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Home My WebLink About20180112IPC to Vote Solar 69-77.pdf8Iffi* January 12,2018 VIA HAND DELIVERY Diane Hanian, Secretary ldaho Public Utilities Commission 472 West Washington Street Boise, ldaho 83702 Re Case No. !PC-E-17-13 New Schedules for Residential and Small General Service Customers with On-Site Generation - ldaho Power Company's Response to Vote Solar's Sixth Set of Data Requests to ldaho Power Company Dear Ms. Hanian Enclosed for filing are an original and three (3) copies of ldaho Power Company's Response to Vote Solar's Sixth Set of Data Requests to ldaho Power Company in the above matter. Very ly yours, RECEIVED ?018 Jnil l2 Pll h: 3 | ' i T i Ji?iETr#ffiihl8 t' o n,LISA D. NORDSTROM Lead Counsel I nordstrom@idahooower.com LDN:kkt Enclosures o An IDACORP Company P.O. Box 70 (83707) I22t W. ldaho St. Boise, lD 83702 MK Lisa D. Nordstrom LISA D. NORDSTROM (!SB No. 5733) ldaho Power Company 1221West ldaho Street (83702) P.O. Box 70 Boise, ldaho 83707 Telephone: (208) 388-5825 Facsimile: (208) 388-6936 I nordstrom@ idahopower. com Attorney for ldaho Power Company BEFORE THE ]DAHO PUBLIC UTILITIES COMMISSION RECEIVED 20lB Jf,tl l2 PH lr: 3 | -!rnt tAi, ..i.i i-ulLliJr i.i , :lt tl{liitMissloN 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. !PC-E-17-13 IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S SIXTH SET OF DATA REQUESTS TO IDAHO POWER COMPANY ) ) ) ) ) ) ) ) COMES NOW, ldaho Power Company ("ldaho Power" or "Comp?ny"), and in response to Vote Solar's Sixth Set of Data Requests to ldaho Power dated December 22,2017, herewith submits the following information: IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S SIXTH SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 1 REQUEST NO. 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 '2016_1D01_04", Cell MU254 in File "Request No. 27 - Attachment 2: ldaho 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. RESPONSE TO REQUEST NO. 69: a & b. While uncommon, it is possible to have negative interval data on accounts that do not have generation. The following situations explain the circumstances, in addition to on-site generation, where a negative load value can occur. . lf the Company's Advanced Metering lnfrastructure ("AMl") fails to obtain the hourly interval data from a meter, this results in a missing interval for that meter. When this occurs, the Company's Meter Data Management System ('MDMS") estimates the interval using a programmed algorithm. The estimation is done by comparing the difference between the start and stop daily register reads of the meter to the sum of the intervals for that day. For example, if the difference between two register reads is 10 (start 5 and end 15) and there is one missing interval, but the sum of the populated intervals for the day is 10.4, the one missing interval will be estimated at (0.4). This will reconcile the sum of the hourly intervals to the IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S SIXTH SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 2 difference of the daily register reads. Most cases of negative interval data for customers without on-site generation fall into this category. . On the day of a meter exchange, there could be a higher register start read (from the meter being removed) and a lower register stop read (from the new meter that was installed). lf there are any intervals missing on that day that require estimation, it is possible to see very large negative interval data on that day. The Company does discover and correct the majority of these situations. o A customer installs on-site generation on their premise but does not inform the Company. The Company does discover these situations once there is negative usage recorded at the meter. It is important to note that the hourly interval data, retrieved by the Company's AMl, is not used for billing purposes for Schedule 1, Residential Service Standard Plan, customers or for Schedule 7, Small General Service, customers. The AMI system retrieves a different register read, called the daily register read, that is used for billing. The response to this Request is sponsored by Dave M. Angell, Senior Manager, Transmission and Distribution Planning, ldaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S SIXTH SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 3 REQUEST NO. 70: Please fully explain how the methodology you used to generate the residential and SGS load research samples for 2015 and 2016, as provided in response to Vote Solar Request 27, resulted in values that are exclusively multiples of 128 Watts. RESPONSE TO REQUEST NO. 70: Solid-State meters are used to measure customer energy use in the Company's AMl. These meters use a digital multiplication measurement technique that produce a minimum reading of 128 watts. Therefore, the minimum energy read is 128 watt-hours and all reads will be multiples of 128 watt- hours. The response to this Request is sponsored by Dave M. Ange!