20180116Staff to IPC 1-3.pdf

SEAN COSTELLO
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 8743
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
RECEIVED
2018JAH l6 Pll 2:2h
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Street Address for Express Mail:
472 W . WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THB IDAHO PUBLIC UTILITIES COMMISSION
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CASE NO. IPC,E.17-13
STAFF'S RE,SPONSE TO
IDAHO POWER COMPANY'S
FIRST PRODUCTION
REQUEST
The Staff of the Idaho Public Utilities Commission responds as follows to Idaho
Power Company's First Production Request to Commission Staff.
REQUEST NO. 1: Please provide all workpapers 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
workpapers in native format with formulas and links intact, including the following.
a. Workpapers substantiating the $100.63 cost shift (p.l2,line 5) of the Direct
Testimony of Michael Morrison.
b. Workpapers substantiating the Figure 2, and Tables I and2 in the Direct
Testimony of Michael Morrison.
STAFF'S PRODUCTION RESPONSE
TO IDAHO POWER COMPANY I JANUARY 16,2018
STAFF RESPONSE NO. 1: As described on pages 10 and 11 of his testimony, Dr.
Morrison used data provided by the Company through Staff s Production Request No. 8 in his
analysis of Net Metering consumption patterns. Dr. Morrison's calculation of net metering
consumption and billing under current rates and Staffls proposal can be found in cells E8789
through 8895 of the "Residential" tab in the spreadsheet "Net Metering Analysis_l71228.xlsx."
These cells have been highlighted in Blue.
Dr. Morrison used data provided by the Company through Staff s Production Request
No. l2 in his analysis of Non Net Metering consumption patterns. Dr. Morrison's calculation of
Non Net Metering consumption and billing under current rates and Stafls proposal can be found
in cells E8790 through E8825 of the "Regional Summary" tab in the spreadsheet "Non Net
Metering Analysis_171228.xlsx." These cells have been highlighted in Blue.
The data obtained from these spreadsheets, and used as the basis for Tables 1 and 2, and
Figures 2,3, and 4 of Dr. Morrison's testimony can be found in the spreadsheet
"TestimonyGraphics_l71228.xlsx." All three spreadsheets are included in File Name Idaho
Power PR #1 - 3 on the CD produced with this response.
This response is sponsored by Idaho Public Utilities Commission Staff Engineer, Michael
Morrison, PhD.
REQUEST NO. 2: Please explain the quantification of the average net metering
customer's peak generation (referenced in the Direct Testimony of Michael Morrison (p. 14,
lines 22-25). Does this include generation consumed on-site?
STAFF RESPONSE NO. 2z Dr. Morrison quantified the average net metering
customer's peak generation using the data in cells UY4324 through UY4347 of the "Residential"
tab in the spreadsheet "Net Metering Analysis_171228.xlsx," which was produced in Staffls
Response to Idaho Power's Production Request No. l.
Dr. Morrison's quantification of the average net metering customer's peak generation
does not include generation consumed on-site. Dr. Morrison used only the hourly-metered
consumption/production data provided by the Company. This data includes no information that
would permit an estimate of the customer's generation consumed on-site. It only permits
analysis of the net hourly consumption and net hourly excess generation measured at the
STAFF'S PRODUCTION RESPONSE
TO IDAHO POWER COMPANY 2 JANUARY 16,2018
Company's meter.
This response is sponsored by Idaho Public Utilities Commission Staff Engineer, Michael
Morrison, PhD.
RE,QUEST NO.3: Please see the Direct Testimony of Stacey Donohue atpage 6, lines
7-10. Please provide the page number and line reference to Dr. Morrison's testimony describing
that "most of the energy produced is used to offset the customer's consumption." Please provide
the data and analyses used to substantiate Staff s position.
STAFF RESPONSE NO. 3: Page 6, lines 7-10 of Ms. Donohue's testimony states: "A.
No. Dr. Morrison's testimony shows that the average residential net metering customer pushes
very little energy onto the grid. Most of the energy produced is used to offset the customer's
consumption." Only the second sentence references Dr. Morrison's testimony. The third
sentence -((\z[s5f of the energy produced is used to offset the customer's consumption"-ig
illustrated on page 10, Table 4 of Idaho Power's 2016 Net Metering Report.
This response is sponsored by Idaho Public Utilities Commission, Technical Analysis
Program Manager, Stacey Donohue, MPA.
