20171213IPC to Sierra Club 1-16.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]
lnordstrom@id ahopower.com
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISS]ON
IlEC E IVED
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ij-r iLl i iIf-r;0i'l itlssl0N
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
CASE NO. IPC-E-17-13
IDAHO POWER COMPANY'S
RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
IDAHO SIERRA CLUB TO IDAHO
POWER COMPANY
COMES NOW, ldaho Power Company ("ldaho Power" or "Comp?ny"), and in
response to the First Production Request of ldaho Sierra Club to Idaho Power Company
dated November 22,2017, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF IDAHO SIERRA CLUB TO IDAHO POWER COMPANY - 1
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REQUEST FOR PRODUCTION NO. 1: Please provide the most recently used
alternate, marginal, or avoided costs lor analyzing demand side resources, including
ldaho Power's energy efficiency and demand response resources. Please provide
these costs for each hour of the year and for the future 20 years. Please provide these
costs in Excel spreadsheet format.
RESPONSE TO REQUEST FOR PRODUCTION NO. 1: The hou rly energy
demand-side management ('DSM') alternate costs are attached to this response. The
data values in the attachment (Price) correspond to the nominal average energy
summarized in Table DSM-2 DSM alternate costs by pricing period found on page 64 of
ldaho Power's 2017 lntegrated Resource Plan ("lRP") - Appendix C. Please see
Attachment 1 to Sierra Club's Request No. 6 for the avoided costs used in ldaho
Power's cost-effectiveness analyses.
The response to this Request is sponsored by Connie Aschenbrenner, Rate
Design Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF IDAHO SIERRA CLUB TO IDAHO POWER COMPANY - 2
REQUEST FOR PRODUCTION NO. 2: For the alternate, marginal, or avoided
cost data requested above, please identify and quantify the following components. lf
ldaho Power has not identified or quantified any of the following, please explain why
not.
Energy
Generation Capacity
Transmission
Distribution
Operations and maintenance
f. Avoided line losses identified and quantified separately for the
transmission and distribution systems.
g. Any other components ldaho Power includes in alternate costs not
specifically referred to in a-f.
Please provide the workpapers and calculations used to develop each of the
above components that ldaho Power has calculated. Please provide these workpapers
and calculations in Excel spreadsheet format.
RESPONSE TO REQUEST FOR PRODUGTION NO. 2:
a. Please see the attachment to Sierra Club's Request No. 1 for the hourly
energy component of the DSM alternate cost.
b. Generation Capacity is not used in the calculation of the DSM alternate
costs provided in part a. of this response; however, the Company uses $122 kilowatts
('kW") per year, which reflects the value of a simple cycle gas turbine, for analyzing
energy efficiency cost-effectiveness. Please see page 63 of ldaho Power's 2017 IRP -
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF IDAHO SIERRA CLUB TO IDAHO POWER COMPANY - 3
a.
b.
c.
d.
e.
Appendix C for an explanation of how capacity is valued for energy efficiency cost-
effectiveness. A more detailed cost breakdown of capacity costs of a peaker plant can
be found on Page 76 in the same document. Please note that amounts in the table are
in kW-month, and therefore, need to be multiplied by 12 for conversion to kW-year.
Please see Attachment 1 to this response for the workpaper used to develop the
capacity valuation.
c & d. The value of deferred transmission and distribution ("T&D") is not used in
the calculation of the DSM alternate costs provided in part a. of this response; however,
the Company uses $3.76 per kW per year as the T&D deferra! value when analyzing
energy efficiency cost-effectiveness. This value is referenced on page 53 of the 2017
!RP. Please see Attachment 2 to this response for the T&D deferral analysis that was
presented to the Energy Efficiency Advisory Group on August 30, 2016, and also to the
lntegrated Resource Plan Advisory Council on October 13, 2016. The workpapers
underlying the T&D deferral analysis are not included for reasons detailed in the
Company's objection to Sierra Club's Request Nos. 15 and 16.
