voltage at the point of interconnection
for several DER interconnections. See the response to Request No.
39 for a list of each time ldaho Power has experienced a voltage
violation as a result of current DER penetration levels.
d. ldaho Power has not documented any short circuit detection issues as a
result of current levels of DER penetration.
e. On May 6, 2016, a DER interconnected to the Tamarack 012 distribution
circuit operated in an islanded condition. The documentation of the event follows:
A customer operates a DER that is interconnected to ldaho Power's Tamarack
Substation 012 distribution circuit. The following sequence of events were recorded on
May 6, 2017, for the Tamarack 012 distribution circuit:
8:00 - The Regional System Operator opened Tamarack 0114 and 012A
d istribution circu it breakers.
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
SECOND SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 8
0)U'(5ojoN
oo)(5
=o
130
128
126
124
122
I Voltage AMIoo-- -
-EOOT
a
O
-
?O
--
|1 il lr
l
i
ll
A troubleman waited by the 114T2 Tamarack-Starkey 138 kilovolt ('kV")
switch with the intent of opening it after the Tamarack load was dropped by 011A
and 012A.
The troubleman heard the noise from the opening of Tamarack 011A and
012A breakers but saw that the lights were still on at the customer's premise.
The troubleman went to the customer's site to investigate before opening
the 138 kV switch.
The troubleman approached one of the pad mount transformers serving
the customer and heard the typical 60 Hz transformer hum. lt appeared that all
the customer's facility lights and machinery were operating.
The troubleman measured 8,000 V on the Tamarack 012 overhead.
The troubleman approached the customer and asked if the generator was
on. The customer said no. They continued to talk but the customer insisted the
generator must be off. The troubleman asked the customer to go and visually
check whether the generator was on or off.
8:20 - The customer approached the generator and seconds later all of the lights
went out as the generator shut down.
The customer said that he didn't think the generator could operate when
the ldaho Power feeder was deenergized.
The troubleman said that the generator had been on for about 20 minutes,
but was now off.
8:27 - The troubleman opened the 114T2 Tamarack-Starkey switch.
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
SECOND SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 9
8:30 - Tamarack 011A closed by the Regional System Operator and the feeder
was energized.
8:31 - Tamarack 012A closed by the Regional System Operator and the feeder
was energized.
The voltage and power flow of the Tamarack 012 distribution circuit during the
islanding condition is shown in Figure 5. The shaded region indicates the time that the
DER operated in an island condition.
Figure 5. DER Operating in an lslanding Condition
DER Operating in an lslanding Condition
-1.5
07.45 08:00
140
120
$'.rooo-o?80oN
=o6oo)g
9ao
20
2
1
2.5
.5
't 9
=0s Eo)05
!-os Elr
-1
-2008:15 08:30
Time of the Day
08:45 09:00
May 06, 2016
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 VOTE SOLAR'S
SECOND SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 1O
l---
-O-oenI-
l/l/1/
+
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
II
I
I
I
!
---*?
I
I
I
I
I
t
I
I
I
I
I
I
I
I
I
I
I
REQUEST NO. 22: Reference the following quote from page 12 of the
Application: "To reduce these operational challenges, ldaho 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.
RESPONSE TO REQUEST NO.22:
a. The following table lists the controllers ldaho Power has replaced as a
result of DER penetration, by year, for each of the last ten years. All of the controllers
identified in the table below were replaced because of voltage issues created by the
interconnection of DER.
b. i. Please see the table referenced in a.
ii. Please see the table referenced in a. Pursuant to Schedule 72, the
Seller pays all costs of interconnecting a Generation Facility to the Company's
system. This payment is recorded as a Contribution in Aid of Construction
(.C|AC") which offsets the expenditure resulting in a net plant amount of $0.
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
SECOND SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 11
iii. The Company is not able to provide the remaining book life,
undepreciated balance of the controller that was replaced, or the salvage credit
of that controller. The controller is not a property unit, it is a minor component of
the substation main transformer property unit.
Project expenditures are tracked by identified property units rather than individual
components. Depreciation is managed on a group asset level rather than individual
component basis. As stated above, a controller is not a unit of property, and therefore,
any replacement activity would not be capitalized. The salvage value applied to each
project is based on a percentage allocation of the monthly salvage receipts to all
projects with equipment removal labor hours charged in that month. Any salvage
amount applied to a project that includes the replacement of a controller is not directly
related to the controller value. Additionally, any salvage applied to a project would
reduce the CIAC requirement amount under Schedule 72, effectively reducing the cost
to the Seller.
