20171121Vote Solar 62-67 to IPC.pdf

David Bender, WI Bar # 1046102 (Pro Hac Vice)
Earthjustice
3916 Nakoma Road
Madison, WI 53711
202-667-4500
d b end er(D,earthj u st i ce. or g
IN THE MATTER OF THE APPLICATION OFIDAHO POWER COMPANY FOR
AUTHORITY TO ESTABLISH NEW
SCHEDULES FOR RESIDENTIAL AND
SMALL GENERAL SERVICE CUSTOMERS
WTTH ON-SITE GENERATION
David Bender
Earthjustice
3916 Nakoma Road
Madison, WI 53711
clbender(raearthj usti ce. org
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
U
SSION
CASE NO. IPC-E-17-13
FIFTH SET OF DATA REQUESTS
BY VOTE SOLAR TO IDAHO
POWER COMPANY
RECEIVED
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Vote Solar hereby seryes its fifth 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 21days, which is December
12,2017.
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(r)votesoIar.org
2. Whenever possible, Vote Solar prefers to receive electronic copies of data
responses via FTP transfer or email, and only if necessary, by mail 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.
Fifth Set of Data Requests by Vote Solar to Idaho 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 Idaho Power Company or any Idaho Power Company
affiliate or parent company.
7. Please reproduce the data request being responded to before the response.
8. 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 if necessary to the understanding of the data, provide a record
layout of the computer files. Cornputer 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.
2
Fifth Set of Data Requests by Vote Solar to Idaho Power Company
13. "You", "your", and "Company" used herein refer to Idaho Power Company, its
agents, employees, and affiliates.
14. When load data are provided in response to these data requests, please anonymize
the data so that personally identifiable information is omitted from the data provided.
Where feasible, please include a consistent customer reference for each customer so that
data from the same customer can be matched from different data sources and/or groups
without disclosing the identity of any customer.
Data Requests
62. Please define the term "pending" when used by you to describe the status of a net
metering application. (See e.g., Aschenbrenner Direct. page 12,line 10 and "2017 Annual
Net Metering Status Report", page 2, Tables 1 and 2.) Has a 'opending" application been
approved by Idaho Power Company to participate in the net metering service? Please
explain your answer.
63. Please provide the total Project Size (in kW-DC, as that term is used in your net
metering application) for each net metering system ID (row 1) in your response to Staff
Request 8 and Vote Solar Request 36. Where applicable, please indicate: whether the
capacity has been aggregated over multiple systems and, if so, the amount of capacity
that is attributed to each ganeration technology (solar, wind, hydro, other).
64. Please provide the number of net metering applications received, by month, frorn
January 2013 through March 37,2017 , and for each application received:
. The generation technology;
. The State the customer is located in (i.e., ID or OR);
. The customer class of the applying customer;
J
Fifth Set of Data Requests by Vote Solar to ldaho Power Company
. Whether the application was rejected or approved by Idaho Power Company
and the date of that rejection or approval;
. The date on which the applicant completed interconnection and energized
his/her system; and
. If the application was approved by Idaho Power Company but was not
interconnected, the number of months since approval and the date on which
the approval expires or expired.
65. Please provide the list of individual net metering systems contained within the
aggregate data provided in "Attachment I - Response to Vote Solar's Request No. 33 -
2017 NM Chart 1". For each such systern identified, please also provide System
Identifier, Class, State, Status, Operation Date, Resource, and kW-DC for all net metering
systems operational between January 1,2001, and March 31,2017, consistent with the
form of the 'Systems' sheet of "Attachment I - Response to Vote Solar's Request No. 34
-2016 NM Report".
66. Please identify each duplicate net metering systems that may have been removed
from the chart provided in "Attachment I - Response to Vote Solar's Request No. 33 -
2017 NM Chart 1". These data should include System Identifier, Class, State, Status,
Operation Date, Resource, and kW-DC for all net metering systerns operational between
January 1,2001, and March 31,2017, consistent with the form of the'Duplicates
Removed' sheet of "Attachment 1 - Response to Vote Solar's Request No. 34 - 2016 NM
Report".
4
Fifth Set of Data Requests by Vote Solar to Idaho Power Company
67. Reference Larkin, DI Testimony, Exhibit No. 30, pageT in Docket No. IPC-E-11-
08. Mr. Larkin describes the process for allocating transmission costs using allocator 013
based on the simple average of an actual component and a weighted component.
(a) Please verify that the development of the transmission cost allocation in
Attachments I and 2 to Idaho Power Company's response to Vote Solar's Request No. l7
did not include the weighted component as described in Larkin, DI Testimony, Exhibit
No. 30, pageT in Docket No. IPC-E-I l-08.
(b) Please explain why you did not include the weighted componant in the
development of the transmission cost analysis for the net metering cost shift estimation
provided in Attachments I and 2 to ldaho Power Company's response to Vote Solar's
Request No. 17.
(c) Please provide transmission marginal cost weighting factors for 2015 and
2016 corresponding to the weighting factors provided on Larkin, DI Testimony, Exhibit
No. 37, page 3 in Docket No. IPC-E-I1-08.
68. Reference Larkin, DI Testimony, Exhibit No. 30, pages 7-8 in Docket No. IPC-E-
11-08 Mr. Larkin describes the process for allocation of energy costs using allocator
El0S and ElONS based on the simple average of an actual component and a weighted
component.