e. For summer On-Peak hours, the hourly energy component of the DSM
alternate cost is based on variable energy and operations and maintenance ("O&M")
costs of a 170 megawatt simple-cycle combustion turbine. For the remaining hours, the
hourly energy component of the DSM alternate cost is based on the marginal electricity
cost as output from production cost modeling using the AURORA model. Variable O&M
costs are input to the AURORA model for the Company's coal and gas plants, which are
the primary marginal resource on which the DSM alternate cost is based. Thus, the
DSM alternate costs provided in response to part a. of this request include O&M costs.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF IDAHO SIERRA CLUB TO IDAHO POWER COMPANY - 4
f. Avoided line losses are not included in the calculation of the DSM
alternate costs provided in response to part a. of this request; however, avoided line
losses are included for purposes of calculating cost-effectiveness for energy efficiency.
The most recent study quantifying avoided line losses is provided as Attachment 3 to
this response. The annual average total system loss coefficient is 1.0965; the annual
average distribution system loss coefficient is 1.0603, and the annual average
transmission loss coefficient is 1.0341.
g. There are no other components included in the calculation of the DSM
alternate costs provided in response to part a. of this request; however, please note that
the Company does apply a conservation adder of 10 percent for energy efficiency cost-
effectiveness calculations. Table DSM-1 on page 63, 2017 IRP - Appendix C contains
the current discounting and escalation factors for calculating the time value of money in
energy efficiency cost-effectiveness. Note that all energy data referred to in part a. are
nominal values.
The response to this Request is sponsored by Dave M. Angell, Transmission and
Distribution Planning Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF IDAHO SIERRA CLUB TO IDAHO POWER COMPANY - 5
REQUEST FOR PRODUCTION NO. 3: Please provide ldaho Power's most
recent marginal cost study, including marginal costs for transmission and distribution
capacity, comparable to the marginal costs that ldaho Power included in its 2011
general rate case showing. See 2011 Marginal Cost Analysis, Larkin Workpapers at
59-66, IPC-E-11-08, (Aprt 28,2011 memo from Scott Wright to Matt Larkin). Please
provide the workpapers for this study in Excel spreadsheet format.
RESPONSE TO REQUEST FOR PRODUCTION NO. 3: The most recent
marginal cost study was prepared for the 2011 general rate case ("GRC'). ldaho Power
has not updated this study since the 2011 GRC. Please see the Attachment to this
request for the workpapers for the 2011 marginal cost study.
The response to this Request is sponsored by Connie Aschenbrenner, Rate
Design Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF IDAHO SIERRA CLUB TO IDAHO POWER COMPANY - 6
REQUEST FOR PRODUCTION NO. 4: Please provide the following information
concerning the implementation of time-differentiated rates on the ldaho Power system:
a. Please describe the time-of-use (TOU) or time-differentiated rates that the
Company offers to its residential and small commercial customers. Please provide the
number of residential and small commercial customers on TOU rates today, in absolute
numbers and as a percentage of the total number of customers in these classes.
b. Does ldaho Power have a customer information and billing system
capable of implementing time-differentiated rates for all of its customers? lf it does not,
please describe the billing and customer service constraints ldaho Power faces in
moving to time-differentiated rates for all of its customers.
c. Does ldaho Power have an advanced metering infrastructure (AMl)
capable of implementing time-differentiated rates for all of its customers? lf it does not,
please describe the metering constraints ldaho Power faces in moving to time-
differentiated rates for all of its customers.
d. Does ldaho Power have a customer information and billing system
capable of applying time-differentiated rates for net metering service? Please describe
in further detail the complexity of the calculations to implement time differentiated rates
for net metering customers.
e. Does ldaho Power have 2-channel meters capable of recording separately
(1) the power that ldaho Power supplies to a customer with on-site generation and (2)
the power that such a customer exports to ldaho Power? !f not, why not?
f. Does ldaho Power plan in the future to move to the use of 2-channel
meters for customers with on-site generation? lf not, why not?