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
SECOND SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 12
Controller Year Expenditure Capitalized
Expenditure
Dry Creek Dairy Digester LTC Controller 2008 $2,900 00 -$2,900 00 $0.00
Nyssa T061 LTC Controller 2015 $3,100.00 -$3,100.00 $0 00
Adrian T061 LTC Controller 2015 $3,000.00 -$3,000.00 $0 00
Vale T061 LTC Controller 2015 $3,000.00 -$3,000 00 $0 00
Holly T061 LTC Controller 2016 $3,100.00 -$3,100.00 $0 00
Hope T061 LTC Controller 2016 $3,000.00 -$3,000.00 $0 00
Mora LTC Controller 2016 $3,000.00 -$3,000.00 $0.00
Sinker Creek T131 Tap Changer 2017 $3,100.00 -$3,100.00 $0 00
The response to this Request is sponsored by Dave M. Angell, Transmission and
Distribution Planning Manager, Idaho Power Company.
Offsetting CIAC
REQUEST NO. 23: Please provide ldaho Power's Response to Staffs
Production Request Nos.6 andl in Case No. IPC-E-O1-39.
RESPONSE TO REQUEST NO. 23: Please see the Attachment for ldaho
Power's Response to Staffs Production Request Nos. 6 and 7 in Case No. IPC-E-O1-
39.
The response to this Request is sponsored by Kimberly Towell, ldaho Power
Company.
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
SECOND SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 13
REQUEST NO. 24: Please provide the following information regarding Figure 3
on page 28 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. lf 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.
a. RESPONSE TO REQUEST NO. 24: Figure 3 on page 28 of Ms.
Aschenbrenner's direct testimony represents a comparison of the load profile of
residential net metering customers and residential standard service customers on June
29, 2016. The data source used to generate the load profile of the residential net
metering customers was the Company's automated metering infrastructure ("AMl")
database. The load profile was generated by calculating the average of the net hourly
energy consumption for each hour for all ldaho residential net metered customers who
had AMI data on June 29,2016. The data source used to generate the load profile of
the residential standard service customer class was the ldaho residential load research
sample (provided in the response and Attachments to Request No. 27). The load profile
was generated by calculating the weighted average of the hourly energy consumption
for each hour for the ldaho residential sample.
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
SECOND SET OF DATA REQUESTS TO IDAHO POWER COMPANY. 14
b. As mentioned in the response to 24a, the load profile of the residential
standard service customer class was generated using the ldaho residential load
research sample. A stratified random sample was designed using Oracle Utilities'
LodeStar sampling package. A multidimensional stratified sample was utilized using the
Delanius/Hodges methodology to identify stratum breakpoints and the Neyman
allocation methodology was used to determine sample size. The sample design target
statistics were based on 10 percent reliability with g0 percent confidence. The sample
consists of four usage strata combined with six demographic strata resulting in 24 tolal
strata (four usage by six demographic). The usage stratifying variable was the average
30-day normalized billed kilowatt-hours ('kwh"). The following usage stratum
breakpoints were identified: 0-700 kwh, 701-1,250 kwh, 1,251-2,150 kwh, and 2,150+
kwh. The demographic stratifying variable was based on the six weather stations
across ldaho Power's service area. They include the following weather stations: Boise,
Ketchum, McCall, Ontario, Pocatello, and Twin Falls. The final sample included 449
sample points, with a target sample size of 498.
c. Please see the Attachment for the data used to develop Figure 3 in Ms.
Aschenbrenner's testimony.
d. No. ldaho power did not conduct a similar analysis for SGS customers.
The Company's analysis focused on the residential net metering customers because
most of the recent growth in the net metering service is in the residential class.
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 VOTE SOLAR'S
SECOND SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 15
REQUEST NO. 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. lf 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.
a. RESPONSE TO REQUEST NO. 25: Figure 4 on page 30 of Ms.
Aschenbrenner's direct testimony represents a comparison of the load profile of
residential net metering customers and the load profile of residential customers with
different energy usage levels on June 29,2016. The data source used to generate the
residential net metering customers was the Company's AMI database. The load profile
was generated by calculating the average of the net hourly energy consumption for
each hour for all ldaho residential net metered customers who had AMI data on June
29,2016. The data source used to generate the load profile of different energy usage
levels was the ldaho residential load research sample (provided in response to Request
No. 27). The load profile was generated by calculating the weighted average of the
hourly energy consumption for each of the four usage strata from the ldaho residential
load research sample. Because the graph was developed to compare the load profile,
and not the magnitude for each hour, the percent of peak was plotted for each hour.