,/
Dated at Boise, Idaho, this fu day of January 2018.
J*c
Sean Costello
Deputy Attorney General
Technical Staff: Michael Morrison
Stacey Donohue
i:umisc:prodreq/ipcelT.l3scmmsd response to ldaho Power prod req
STAFF' S PRODUCTION RESPONSE
TO IDAHO POWER COMPANY aJ JANUARY T6,2018
CERTIFTCATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS I6TH DAY OF JANUARY 2018,
SERVED THE FOREGOING STAFF'S RESPONSE TO IDAHO POWER
coMPANy'S FIRST PRODUCTION REQUEST, IN CASE NO. IPC-E-17-13, By
MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWNG:
LISA D NORDSTROM
REGULATORY DOCKETS
IDAHO POWER COMPANY
PO BOX 70
BOrSE ID 83707-0070
E-MAIL: [e-mail]
dockets@idahopower. com
C TOM ARKOOSH
ARKOOSH LAW OFFICES
802 W BANNOCK ST STE 9OO
PO BOX 2900
BOISE ID 8370I
E-MAIL: [e-mail]
[e-mail]
ANTHONY YANKEL
I27OO LAKE AVENUE
LINIT 2505
LAKEWOOD OH 44107
E-MAIL: [e-mail]
TOM BEACH
CROSSBORDER ENERGY
2560 gTH STREET, SUITE 2I3A
BERKELEY CA 94710
E-MAIL: [e-mail]
TIMOTHY E TATUM
CONNIE ASCHENBRENNER
IDAHO POWER COMPANY
PO BOX 70
BOISE rD 83707-0070
E-MAIL: ttatum(@idahopower.com
caschenbrenner@ idahopower.com
MATTHEW A NYKIEL
ID CONSERVATION LEAGUE
102 S EUCLTD #207
PO BOX 2308
SANDPOINT ID 83864
E-MAIL: [e-mail]
EzuC L OLSEN
ECHO HAWK & OLSEN PLLC
PO BOX 6119
POCATELLO ID 83205
E-MAIL: [e-mail]
KELSEY JAE NUNEZLLC
920 N CLOVER DR
BOISE ID 83703
E-MAI L : kslsQy@kels€yiaenuncz. com
ELECTRONIC ONLY
MICHAEL HECKLER
[e-mail]
ZACK WATERMAN
zack. waterman@ sierraclub. org
CERTIFICATE OF SERVICE
ELIAS BISHOP
AURIC SOLAR LLC
2310 s 1300 w
W VALLEY CITY UT 84I 19
E-MAIL: [e-mail]
ABIGAIL R GERMAINE
DEPUTY CITY ATTORNEY
BOISE CITY ATTORNEY'S
PO BOX 500
BOrSE rD 83701-0s00
E-MAIL: [e-mail]
DAVID BENDER
EARTHJUSTICE
3916 NAKOMA ROAD
MADISON WI 537I I
E-MAIL: [e-mail]
JOHN R HAMMOND JR
FISHER PUSCH LLP
PO BOX 1308
BOISE ID 83701
E-MAIL : j rh@fi shemusch.com
RYAN B FRAZIER
BRIAN W BURNETT
KIRTON McCONKIE
PO BOX 45t20
SALT LAKE CITY UT 841I1
E-MAIL: [e-mail]
[e-mail]
PRESTON N CARTER
DEBORAH E NELSON
GIVENS PURSLEY LLP
601 W BANNOCK ST
BOISE ID 83702
E-MAIL: prestoncarter@,givenspursley.com
den@ givenspursley. com
DAVID H ARKOOSH
LAW OFFICE OF DAVID ARKOOSH
PO BOX 2817
BOISE ID 8370I
E-MAIL: [e-mail]
BRIANA KOBOR
VOTE SOLAR
986 PRINCETON AVENUE S
SALT LAKE CITY UT 84105
E-MAIL: [e-mail]
ELECTRONIC ONLY
SNAKE RIVER ALLIANCE
wwil son@ snakeriveralliance. org
NW ENERGY COALITION
[e-mail]
DOUG SHIPLEY
INTERMOUNTAIN WIND AND
SOLAR LLC
I953 WEST 2425 SOUTH
WOODS CROSS UT 84087
E-MAIL: [e-mail]
SECRETAR
CERTIFICATE OF SERVICE