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF IDAHO SIERRA CLUB TO IDAHO POWER COMPANY - 7
RESPONSE TO REQUEST FOR PRODUCTION NO. 4:
a. ldaho Power's Time-of-Day ("TOD") program is offered on an optional,
voluntary basis to residential customers only. The only requirement is that an AMI
meter exists at the customer's residence.
The TOD program includes seasonal pricing with Peak and Off-Peak rates. The
summer season begins on June 1 of each year and ends on August 31 of each year.
The current rates approved for Schedule 5, Residential Service Time-of-Day Pilot
(Optional), are listed below:
Service Charge, per month $5.00
Energy Charge, per kilowatt-hour ("kwh')
Summer
Peak
Off-Peak
12.94810
7.42260
Non-SummerPeak 9.55810Off-Peak 7.42260,
During the summer season, June 1 through August 31, Peak hours are 1:00 p.m.
to 9:00 p.m. on weekdays and all other hours are Off-Peak. During the non-summer
season, September l through May 31, Peak hours are 7:00a.m. to 9:00p.m. on
weekdays, and all other hours are Off-Peak. Holidays, as defined in the tariff, are Off-
Peak.
Of the 439,333 residential customers that ldaho Power serves, there are
currently 1,206 residential customers enrolled in the TOD program. This represents
0.27 percent of residential customers.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF IDAHO SIERRA CLUB TO IDAHO POWER COMPANY - 8
b. No. ldaho Power's Customer Relationship and Billing (.CR&B') system is
not currently capable of billing time-differentiated rates for all of ldaho Power's
customers as it is configured today. The current limitations to offering time-
differentiated rates to all customers are due to differences between the way the
metering and CR&B systems are designed and configured. These differences affect the
existing integrations between the two systems and the way metering data is passed to
CR&B including data aggregation, date/time stamp issues, and timing of meter reads.
ln addition, new validation and estimation processes would need to be identified and
implemented if the Company were to deploy TOD billing on a large scale today, based
upon existing integrations between the billing and metering systems. Further analysis is
needed to determine the metering and CR&B system modifications needed to
accommodate time-variant pricing on a large-scale, all-customer basis.
c. ldaho Power has deployed the Aclara Two-Way Automated
Communications System ('TWACS") for g9 percent of its retail customers. The
metering infrastructure in place is capable of providing data necessary for the
implementation of time-differentiated rates for those customers. ln order to implement
time-differentiated rates for customers not served by TWACS, ldaho Power would need
to install meters that are capable of recording hourly load profiles that would be read
manually.
d. No. ldaho Power's CR&B system is not capable of billing time-
differentiated rates for customers taking net metering service as it is currently
configured. Modifications to both the metering system and to CR&B would be needed
to accommodate time-variant pricing for customers with on-site generation.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF IDAHO SIERRA CLUB TO IDAHO POWER COMPANY - 9
e. Yes; however, the meters currently installed on residential and small
commercial customer accounts with on-site generation (referred to as "net meters") do
not have that capability. The net meters provide one kWh register read and one hourly
energy channel read, and the meters are configured to record net monthly kWh and net
hourly kwh.
f . Not at this time; however, ldaho Power would explore the implementation
of 2-channel meters if a change in the billing structure required it.
The response to this Request is sponsored by Connie Aschenbrenner, Rate
Design Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF IDAHO SIERRA CLUB TO IDAHO POWER COMPANY - 1O
REQUEST FOR PRODUCTION NO. 5: Does ldaho Power's Fixed Cost
Adjustment mechanism address the recovery of fixed costs that are affected by any
change in customer energy consumption, including from the installation of customer-
sited generation, such that ldaho Power shareholders are not impacted? lf not, why
not?
