20180131Vote Solar 78-100 to IPC.pdf

David Bender, WI Bar # 1046102 (Pro Hac Vice)
Earthjustice
3916 Nakoma Road
Madison, WI 5371I
202-667-4500
db en der(a) earthj usti ce. or g
IN THE MATTER OF THEAPPLICAIION 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, WI537l I
dbender@earthjustice. org
ft[C E IVE D
2$lB J.{il 3 t p}t Z: trS
,,,.l?iilu#i,*l8r,o*
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
)
)
)
)
)
)
)
CASE NO. IPC-E-I7-13
SEVENTH SET OF DATA
REQUESTS BY VOTE SOLAR TO
IDAHO POWER COMPANY
Vote Solar hereby serves its seventh 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 2l days, which is February
20,2018.
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.
Seventh Set of Data Requests by Vote Solar to Idaho Power Company
I
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. ln 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 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.
1 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.
2
Seventh Set of Data Requests by Vote Solar to Idaho Power Corrpany
13. "You", "your", "Company", and "Idaho Power" used herein refer to Idaho 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
78. Reference the following statement by Mr. Timothy E. Tatum on page 5, lines 12-
15 of his rebuttal testimony: "Ensuring customers are making decisions based on
better information will allow the market to advance those technologies that are
competitive from a cost standpoint, not those that compete based on subsidies."
a. Please explain in detail the "better information" that will be provided to
customers under the Company's proposal in this case to establish a rate
class but not the rate design or rates for net metering customers.
b. Please explain how the Company's proposal in this case to establish rate
classes but not rates informs customers of the difference between "those
technologies that are competitive from a cost standpoint" and those that
"compete based on subsidies."
79. Reference the following statement by Mr. Tatum on page 5, lines 18-21 of his
rebuttal testimony: "Lower levels of adoption to date make it easier to address
issues like 'grandfathering' -- the contentiousness of this issue will only grow as
more customers adopt."
a. Please confirm that the Company supports grandfathering at current levels
of adoption.
b. Please indicate the level of adoption at which the Company would no
longer support grandfathering.
80. Reference the following statement by Mr. Tatum on page 5, lines 2l-23 of his
rebuttal testimony: "[C]ustomer education and communication are easier to
facilitate with lower levels of adoption."
a, Please provide all supporting evidence, analysis, documentations, reports,
and information that support this statement.
b. Please identify the customer education and communication efforts that
would be conducted at current levels ofadoption, how each such effort
becomes more difficult with higher adoption levels, and the level of
J
Seventh Set of Data Requests by Vote Solar to Idaho Power Company
adoption at which each customer education and communication effort
becomes infeasible.
81. Reference the following statement by Mr. Tatum on page 5, line 23 through page
6, line 3, of his rebuttal testimony: "Sending a signal today that 'net metering with
volumetric rates is not sustainable' will communicate to those customers
considering investing in solar or other DG that changes in rate design will occur.
Establishing rates that send clear price signals will enable growth of DG in a non-
subsidized manner."
a. Please explain how the Company's proposal in this case to create new
classes but not set rates-with or without volumetric components or any
other rate component- sends a signal that "net metering with volumetric
rates is not sustainable."
b. Please confirm that the Company is not requesting the Commission
establish rates or establish rate design components in this case.
c. Please explain how creating a separate class but not setting rates or a rate
structure communicates that "changes in rate design will occur."
d. Please identify all rates that would send clear price signals to enable
gr6wth of DG in a non-subsidized manner and provide all evidence,
analysis, workpapers and other supporting data that each such rate: (i)
sends a clear price signal; (ii) enables the growth of DG; and (iii)
eliminates any subsidy.
82. Reference the following statement by Mr. Tatum on page 6, lines 19-23 of his
rebuttal testimony: "The Commission has, in other cases, implemented modest
transition periods, and the Company's position is that if the Commission chooses
to implement a transition period in this case, it may be appropriate." Please
identify each instance known to the Company when the Commission has
implemented transition periods.
83. Reference the following statement by Mr. Tatum on page 14, lines l2-15 of his
rebuttal testimony: "Idaho Power does not believe it is in the best interest of its
customers to ignore, and leave in place, a pricing structure that fails to collect
costs from a segment of customers at the expense of other customers."
a. Please explain how the Company's proposal not to change any rates or
pricing until the next General Rate Case does not "leave in place" the
pricing structure described.
b. Identify the number of customers in the residential and small general
service ("R&SGS") classes, other than net metered customers, from whom
the Company fails to collect its cost to serve.
c. Explain all plans the Company has to change its pricing structure for
customers, other than net metered customers, from whom the Company
fails to collect its cost to serve under current pricing.
