20171211IPC to Vote Solar 62-68.pdf

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 nord strom @ idahopower. com
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
RECEIVED
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Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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CASE NO. IPC-E-17-13
IDAHO POWER COMPANY'S
RESPONSE TO VOTE SOLAR'S
FIFTH SET OF DATA REQUESTS
TO IDAHO POWER COMPANY
COMES NOW, ldaho Power Company ("ldaho Power" or "Company"), and in
response to Vote Solar's Fifth Set of Data Requests to ldaho Power dated November
21,2017, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
FIFTH SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 1
REQUEST NO. 62: Please define the term "pending" when used by you to
describe the status of a net metering application. (See e.9., Aschenbrenner Direct,
page 12,\ine 10 and "2017 Annual Net Metering Status Report", page 2, Tables 1 and
2.) Has a "pending" application been approved by Idaho Power Company to participate
in the net metering service? Please explain your answer.
RESPONSE TO REQUEST NO. 62:"Pending" refers to net metering
applications received by ldaho Power that have not completed the generation
interconnection process to ensure compliance with Schedule 72, lnterconnections to
Non-Utility Generation ("Schedule 72"). Once the "pending" system passes the
Company's inspection to confirm compliance with Schedule 72, the net meter is
installed, the rate is changed, and the customer's system is considered "active". lf a
customer does not complete the generation interconnection process within 12 months of
ldaho Power completing the feasibility review, the application expires and the system is
no longer considered "pending".
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
FIFTH SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 2
REQUEST NO. 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 lD (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 generation technology (solar, wind,
hydro, other).
RESPONSE TO REQUEST NO. 63: Please see the Attachment to this response
for the requested information.
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
FIFTH SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 3
REQUEST NO. 64: Please provide the number of net metering
applications received, by month, from January 2013 through March 31,2017,
and for each application received:
o The generation technology;
. The State the customer is located in (i.e., lD or OR);
. The customer class of the applying customer;
. Whether the application was rejected or approved by ldaho Power
Company and the date of that rejection or approval;
o The date on which the applicant completed interconnection and
energized his/her system; and
. lf the application was approved by ldaho Power Company but was not
interconnected, the number of months since approval and the date on
which the approval expires or expired.
RESPONSE TO REQUEST NO. 64: Please see the Attachment to this response
for the requested information.
To date, ldaho Power has not denied any net metering applications received. lf
an application is received that does not meet the tariff requirements of Schedule 72,
ldaho Power works with the customer or installer to revise the project to comply with the
tariff requirements. ln some cases, the customer may decide not to move forward with
the project and may withdraw their application.
Pursuant to Schedule 72, an application will expire one year from the date of the
feasibility review (column G in the Attachment). Prior to mid-2017, ldaho Power
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
FIFTH SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 4
identified this as "Application Withdrawn". However, since then, the Company identifies
this as "Application Expired".
The system is considered approved the date it passes the feasibility review
(column H in the Attachment). The date of the feasibility review was not consistently
recorded electronically prior to 2017 , and therefore, may not be listed for all records. To
the extent hard copy records exist, those will be made available on site for review.
The response to this Request is sponsored by Connie Aschenbrenner, Rate
Design Manger, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
FIFTH SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 5
REQUEST NO. 65: Please provide the list of individual net metering systems
contained within the aggregate data provided in "Attachment 1 - Response to Vote
Solar's Request No.33 -2017 NM Chart 1". Foreach such system identified, please
also provide System ldentifier, 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 1 - Response to
Vote Solar's Request No. 34 - 2016 NM Report".
RESPONSE TO REQUEST NO. 65: Please see the Attachment to this response
for the requested information.
The response to this Request is sponsored by Connie Aschenbrenner, Rate
Design Manager, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
FIFTH SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 6
REQUEST NO. 66: Please identify each duplicate net metering systems that
may have been removed from the chart provided in "Attachment 1 - Response to Vote
Solar's Request No. 33 - 2017 NM Chart 1". These data should include System
ldentifier, 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 'Duplicates Removed' sheet of "Attachment 1 - Response
to Vote Solar's Request No. 34 - 2016 NM Report".
RESPONSE TO REQUEST NO. 66: There were no duplicates removed from
the chart provided in "Attachment 1 - Response to Vote Solar's Request No. 33 - 2017
NM Chart 1". This chart represented the total number of net metering systems. This is
as compared to Chart 6 on page 11 ol the 2016 Annual Net Metering Status Report that
represented the number of customers, not systems. ln order to not overstate the
customer count, if a customer had more than one system, they were counted only once.
