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Home My WebLink About20171213Sierra Club 15 to IPC - Revised.pdfKelsey Jae Nunez, ISB No. 7899 KELSEY JAE NUNEZLLC 920 N. Clover Dr. Boise, ID 83703 Telephone: (208) 391 -2961 kelsey@kelseyj aenunez. com Attorneyfor Sierua Club IN THE MATTER OF IDAHO POWER COMPANY'S APPLICATION FOR AUTHORITY TO ESTABLISH NEW SCHEDULES FOR RESIDENTIAL AND SMALL GENERAL SERVICE CUSTOMERS WITH ON-SITE GENERATION R EC E IVED 2Bl7 OtC l3 Pl{ L: lr0 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION rPC-E-17-13 SIERRA CLUB'S REVISED FIRST PRODUCTION REQUEST TO IDAITO POWER COMpAIyy COMES NOW Sierra Club, by and through its attorney of record, Kelsey Jae Nunez of the firm Kelsey Jae Nunez LLC, request that Idaho Power Company ("Idaho Power" or o'the Company") provide the following documents and information preferably within the 2l day time period of the original production request dated November 22, 2017 , but no later than 2 1 days from Decernber 13, 2017. This Production Request is continuing, and ldaho Power is requested to provide, by way of supplernentary responses, additional documents that it or any person acting on its behalf may later obtain that will augment the documents produced. Please provide answers to each question and supporting workpapers that provide detail or are the source of information used in calculations, and in addition to written copies, please provide any Excel and electronic files on CD with formulas active. Additionally, please include the name and phone number of the person preparing the document, and the name, location, and phone number of the record holder and if Siena Club - Revised First Production Request to Idaho Power Company - IPC-E-17-13 - I IDAiiO iJUBLIC t ;T it.iTt Is cOMPdtsstoN different the witness who can sponsor the answer at hearing if need be. As allowed by IDAPA 31.01.01 .228.01, if any response is voluminous Sierra Club agrees to ldaho Power depositing the response in an electronic depository. COMMENTARY TO REVISION: On December 6th, 2017, tdaho Power Company filed objections to Sierra Club's Requests for Production Nos. I l, 15, and 16. The objection to Request No. l5 was based on the Company's contention that the information sought was "not reasonably calculated to lead to the discovery of admissible evidence andlor information that is not relevant to the subject matter of this proceeding." Sierra Club contends that the information sought is not only relevant to the current proceeding but fundamental to addressing whether creation of a new rate class is warranted. In its application, Idaho Power posits that the current treatment of net-metering ("NEM") customers harms non-NEM customers based upon data purporting to show that NEM customers absorb fewer fixed costs than non-NEM customers. Idaho Power's request for closing Schedule 84 and establishing two new customer classifications is prernised upon their allegation of a cost shift from NEM customers to non-NEM customers. However, Idaho Power fails to consider numerous cost savings that may accrue to ratepayers at large. The several hundred current NEM customers connect to Idaho Power's distribution system. Their generation may provide benefits by reducing required maintenance or deferring upgrades to the distribution system. These benefits and others may outweigh the costs Idaho Power uses to justifu the remedies it seeks. However, without examining benefits that NEM customers may provide, in addition to costs, no conclusion can be reached as to whether costs and benefits net out to a source of harm to non-NEM customers. Sierra Club - Revised First Production Request to Idaho Power Company - IPC-E- I 7 -13 - 2 preparing the document, and the name, location, and phone number of the record holder and if different the witness who can sponsor the answer at hearing if need be. As allowed by IDAPA 31.01.01.228.01, if any response is voluminous Sierra Club agrees to Idaho Power depositing the response in an electronic depository. COMMENTARY TO REVISION: On December 6th, 2017,Idaho Power Company filed objections to Sierra Club's Requests fbr Production Nos. I l, 15, and 16. The objection to Request No. 15 was based on the Company's contention that the information sought was "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." Sierra Club contends that the information sought is not only relevant to the current proceeding but fundamental to addressing whcther creation of a new rate class is wamanted. In its application, Idaho Power posits that the current treatment of net-metering ("NEM") customers harms non-NEM customers based upon data purporting to show that NEM customers absorb fewer fixed costs than non-NEM customers. Idaho Power's request for closing Schedule 84 and establishing two new customer classifications is premised upon their allegation of a cost shift from NEM customers