|, Senior Manager, Transmission and Distribution Planning, ldaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S SIXTH SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 4 REQUEST NO. 71: Please confirm that the residential and SGS load research samples for 2015 and 2016, as provided in response to Vote Solar Request 27, contain 12 complete months of usage data for all Site ID's included in the respective samples. (For example, in the file "Request No. 27 -Atlachment 2: ldaho 2016 Residential Sample", the Sheets "2016_1D01_06" and "2016_1D01_07" contain only 487 Site !Ds, while all other months contain 516 Site lD's.) Please fully explain the reason for this discrepancy. RESPONSE TO REQUEST NO. 71: Several of the 516 customers participate in the A/C Cool Credit demand response program. Demand response participants are removed from ldaho Power's samples in months that demand response events are called for the respective customer classes. The customers that participate in the A/C Cool Credit program were removed from the sample in June and July when an A/C Cool Credit demand response event was activated. When the samples are designed, the Company over samples to ensure adequate sample sizes. This methodology is consistent with the filed class cost-of-service study from the Company's last general rate case. The response to this Request is sponsored by Dave M. Angell, Senior Manager, Transmission and Distribution Planning, ldaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S SIXTH SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 5 REQUEST NO. 72: Regarding your response to Vote Solar Data Request No. 27. a. Please identify the data source for the residential and SGS load research samples for 2015 and 2016, as provided in response to Vote Solar Request 27. 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 lD 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? RESPONSE TO REQUEST NO. 72: a. The data source for the residential and SGS load research samples for 2015 and 2016, provided in the Company's response to Vote Solar's Request No. 27, is the Company's AMI system. b. Actual measured kilowatt-hour interval data is used when the AM! system successfully retrieves the hourly interval data for a meter whenever possible. lf the Company's AM! fails to retrieve the hourly interval data from a meter, this results in a missing interval(s) for that meter. When this occurs, the Company's MDMS estimates the value for the interval(s) based on the daily energy reading, non-missing intervals and an algorithm which incorporates prior use history. Less than one percent of hourly interval reads are estimated. c. Yes. A Site lD is assigned to a specific customer in the load research sample. The actual hourly interval data is used for that specific customer. The only exception to this is when the AMI system fails to retrieve the interval data for that IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S SIXTH SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 6 customer. ln this case, the interval(s) would be estimated if possible or set to zero if the system is not able to estimate the read based on the algorithm described above. The response to this Request is sponsored by Dave M. Angell, Senior Manager, Transmission and Distribution Planning, ldaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S SIXTH SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 7 REQUEST NO. 73: Please confirm that the residential and SGS load research samples for 2016 and 2016, as provided in response to Vote Solar Request 27, do not contain any customers with onsite generation. RESPONSE TO REQUEST NO. 73: Yes. The residential and SGS load research samples for 2015 and 2016, as provided in the response to Vote Solar Request No. 27, contain only Schedule 1, Residential Service Standard Plan, customers and Schedule 7, Small General Service, customers, respectively. The response to this Request is sponsored by Dave M. Angell, Senior Manager, Transmission and Distribution Planning, ldaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S SIXTH SET OF DATA REQUESTS TO IDAHO POWER COMPANY. S REQUEST NO. 74: Please provide the number of active SGS customer- generators as of March 31, 2017, and total installed capacity of generation of those customer-generators RESPONSE TO REQUEST NO. 74: As of March 31 ,2017, there were 38 Small General Service customers with active net metering systems with a total generator or inverter nameplate capacity of 326 kilowatts ('kW'). 