20180116Staff to Vote Solar 1-7.pdf

SEAN COSTELLO
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720.007 4
(208) 334-03t2
IDAHO BAR NO. 8743
Street Address for Express Mail:
472 W . WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BBFORE THE IDAHO PUBLIC UTILITIBS COMMISSION
R E CE IVED
2018 JAN l5 Pl{ Z: 25
iilrtli,) l*ljBLlCi, .: j il::li CCIJMISSION
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. IPC.E-17-13
STAFF'S RESPONSE TO VOTE
SOLAR'S FIRST SET OF DATA
REQUESTS
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The Staff of the Idaho Public Utilities Commission responds as follows to Vote
Solar's First Set of Data Requests to Commission Staff.
REQUEST NO. 1: 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.
STAFF'S PRODUCTION RESPONSE
TO VOTE SOLAR 1 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 Staff s proposal can be found in cells E8789
through 8895 of the "Residential" tab in the spreadsheet "Net Metering Analysis_171228.xlsx."
These cells have been highlighted in Blue.
Dr. Morrison used data provided by the Company through Staff s Production Request
No. 12 in his analysis of non-net metering consumption patterns. Dr. Morrison's calculation of
non-net metering consumption and billing under current rates and Staff s 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 7 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 Staff s Response to Idaho Power Company's First
Production Request.
This response is sponsored by Idaho Public Utilities Commission Staff Engineer, Michael
Morrison, PhD.
REQUEST NO. 2: On page 11, lines 7-12Mr. Morrison's Direct testimony refers to
"2016 DSM avoided cost rates" that were used to estimate an average net metering customer's
bill under Staffls 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.
STAFF RESPONSE NO.2:
a. Dr. Morrison used the 20i5 costs from the Company's 2013 IRP, Technical Index
(Appendix C), Page 77, Docket No. IPC-E-I3-15.
b. The Company's filing can be found at the Idaho Public Utilities Commission website:
STAFF' S PRODUCTION RESPONSE
TO VOTE SOLAR 2 JANUARY 16,2018
idaho.I I
TE,CHNICAL INDEX.PDF.
This response is sponsored by Idaho Public Utilities Commission Staff Engineer, Michael
Morrison, PhD.
REQUEST NO. 3: Please confirm that Mr. Morrison's statements on page 9,
lines 1 l-77 , regarding a customer's "share" of costs and whether customers "are subsidized" and
on page 12, lines 5-T,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.
STAFF RESPONSE NO. 3: As stated on page 4 of Dr. Morrison's testimony, the
Company did not provide a cost of service study, so neither of these statements is correct.
This response is sponsored by Idaho Public Utilities Commission Staff Engineer, Michael
Morrison, PhD.
REQUEST NO.5: Please reference page 16, lines 17-20, and Table 2 of Mr. Morrison's
Direct.
a. Please identify the distribution plant component costs caused by the Net Metering
Group's non-coincident peak load.
b. Please identify the Net Metering Group's load at 7:00 pm on July 26,2016 (i.e.,
during the Non-Net Metering Group's Non Coincidental 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.
STAFF'S PRODUCTION RESPONSE
TO VOTE SOLAR J JANUARY 16,2018
STAFF RESPONSE NO. 5:
a. The Company did not provide a cost of service study in this case, and Staff did not
perform such an analysis, so it is not possible to provide the information requested by Vote
Solar.
b. The average net metering load for the hour endingatT:00 pm on July 26th,2016 was
2.351 kW.
c. Dr. Morrison disagrees that Vote Solar's proposed allocator premise is appropriate. In
an idealized cost allocation scenario, the costs of distribution equipment would be allocated
based on each group's contribution to the peak loading of each distribution plant component;
however, because this would require a separate analysis of each component, this is not always
practical. Outside of the idealized scenario discussed above, distribution plant is often allocated
based on each class' share ofnon-coincident peak.
This response is sponsored by Idaho Public Utilities Commission Staff Engineer, Michael
Morrison, PhD.
REQUEST NO.6: Reference Direct Testimony of Stacey Donohue, page 5,lines 1-4.
Please identify each of the capacity costs that are lowered by net metering customers.
STAFF RESPONSE NO. 6: The Company did not provide a cost of service study in
this case, so the specific capacity costs which are lowered are unknown.
This response is sponsored by Idaho Public Utilities Commission, Technical Analysis
Program Manager, Stacey Donohue, MPA.