to non-NEM customers. However, Idaho Power fails to consider numerous cost savings that may accrue to ratepayers atlarge. The several hundred current NEM customers connect to Idaho Power's distribution system. Their generation may provide benefits by reducing required maintenance or deferring upgrades to the distribution system. These benefits and others may outweigh the costs Idaho Power uses to justify the remedies it seeks. However, without examining benefits that Sierra Club - Revised First Production Request to Idaho Power Company - IPC-E-17-13 - 2 NEM customers may provide, in addition to costs, no conclusion can be reached as to whether costs and benefits net out to a source of harm to non-NEM customers. With these matters in mind, Sierra Club submits the following, slightly revised, Production Request Number 15. REVISED REOUEST NO 15. Please provide Idaho Power's most recent plan for future upgrades to its distribution system that are intended to serve load growth. This should include: a, A map identifying the name/location of each of the existing substations within the Company's service area. b. A list of distribution circuits and substations planned to be upgraded. s. The curent peak capacity of each of these distribution circuits and substations. d. The recent peak loads, and the forecasted load growth (i.e. the 0% increase in peak demand each year) on each of these distribution circuits and substations. 9. The expected cost and in-service date ofeach planned upgrade, and the kW of capacity added with each upgrade. f. 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. Dated this 13th day of December, 2017. Respectfully submitted, ,l$t""5e Nt"ttt* Kelsey Jae Nunez, Attorney for Sierra Club Sierra Club - Revised First Production Request to Idaho Power Company - IPC-E-17-13 - 3 CERTIFICATE OF SERVICE I certify that on this l3th day of December, 2017 , true and correct copies of the above REVISED FIRST PRODUCTION REQUEST TO IDAHO POWER COMPANY were sent to the following persons via the methods noted: Emailed: Idaho Power Company Lisa D. Nordstrom Timothy E. Taturn Connie Aschenbrenner l22l W.Idaho St. PO Box 70 Boise,Idaho 83707 I norclstrorn @ i dahopowtlr.corn dockets @) idahopowcr.cont ttaturn G) idalropowcr. conr cas hcn brc n ncr @) i dahopowcr.cout Commission Staff Sean Costello Deputy Attorney General Idaho Public Utilities Commission 472W. Washington Boise, Idaho 83702 sean. costel l o @f [ruc. i daho. gov Idahydro C. Tom Arkoosh Arkoosh Law Offices 802 W. Bannock Street, Suite 900 PO Box 2900 Boise, tD 83701 tonr.arkoosh @ arkoosh.com eri n.ceci I @ arkoosh.corn Idaho Irrigation Pumpers Association, Inc. Eric L. Olsen ECHO HAWK & OLSEN, PLLC 505 Pershing Ave., Ste. 100 PO Box 6l l9 Pocatello, Idaho 83205 clo @)cchohawk.corrr Anthony Yankel 12700 Lake Ave, LInit 2505 Lakewood, AH 44107 Email: tony@yankel.nct Idaho Conservation League Matthew A. Nykiel PO Box 2309 102 S. Euclid #207 Sandpoint, ID 83864 rnnykiel @ idahoconservation.org Ben Otto 7 l0 N 6 th Street Boise,ID 83701 Ph: (208) 345-6933 x 12 Fax: (208) 344-0344 botto @ idahoconservation.org Auric Solar, LLC Elias Bishop 2310 s. 1300 w. West Valley City, UT 84119 Telephone: (801 ) 878-3363 el ias.bi shop @ auri csol ar.oom Preston N. Cafier Deborah E. Nelson Givens Pursley LLP 601 W. Bannock St. Boise, ID 83702 Drcstoncarter@ si vensnurslcv.conr den @ givenspursley.com Siena Club - Revised First Production Request to Idaho Power Company - IPC-E- l7- l3 - 4 City of Boise Abigail R. Germaine Deputy City Attorney Boise City Attorney's Office 105 N. Capitol Blvd. P0 Box 500 Boise, ID 83701-0500 agcrmai rrc (l) ci t)rolboi sc.org Idaho Clean Energy Association C. Tom Arkoosh Arkoosh Law Offices 802 W. Bannock Street, Suite 900 PO Box 2900 Boise, ID 83701 tom. arkoosh @ arkoosh.com erin.ccci I @ arkoc,sh,conr David H. Arkoosh Law Office of David Arkoosh POBox28l7 Boise, ID 83701 david@arkooshlaw.com Vote Solar David Bender Earthjustice 3916 Nakoma Road Madison, WI537l I dbender@ carthi ustice.org Briana Kober Vote Solar 360 22nd Street., Suite 730 Oakland, CA94612 briana @ votesolar.org Snake River Alliance and Northwest Energy Coalition .Iohn R. Hammond, Jr. Fisher Pusch LLP I0l 5. Capitol Blvd., Suire 701 P0 Box 1308 Boise,ID 83701 jrh @ flsherpusch.conr Electronic service only: Snake River Alliance wwi lson @ snakeri veral liancc.org NW Energy Coalition di cgo (4) n we n e rg.v . org Intermountain Wind and Solar, LLC Ryan B. Frazier Brian W. Burnett Kirton McConkie 50 East Temple, Suite 400 P0 Box 4512A Salt Lake City, UT 841I I rfrazier@kmclaw.corn bburnett@kmclaw.com lntermountain Wind and Solar, LLC 1952 West 2425 South Woods Cross, UT 84087 dou g @ iniwi ndandsolar'.com dale @ i mwinclanclsol ar.c<r $\e N,,Lrb Kelsey Jae Nunez, Attorney for Sierra Club Sierra Club - Revised First Production Request to Idaho Power Company - IPC-E-17-13 - 5