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 SIXTH SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 9 REQUEST NO. 75: Please provide the number and total capacity of SGS customers who had pending net metering applications as of March 3,2017 RESPONSE TO REQUEST NO. 75: As of March 31 ,2017, there were two small general service customers with pending net metering applications with a total inverter nameplate capacity of 10 kW. 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 SIXTH SET OF DATA REQUESTS TO IDAHO POWER COMPANY. 1O REQUEST NO. 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. RESPONSE TO REQUEST NO. 76: Please see Exhibit 29 and pages 2-8 of Matthew T. Larkin's Direct Testimony in Case No. IPC-E-11-08, the Company's last general rate case. The testimony describes the derivation of the residential class billing determinants. This information is publicly available. For ease of information, a link to Mr. Larkin's Direct Testimony is provided below: http://www. puc. idaho.qov/fileroom/cases/elec/l PC/l PCE 1 1 08/company/2O 1 1 0602 LAR Kl N % 20Dl .o/o20EXH I B I TS. P D F 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 SIXTH SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 11 REQUEST NO. 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. RESPONSE TO REQUEST NO. 77: The residential class billing determinants employed in the Company's last general rate case were representative of the residential class, inclusive of residential customers with on-site generation. The response to this Request is sponsored by Connie Aschenbrenner, Rate Design Manager, ldaho Power Company. DATED at Boise, ldaho, this 12t^ day of January 2018. I LISA D. NO STROM Attorney for Idaho Power Company IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S SIXTH SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 12 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 12th day of January 2018 I served a true and correct copy of IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S SIXTH 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 Idaho 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, Idaho 83205 _Hand Delivered _U.S. Mail _Overnight Mail _FAXX Email sean.costello@puc.idaho.qov _Hand Delivered _U.S. Mail _Overnight Mail _FAXX Email tom.arkoosh@arkoosh.com eri n. ceci l@arkoosh. com _Hand Delivered _U.S. Mail _Overnight Mail _FAXX Email mnvkiel@idahoconservation.orq _Hand Delivered _U.S. Mail _Overnight Mail _FAXX Email botto@idahoconservation.oro _Hand Delivered _U.S. Mail _Overnight Mail_FAXX Email elo@echohawk.com IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S SIXTH SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 13 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 84'119 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, Idaho 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 _Hand Delivered _U.S. Mail _Overnight Mail _FAXX Email tony@yanl<eLnet _Hand Delivered _U.S. Mail _Overnight Mail _FAXX Email prestoncarter@qivenspurslev.com de lev.com _Hand Delivered _U.S. Mail _Overnight Mail _FAXX Email elias.bishop@auricsolar.com _Hand Delivered _U.S. Mail _Overnight Mail _FAXX Email dbender@earthjustice.orq _Hand Delivered _U.S. Mail _Overnight Mail _FAXX Email briana@vatesalal.orq _Hand Delivered _U.S. Mail _Overnight Mail _FAXX Email aoermaine@cityofboise.orq _Hand Delivered _U.S. Mail _Overnight Mail _FAXX Email tom.arkoosh@arkoosh.com eri n. ceci l@arkoosh. com IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S SIXTH SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 14 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 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 _Hand Delivered _U.S. Mail _Overnight Mail _FAXX Email david@arkooshlaw.com _Hand Delivered _U.S. Mail _Overnight Mail _FAX X Email kelsev@kel seylaenunez.com _Hand Delivered _U.S. Mail _Overnight Mail_FAXX Email tomb@crossborderenerqy.com _Hand Delivered _U.S. Mail _Overnight Mail_FAXX Email zack.waterman@sierraclub.orq _Hand Delivered _U.S. Mail _Overnight Mail _FAXX Email michael.p.heckler@smail.com _Hand Delivered _U.S. Mail _Overnight Mail _FAXX Email irh@fisherpusch.com wwi lson@snakeriveral I iance. orq dieqo@nwenerov.oro _Hand Delivered _U.S. Mail _Overnight Mail _FAXX Email rfrazier@kmclaw.com bburnett@kmclaw.com IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S SIXTH SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 15 Michael Heckler 3606 North Prospect Way Garden City, ldaho 83714 Doug Shipley lntermountain Wind and Solar, LLC 1953 West2425 South Woods Cross, Utah 84087 _Hand Delivered _U.S. Mail _Overnight Mail _FAXX Email douq@imwindandsolar.com o Assistant IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S SIXTH SET OF DATA REQUESTS TO IDAHO POWER COMPANY. 16