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Home My WebLink About20171206IPC Objection to Sierra Club.pdf<Effi*. An IDACORP Company RECEIVED ?01? EtC -6 Pll lrt l5 LISA D. NORDSTROM tilrii"i* pUBLIC Lead counser tiTiliTlrrlr c0MMlssloNInordstrom@idahopower.com December 6,2017 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 Objection to Sierra Club's Production Request Nos. 1 1 , 15, and 16 to ldaho Power Company Dear Ms. Hanian Enclosed for filing are an original and three (3) copies of ldaho Power Company's Objection to Sierra Club's Production Request Nos. 11,15, and 16 to ldaho Power Company in the above matter. If you have any questions about the enclosed documents, please do not hesitate to contact me. Very truly yours, Lisa D. Nordstrom LDN:kkt Enclosures PO. 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: (208) 388-5825 Facsimile: (208) 388-6936 I n o rd strom @ id a h opowe r. com RECEIVED ?0l1OEC -6 PH lr: l5 lll.'ri-iJ ijUBLIC : i i iI'irIi::ac0F {Mlssl0N Attorney for ldaho Power Company BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION OF IDAHO POWER COMPANY FOR AUTHORIry TO ESTABLISH NEW SCHEDULES FOR RESIDENTIAL AND SMALL GENERAL SERVICE CUSTOMERS WITH ON-SITE GENERATION ) ) ) ) ) ) ) ) ) ) CASE NO. IPC-E-17-13 IDAHO POWER COMPANY'S OBJECTION TO PRODUCTION REQUEST NOS. 11,15, AND 16 OF SIERRA CLUB'S FIRST PRODUCTION REQUEST TO IDAHO POWER COMPANY COMES NOW, ldaho Power Company ("ldaho Power" or "Company"), and objects to Production Request Nos. 11, 15, and 16 of Sierra Club's First Production Request to ldaho Power dated November 22,2017, as follows: IDAHO POWER COMPANY'S OBJECTION TO PRODUCTION REQUEST NOS. 11, 15, AND 16 OF SIERRA CLUB'S FIRST PRODUCTION REQUEST TO IDAHO POWER COMPANY - 1 REQUEST FOR PRODUCTION NO. 11: Please provide all studies, reports, testimony, analyses, and state commission decisions that ldaho Power, including its executives and witnesses in this case, have reviewed concerning the following: a. the benefits and/or costs of distributed generation or net-metered renewable generation in states other than ldaho b. cost-of-service analyses for customers who install on-site distributed generation c. alternatives to net metering that have been developed in other states. RESPONSE TO REQUEST FOR PRODUCTION NO. 11: ldaho Power objects to this request as being overly broad, burdensome, and not reasonably calculated to lead to the discovery of admissible evidence. The request is not bound by time nor does it specify specific employee(s), of which ldaho Power employs nearly 2,000. Notwithstanding this objection, ldaho Power does not possess the information requested because employees do not keep logs of "all studies, reports, testimony, analyses and state commission decisions" reviewed in the ordinary course of business. The response to this Request is sponsored by Lisa D. Nordstrom, ldaho Power Company. IDAHO POWER COMPANY'S OBJECTION TO PRODUCTION REQUEST NOS. 11, 15, AND 16 OF SIERRA CLUB'S FIRST PRODUCTION REQUEST TO IDAHO POWER COMPANY - 2 REQUEST FOR PRODUCTION NO. 15: Please provide ldaho Power's most recent plan for future upgrades to its distribution system that are intended to serve load groMh. This should include: a. A list of distribution circuits and substations planned to be upgraded. b. The current peak capacity of each of these distribution circuits and substations. c. The recent peak loads, and the forecasted load growth (i.e. the o/o increase in peak demand each year) on each of these distribution circuits and substations. d. The expected cost and in-service date of each planned upgrade, and the kW of capacity added with each upgrade. e. For each distribution substation (not circuit) planned to be upgraded, please provide a recent calendar year (2016) of hourly load data in Excel spreadsheet format for each of these substations, and indicate the maximum capacity of each such substation. RESPONSE TO REQUEST FOR PRODUCTION NO. 15: The Company's Application requested the Commission authorize closure of Schedule 84 for residential and small general service customers, establish two new customer classifications with no pricing changes at this time, acknowledge the future need for smart inverters, and open a generic docket at the conclusion of this case to establish a compensation structure for customer-owned distributed energy resources ("DER'). ldaho Power objects to this request because it seeks information that is not reasonably calculated to lead to the discovery of admissible evidence and/or information that is not relevant to the subject IDAHO POWER COMPANY'S OBJECTION TO PRODUCTION REQUEST NOS. 11, 15, AND 16 OF SIERRA CLUB'S FIRST PRODUCTION REQUEST TO IDAHO POWER COMPANY - 3 matter of this proceeding. While the information requested is relevant to the compensation structure for customer-owned DER, it is outside the scope of the current case. The response