20171226Vote Solar 69-77 to IPC.pdf

RE C T IVED
?fiil DEC 26 fi?{ il: 39David Bender, WI Bar # 1046102 (Pro Hac Vice)
Earthjustice
3916 Nakoma Road
Madison, WI 5371I
202-667-4500
dbenderfrD earthj usti c e. or g
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 53711
dbcnder@learthj u st i c e. org
.:.::sr0N
BEFORE THE IDAIIO PUBLIC UTILITIES COMMISSION
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CASE NO. IPC-E-17-13
SIXTH SET OF DATA REQUESTS
BY VOTE SOLAR TO IDAHO
POWER COMPANY
Vote Solar hereby serves its sixth set of data requests regarding the above-mentioned
docket. Vote Solar requests that Idaho Power Company provide responses as expeditiously as
possible, but not later than the deadline of 21 days, which is January 12,2018.
INSTRUCTIONS
l. Please provide copies of responses to the following contacts:
Briana Kobor
Vote Solar
986 Princeton Ave S
Salt Lake City, UT 84105
[e-mail]
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 Idaho Power Company.
4. The requests herein shall be deemed to be continuing in nature and Idaho Power Company
is requested to supplement its 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, identify the person who prepared the answer to the data request as well
as his or her position with Idaho Power Company or any Idaho Power Company affiliate or
parent company.
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 ofthe
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 "Company" used herein refer to ldaho Power Company, 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
69. Regarding your response to Vote Solar Data Request No. 27:
a. Please fully explain the reason(s) for the hourly load for a customer without on-
site generation, as provided in the load research sample in response to Vote Solar
Request 27, would be negative. See, for example, Sheet "20l6_ID01_04", Cell
MU254 in File "Request No. 27 -Attachment 2: Idaho 2016 Residential Sample"
for an instance where a negative load value occurs.
b. Please list all circumstances, in addition to having on-site generation, that result in
a negative hourly usage value.
70. Please fully explain how the methodology you used to generate the residential and SGS
load research samples for 20 I 5 and 2016, as provided in response to Vote Solar Request
27, resulted in values that are exclusively multiples of 128 Watts.
71. Please confirm that the residential and SGS load research samples for 2015 and 2016, as
provided in response to Vote Solar Request2T, contain l2 complete months of usage data
for all Site ID's included in the respective samples. (For example, in the file "Request
No. 27 -Attachment 2: Idaho 2016 Residential Sample", the Sheets "2016_ID01_06" and
"2016_[D0l_07" contain only 487 Site IDs, while all other months contain 516 Site
ID's.) Please fully explain the reason for this discrepancy.
T2.Regarding your response to Vote Solar Data Request No. 27:
a. Please identiff the data source for the residential and SGS load research samples
for 2015 and2016, as provided in response to Vote Solar Request2T.
b. Please describe the extent to which the Company relied on actual measured
metering data and the extent to which the data may have been simulated.
c. Does the hourly usage for each Site ID represent the actual hourly usage, as
sourced from the Company's automated metering infrastructure database, for a
randomly selected customer within the specified sample stratum?
73. Please confirm that the residential and SGS load research samples for 2016 and 20 I 6, as
provided in response to Vote Solar Request2T, do not contain any customers with onsite
generation.
74. Please provide the number of active SGS customer-generators as of March 3 l, 2017 , and
total installed capacity of generation of those customer-generators.
75. Please provide the number and total capacity of SGS customers who had pending net
metering applications as of March 3,2017.
76. Please describe how the residential class billing determinants employed in your last
general rate case were derived. Please explain whether sample data were obtained and
how those data were processed to result in the final determinant measures.
77.Please indicate whether the residential class billing determinants employed in your last
general rate case were representative of the residential class inclusive of customer-
generators, or whether billing determinants were derived only for non-customer-
generators.