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
SECOND SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 16
b. As mentioned in the response to 25a, the data source used to generate
the load profile of different energy usage levels was the ldaho residential load research
sample. Please see the response to Vote Solar's Data Request No. 24 for lhe
description of the sampling methodology and the sample size.
c. Please see the Attachment for the data used to develop Figure 4 in Ms.
Aschenbrenner's testimony.
d. No. ldaho Power did not conduct a similar analysis for SGS customers.
The Company's analysis focused on the residential net metering customers because
most of the recent grovuth in the net metering service is in the residential class.
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 VOTE SOLAR'S
SECOND SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 17
REQUEST NO. 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)
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. lf neither a
census nor a statistically significant sample of individual customer data is available,
please provide aggregate class data.
RESPONSE TO REQUEST NO. 26:
a. & b. & c. Because ldaho Power uses a single meter to measure consumption
over a billing period for the residential and small general service customers with on-site
generation, the Company does not have the ability to measure "non-netted" deliveries or
exports separately.
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 VOTE SOLAR'S
SECOND SET OF DATA REQUESTS TO IDAHO POWER COMPANY. 18
REQUEST NO. 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. lf neither a census nor a statistically significant sample of
individual customer data is available, please provide aggregate class data.
RESPONSE TO REQUEST NO. 27: Please see the following Attachments for
ldaho Power's load research sample datasets as described in the Company's response
to Request No. 24. When using the data, please note that the data is reported in watts,
not in kilowatts ("kW"). The strata definitions and strata weights are included in a
separate worksheet within each attachment.
o Attachment 1: ldaho 2015 Residential Load Research Sample data
. Attachment 2: ldaho 2016 Residential Load Research Sample data
. Attachment 3: ldaho 2015 SGS Load Research Sample data
o Attachment 4: ldaho 2016 SGS Load Research Sample data
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 VOTE SOLAR'S
SECOND SET OF DATA REQUESTS TO IDAHO POWER COMPANY. 19
REQUEST NO. 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
RESPONSE TO REQUEST NO. 28: Please see the response and Attachments
to Request No. 20 for all underlying data that supports the Company's Application and
allwitness testimony.
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 VOTE SOLAR'S
SECOND SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 20
REQUEST NO. 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.
RESPONSE TO REQUEST NO. 29: Because ldaho Power uses a single meter
to measure consumption over a billing period for the residential customers with on-site
generation, the Company does not have the ability to measure consumption and
generation separately. Therefore, the Company has not performed an analysis of the
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.
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 VOTE SOLAR'S
SECOND SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 21
REQUEST NO. 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.
RESPONSE TO REQUEST NO. 30: Because ldaho Power uses a single meter
to measure consumption over a billing period for the small general service customers
with on-site generation, the Company does not have the ability to measure consumption
and generation separately. Therefore, the Company has not performed an analysis of
the percentage of on-site monthly energy use that is offset by solar net energy
generation among the Company's small general service customers with on-site
generation.
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 VOTE SOLAR'S
SECOND SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 22
REQUEST NO. 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.
RESPONSE TO REQUEST NO. 31: As defined on page 11 of Mr. Angell's
testimony, a net zero customer is one that, over the course of a year, generates as
much or more energy (kilowatt-hours) than they consume. The table below lists the
number of residential customers with on-site generation who were net zero customers in
each of the last five calendar years.
No. of Residential Net Zero Percent of NM Customers*
2012*"
2013
2014
2015
2016
29
27
29
38
70
12%
11o/o
10%
10%
12%
*lncluding only customers who had 12 months of billing data for each year.
"*Monthly billed energy was used for 2012 because AMI data was not available for the
entire year.
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 VOTE SOLAR'S
SECOND SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 23
REQUEST NO. 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.
RESPONSE TO REQUEST NO. 32: As defined on page 11 of Mr. Angell's
testimony, a net zero customer is one that, over the course of a year, generates as
much or more energy (kilowatt-hours) than they consume. The table below lists the
number of small general service customers with on-site generation who were net zero
customers in each of the last five calendar years.