RESPONSE TO REQUEST FOR PRODUCTION NO. 5: The Fixed Cost
Adjustment ("FCA") largely addresses fixed cost recovery lost due to reductions in
energy usage; however, because fixed cost recovery under the FCA is tracked using a
flat rate per unit of energy, the tiered rate structure applicable to the Company's
residential and small general service customer classes does not perfectly align actual
fixed costs collected with allowed fixed cost recovery. The Company's FCA mechanism
does not apply to any other customer classes outside of the residential and small
general service classes.
The response to this Request is sponsored by Timothy E. Tatum, Vice President
of Regulatory Affairs, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF IDAHO SIERRA CLUB TO IDAHO POWER COMPANY - 11
I
REQUEST FOR PRODUCTION NO. 6: Please provide the Company's most
recent cost-effectiveness analyses of its demand-side resources, including EE and DR
programs, that it has submifted to the Commission. Please include all workpapers for
these cost-effectiveness analyses, including the alternate or avoided costs that the
Company used, in Excel spreadsheet format.
RESPONSE TO REQUEST FOR PRODUCTION NO. 6: Please see the
attachment to this response for the most recent cost-effectiveness analyses of ldaho
Power's energy efficiency programs that was submitted to the ldaho Public Utilities
Commission ("Commission" or "!PUC") as part of Case No. lPC-E-17-03, Application for
Determination of 2016 Demand-Side Management Expenses. For a full description of
the Company's methodology and assumptions, please see the introduction to ldaho
Power's Demand-Side Management 2016 Annual Report, Supplement 1: Cosf-
Effectiveness.
Pursuant to the Settlement Agreement approved in IPUC Case No. IPC-E-13-14
and Public Utility Commission of Oregon Case No. UM 1653, the annual value of
demand response is equal to the levelized annual cost of the minimum size deferred
resource, measured over a period of 20 years, plus the corresponding deferred energy
savings for 60 program hours. The most recent cost-effectiveness analysis for demand
response was submitted to the Commission as a compliance filing in Case No. IPC-E-
15-03. In that analysis, the Company identified the levelized annual cost of a simple-
cycle combustion turbine as $18.5 million and estimated the preliminary cost of
operating the three demand response programs in2017 to be $8.5 million.
The response to this Request is sponsored by Connie Aschenbrenner, Rate
Design Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF IDAHO SIERRA CLUB TO IDAHO POWER COMPANY. 12
REQUEST FOR PRODUCTION NO. 7: Please provide in Excel spreadsheet
format the hourly load curves and data for the most recent calendar year period for the
ldaho jurisdiction of ldaho Power's system for the following customer classes:
a. Residential
b. Small General Service
RESPONSE TO REQUEST FOR PRODUCTION NO. 7: The 2016 average
hourly demands for the ldaho residential and small general service customer classes
are attached to this response.
The response to this Request is sponsored by Dave M. Angell, Transmission and
Distribution Planning Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF IDAHO SIERRA CLUB TO IDAHO POWER COMPANY - 13
REQUEST FOR PRODUCTION NO. 8: Please provide in Excel spreadsheet
format the monthly ldaho jurisdiction retail peak demands and consumption for the most
recent calendar year for the entire system and by customer class, as well as the date
and time on which each of those peaks occurred.
RESPONSE TO REQUEST FOR PRODUCTION NO. 8: The 2016 customer
level system coincident demands and consumption for the ldaho jurisdiction is attached
to this response. The date and time of the monthly system peaks for 2016 are listed
below.
Month System Peak
January
February
March
April
May
June
July
August
September
October
November
December
11211610:00
212116 8:00
3118116 8:00
412111618:00
513111619:00
6128116 19:00
713011618:00
812116 19:00
91111618:00
10117116 20:00
1113011619:00
12119116 9:00
The response to this Request is sponsored by Dave M. Angell, Transmission and
Distribution Planning Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF IDAHO SIERRA CLUB TO IDAHO POWER COMPANY - ,14
REQUEST FOR PRODUCTION NO. 9: Please provide the average monthly
consumption per customer for the residential and small general service classes for
calendar years 2007 through 2016.