to this Request is sponsored by Lisa D. Nordstrom, ldaho Power Company. IDAHO POWER COMPANY'S OBJECTION TO PRODUCTION REQUEST NOS. 11, 15, AND 16 OF SIERRA CLUB'S FIRST PRODUCTION REQUEST TO IDAHO POWER COMPANY - 4 REQUEST FOR PRODUCTION NO. 16: Please provide ldaho Power's most recent plan for future upgrades or additions to its transmission system, including high- voltage bulk transmission. This should include: a. A list of transmission lines and substations planned to be added or upgraded, their voltage level, and the principal reason for each addition or upgrade. b. The expected capital cost and in-service date of each planned transmission addition or upgrade. RESPONSE TO REQUEST FOR PRODUCTION NO. 16: The Company's Application requested the Commission authorize closure of Schedule 84 for residential and small general service customers, establish two new customer classifications with no pricing changes at this time, acknowledge the future need for smart inverters, and open a generic docket at the conclusion of this case to establish a compensation structure for customer-owned DER. ldaho Power objects to this request because it seeks information that is not reasonably calculated to lead to the discovery of admissible evidence and/or information that is not relevant to the subject matter of this proceeding. While the information requested is relevant to the compensation structure for customer- owned DER, it is outside the scope of the current case. The response to this Request is sponsored by Lisa D. Nordstrom, ldaho Power Company. DATED at Boise, ldaho, this 6th day of December,2017. D M Attorney for ldaho Power Company IDAHO POWER COMPANY'S OBJECTION TO PRODUCTION REQUEST NOS. 11, 15, AND 16 OF SIERRA CLUB'S FIRST PRODUCTION REQUEST TO IDAHO POWER COMPANY - 5 -AOzz^rs,,u CERTIFICATE OF SERVICE ! HEREBY CERTIFY that on the 6th day of December 2017 I served a true and correct copy of IDAHO POWER COMPANY'S OBJECTION TO PRODUCTION REQUEST NOS. 11, 15, AND 16 OF SIERRA CLUB'S FIRST PRODUCTION REQUEST 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 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 lrrigation Pumpers Association, lnc. Eric L. Olsen ECHO HAWK & OLSEN, PLLC 505 Pershing Avenue, Suite 100 P.O. Box 6119 Pocatello, ldaho 83205 _Hand Delivered _U.S. Mail _Overnight Mail _FAXX Email sean.costello@puc.idaho.qov _Hand Delivered _U.S. Mail _Overnight Mail _FAXX Email tom.arkoosh@arkoosh.com eri n. ceci l@a rkoosh-cpm _Hand Delivered _U.S. Mail _Overnight Mail _FAXX Email mnvkiel@idahoconservation.orq _Hand Delivered _U.S. Mail _Overnight Mail _FAXX Email botto@idahoconservation.oro _Hand Delivered _U.S. Mail _Overnight Mail FAX x Email elo@echohawk.com IDAHO POWER COMPANY'S OBJECTION TO PRODUCTION REQUEST NOS. 11, 15, AND 16 OF SIERRA CLUB'S FIRST PRODUCTION REQUEST TO IDAHO POWER COMPANY - 6 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 Gity 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 Clean Energy Association C. Tom Arkoosh ARKOOSH LAW OFFICES 802 West Bannock Street, Suite 900 P.O. Box 2900 Boise, ldaho 83701 _Hand Delivered _U.S. Mail _Overnight Mail FAX X Email tonv@vankel net _Hand Delivered _U.S. Mail _Overnight Mail FAX x Email prestoncarter@o ivenspurslev. com den@q ivenspursley.com _Hand Delivered _U.S. Mail _Overnight Mail FAX x Email elias.bishop@auricsolar.com _Hand Delivered_U.S. Mail _Overnight Mail _FAXX Email dbender@earthiustice.orq _Hand Delivered_U.S. Mail _Overnight Mail FAX x Email briana@votesolar org _Hand Delivered _U.S. Mail _Overnight Mail _FAXX Email asermaine@cityofboise.oro _Hand Delivered _U.S. Mail _Overnight Mail _FAXX Email tom.arkoosh@arkoosh.com erin.cecil@a rkoosh.com IDAHO POWER COMPANY'S OBJECTION TO PRODUCTION REQUEST NOS. 11, 15, AND 16 OF SIERRA CLUB'S FIRST PRODUCTION REQUEST TO IDAHO POWER COMPANY - 7 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 _Hand Delivered _U.S. Mail _Overnight Mail FAX X Email david@arkooshlaw.com _Hand Delivered _U.S. Mail _Overnight Mail FAXX Email kelsey@ke nunez.com _Hand Delivered _U.S. Mail _Overnight Mail _FAXX Email zack.waterman@sierraclub.orq _Hand Delivered _U.S. Mail _Overnight Mail _FAXX Email michael.p.heckler@qmail.com _Hand Delivered _U.S. Mail _Overnight Mail FAXX Email irh@fish sch.com wwi lson@snakerive ral I ia nce. orq dieqo@nwene rqv.orq _Hand Delivered _U.S. Mail _Overnight Mail _FAXX Email rfrazier@kmclaw.com bburnett@kmclaw.com IDAHO POWER COMPANY'S OBJECTION TO PRODUCTION REQUEST NOS. 11, 15, AND 16 OF SIERRA CLUB'S FIRST PRODUCTION REQUEST TO IDAHO POWER COMPANY - 8 Doug Shipley lntermountain Wind and Solar, LLC 1953 Wesl2425 South Woods Cross, Utah 84087 _Hand Delivered _U.S. Mail _Overnight Mail _FAXX Email douq@imwindandsolar.com o Ki T , Executive Assistant IDAHO POWER COMPANY'S OBJECTION TO PRODUCTION REQUEST NOS. 11, 15, AND 16 OF SIERRA CLUB'S FIRST PRODUCTION REQUEST TO IDAHO POWER COMPANY - 9