No. of Residential Net Zero Percent of NM Customers*
2012**
2013
2014
2015
2016
I
12
7
11
14
21%
23o/o
41%
65o/o
61%*lncluding only customers who had 12 months of billing data for each year.**Monthly billed energy was used for 2012 because AMI data was not available for the
entire year.
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 VOTE SOLAR'S
SECOND SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 24
REQUES T NO. 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.
RESPONSE TO REQUEST NO. 33: For clarity, the 2017 Net Metering Status
Report was attached to Ms. Aschenbrenner's direct testimony as Exhibit No. 9.
Please see Attachment 1 for the workpapers supporting Chart 1 of the 2017 Net
Metering Status report.
Please see Attachment 2 for the workpapers supporting Chart 2 of the 2017 Net
Metering Status report.
Please see the attachment to the Company's response to Request No. 24 for the
workpapers supporting Chart 3 of the 2017 Net Metering Status report.
Please see Attachment 3 to the Company's response to Request No. 20 for the
workpapers to support Charts 4 and 5 of the 2017 Net Metering Status Report.
Please see Attachment 2 to the Company's response to Request No. 20 for the
workpapers to support Table 3 of the 2017 Net Metering Status Report.
Please see Attachment 3 for the workpapers supporting Chart 6 of the 2017 Net
Metering Status Report.
The response to this Request is sponsored by Connie Aschenbrenner, Rate
Design Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
SECOND SET OF DATA REQUESTS TO IDAHO POWER COMPANY.25
REQUEST NO. 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.
RESPONSE TO REQUEST NO. 34: Please see Attachment 1 for the
workpapers supporting Charts 1,2,5, and 6 of the 2016 Net Metering Status report.
Please see Attachment 2 for the workpapers supporting Chart 3 of the 2016 Net
Metering Status report.
Please see Attachment 3 for the workpapers supporting Table 3 and Chart 4 of
the 2016 Net Metering Status report.
Please see Attachment 4 for the workpapers supporting Table 4 and Charts 7
and 8 of the 2016 Net Metering Status report.
The response to this Request is sponsored by Connie Aschenbrenner, Rate
Design Manager, ldaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
SECOND SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 26
REQUEST NO. 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.
RESPONSE TO REQUEST NO. 35: Please see the Attachment for the
presentation that was provided as Exhibit No. 10 to Ms. Aschenbrenner's testimony.
The workpapers supporting the presentation are included in the Attachments to the
Company's response to Request No. 34.
The response to this Request is sponsored by Connie Aschenbrenner, Rate
Design Manager, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
SECOND SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 27
REQUEST NO. 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.
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. lf 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.
RESPONSE TO REQUEST NO. 36:
a. Please see the Attachment to the Company's Response to Vote Solar's
Request No. 14 for the calendar year 2016 hourly net energy consumption for the net
zero residential customer and the nearby standard service residential customer
depicted in Figure 1 of Mr. Angell's testimony. The Company is not able to separate
energy used by the customer coincident to its production by the customer (self-
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
SECOND SET OF DATA REQUESTS TO IDAHO POWER COMPANY.23
consumed customer generation) and energy delivered to the customer from the
Company. ldaho Power uses a single meter to measure consumption over a billing
period for the R&SGS customers with on-site generation, the Company does not have
the ability to measure total consumption and total generation separately.
b. The Company has hourly energy data for approximately 99 percent of its
ldaho R&SGS customers, 441,705 residential customers and 28,109 small general
service customers. The hourly energy data is provided by the Company's AMl. The
Company does not have hourly energy data for the remaining one percent of R&SGS
customers because there are a few substations where it was cost-prohibitive to install
AMl, and therefore, the Company is not able to obtain hourly energy data for those
customers.
c. Please see the Attachment for the net hourly energy consumption for the
ldaho R&SGS customers with on-site generation for 2016. The Company is not able to
separate energy used by the customer coincident to its production by the customer
(self-consumed customer generation) and energy delivered to the customer from the
Company. ldaho Power uses a single meter to measure consumption over a billing
period for the R&SGS customers with on-site generation, the Company does not have
the ability to measure total consumption and total generation separately.
d. On October 23, 2017, ldaho Power contacted David Bender to explain
that, to provide all available load data for R&SGS customers without on-site generation
for 2016, would be too voluminous. Per an email exchange between ldaho Power and
Mr. Bender, Vote Solar agreed that the load research sample data could be provided in
lieu of full census data. lt was also agreed upon that ldaho Power would provide the
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
SECOND SET OF DATA REQUESTS TO IDAHO POWER COMPANY.29
sample size, the sampling methodology, and the strata weights for the residential and
small general service load research samples.
