20171129IPC to Vote Solar 58-61.pdf

3Iffi*.
An IDACORP Company
RECEIVED
201? HOY 29 Pt{ h: 09
LISA D. NORDSTROM
Lead Counsel
I nordstrom@ida hopower.com
,,, r8',[i*f*''.?#l I u' o*
November 29,2017
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
Fourth 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 Fourth Set of Data Requests to Idaho Power Company in the
above matter.
Also enclosed are four (4) copies of disks containing information responsive to Vote
Solar's data requests.
lf you have any questions about the enclosed documents, please do not hesitate to
contact me.
Very truly yours,
Ua-9 Z1-l"tyen.--t
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 no rd strom @ id a h opower. epm
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
RECEIVED
?$l1t{0Y 29 PH lr: 09
, ,i rl,? itfocPcr#*l8t'o*
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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CASE NO. tPC-E-17-13
IDAHO POWER COMPANY'S
RESPONSE TO VOTE SOLAR'S
FOURTH SET OF DATA
REQUESTS TO IDAHO POWER
COMPANY
COMES NOW, ldaho Power Company ("ldaho Power" or "Company"), and in
response to Vote Solar's Fourth Set of Data Requests to ldaho Power dated November
8,2017, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
FOURTH SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 1
REQUEST NO. 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. lf 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 rooftop solar (NM) on the sales forecast, avg reduction in summer billing
demand -10o/o" on slide 20. Please include a definition of "summer billing demand."
RESPONSE TO REQUEST NO. 58:
a. No. The term "DSM" used in the presentation did not include customer-
sited generation.
b. The annual megawatt-hour ("MWh") energy reduction corresponding to
the average megawatt-hour figures in the Net-Metering Forecast table on slide 20 is
reported in the following table:
Net-Metering Forecast 2016 202L 2026 2036
Energy Reduction - in MWh
Residentia!
Commercial
-5,270
-7,757
-79,676
-3,022
-47,O57
-3,814
-L63,648
-5,916
c. The Company used historical groMh trends to inform the estimation of
residential and commercial net metering customer counts coupled with customer billing
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
FOURTH SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 2
histories to estimate the average reduction. The residential and commercial average
reduction per customer calculations used to adjust the load forecast for future additions
of net metering customers is provided as an attachment to this request.
Summer Billing Demand is the average kilowatt ("kW') supplied during the 15-
consecutive-minute period of maximum use during a customer's summertime billing
periods, which include June, July, and August billing periods.
The response to this Request is sponsored by David M. Angell, Transmission
and Distribution Planning Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
FOURTH SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 3
REQUEST NO. 59: Regarding Attachment 1 and Attachment 2 provided in your
response to Vote Solar's Request No. 17:
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.
c. For the tabs entitled "Demand Factors NM," is column D the only column
that contains absolute values of MW usage? lf not please explain.
d. Please provide a revised version of Attachment 1 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 1 and your 2016 cost shift analysis provided in
Attachment 2.
RESPONSE TO REQUEST NO. 59:
a. The label "At the Hour of the Residential GRP Co" refers to the date and
time of the residential customer segment's group-coincident demand. This is also
referred to as the segment's non-coincident demand.
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
FOURTH SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 4
b. Please see the Company's response to Vote Solar's Request No. 57(b) for
the date and hour of the system coincident demand and the residential segment's non-
coincident demand used to estimate the net metering segment's 2015 and 2016
revenue requirement.
c. Yes. Also, please note that the data listed in column D is reported as kW,
not as megawatts.
d. The Company has not performed this analysis. However, the original data
for 2016 has been provided in the attachment to the Company's response to Vote
Solar's Request No. 36 and the original data for 2015 is provided in Attachment 1 to this
response.
e. The non-coincident demand (NCD) is the mean demand per customer at
the hour of the monthly group peak. As stated in the Company's response to Vote
Solar's Data Request No. 17(b), the absolute value of each hourwas used to calculate
the non-coincident kW for the residential net metering segment. This means that, if the
net energy consumption was negative, the positive value of that net energy
consumption was used to calculate the average for that hour.
The system coincident demand (SCD) is the mean demand per customer at the
hour of the monthly system peak. As stated in the Company's response to Vote Solar's
Data Request No. 17(b), the average of each customer's positive consumption was
used to calculate the system coincident kW. This means that if the net energy
consumption was negative in any given hour, the value was zeroed for the calculation of
the average for that hour.
f. The underlying workpapers supporting the 2015 values presented in the
tab entitled "Demand Factors NM" are provided in Attachment 1 to this response. The
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
FOURTH SET OF DATA REQUESTS TO IDAHO POWER COMPANY. S
underlying workpapers supporting the 2016 values presented in the tab entitled
"Demand Factors NM" are provided in Attachment 2 to this response.
g. For the 2016 analysis, the Company updated the segment of customers to
include the residential net metering customers who had 12 months of billing data during
2016. Using this data set, the Company updated the segment's average monthly
kilowatt-hour ("kWh") usage, system coincident demand, and non-coincident demand
for 2016. The base rate revenue was also updated to reflect the base rate revenue
collected from those customers during 2016 that was then compared to the estimated
revenue requirement.