DATED: December 22, 2017
Respectfu lly submitted,
s/ David C. Bender
David C. Bender
Earthjustice
3916 Nakoma Road
Madison, WI 5371I
(202) 6674s00
dbender(alearthj usti ce. org
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that I have this 22't day of December 2017, served the foregoing
sIxTH SET OF DATA REQUESTS BY VOTE SOLAR TO IDAHO POWER
COMPAIIY upon all parties of record in this proceeding, via the manner indicated:
FedEx and Electronic Mail
Diane Hanian
Commission Secretary
Idaho Public Utilities Commission
47 2 West Washington Street
Boise, ID 83702
D i ane. hanian(rDpub. idaho. gov
Diane.holt(Epuc. idaho. eov
(Three copies)
Electronic Mail
Lisa D. Nordstrom
Idaho Power Company
l22l West Idaho Street (83702)
P.O. Box 70
Boise,lD 83707
[e-mail]
dockets (d i dahopower. com
Timothy E. Tatum
Connie Aschenbrenner
Idaho Power Company
l22l West Idaho Street (83702)
P.O. Box 70
Boise, ID 83707
ttatum (g), i dahopowe r. com
c as c henbremrer(d i dahopow er. com
Sean Costello
Deputy Attorney General
Idaho Public Utilities Commission
47 2 West Washington (837 02)
PO Box 83720
Boise, ID 83720-0074
S ean. c ostel lo(rip uc. idaho. gov
MatthewA. Nykiel
Idaho Conservation League
P.O. Box 2308
l02E.Euclid,#207
Sandpoint,ID 83864
nrn vk i c I (@ i dahoc onserva t i o n. org
Benjamin J. Otto
710 N 6m Street
Boise,ID 83701
bottofd i dahoconservation. org
Abigail R. Germaine
Deputy CityAttorney
BOISE CITY ATTORNEY'S OFFICE
150 N. Capitol Blvd.
P.O. Box 500
Boise, Idaho 83701-0500
a germa i ne(rr, c i tyo fboi se.tlrg
David Bender
Earthjustice
3916 Nakoma Road
Madison, WI53711
dbender@ earthj ustice. org
Briana Kobor
Vote Solar
360 22"d Sfieet, Suite 730
Oakland, CA946l2
[e-mail]
Idaho Irrigation Pumpers Association, Inc
Eric L. Olsen
ECHO HAWK & OLSEN, PLLC
505 PershingAve., Ste. 100
P.O. Box 6119
Pocatello,Idaho 83205
elo(rDechohawk.com
Anthony Yankel
12700 Lake Ave., Unit 2505
Lakewood, OH 44L07
tony(/r,yankel.nct
Elias Bishop
Auric Solar, LLC
2310 s. 1300 w.
West Valley City, UT 84119
El [e-mail]
Preston N. Carter
Deborah E. Nelson
Givens Pursley LLC
601 West Bannock Street
Boise, ID 83702
prestoncarter(d gi venspursley.com
den@ givenspursley. com
Idahydro cloC. TomArkoosh, and
Idaho Clean EnergyAssociation clo C. TomArkoosh
Arkoosh Law Offices
802 W. Bannock Street, Suite 900
P.O. Box 2900
Boise,ID 83701
Tom. arkoosh@arkoosh. com
Eri n. cec i I (Zlarkoosh. com
David H. Arkoosh
Idaho Clean Energy Association clo Law Offrce of David Arkoosh
P.O. Box 2817
Boise,ID 83701
[e-mail]
Zack Waterman
IDAHO SIERRA CLUB
503 W. Franklin St.
Boise, lD 83702
Za ch. waterman(@ s i errac I ub. org
Kelsey Jae Nunez
KELSEY JAE NLTNEZLLC
920 N. Clover Dr.
Boise,ID 83703
keI sey (@keI seyj aenunez. conr
Attorney for Sierra Club
Michael Heckler
3606 N. Prospect Way
Garden City,ID 83714
M ichael. p. heckler(a) gmail. com
John R. Hammond Jr.
Fisher Pusch LLP
101 South Capitol Blvd., Suite 701
PO Box 1308
Boise,Idaho 83702
irh(dfishemusch.com
Snake RiverAlliance
wwi lsonf@ snaleriveralliance. ore
NW Energy Coalition
diego(rDnwenergy.ore
Intermountain 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, UT 841I I
[e-mail]
bbu rn ett (rD,km c I aw. conr
Intermountain Wind and Solar, LLC
1952 West 2425 South
Woods Cross, UT 84087
dou g@ imwindandsolar.com
dale@imwindandsolar. com
s/ David Bender
David Bender
Earthjustice