4
Seventh Set of Data Requests by Vote Solar to Idaho Power Company
84. Reference the following statement by Mr. Tatum on page 15, lines 16-22 of his
rebuttal testimony: "The Company's proposal would take an important step
toward establishing a framework in which a customer's decision to install his or
her own generation system can be informed by the actual economics of doing so
without hidden subsidies that exist within an outdated rate design and
compensation structure."
a. Please explain how approval of "the Company's proposal" in this docket,
which does not change any rates, informs customers of "the actual
economics" of a choice to adopt distributed generation.
b. Please describe the elements of a rate design for customers with
generation that provide the "actual economics" of self generation without
"hidden subsidies," that this case will provide to "inform" customers.
85. Reference the following statements by Mr. Tatum on page 16, lines 5-9 and page
l9,lines 8-15 of his rebuttal testimony: "The Company's proposal recognizes
that, under the status quo, the current pricing structure for R&SGS is ill-suited to
appropriately recover the costs associated with the distinctly different usage
characteristics of R&SGS customers with on-site generation" and "I believe that
there is one relatively limited, but important, policy issue to resolve in this case,
which is to answer the question: 'Do the different load service requirements and
usage characteristics of R&SGS customers who install on-site generation justify a
separate and unique rate structure to provide a reasonable opportunity to recover
the costs of serving those customers?"'
a. Does the Company contend that the Commission should create new
customer classes based on the Company's allegation that it does not have a
reasonable opportunity to recover costs of serving customers with
generation under current rates? Please set forth the full basis for your
answer.
b. If so, does the Company contend that the Commission can make that
determination without first determining the cost of service and/or revenue
recovery under current rates? Please set forth the full basis for your
answer.
86. Reference the discussion of the Fixed Cost Adjustment ("FCA") mechanism on
pages l8 and 19 of Mr. Tatum's rebuttal testimony.
a. Please confirm that the FCA mechanism allows the Company to recover
any shortfall in fixed cost recovery due to decreased energy consumption
by customers for any reason, not limited to net metering.
b. Please confirm that the FCA "facilitates annually any cost shifting that
may exist" from any customer who uses less energy for any reason, not
limited to net metering.
c. If you contend that the FCA facilitates "cost shifting" rather than shifting
the collection of revenue, please explain the basis for your contention,
including, but not limited to, how the Company determines costs for each
FCA adjustment.
5
Seventh Set of Data Requests by Vote Solar to Idaho Power Company
87. Reference Mr. Tatum's discussion of the comparison of "pattern of usage"
between customers with and without on-site generation on pages 20-23 of his
rebuttal testimony and pages 4 through l7 of Mr. Angell's rebuttal testimony.
a. Please provide the electricity load factor, load profile, system coincident
demands ("SCD") and the non-coincident demands ("NCD") for
residential customers who have natural gas service and those who do not.
b. Please provide the electricity load factor, load profile, system coincident
demands ("SCD") and the non-coincident demands ("NCD") for
residential customers who reside in the City of Boise and those who do
not.
c. Please provide the electricity load factor, load profile, system coincident
demands ("SCD") and the non-coincident demands ("NCD") for
residential customers in the top 90th percentile of annual kilowatt-hour
usage and the lowest lOth percentile of annual kilowatt-hour usage.
d. Please provide the electricity load factor, load profile, system coincident
demands ("SCD") and the non-coincident demands ("NCD") for
residential customers in the top 90th percentile of individual customer peak
hour usage and the lowest lOth percentile of individual customer peak hour
usage.
88. Please confirm that Dr. Faruqui's reference to "distributed generation" and "DG"
customers throughout his rebuttal testimony in this case refers to net metered
customers in the residential and small general service classes. If your response is
anything other than an unequivocal confirmation, please define "distributed
generation" and "DG" as used by Dr. Faruqui and explain how it differs from net
metered customers in the residential and small general service classes.
89. Reference the following statement by Dr. Faruqui on page 5, lines 5-7 of his
rebuttal testimony: "This results in an unintended cross-subsidy from non-DG
customers (including a disproportionately large share of lower income customers)
to DG customers."
a. Please quantify the "cross-subsidy" referenced.
b. Please provide all empirical evidence relied on and all workpapers and
calculations of the "cross-subsidy."
c. Please provide the income threshold used to determine a "lower income
customer" in Idaho Power's service territory
d. Please provide the proportion of lower income customers to non-lower
income customers in Idaho Power's service territory and, for each
category, the percentage of customers with distributed generation in Idaho
Power's service territory,
e, Please provide all empirical evidence from Idaho Power's service territory
that supports the assertion that any alleged "cross-subsidy" is from "a
disproportionately large share of lower income customers."