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
FOURTH SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 6
REQUEST NQ. tO:Regarding your response to Vote Solar Request No. 9 and
Direct Testimony of Aschenbrenner Exhibit No. 9:
a. The 2016 and 2017 Annual Net Metering Status Reports quantify a
purported cost shift of $55,712 and $116,682, 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 Annual Net Metering
Status Report. lf 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.
c. Page 10 of the 2016 Annual Net 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
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
FOURTH SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 7
Net Metering Status Report. lf 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.
RESPONSE TO REQUEST NO. 60:
a. To clarify, the 2016 and 2017 Annual Net Metering Status Reports
estimated cost shifts occurring in calendar years 2015 and 2016, respectively.
Therefore, to provide the "equivalent purported cost shift for the 2014 and 2015 Annual
Net Metering Status Reports" would require estimating the cost shifts occurring in
calendar years 2013 and 2014, respectively. The requested analyses for calendar
years 2013 and 2014 have not been performed. However, please see Attachment 1 to
this request for the hourly load data for all residential net metering customers who had a
full 12 months of billing data in 2013. Also, please see Attachment 2 to this request for
the hourly data for all residential net metering customers who had a full 12 months of
billing data in 2014.
b. The Company did not quantify a cost shift based on data in the 2015
Annual Net Metering Status Report.
c. i. Please see Attachment 4 to the Company's Response to Vote
Solar's Request No. 34.
ii. ln the 2016 Annual Net Metering Status Report, the Company
performed an analysis to estimate the annual potential cost shift per customer.
Because the average energy usage per customer has declined since the 2011 general
rate case, the $96 adjustment was intended to provide a more accurate comparison
between the two different time periods.
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
FOURTH SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 8
iii. The Company did not perform an analysis quantifying an updated
"annual potential cost shift per customer" for the 2017 Annual Net Metering Status
Report. However, if an analysis were performed, it would still be appropriate to include
an adjustment to reflect the changes in usage per customer between the two time
periods.
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
FOURTH SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 9
REQUEST NO. 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.
RESPONSE TO REQUEST NO. 61:
a. As stated in the 2017 lntegrated Resource Plan Appendix A: Sa/es and
Load Forecast'. "Schedule 84 (net-metering) customer billing histories were compared to
billing histories prior to said customer becoming a net-metering customer." More
specifically, the historical billing data (kWh and kW) was queried for each residential
and commercial net metering customer dating back to the year 2000. The 12 complete
billing months before converting to net metering and the 12 complete billing months
after converting to net metering were queried for comparison. The comparisons were
limited to the same billing month; i.e., Jan/Jan, Feb/Feb. The years compared for each
individual net metering customer differs based upon when that customer converted to a
net metering schedule. The average reduction per customer (in kwh) was calculated
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
FOURTH SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 1O
for each month of the year. The average reduction per customer was then used to
apply to a forecast of net metering customer counts to determine the reduction in sales
in the forecast period. The average billing demand reduction per customer (in kW) was
also calculated for each month of the year. Billing demand data was only available
since late mid-2009, which resulted in fewer available comparisons.
b. As stated in part a. above, historical billing data was queried for each
residentia! and commercial net metering customer dating back to the year 2000. Please
see the Attachment to Vote Solar's Request No. 58 for the query results provided at the
bottom of the "EDW RESI Summary" worksheet. The query results include the sum of
the energy (kwh) and demand (kW) by month for customers before and after becoming
a net metering customer.
The response to this Request is sponsored by Dave M. Angell, Transmission and
Distribution Planning Manager, ldaho Power Company.
DATED at Boise, ldaho, this 29th day of November 2017.
LISA D. N
Attorney for ldaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
FOURTH SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 11
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 29th day of November 2017 I served a true and
correct copy of IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
FOURTH 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
47 2 W est Washington (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
ldahydro
C. Tom Arkoosh
ARKOOSH IAW OFFICES
802 West Bannock Street, Suite 900
P.O. Box 2900
Boise, ldaho 83701
ldaho Conservation 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 !rrigation 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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eri n. cecil@arkoosh. com
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IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
FOURTH SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 12
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 11
Briana Kobor
Vote Solar
986 Princeton Avenue S
Salt Lake City, Utah 84105
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, Idaho 83701
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den@ g ive nsp u rslev. com
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erin. [e-mail]
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
FOURTH SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 13
David H. Arkoosh
Law Office of David Arkoosh
P.O. Box 2817
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
P.O. Box 1308
Boise, ldaho 83701
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
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wwi lso n @s nake rive ra I I ia nce. o ro
[e-mail]
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[e-mail]
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
FOURTH SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 14
Doug Shipley
lntermountain Wind and Solar, LLC
1953 West2425 South
Woods Cross, Utah 84087
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AssTowell
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
FOURTH SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 15