REQUEST NO. 7: Reference Direct Testimony of Stacey Donohue, page 10,
lines 15-17. 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 the cost of service studv.
STAFF' S PRODUCTION RESPONSE
TO VOTE SOLAR 4 JANUARY 16,2018
STAFF RESPONSE NO. 7: Neither of these statements were based on a cost of service
study because the Company did not provide such a study in this case.
This response is sponsored by Idaho Public Utilities Commission, Technical Analysis
Program Manager, Stacey Donohue, MPA.
JDated at Boise, Idaho, this /2 day of January 2018.
Costello
Deputy Attorney General
Technical Staff: Michael Morrison
Stacey Donohue
i.umisc:prodreq/ipcelT.l3scmmsd response to Vote Solar prod req
STAFF' S PRODUCTION RESPONSE
TO VOTE SOLAR 5 JANUARY 16,2OI8
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS I6TH DAY OF JANUARY 2018,
SERVED THE FOREGOING STAFF'S RESPONSE TO VOTE SOLAR'S FIRST SET
oF DATA REQUESTS, N CASE NO. IPC-E-17-73, By MAILING A COpy
THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
LISA D NORDSTROM
REGULATORY DOCKETS
IDAHO POWER COMPANY
PO BOX 70
BOrSE rD 83707-0070
E-MAIL: [e-mail]
com
C TOM ARKOOSH
ARKOOSH LAW OFFICES
802 W BANNOCK ST STE 9OO
PO BOX 2900
BOISE ID 8370I
E-MAIL : [e-mail]
erin.ceci l@arkoosh. com
ANTHONY YANKEL
I27OO LAKE AVENUE
LINIT 2505
LAKEWOOD OH 44107
E-MAIL: tony@y .net
TOM BEACH
CROSSBORDER ENERGY
2560 9TH STREET, SUITE 2I3A
BERKELEY CA 94710
E-MAIL: [e-mail]
TIMOTHY E TATUM
CONNIE ASCHENBRENNER
IDAHO POWER COMPANY
PO BOX 70
BOrSE iD 83707-0070
E-MAIL : [e-mail]
caschenbrenner@idahopower. com
MATTHEW A NYKIEL
ID CONSERVATION LEAGUE
I02 S EUCLID #207
PO BOX 2308
SANDPOINT ID 83864
E-MAIL: [e-mail]
ERIC L OLSEN
ECHO HAWK & OLSEN PLLC
PO BOX 6119
POCATELLO ID 83205
E-MAIL: elo@.echohawk.com
KELSEY JAE NUNEZ LLC
920 N CLOVER DR
BOISE ID 83703
E-MAIL: kelse),@kelseyj aenunez.com
ELECTRONIC ONLY
MICHAEL HECKLER
michael.p.heckler@ gmail.com
ZACK WATERMAN
zack. waterman @,si erracl ub. orq
CERTIFICATE OF SERVICE
ELIAS BISHOP
AURIC SOLAR LLC
2310 s 1300 w
W VALLEY CITY UT 84119
E-MAIL: [e-mail]
ABIGAIL R GERMAINE
DEPUTY CITY ATTORNEY
BOISE CITY ATTORNEY'S
PO BOX 500
BOrSE ID 83701-0500
E-MAIL : [e-mail]
DAVID BENDER
EARTHJUSTICE
3916 NAKOMA ROAD
MADISON WI 53711
E-MAIL: [e-mail]
JOHN R HAMMOND JR
FISHER PUSCH LLP
PO BOX 1308
BOISE ID 83701
E-MAIL : j rh@fi sherpusch.corn
RYAN B FRAZIER
BRIAN W BURNETT
KIRTON McCONKIE
PO BOX 45120
SALT LAKE CITY UT 84I 1 1
E-MAIL: [e-mail]
[e-mail]
PRESTON N CARTER
DEBORAH E NELSON
GIVENS PURSLEY LLP
601 W BANNOCK ST
BOISE TD 83702
E-MAIL: [e-mail]
den@ givenspursle),. com
DAVID H ARKOOSH
LAW OFFICE OF DAVID ARKOOSH
PO BOX 2817
BOISE ID 83701
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
wwi I [e-mail]
NW ENERGY COALITION
[e-mail]
DOUG SHIPLEY
INTERMOUNTAIN WIND AND
SOLAR LLC
1953 WEST 2425 SOUTH
WOODS CROSS UT 84087
E-MAIL: [e-mail]
SECRET
CERTIFICATE OF SERVICE