20171120IPC to Staff 12.pdf

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An IDACORP Companv
RECEIVED
2011HOU A0 PH tr: 06
LISA D. NORDSTROM
Lead Counsel
I [e-mail]
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November 20,2017
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 Residentia! and Small General Service Customers with
On-Site Generation - ldaho Power Company's Response to the Second
Production Request of the Commission Staff to ldaho Power Company
Dear Ms. Hanian
Enclosed for filing are an original and three (3) copies of ldaho Power Company's
Response to the Second Production Request of the Commission Staff to ldaho Power
Company in the above matter.
lf you have any questions about the enclosed documents, please do not hesitate to
contact me.
Very truly yours,
Lisa D
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 no rd strom @ id a h apawel&qm
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
AUTHORIW TO ESTABLISH NEW
SCHEDULES FOR RES!DENTIAL AND
SMALL GENERAL SERVICE CUSTOMERS
WITH ON-SITE GENERATION
RECEIVED
20ll H0Y 20 Plt t: 06
li.i|-i'3 ,rUIl-lCi !r I tTrt :l- C0ill$llSSl0N
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISS]ON
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CASE NO. |PC-E-17-13
IDAHO POWER COMPANY'S
RESPONSE TO THE SECOND
PRODUCTION REQUEST OF
THE COMMISSION STAFF
COMES NOW, ldaho Power Company ("ldaho Power" or "Company"), and in
response to the Second Production Request of the Commission Staff to ldaho Power
dated October 30,2017, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF - 1
REQUEST NO. 12: Please provide the following data for a stratified random
sample of ldaho Power's residential non-net metering customers who were connected
to ldaho Power for the entire period between January 1, 2016 through December 31,
2016:
a. The County in which each customer is located.
b. Hourly power consumption data. Please explain how the Company
accounted for changes from MST to MDT and vice versa.
c. An explanation of the method used to determine sampling strata, sample
sizes, and weighting factors.
d. An explanation of any missing data.
RESPONSE TO REQUEST NO. 12:
The following table lists the county associated with each stratuma.
County Strata
Ada 1,2,3, and 4
Blaine 5, 6, 7, and 8
Valley 9,10,11,and12
Payette 13,14,15, and 16
Bannock 17 , 18, 19, and 20
Twin Falls 21,22,23, and 24
b. Please see Attachment 2 to the Company's response to Vote Solar's
Request No. 27 for the 2016 ldaho Residential Sample hourly data. To adjust for
Daylight Savings Time ('DST'), the Company formatted the data so that there are 24
hours/per day in both the spring and the fall. For the spring DST shift, the hour ending 3
a.m. is left blank. For the fall DST shift, the hour ending 3 a.m. is repeated, and
therefore, the Company calculates an average of the two hours, and reports the
average in the hour ending 3:00 a.m.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF - 2
c. Please see the Company's response to Vote Solar's Request No. 36(d) for
a description of the sampling methodology used to determine sampling strata and
sample sizes. The strata weights are provided with the hourly data.
d. Missing data can be categorized in the following three scenarios:
. The Company's Advanced Metering lnfrastructure ("AMl") system,
which uses power line carrier technology, experiences occasional
communication issues when trying to retrieve data over the power line.
For example, if a feeder is taken out of service for maintenance or if a
section of line goes down due to an unplanned outage, the AMI system
may be temporarily unable to communicate with the meters on that line
depending on if there is an alternate path to get the readings. The
Company does attempt to go back and retrieve missing data but may
not be able to retrieve all missing data given that the system has
limited bandwidth. lt is important to note that the hourly data is not
used for billing purposes for Schedule 1, Residential Service Standard
Service, customers. The AMI system retrieves a different register,
called the daily register read, that is used for billing. lt is for this reason
that the Company over-samples when the samples are designed. As
stated in the Company's response to Vote Solar's Request No. 36, the
ldaho residential sample was designed to include 449 sample points;
however, the Company has a target sample size of 498 to ensure that
it has data for 449 sample points for each hour in the event that there
is missing data for some sample points.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REOUEST OF THE COMMISSION STAFF - 3
o Demand response participants are removed from the sample in
months that demand response events are called. ln the case of the
residential customer class, demand response events were called in
June and July of 2016. This methodology is consistent with the filed
class cost-of-service study from the Company's last general rate case.
. There is missing data on March 13,2017, due to spring DST. Please
see part (b) of this response for an explanation of how the Company
handles the changes from Mountain Standard Time to Mountain
Daylight Time and vice versa.
The response to this Request is sponsored by Dave M. Angell, Transmission and
Distribution Planning Manager, ldaho Power Company.
DATED at Boise, ldaho, this 20th day of November 2017.
,9'a,'
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF - 4
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 20th day of November 2017 I served a true and
correct copy of IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF upon the following named
parties by the method indicated below, and addressed to the following:
Commission Staff
Sean Costello
Deputy Attorney General
ldaho Public Utilities Commission
472 West Washington (83702)
P.O. Box 83720
Boise, Idaho 83720-007 4
Idahydro
C. Tom Arkoosh
ARKOOSH LAW OFFICES
802 West Bannock Street, Suite 900
P.O. Box 2900
Boise, ldaho 83701
ldaho Gonservation 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 North 6th Street
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
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enn-ceci I @a rkoosh. com
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IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF - 5
Anthony Yankel
12700 Lake Avenue, Unit 2505
Lakewood, Ohio 44107
Auric Solar, LLC
Preston N. Carter
Deborah E. Nelson
GIVENS PURSLEY LLP
601 West Bannock Street
Boise, ldaho 83702
Elias Bishop
Auric Solar, LLC
2310 South 1300 West
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 North Capitol Boulevard
P.O. Box 500
Boise, ldaho 83701-0500
ldaho Glean Energy Association
C. Tom Arkoosh
ARKOOSH LAW OFFICES
802 West Bannock Street, Suite 900
P.O. Box 2900
Boise, ldaho 83701
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den@q ivenspu rsley. com
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erin. cecil@arkoosh. com
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF - 6
David H. Arkoosh
Law Office of David Arkoosh
P.O. Box 2817
Boise, ldaho 83701
Sierra Glub
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 Goalition
John R. Hammond, Jr.
F]SHER PUSCH LLP
101 South Capitol Boulevard, Suite 701
P.O. Box 1731
Boise, ldaho 83701
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, Utah 84111
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wwi lson@snakerivera I I iance. orq
[e-mail]
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IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF - 7
Doug Shipley
lntermountain Wind and Solar, LLC
1953 West2425 South
Woods Cross, Utah 84087
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Towel nt
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF - 8