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
FIFTH SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 7
REQUEST NO. 67: Reference Larkin , Dl Testimony, Exhibit No. 30, page 7 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 1 and 2 to ldaho Power Company's response to Vote Solar's Request No.
17 did not include the weighted component as described in Larkin, Dl Testimony,
Exhibit No. 30, page 7 in Docket No. IPC-E-1 1-08.
(b) Please explain why you did not include the weighted component in the
development of the transmission cost analysis for the net metering cost shift estimation
provided in Attachments 1 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, Dl Testimony, Exhibit
No. 37, page 3 in Docket No. IPC-E-11-08.
RESPONSE TO REQUEST NO. 67:
(a) The Company developed the residential customer class' revenue
requirement as presented in Attachments 1 and 2 to ldaho Power's response to Vote
Solar's Request No. 17 utilizing the D13 allocator described on page 7 of Mr. Larkin's
Exhibit 30 in Docket No. IPC-E-11-08. However, the Company did not apply marginal
cost weighting to the net metering customer segment's usage when calculating that
segment's transmission-related revenue requirement as detailed in row 17 of
Attachments 1 and 2 described above.
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
FIFTH SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 8
(b) Because the Company develops the transmission marginal costs in
preparation of a general rate case ('GRC'), the Company used unweighted usage as a
proxy to assign costs when quantifying the estimated cost shift attributable to residential
net metering customers. During a GRC, the transmission marginal costs are utilized in
the development of allocation factors for each class within the entire ldaho jurisdiction;
therefore, applying the Company's exact class cost-of-service process used in a GRC
would require the development of a full study - one inclusive of all customer classes
with net metering customers separated into their own respective class(es).
(c) The Company develops the requested information in preparation of a
GRC; the requested analysis does not exist.
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
FIFTH SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 9
REQUEST NO. 68: Reference Larkin, Dl 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 E10S and E10NS 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 ldaho 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
provided in Attachments 1 and 2 to ldaho Power Company's response to Vote Solar's
Request No. 17.
(c) Please provide energy marginal cost weighting factors for 2015 and 2016
corresponding to the weighting factors provided on Larkin, Dl Testimony, Exhibit No. 37,
page 5 in Docket No. IPC-E-11-08.
RESPONSE TO REQUEST NO. 68:
(a) The Company developed the residential customer class revenue
requirement as presented in Attachments 1 and 2 to ldaho Power's Response to Vote
Solar's Request No. 17 utilizing the E10S and E1ONS allocators described on pages 7-8
of Mr. Larkin's Exhibit 30 in Docket No. IPC-E-11-08. However, the Company did not
apply marginal cost weighting to the net metering customer segment's usage when
calculating that segment's energy-related revenue requirement as detailed in rows 12
and 13 in Attachments 1 and 2 described above.
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
FIFTH SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 1O
(b) Because the Company develops the marginal energy costs in preparation
of a GRC, the Company used unweighted usage as a proxy to assign costs when
quantifying the estimated cost shift attributable to residential net metering customers.
During a GRC, the marginal energy costs are utilized in the development of allocation
factors for each class within the entire ldaho jurisdiction; therefore, applying the exact
class cost-of-service process used in a GRC would require the development of a full
study - one inclusive of all customer classes with net metering customers separated
into their own respective class(es).
(c) The Company develops the requested information in preparation of a
GRC; the requested analysis does not exist.
The response to this Request is sponsored by Connie Aschenbrenner, Rate
Design Manager, ldaho Power Company.
DATED at Boise, ldaho, this 11th day of December 2017.
LISA . NORDST
Attorney for ldaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
FIFTH SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 11
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 11th day of December 2017 I served a true and
correct copy of IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S FIFTH
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
472 West Washington (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
!dahydro
C. Tom Arkoosh
ARKOOSH LAW 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
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FAXX Email sean.costell puc.idaho.oov
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FAXX Email tom.arko OSh rkoosh.com
erin.cecil@arkoosh. com
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IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
FIFTH 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 Clean 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@o ive nsp u rsley. com
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eri n. cecil@arkoosh. com
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
FIFTH 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
Tom Beach
Crossborder Energy
2560 9th Street, Suite 213A
Berkeley,CA 94710
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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wwilson @snakerivera I I ia nce. orq
[e-mail]
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[e-mail]
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
FIFTH 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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IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
FIFTH SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 15