The URL can be used to link to this page

Home My WebLink About20171226Vote Solar 1-7 to Staff.pdfDavid Bender, WI Bar # 1046102 (Pro Hac Vice) Earthjustice 3916 Nakoma Road Madison, WI 5371I 202-667-4500 dbender@earthjustice.org 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 David Bender Earthjustice 3916 Nakoma Road Madison, WI 5371I db cn der(ge arthj u sti c e. org BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION RECEIVED 2Bll DIC 26 PH tr: lr0 iDi-'iri; Ilu#Llcjr i i-ll [ : i.;ci,{MlssloN CASE NO. IPC-E-17-13 FIRST SET OF DATA REQUESTS BY VOTE SOLAR TO IDAHO PUBLIC UTILITIES COMMISSION STAFF ) ) ) ) ) ) ) ,Vote Solar hereby serves its first set of data requests regarding the above- mentioned docket. Vote Solar requests that the tdaho Public Utilities Commission Staff ("Staff," "you" or "your") provide responses as expeditiously as possible, but not later than the deadline of 2l days, which is January 16, 2018. INSTRUCTIONS 1. Please provide copies of responses to the following contacts: Briana Kobor Vote Solar 986 Princeton Ave S Salt Lake City, UT 84105 bri ana(lvotesolar. org 2. Whenever possible, Vote Solar prefers to receive electronic copies of data responses via FTP transfer or email, and only if necessary, by mail on a CD or DVD 3. Responses to any and all of Vote Solar's data requests should be supplied to Vote Solar as soon as they become available to Staff. 4. The requests herein shall be deemed to be continuing in nature and Vote Solar requests that you supplement your responses as necessary and as additional information becomes available. 5. In responding to each data request, please consult every document source which is in your possession, custody, or control, including all documents in the possession of experts or consultants. 6. For each response, identifu the person who prepared the answer to the data request as well as his or her position with Staff. 7. Please reproduce the data request being responded to before the response. 8. If the responses include computer modeling input and output files, please provide those data files in electronic machine-readable or txt format. 9. If the responses include spreadsheet files, please provide those spreadsheet files in usable electronic Excel-readable format. 10. In responses providing computer files, list the file names with the cross-reference to the data request, and ifnecessary to the understanding ofthe data, provide a record layout of the computer files. Computer files provided with a response must be in or compatible with the current version, or the immediately prior version, of Microsoft Office. I 1. For each dollar amount provided in response to a discovery request please state if the amount is in nominal or constant dollars and what years' dollars. 12. All references to electricity load during a specific hour are assumed to be the hour ending at the indicated time unless you state otherwise in your response. 13. "You", "your", and "Staff'used herein refer to ldaho Public Utilities Commission Staff, its agents, employees, and affiliates. 14. When load data are provided in response to these data requests, please anonymize the data so that personally identifiable information is omitted from the data provided. Where feasible, please include a consistent customer reference for each customer so that data from the same customer can be matched from different data sources and/or groups without disclosing the identity of any customer. Data Requests l. Please provide all work papers to support all witness testimony you filed in this case, including but not limited to all underlying data and analyses supporting any numerical calculations, tables, and/or figures presented in your testimony. Please provide work papers in native format with formulas and links intact. To the extent that statistical software, other than Excel, was used in the development of your analysis please provide the log file, script and/or code written in the software language that was used, including the original data and output data. Please consider this an ongoing request and timely provide any additional work papers supporting additional testimony filed in this proceeding. 2. On page 11, lines 7-l2Mr. Morrison's Direct testimony refers to "2016 DSM avoided cost rates" that were used to estimate an average net metering customer's bill under Staff s proposal. a. Please provide a reference to the docket number in which those rates were developed and a reference to the Commission Order approving the rates. b. Please provide a copy of the filing(s) relied upon to obtain the 2016 DSM avoided cost rates used in Mr. Morrison's analysis. 3. Please confirm that Mr. Morrison's statements on page 9, lines ll-17, regarding a customer's "share" of costs and whether customers "are subsidized" and on page 12,lines 5-7, regarding a "cost shift" are based on a comparison of a customer's bills to the average per-customer cost of service, rather than a customer's bills to that particular customer's cost of service or that customer's load contributions to the class loads used to allocate costs to the class in the cost of service study. 