RESPONSE TO REQUEST FOR PRODUCTION NO. 9: The average monthly
consumption per customer for the residential and small general service classes for
calendar years 2007 through 2016 are attached to this response.
The response to this Request is sponsored by Dave M. Angell, Transmission and
Distribution Planning Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF IDAHO SIERRA CLUB TO IDAHO POWER COMPANY - 15
REQUEST FOR PRODUCTION NO. 10: Please provide any study that ldaho
Power has performed that specifically and separately identifies and quantifies the long-
term benefits provided to ldaho Power by the installation of customer-sited distributed
generation, including solar, wind, and small hydro technologies.
RESPONSE TO REQUEST FOR PRODUCTION NO. 10: The Com pany has not
conducted any analyses to identify or quantify the benefits associated with serving
customers with on-site generation; however, the Company has requested a new docket
be opened at the conclusion of this case with the purpose of establishing a
compensation structure for customer-owned distributed energy resources ("DER") that
reflects both the benefits and costs that DER interconnection brings to the electric
system.
The response to this Request is sponsored by Connie Aschenbrenner, Rate
Design Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF IDAHO SIERRA CLUB TO IDAHO POWER COMPANY. 16
REQUEST FOB PJODUCTION 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, Lead Counsel,
ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF IDAHO SIERRA CLUB TO IDAHO POWER COMPANY - 17
REQUEST FOR PRODUCTION NO. 12: Does ldaho Power agree that net-
metered systems are qualifying facilities under PURPA? !f not, why not?
RESPONSE TO REQUEST FOR PRODUCTION NO. 12: Net-metered systems
may or may not be Public Utility Regulatory Policies Act of 1978 (.PURPA") qualifying
facilities ("QF') depending upon whether, or not, such net-metered systems meet the
requirements for being a QF set forth by PURPA, and either properly self-certify such
net-metered system's QF status or files for QF certification which is approved by the
Federal Energy Regulatory Commission. See, 18 C.F.R. SS 292.203, 292.204,
292.207.
The response to this Request is sponsored by Donovan E. Walker, Lead
Counsel, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF IDAHO SIERRA CLUB TO IDAHO POWER COMPANY - 18
REQUEST FOR PRODUCTION NO. 13: Net metered solar photovoltaic
generation is not the only type of distributed energy resource (DER) that can
significantly impact a customer's load profile or result in exports of power to the ldaho
Power distribution system. Other DERs include programmable thermostats, various
types of on-site energy storage including batteries and thermal storage, electric
vehicles, and demand response programs.
a. Please explain whether the Company intends to create a distinct customer
class for each type of DER that might be added to its system. lf the Company does not,
please justify which types of DER will merit a separate customer class and which will
not.
b. Please explain whether the Company intends to create a distinct customer
class for each combination of DERs that might be added to its system, for example,
solar plus on-site storage, or solar plus EVs with time-differentiated rates for charging.
lf not, please justify which combinations of DERs will merit a separate customer class
and which will not.
RESPONSE TO REQUEST FOR PRODUCTION NO. 13:
a. & b. As part of this case, ldaho Power does not intend to create a distinct
customer class for each type of DER or for each combination of DERs that might be
added to its system. The Company's Application requested the Commission authorize
closure of Schedule 84, Customer Energy Production Net Metering ("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
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF IDAHO SIERRA CLUB TO IDAHO POWER COMPANY - 19
compensation structure for customer-owned DER. !n this current filing, the Company
does not suggest creating additional customer classes for each type of DER or for each
combination of DERs; rather, it seeks to establish new residential and small general
service customer classes for customers who interconnect on-site generation fueled by
solar, wind, biomass, geothermal, or hydropower, or fuel cell technology, as described
in proposed Schedule 6, Residential Service On-Site Generation, and Schedule 8,
Small Genera! Service On-Site Generation.
