20171109Vote Solar 58-61 to IPC.pdf

David Bender, WI Bar # 1046102 (Pro Hac Vice)
Earthjustice
3916 Nakoma Road
Madison, WI537l I
(4ts) 977-s727
d bend e rG)earthj ust i ce. or g
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 GENERATION
David Bender
Earthjustice
3916 Nakoma Road
Madison, WI 53711
d bender(a)earthj u stice.org
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
RECE IVED
?0l1HCY -9 Atl 9: l+ I
iD,'.1-lo i;LlELic
:-iT iI- IT][S COiIMISSION
CASE NO. IPC-E-17-13
FOURTH SET OF DATA
REQUESTS BY VOTE SOLAR TO
IDAHO POWER COMPANY
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Vote Solar hereby serves its fourth set of data requests regarding the above-
mentioned docket. Vote Solar requests that Idaho Power Company provide responses as
expeditiously as possible, but not later than the deadline of 21 days, which is November
29,2017.
INSTRUCTIONS
l. Please provide copies of responses to the following contacts:
Briana Kobor
Vote Solar
986 Princeton Ave S
Salt Lake city, UT 84105
briana(Ovotesola r.org
2. Whenever possible, Vote Solar prefers to receive electronic copies of data
responses via FTP transfer or email, and only if necessary, by rnail on a CD or DVD.
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
Fourth Set of Data Requests by Vote Solar to ldaho Power Company
4. The requests herein shall be deemed to be continuing in nature and Idaho Power
Company is requested to supplement its responses as necessary and as additional
information becomes available.
5. In responding to each data request, please consult every document source which is
in your possession, custody, or control, including all documents in the possession of
experts or consultants.
6. For each response, identify the person who prepared the answer to the data request
as well as his or her position with ldaho Power Company or any Idaho Power Company
affiliate or parent company.
7. Please reproduce the data request being responded to before the response.
8. If the responses include computer modeling input and output files, please provide
those data files in electronic machine-readable or txt format.
9. If the responses include spreadsheet files, please provide those spreadsheet files in
usable electronic Excel-readable format.
10. In responses providing computer files, list the file names with the cross-reference
to the data request, and 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 l. 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.
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.
Fourth Set of Data Requests by Vote Solar to Idaho Power Company
2
13. "You", o'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
58. Regarding the presentation that you provided as "Attachment - Response to Vote
Solar's Request No. 8.pdf':
a. Please indicate whether the term "DSM" used in the presentation includes
customer-sited generation. If the response varies by instance, please
clarify, by slide number, which references to "DSM" include customer-
sited generation and which do not.
b. Please provide the annual MWh energy reduction corresponding to the
aMW figures in the Net-Metering Forecast table on slide 20.
c. Please provide the calculation and inputs used to determine that "Modeled
the impact of roof-top solar (NM) on the sales forecast, avg reduction in
summer billing demand -10o " on slide 20. Please include a definition of
"summer billing demand."
59. Regarding Attachment I and Attachment 2 provided in your response to Vote
Solar's Request No. l7:
a. For the tabs entitled "Demand Factors NM" please describe what the label
"At the Hour of the Residential GRP Co" refers to.
b. For the tabs entitled "Demand Factors NM" please identify the hour and
date selected for the peak usage identified for each month in columns C
and D.
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Fourth Set of Data Requests by Vote Solar to Idaho Power Company
c. For the tabs entitled "Demand Factors NM," is column D the only column
that contains absolute values of MW usage? If not please explain.
d. Please provide a revised version of Attachment I and Attachment 2 that
contains the original values for customer usage, rather than absolute
values, on the tabs entitled "Demand Factors NM".
e. Please describe the process used to derive the values provided on the tabs
entitled "Demand Factors NM."
f. Please provide underlying work papers supporting the values presented in
the tabs entitled "Demand Factors NM." Please include all work papers in
native Excel format with formulas and links intact.
g. Please identify the data that was updated between your 2015 cost shift
analysis provided in Attachment I and your 2016 cost shift analysis
provided in Attachment 2.