(a) Please verify that the energy cost allocation in the "cost shift" calculation in
Attachments 1 and 2 to Idaho Power Company's response to Vote Solar's Request No. 17
did not include the weighted component.
(b) Please describe why you elected not to include a weighted component when
developing the energy cost component of the net metering "cost shift" estimation
5
Fifth Set of Data Requests by Vote Solar to ldaho Power Company
provided in Attachments I and2 to Idaho Power Company's response to Vote Solar's
Request No. 17.
(c) Please provide energy marginal cost weighting factors for 2015 and2016
corresponding to the weighting factors provided on Larkin, DI Testimony, Exhibit No.
37,page 5 in DocketNo. IPC-E-Il-08.
DATED: November 21, 2017
Respectfully submitted,
V Payra!-gsudst
David C. Bender
Earthjustice
3916 Nakoma Road
Madison, WI 5371I
(202) 667-4s00
clbencler(oearthj ust i ce.org
6
Fifth Set of Data Requests by Vote Solar to Idaho Power Company
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that I have this 2l't day of November 2017, served the
foregoing FIF"IH 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
47 2 W est Washington Street
Boise, lD 83702
Di ane. hani an(li)pub. i daho. go v
Di ane. hol t(D,puc. idaho. qov
(Three copies)
Electronic Mail
Lisa D. Nordstrom
Idaho Power Company
l22l West Idaho Street (83702)
P.O. Box 70
Boise, ID 83707
I nord st ro rn (eD i d ahopow er. co rn
dockets@idahopower. com
Timothy E. Tatum
Connie Aschenbrenner
Idaho Power Company
l22l West ldaho Street (83702)
P.O. Box 70
Boise, ID 83707
ttat urn (g)i dahopower. corn
caschenbrenner@i dahopow er. cotn
Sean Costello
Deputy Attorney General
Idaho Public Utilities Commission
47 2 W est Washington (83 702)
PO Box 83720
Boise, lD 83720-0074
Sean idaho.sov
7
Fifth Set of Data Requests by Vote Solar to Idaho Power Company
MatthewA. Nykiel
Idaho Conservation League
P.O. Box 2308
l02E.Euiclid,#207
Sandpoint, ID 83864
rn nyk i el (ra i dahocon serv at ion. org
Benjamin J. Otto
710 N 6th Street
Boise, ID 83701
botto (g), i d aho co n servat i on. orq
Abigail R. Germaine
Deputy CityAttorney
BOISE CITY ATTORNEY'S OFFICE
150 N. Capitol Blvd.
P.O. Box 500
Boise, Idaho 83701 -0500
a gennaine(g'cityo fboise.org
David Bender
Earthjustice
3916 Nakoma Road
Madison, WI 53711
db end er(/D eartlij u st i ce. or g
Briana Kobor
Vote Solar
360 22"d Street, Suite 730
Oakland, CA946l2
briana(4votesol ar.ors
Idaho lrrigation Pumpers Association, Inc.
Eric L. Olsen
ECHO HAWK & OLSEN, PLLC
505 Pershing Ave., Ste. 100
P.O. Box 6ll9
Pocatello, Idaho 83205
elo(liechohawk.com
AnthonyYankel
12700 Lake Ave., Unit 2505
Lakewood, OH 44107
tony(rzyankel.net
8
Fifth Set of Data Requests by Vote Solar to Idaho Power Company
Elias Bishop
Auric Solar, LLC
2310 s. 1300 w.
West Valley City, UT 84119
E I i as. bi shop(rDauri cso I ar. co m
Preston N. Carter
Deborah E. Nelson
Givens Pursley LLC
601 West Bannock Street
Boise, lD 83702
prestoncarter(rO gi venspursley. com
d en(@ gi ven sp u rsl ey. corn
Idahydro clo C. Tom Arkoosh, and
Idaho Clean Energy Association c/o C. Tom Arkoosh
Arkoosh Law Offices
802 W. Bannock Street, Suite 900
P.O. Box 2900
Boise, ID 83701
Torn. arkoo sh (gr.ark oo sh. co n r
Eri n. ceci I (r)arkoosh. corn
David H. Arkoosh
Idaho Clean EnergyAssociation c/o Law Office of David Arkoosh
P.O. Box 2817
Boise, ID 83701
d av i d (gr,arkoo sh I aw. corn
Zack Waterman
IDAHO SIERRA CLUB
503 W. Franklin St.
Boise, ID 83702
Zach. wat emran (g.si erracl ub. org
Kelsey Jae Nunez
KELSEY JAE NI-INEZLLC
920 N. Clover Dr.
Boise, ID 83703
kel se)r(r-rkel sevj aenunez. ctlm
Attomey for Sierra Club
Michael Heckler
3606 N. Prospect Way
Garden City, ID 83714
Michael.l.corn
9
Fifth 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(ri.fi shem usch. corn
Snake RiverAlliance
wwi lson(LD,snaleri veralliance.orq
NW Energy Coalition
d i eqofrr,n wenerg)r. o rq
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 84lll
rfiaz i er(rDkm cl aw. corn
bb urnett @,k rn cl aw. co n'r
Intermountain Wind and Solar, LLC
1952 West 2425 South
Woods Cross, UT 84087
dou g(LDi rnwi ndandso I ar. corn
d a I e(lD i rnw i nd and so I ar. com
s/ Al Luna
Al Luna, Litigation Assistant
Earthjustice
Fifth Set of Data Requests by Vote Solar to Idaho Power Company
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