6
Seventh Set of Data Requests by Vote Solar to Idaho Power Cornpany
90. Reference the following statement by Dr. Faruqui on page 8, lines l3-16 of his
rebuttal testimony: "I calculated the hourly average consumption of DG
customers before and after the installation of DG. This gives a sense of how the
DG customer load profiles differ before and after the installation of rooftop PV."
a. Please provide a detailed explanation of the methodology employed to
determine hourly average consumption of DG customers before the
installation of DG from the data provided by Idaho Power.
b. Please provide all data relied on in the above-referenced analysis, in the
format it was provided by Idaho Power to Dr. Faruqui.
91. Reference Dr. Faruqui's Table I on page 10 of his rebuttal testimony. Please
identify:
a. The total number of non-DG residential class customers with a load factor
of llo/o or less during summer months;
b. The total number of non-DG residential class customers with a load factor
of 17% or less during winter months;
c. The total number of non-DG residential class customers with a load factor
of 14% or less during all months; and
d. The load factor of irrigation customers during summer months, winter
months, and all other months.
92. Please provide:
a. All customer data and documentation provided to Dr. Faruqui, in the
format that it was provided by Idaho Power, as referenced on page 11,
lines 14-16 of his rebuttal testimony: "For EE customers, Idaho Power
provided me with hourly load data for a sample of 576 customers."
b. All workpapers and spreadsheets developed by Dr. Faruqui from those
data.
93. Reference page 16 in Dr. Faruqui's rebuttal testimony:
a. Provide all studies, determinations, orders, and any other references to a
"cost shift" Dr, Faruqui considered as part of his "survey" but did not
include in Figure 5.
b. Provide the methodology for Dr. Faruqui's "survey" of "cost shift
estimates" from other jurisdictions, including but not limited to how
studies were identified and how the determination was made as to which
studies to include in Figure 5.
c. Provide all documentation, analysis, and relevant workpapers supporting
Dr, Faruqui's analysis, if any, of any of the alleged "cost shift estimates"
depicted in Figure 5.
7
Seventh Set of Data Requests by Vote Solar to Idaho Power Company
94. Identify, describe, and provide a copy of all analyses and workpapers for each
assessment of actual Idaho Power system costs by Dr. Faruqui in preparation of
his rebuttal testimony in this proceeding, including but not limited to the cost to
serve Distributed Generation customers and/or the cost to serve non-Distributed
Generation customers.
95. Reference the following statement by Dr. Faruqui on page 27,lines l9-21 of his
rebuttal testimony that: "These load characteristics lead to a significant cost shift
when DG customers are billed under the current residential rates with net
metering."
a. Please identify and provide all data and analyses of Idaho Power's service
territory that Dr. Faruqui relied upon to conclude that there exists a
"signifi cant cost shift."
b. Please indicate whether Dr. Faruqui performed any analysis to quantify
the level of "cost shift" from DG customers being billed under the current
residential rates with net metering in Idaho Power's service territory and if
so, provide all such analyses, documentation, and workpapers by Dr.
Faruqui.
96. Please provide, in unlocked Excel file format, with all formulas intact, the data
that form the basis for Ms. Aschenbrenner's Table I and Table 2 onpage 3 of her
rebuttal testimony that differentiates the number of active systems and level of
capacity from the number of systems and level of capacity that is pending.
97. Reference Mr. Angell's discussion of load factor in his rebuttal testimony on
pages 4-5.
a. Please confirm that load factor is not used to determine or allocate cost of
service to customers in the Company's cost of service study methodology.
b. Please confirm that load factor, as discussed by Mr. Angell, is a ratio of
average load to a peak load which is not necessarily a peak load used to
allocate costs in a cost of service study (i.e., the individual customer's
peak load does not correspond to the system coincident peaks or class
peaks used to determine cost allocation in a cost of service study).
98. Please provide your hourly system loads for each of the months represented in
Figures 3 through 5 of Mr. Angell's rebuttal testimony.
99. Reference the following statement by Mr. Angell on page 13, lines 20-22 of his
rebuttal testimony that: "This constraint causes the Company to dispatch less
economic resources resulting in higher energy costs for retail customers."
a. Please quantify the incremental energy costs that were incurred, by month,
for each of the last five years as a result of distributed generation
customers'rate of change in usage.
b. Please provide supporting documentation for your response.
8
Seventh Set of Data Requests by Vote Solar to Idaho Power Company
100. Please provide all analysis and workpapers supporting all rebuttal testimony you
filed in this case in electronic, unlocked, native format with all formulas intact.