Please see the Attachments to the Company's response to Request No. 27 for
the following load research sample datasets. When using the data, please note that the
data is reported in watts, not in kW. The strata definitions and strata weights are
included in a separate worksheet within each attachment.
. Request No. 27 - Attachment 1: ldaho 2015 Residential Sample data
. Request No. 27 - Aftachment 2: ldaho 2016 Residential Sample data
. Request No. 27 - Attachment 3: ldaho 2015 SGS Sample data
. Request No. 27 - Allachment 4: ldaho 2016 SGS Sample data
The ldaho residential sample is a stratified random sample that was designed
using Oracle Utilities' LodeStar sampling package. A multidimensional stratified sample
was utilized, using the Delanius/Hodges methodology to identify stratum breakpoints
and the Neyman allocation methodology was used to determine sample size. The
sample design target statistics were based on 10 percent reliability with 90 percent
confidence. The sample consists of four usage strata combined with six demographic
strata resulting in 24 total strata (four usage by six demographic). The usage stratifying
variable was the average 30-day normalized billed kwh. The following usage stratum
breakpoints were identified: 0-700 kwh, 701-1,250 kwh, 1,251-2,150 kwh, and 2,150+
kwh. The demographic stratifying variable was based on the six weather stations
across ldaho Power's service area. They include the following weather stations: Boise,
Ketchum, McCall, Ontario, Pocatello, and Twin Falls. The final sample included 449
sample points, with a target sample size of 498.
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
SECOND SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 30
The ldaho small general service sample is also a stratified random sample that
was designed using Oracle Utilities' LodeStar sampling package. A multidimensional
stratified sample was utilized, using the Delanius/Hodges methodology to identify
stratum breakpoints and the Neyman allocation methodology was used to determine
sample size. The sample design target statistics were based on 10 percent reliability
with 90 percent confidence. The sample consists of three usage strata combined with
six demographic strata resulting in 18 total strata (three usage by six demographic). The
usage stratifying variable was the average 30-day normalized billed kwh. The following
usage stratum breakpoints were identified: 0-334 kwh, 335-834 kwh, and 835+ kwh.
The demographic stratifying variable was based on the six weather stations across
ldaho Power's service area. They include the following weather stations: Boise,
Ketchum, McCall, Ontario, Pocatello, and Twin Falls. The final sample included 798
sample points, with a target sample size of 877.
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 VOTE SOLAR'S
SECOND SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 31
REQUEST NO. 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.
RESPONSE TO REQUEST NO. 37: To find relationships between solar
intensity and load, the data was nominalized so that each variable ranged between one
and zero. That allowed the two correlated time-series to be more easily relatable when
graphed.
a. The standardized unit of the load curve is based on a peak kW of
16,01 8.77 kW.
b. There is no standardized unit value for the curve that represents the
difference of the load and the irradiance (load-irradiance). The graph is a visualization
of the time relationship of load and irradiance. However, the standardized unit of the
southerly solar irradiance curve is based on a peak irradiance of 1,010.316
watts/mete12.
c. The executable files require a specific database engine and application
software, without which the files are unusable. However, the output from the application
software that was used to create the plots is being provided as an Attachment.
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 VOTE SOLAR'S
SECOND SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 32
REQUEST NO. 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.
c. Please provide all underlying data used to support this figure in Excel
format with formulas and links intact.
RESPONSE TO REQUEST NO. 38: To find relationships between solar
intensity and load, the data was nominalized so that each variable ranged between one
and zero. That allowed the two correlated time-series to be more easily relatable when
graphed.
a. The standardized unit of the load curve is based on a peak kW of
16,018.77 kW.
b. There is no standardized unit value for the curve that represents the
difference of the load and the irradiance (load-irradiance). The graph is a visualization
of the time relationship of load and irradiance. However, the standardized unit of the
westerly solar irradiance curve is based on a peak irradiance of 1,002.249 watts/meter2.
c. The executable files require a specific database engine and application
software, without which the files are unusable. However, the output from the application
software that was used to create the plots is being provided as an Attachment.
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 VOTE SOLAR'S
SECOND SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 33
REQUEST NO.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.