60. Regarding your response to Vote Solar Request No. 9 and Direct Testimony of
Aschenbrenner Exhibit No. 9:
a. The 2016 and2017 AnnualNet Metering Status Reports quantify a
purported cost shift of $55,712 and $1 16,682, respectively. Please provide
the equivalent purported cost shift for the 2014 and 2015 Annual Net
Metering Status Reports. Please include all work papers in native Excel
format with formulas and links intact. lf equivalent purported cost shifts
for 2014 and 2015 have not been calculated, please identify and provide
the data points necessary to conduct such calculations.
b. Page 5 of the 2015 Annual Net Metering Status Report contains the
following sentence: "Given current participation levels and the rounding
of energy rates to six digits, cost shifting is not currently impacting
customer rates." Please indicate whether you quantified the cost shift
based on the data in the 2015 AnnualNet Metering Status Report. If so,
please provide that quantification as an annual dollar value as well as an
impact on customer rates. Please include all work papers in native Excel
format with formulas and links intact.
Fourth Set of Data Requests by Vote Solar to Idaho Power Company
4
c. Page l0 of the 2016 AnnualNet Metering Status Report references a $96
existing intra-class subsidy:
i. Please provide work papers supporting the derivation of this value.
Please include all work papers in native Excel format with
formulas and links intact.
ii. Please describe the basis of this intra-class subsidy.
iii. Please indicate whether this intra-class subsidy should be
calculated differently if it were to be updated based on data in the
2017 Annual Net Metering Status Report. If so, please provide
updated work papers supporting the derivation of this value. Please
include all work papers in native Excel format with formulas and
links intact.
61. Reference the statement on page 35 of the 2017 lntegrated Resource Plan
Appendix A: Sales and Load Forecast: "Schedule 84 (net-metering) customer billing
histories were compared to billing histories prior to said customer becoming a net-
metering customer. The resulting average monthly impact-per-customer (in kWh) was
then multiplied by a forecast of the Schedule 84 residential and commercial customer
count to estimate the future energy impact on the sales forecast."
a. Please describe the analysis that was undertaken to compare customer
billing histories. Please include a description of the sample of customers
examined and the time period of the analysis.
b. Please provide all relevant work papers and analyses supporting the
comparison of customer billing histories referenced. Please include all
work papers in native Excel format with formulas and links intact.
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Fourth Set of Data Requests by Vote Solar to Idaho Power Company
DATED: November 8,2017
Respectfully submitted,
s/ David C. Bender
David C. Bender
Earthjustice
3916 Nakoma Road
Madison, WI 5371I
(202) 667-4s00
dbender&)eaft h.i u st i ce.org
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Fourth Set of Data Requests by Vote Solar to ldaho Power Company
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that I have this 8th day of November 2017, served the
foregoing FOURTH SET OF DATA REQUESTS BY VOTE SOLAR TO IDAHO
POWER COMPANY upon all parties of record in this proceeding, via the manner
indicated:
FedEx and Electronic Mail
Diane Hanian
Commission Secretary
Idaho Public Utilities Commission
472 West Washington Street
Boise, lD 83702
D i ane. h an i an(g)pu b. id alro. gov
D i a rre. ho ltri!)puc. i daho. gov
(Three copies)
Electronic Mail
Lisa D. Nordstrom
Idaho Power Company
l22l West Idaho Street (83702)
P.O. Box 70
Boise, lD 83707
lnord stro rn f@idahopower. co rn
dock et s({r) i dah o rro rve r. co m
Timothy E. Tatum
Connie Aschenbrenner
ldaho Power Company
l22l West Idaho Street (83702)