DATED: January 30, 2018
Respectfully submitted,
s/ David C. Bender
David C. Bender
Earthjustice
3916 Nakoma Road
Madison, WI 53711
(202) 667-4s00
db en der(@ e arthj usti ce. or g
9
Seventh Set of Data Requests by Vote Solar to Idaho Power Company
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that I have this 30th day of January 2018, served the
foregoing SEVENTH SET OF DATA REQUESTS BY VOTE SOLAR TO IDAHO
POWER COMPANY upon all parties of record in this proceeding, via the manner
indicated:
FedEx and Electronic Mail
Diane Hanian
Cornmission Secretary
Idaho Public Utilities Commission
472 West Washington Street
Boise, lD 83702
Diarre. holt@puc. idaho. gov
(Three copies)
Electronic Mail
IDAHO POWER COMPANY
Lisa D. Nordstrom
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, ID 83707
lno rdstrom(ru idahop ower. com
dockets@idahopower. corn
Timothy E. Tatum
Connie Aschenbrenner
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, ID 83707
ttatr-un @,i dahopow er. com
caschenbrenn er(rD,i dahopower. corn
Seventh Set of Data Requests by Vote Solar to Idaho Power Company
l0
COMMISSION STAFF
Sean Costello
Deputy Attorney General
Idaho Public Utilities Commission
47 2 West Washington (83 702)
PO Box 83720
Boise, lD 83120-0074
Sean. costel lo((Dpuc. idaho. gov
IDAHYDRO
Idahydro clo 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
Tom. arko o shGDarkoo sh. corn
Erin. ceci [e-mail]
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC
Idaho Irrigation Pumpers Association, Inc.
Eric L. Olsen
ECHO HAWK & OLSEN, PLLC
505 PershingAve., Ste. 100
P.O. Box 6119
Pocatello, Idaho 83205
[e-mail]
Idaho Irrigation Pumpers Association, Inc.
Anthony Yankel
12700 Lake Ave., Unit 2505
Lakewood, OH44107
[e-mail]
IDAHO CONSERVATION LEAGUE
MatthewA. Nykiel
Idaho Conservation League
P.O. Box 2308
102 E . Eu,clid, #207
Sandpoint, ID 83864
mnlzkie I (Ei dahoconservati on. org
Seventh Set of Data Requests by Vote Solar to Idaho Power Company
ll
AURIC LLC
Elias Bishop
Auric Solar, LLC
2310 s. 1300 w.
West Valley City, UT 841l9
El i a s. b i shop (g) auric so lar. c om
Preston N. Carter
Deborah E. Nelson
Givens Pursley LLC
601 West Bannock Street
Boise, lD 83702
prestoncarter(@ given spurs Iey. com
den@ gi venspursley.com
SIERRA CLUB
Kelsey Jae Nunez
KELSEY JAE NUNEZ LLC
920 N. Clover Dr.
Boise, ID 83703
k eJ s e v Ca) kel s e yiacnunez.ao m
Tom Beach
Crossborder Energy
2560 gth Street, Suite 213,A.
Berkeley, CA947l0
tomb@)cros sborderenergy. com
ZackWaterman
IDAHO SIERRA CLUB
503 W. Franklin St.
Boise, ID 83702
Zach. waterman@) s i errac lub. org
Michael Heckler
3606 N. Prospect Way
Garden City, ID 83714
Michael.p. heckler@ gmail. com
Seventh Set of Data Requests by Vote Solar to Idaho Power Company
t2
CITY OF BOISE CITY
Abigail R. Germaine
Deputy City Attorney
Boise City Attorney's Office
150 N. Capitol Blvd.
P.O. Box 500
Boise, Idaho 83701-0500
a genna i n e (rD.c i tyo fbo i s e. org
IDAHO CLEAN ENERGY ASSOCIATION
Preston N. Carter
Deborah E. Nelson
Givens Pursley LLC
601 West Bannock Street
Boise, lD 83702
prestoncarter@ givenspursley. com
den(d gi v ensp urs lel,.ceul
VOTE SOLAR
David Bender
Earthjustice
3916 Nakoma Road
Madison, WI 53711
db ender@) earthj ust i ce. org
Briana Kobor
Vote Solar
360 22"d Street, Suite 730
Oakland, CA94612
bri ana (a) voteso I ar. o rg
Seventh Set of Data Requests by Vote Solar to Idaho Power Company
l3
SNAKE RIVER ALLIANCE AND NW ENERGY COALITION
John R. Hammond Jr.
Fisher Pusch LLP
101 South Capitol Blvd., Suite 701
PO Box 1308
Boise, Idaho 83702
irh(g)fisherpusch.com
Snake River Alliance
wwilson(@snakeriveralliance. org
NW Energy Coalition
dicgo(qDnwenergy.org
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
rfrazier@kmclawcom
bburn e tt (D,kmslarry. cala
Intermountain Wind and Solar, LLC
1952 West 2425 South
Woods Cross, UT 84087
dou g(@ imwindands o I ar c om
s/ Mario A. Luna
David C. Bendeq Staff Attorney
Earthjustice
Seventh Set of Data Requests by Vote Solar to Idaho Power Cornpany
l4