RESPONSE TO REQUEST NO. 39:
a. Please see the response to Request No. 21a.
b. Please see the Attachment for a list of recent dates and times when ldaho
Power experienced a voltage violation as a result of current DER penetration levels is
attached to this request.
c. ldaho Power has not documented a short circuit detection as a result of
current levels of DER penetration.
d. Please see the response to Request No. 21e.
e. Please see the response to Request No. 21
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
SECOND SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 34
f. No additional costs were incurred to remediate the events identified in
subparts b through d. Maintenance was performed by Company employees and were
included in ldaho Power's day-to-day operations and maintenance budget.
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 VOTE SOLAR'S
SECOND SET OF DATA REQUESTS TO IDAHO POWER COMPANY.35
REQUEST NQ. 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 "l5 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.
RESPONSE TO REQUEST NO.40:
a. Peak load in this case refers to the peak load on the distribution circuit(s)
that are connected to a substation transformer.
b. ldaho Power has not performed this analysis. However, DER penetration
has already reached 15 percent of peak load at several of ldaho Power's substations.
The following substations are already experiencing above 15 percent DER penetration:
Mora, Hope, Orchard, Holly, Sinker Creek, Adrian, Nyssa, Blue Gulch, Vale, Millner,
Cairo, Garden Valley, Canyon Creek, Lime, and Fossil Gulch.
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 VOTE SOLAR'S
SECOND SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 36
REQUEST NO. 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.
RESPONSE TO REQUEST NO. 41: The Company's proposal 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
applies to new customers seeking interconnection. Existing customers will not be
required to upgrade their inverters.
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 VOTE SOLAR'S
SECOND SET OF DATA REQUESTS TO IDAHO POWER COMPANY.3T
REQUEST NO. 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 ldaho 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. lf
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. lf applicable, please provide supporting work papers in their native format
with formulas and links intact.
RESPONSE TO REQUEST NO. 42:
a. The Company performed two separate analyses to estimate the cost shift,
and the cost to serve residential customers with on-site generation, as of the end of
2015 and 2016. Please see the response and Attachments to Request No. 17 for a
description of the analysis and the workpapers for the analyses.
b. The Company has not conducted any analyses to quantify the benefits
associated with serving customers with on-site generation. However, the Company has
requested a new docket be opened 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.
The response to this Request is sponsored by Connie Aschenbrenner, Rate
Design Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
SECOND SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 38
REQUEST NO. 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."
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.
RESPONSE TO REQUEST NO. 43:
a. The Company is not proposing a cost assignment methodology as a part
of this case. The Company has recommended that, in order to establish a methodology
that determines the appropriate amount of costs and accurately reflects their utilization
of the grid, the ldaho Public Utilities Commission ("Commission") establish a formal
process by which a comprehensive review of the compensation structure for customers
with on-site generation can be analyzed and vetted collaboratively with interested
parties. ldaho Power believes this would best be done through a collaborative process
where stakeholders and other utilities can participate.
b. No.
The response to this Request is sponsored by Tim Tatum, Vice President of
Regulatory Affairs, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
SECOND SET OF DATA REQUESTS TO IDAHO POWER COMPANY.39
REQUEST NO. 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 ldaho 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. lf 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.
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.
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
SECOND SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 40
RESPONSE TO REQUEST NO. 44: ldaho Power objects to this Request
because subpart (a) requests a statement of opinion not previously written or published
as proscribed by RP 255.01 and subparts (b-d) request the identification of information
that is publicly available at the ldaho Public Utilities Commission office (472 W.
Washington, Boise, lD 83702) or at the Commission's website
(http://www.puc.idaho.gov|. The research requested in subparts (b-d) has not been
previously completed by ldaho Power and thus cannot be produced.
The response to this Request is sponsored by Lisa Nordstrom, Lead Counsel,
ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
SECOND SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 41
REQUEST NO. 45: Refer to the statement by Mr. Tatum on page 22lines 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.
RESPONSE TO REQUEST NO.45:
a. ln the context of the referenced statement, a general rate case is specific
to ldaho Power whereas a generic docket addresses issues that may pertain more
broadly to other utilities.
b. ldaho Power is not proposing any pricing changes in this case. The
Company anticipates that pricing changes will be considered in a future rate
proceeding, general or otherwise.