5. Please reference page 16, lines 17-20, and Table 2 of Mr. Morrison's Direct. (a) Please identifu the distribution plant component costs caused by the Net Metering Group's non-coincident peak load. (b) Please identifu the Net Metering Group's load at 7:00 pm on July 26,2016 (i.e., during the Non-Net Metering Group's Non Coincident Peak hour). Please provide this in the same format as the data in Table 2 (which appears to be a per customer average). (c) To the extent that net metering customers share distribution equipment with non-net metering customers, and the consumption characteristic that causes the Company to incur the cost of that shared distribution equipment is the peak load on the shared equipment, please explain why the net metering customer group's non-coincident peak, rather than the group's contribution to peak loading on the distribution equipment at issue, is an appropriate cost causation allocator. 6. Reference Direct Testimony of Stacey Donohue, page 5, lines l-4. Please identiff each of the capacity costs that are lowered by net metering customers. 7. Reference Direct Testimony of Stacey Donohue, page 10, lines l5-17. Please confirm (l) that the reference to a below average usage customer receiving a subsidy is based on a comparison between below average usage customer bills and the cost to serve a customer with an average load, and (2) that this statement is not based on a cost of service analysis for below average use customers as a class, or an analysis of the below average usage customer's actual contribution to class loads during the hours to which costs are allocated to the class as a whole in a cost of service study. DATED: December 26, 2017 Respectfu lly submitted, s/ David C. David C. Bender Earthjustice 3916 Nakoma Road Madison, WI 53711 (202) 6674s00 db en der(rD e art hj ust i c e. or g CERTIFICATE OF SERVICE I HEREBY CERTIFY that I have this 26th day of December 2017, served the foregoing FIRST SET OF DATA REQUESTS BY VOTE SOLAR TO IDAHO PUBLIC UTILTIES COMMISSION STAFF upon all parties of record in this proceeding, via the manner indicated: Electronic and U.S. Mail Diane Hanian Commission Secretary Idaho Public Utilities Commission 47 2 W est Washington Street Boise, lD 83702 Di ane. hanian (gjpub. idaho. gov Diane.holt@puc. idaho. gov (Three copies) Electronic Mail Lisa D. Nordstrom Timothy E. Tatum Connie Aschenbrenner Idaho Power Company l22l West ldaho Street (83702) P.O. Box 70 Boise, lD 83707 lnordstrom(a) idahopower. com dockets@idahopower.com ttatum@idahopower.com caschenbrenner@idahopower. com Sean Costello Deputy Attorney General Idaho Public Utilities Commission 47 2 W est Washington (837 02\ PO Box 83720 Boise, lD 83720-0074 S ean. cos te l l o(a,;puc. i daho. eov Matthew A. Nykiel Idaho Conservation League P.O. Box 2308 1028. Euclid, #207 Sandpoint,ID 83864 rnnykiel(a;idahoconservation.ore Idahydro c/o C. Tom Arkoosh, and Idaho Clean Energy Association c/o C. Tom Arkoosh Arkoosh Law Offices 802 W. Bannock Street, Suite 900 P.O. Box 2900 Boise, ID 83701 Torr. arkoosh(rDarkoosh. c orn Erin.ceci l(@arkoosh.com David H. Arkoosh Idaho Clean Energy Association c/o Law Office of David Arkoosh P.O. Box 2817 Boise, ID 83701 dav id(g)ark oosh I aw. com Zack Waterman TDAHO SIERRA CLUB 503 W. Franklin St. Boise, lD 83702 Zach. waterman(rD s i errac l u b. or g Kelsey Jae Nunez KELSEY JAE NUNEZ LLC 920 N. Clover Dr. Boise, ID 83703 kelsey(n,kel seyj aenunez. com Attorney for Sierra Club Benjamin J. Otto 710 N 6s Street Boise,ID 83701 botto (d idahocon s erv at ion. org Michael Heckler Abigail R. Germaine Deputy City Attorney BOISE CITY ATTORNEY'S OFFICE 150 N. Capitol Blvd. P.O. Box 500 Boise, Idaho 83701 -0500 agermaine@c ityofboi se. ore 3606 N. Prospect Way Garden City, ID 83714 M ichael. o. hec k ler(ra. gmai l. com John R. Hammond Jr. Fisher Pusch LLP 101 South Capitol Blvd., Suite 701 PO Box 1308 Boise, Idaho 83702 com Idaho Irrigation Pumpers Association, Inc. Eric L. Olsen ECHO HAWK & OLSEN, PLLC 505 Pershing Ave., Ste. 100 P.O. Box 6l 19 Pocatello, Idaho 83205 elo@,echohawk.com Snake River Alliance wwilson@snaleriveralliance.ors NW Energy Coalition diego(dnwenergy.ors Anthony Yankel 12700Lake Ave., Unit 2505 Lakewood, OH44107 tony(@yankel.net Intermountain Wind and Solar, LLC Ryan B. Frazier Brian W. Bumett KIRTON McCONKIE 50 East South Temple, Suite 400 P.O. Box 45120 Salt Lake City, UT 841I I rfrazier(a,lkmc I aw. com bburnett(g) kmc I aw. co m Elias Bishop Auric Solar, LLC 2310 s. 1300 w. West Valley City, UT 841l9 Elias.bishop@auricsolar.com Intermountain Wind and Solar, LLC 1952 West 2425 South Woods Cross, UT 84087 dou g@imwindandsolar.com dale@imwindandsolar.com Preston N. Carter Deborah E. Nelson Givens Pursley LLC 601 West Bannock Street Boise, lD 83702 pre s tonc arter(g) g i ven spu rs I ey. c om den@ eivenspursley.com s/ David Bender David Bender Earthjustice