The response to this Request is sponsored by Timothy E. Tatum, Vice President
of Regulatory Affairs, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF IDAHO SIERRA CLUB TO IDAHO POWER COMPANY - 20
REQUEST F : This request builds upon Vote Solar's
Request for Production No. 40.
a. Please provide Idaho Power's definition of "DER" used in that response.
b. Please provide the number & technology of DER units and the total
capacity of such units by technology, on each of the circuits for which "DER" penetration
exceeds 15o/o.
c. Please specify the peak load and maximum capacity of each circuit
identified in the response to Vote Solar's Request No. 40.
d. Please provide a recent calendar year (2016) of hourly load data in Excel
spreadsheet format on each of the circuits for which "DER' penetration exceeds 15%.
RESPONSE TO REQUEST FOR PRODUCTION NO. 14:
a. DER is defined as any type of generation connected to the distribution
system.
b. Please see Attachment 1 provided on the confidential CD for the
requested information.
c. PIease see Attachment 2 provided on the confidential CD for the
req uested information.
d. Please see Attachment 3 provided on the confidential CD for the
requested information.
The confidential CD will be provided to those parties that have executed the
Protective Agreement in this matter.
The response to this Request is sponsored by Dave M. Angell, Transmission and
Distribution Planning Manager, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF IDAHO SIERRA CLUB TO IDAHO POWER COMPANY - 21
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 %
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 DER. Idaho 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.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF IDAHO SIERRA CLUB TO IDAHO POWER COMPANY - 22
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, Lead Counsel,
ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF IDAHO SIERRA CLUB TO IDAHO POWER COMPANY - 23
REOUEST FOR P cTtoN No. {6 : 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.
There is, however, a biennial report on the ldaho Power Open Access Same-
Time Information System ("OAS|S') website that includes a list of major transmission
facilities planned to go into service over the next 20 years. Biennially, ldaho Power
creates a 2O-year Local Transmission Plan, through ldaho Power's Local Transmission
Planning process as detailed in Attachment K of ldaho Power's Open Access
Transmission Tariff. ldaho Power hosts quarterly meetings open to the public at
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF IDAHO SIERRA CLUB TO IDAHO POWER COMPANY - 24
specific milestones, as detailed in the process, and publishes a biennial report on the
ldaho Power OASIS website.
The response to this Request is sponsored by Lisa D. Nordstrom, Lead Counsel,
and Dave M. Angell, Transmission and Distribution Planning Manager, ldaho Power
Company.
DATED at Boise, ldaho, this 13th day of December 2017 .
LISA D. NORDSTROM
Attorney for ldaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF IDAHO SIERRA CLUB TO IDAHO POWER COMPANY - 25
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 13th day of December 2017 ! served a true and
correct copy of IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF IDAHO SIERRA CLUB TO IDAHO POWER COMPANY
upon the following named parties by the method indicated below, and addressed to the
following:
Gommission Staff
Sean Costello
Deputy Attorney General
ldaho Public Utilities Commission
47 2 W est Wash i n gton (83702)
P.O. Box 83720
Boise, Idaho 83720-007 4
ldahydro
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, Idaho 83702
Idaho 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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IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF IDAHO SIERRA CLUB TO IDAHO POWER COMPANY - 26
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
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@q ivenspu rsley. com
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erin. [e-mail]
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF IDAHO SIERRA CLUB TO IDAHO POWER COMPANY - 27
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, Idaho 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 @snakeriveral I iance. org
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IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF IDAHO SIERRA CLUB TO IDAHO POWER COMPANY - 28
Doug Shipley
lntermountain Wind and Solar, LLC
1953 West2425 South
Woods Cross, Utah 84087
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Ki T
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF IDAHO SIERRA CLUB TO IDAHO POWER COMPANY - 29