The response to this Request is sponsored by Tim Tatum, Vice President of
Regulatory Affairs, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
SECOND SET OF DATA REQUESTS TO IDAHO POWER COMPANY.42
REQUEST NO. 46: Reference the statement by Mr. Tatum on page 22lines 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.
b. Please explain whether the "future rate proceeding" is the same as a
general rate case proceeding. lf different, please explain.
RESPONSE TO REQUEST NO. 46:
a. These proceedings are distinct; ldaho Power envisions using any DER
cost and benefit determination methodology approved by the Commission resulting from
the referenced generic docket to inform the development of customer rates for
consideration in a subsequent rate proceeding. However, the Company is not opposed
to considering rate and/or DER compensation structural changes as a part of the
referenced generic docket.
b. A "future rate proceeding" could take the form of a general rate case in
which all matters related to revenue requirement, rates, charges, and service are at
issue (RP 124). However, the structure of a future rate proceeding may be more
focused in nature, influenced by factors that include future Commission orders and the
timing of future general rate cases.
The response to this Request is sponsored by Tim Tatum, Vice President of
Regulatory Affairs, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
SECOND SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 43
REQUEST NO.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. lf 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. lf 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.
RESPONSE TO REQUEST NO. 47:
a. Yes, with additional modifications described in b.
b. Under the "Applicability" section of proposed tariff Schedules 6 and 8, the
Company specified that "[a Generation Facility] that is connected in parallel with the
ldaho Power System" would take service under Schedules 6 or 8. The Company also
added a definition for "Parallel" in the "Definitions" section of the tariff schedule.
The Company also added a provision to the Monthly Charge section stating: "The
following rate structure and charges are subject to change upon Commission approval."
c. As Mr. Tatum testifies on page 18 of his testimony: "While the Company
provides its customers with information that rates are subject to change, some
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
SECOND SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 44
customers may be investing in DER systems under the assumption that rate design
changes or compensation for excess net energy will never occur; that misunderstanding
may negatively impact the economics of their investment."
While the statement is true for all existing rate schedules, the proposed provision
is simply intended to alleviate any misconception that may arise before an investment
decision is made.
The response to this Request is sponsored by Connie Aschenbrenner, Rate
Design Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
SECOND SET OF DATA REQUESTS TO IDAHO POWER COMPANY.45
REQUEST NO. 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.
RESPONSE TO REQUEST NO. 48: Please see the Attachment for the
workpapers supporting the payback period calculated by the Company.
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.
ISA D. NORD
Attorney for ldaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
SECOND SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 46
CERT!FICATE OF SERVICE
I HEREBY CERTIFY that on the 31st day of October 2017 I served a true and
correct copy of IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
SECOND SET OF DATA 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 Conselation 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, ldaho 83864
ldaho lrrigation Pumpers Association, lnc
Eric L. Olsen
ECHO HAWK & OLSEN, PLLC
505 Pershing Avenue, Suite 100
P.O. Box 6119
Pocatello, ldaho 83205
X Hand Delivered
_U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
_Hand DeliveredX U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
erin. cecil@a rkoosh. com
_Hand DeliveredX U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
_Hand DeliveredX U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
_Hand DeliveredX U.S. Mail
_Overnight Mail
FAX
x Email [e-mail]
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
SECOND SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 47
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 11
Briana Kobor
Vote Solar
360 22nd Street, Suite 730
Oakland, California 94612
Gity 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 DeliveredX U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
_Hand DeliveredX U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
den@qivenspu rsley. com
_Hand DeliveredX U.S. Mail
_Overnight Mait
_FAXX Email [e-mail]
_Hand DeliveredX U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
_Hand DeliveredX U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
_Hand DeliveredX U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
_Hand DeliveredX U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
erin. ceci [e-mail]
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
SECOND SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 48
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
X U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
_Hand DeliveredX U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
_Hand DeliveredX U.S. Mail
_Overnight Mail
_FAXxEmai I zaaK.tryalerman@sierracl ub.olg
_Hand Delivered
_U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
_Hand DeliveredX U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
wwilson @snakerivera I I ia nce. orq
[e-mail]
_Hand DeliveredX U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
[e-mail]
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
SECOND SET OF DATA REQUESTS TO IDAHO POWER COMPANY.49
Doug Shipley
Dale Crawford
lntermountain Wind and Solar, LLC
1952 Wesl2425 South
Woods Cross, Utah 84087
_Hand DeliveredX U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
[e-mail]
AssistantT
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
SECOND SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 50