P.O. Box 70
Boise, lD 83707
1ta1u m1O idahopower. com
cascheubrenner(,Didahopower.com
Sean Costello
Deputy Attorney General
Idaho Public Utilities Commission
472 W est Washington (837 02)
PO Box 83720
Boise, lD 83720-0074
Sean.ooste I lo,r?puc. iclalro. gov
7
Fourth Set of Data Requests by Vote Solar to Idaho Power Company
Matthew A. Nykiel
Idaho Conservation League
P.O. Box 2308
102 E. Euclid, #207
Sandpoint. ID 83864
rn rr )rk i e I (g) iclalr ocon serv at i on. org
Benjamin J. Otto
710 N 6th Street
Boise, ID 83701
bo ft o ri? i dahoco n serv a t i o n. o rg
Abigail R. Germaine
Deputy CityAttorney
BOISE CITY ATTORNEY' S OFFICE
150 N. capitol Blvd.
P.O. Box 500
Boise, Idaho 83701 -0500
agenna i ne @c itr-o tbo i se.om
David Bender
Earthjustice
3916 Nakoma Road
Madison, WI537ll
d ben derfOeart hj ir sti ce.org
Briana Kobor
Vote Solar
360 22"d Street, Suite 730
Oakland, CA94612
b r i an a (g--r v o te so I a r. o r g
Idaho Irrigation Pumpers Association, Inc
Eric L. Olsen
ECHO HAWK & OLSEN, PLLC
505 PershingAve., Ste. 100
P.O. Box 6119
Pocatello, Idaho 83205
elerr?echohawk.corn
Anthony Yankel
12700 Lake Ave., Unit 2505
Lakewood, OH44107
to n)'irz))'a nke I . rret
8
Fourth Set of Data Requests by Vote Solar to Idaho Power Company
Elias Bishop
Auric Solar, LLC
23r0 s. r300 w.
West Valley City, UT 841l9
Hlias.lar.com
Preston N. Carter
Deborah E. Nelson
Givens Pursley LLC
601 West Bannock Street
Boise, lD 83702
prestoncarter(D gi venspursl el-.conr
den(J) g i ven spurs I e),.conr
Idahydro clo C. Tom Arkoosh, and
Idaho Clean Energy Association clo C. Tom Arkoosh
Arkoosh Law Offices
802 W. Bannock Street, Suite 900
P.O. Box 2900
Boise, ID 83701
@
Eri n.cec i l.(0)arkoosh.com
David H. Arkoosh
Idaho Clean Energy Association clo Law Office of David Arkoosh
P.O. Box 2817
Boise, ID 83701
dav id@arkoosh law.corn
Zack Waterman
IDAHO SIERRA CLUB
503 W. Franklin St.
Boise, lD 83702
Zach. r,r,aterrnan(0si errac lu b.org
Kelsey Jae Nunez
KELSEY JAE NUNEZ LLC
920 N. Clover Dr.
Boise, ID 83703
ke I se y (cr) ke I se -v i aen u nez.co rn
Attorney for Sierra Club
Michael Heckler
3606 N. Prospect Way
Garden City, ID 83714
M i c h ae I . p. hec k I e rl.Ogmd l.qqqr
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Fourth 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
i rh(j){isherpusch.com
Snake RiverAlliance
r.t wi I sonril)snalerivera I I iance.org
NW Energy Coalition
diego(ilnwenergy.org
Intermountain Wind and Solar, LLC
Ryan B. Frazier
Brian W. Burnett
KIRTON McCONKIE
50 East South Temple, Suite 400
P.O. Box 45120
salt Lake city, UT 841 I I
[e-mail]
b bunrett(Okmc lart,.co m
Intermountain Wind and Solar, LLC
1952 West 2425 South
Woods Cross, UT 84087
dou g(g] imw'i ndand sol ar. c,orr
dale@i rnwindandsolar.com
s/ Al Luna
Al Luna, Litigation Assistant
Earthjustice
Fourth Set of Data Requests by Vote Solar to Idaho Power Company
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