20180220IPC to Vote Solar78-100.pdf

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An IDACORP Company
LISA D. NORDSTROM
Lead Counsel
I [e-mail]
February 20,2018
VIA HAND DELIVERY
Diane Hanian, Secretary
ldaho Public Utilities Commission
472 West Washington Street
Boise, ldaho 83702
Re: Case No. IPC-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
Seventh 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 Seventh Set of Data Requests to ldaho Power Company in the
above matter.
Also enclosed are four (4) copies each of nonconfidential and confidential disks
containing information responsive to Vote Solar's data requests. Please handle the
confidential information in accordance with the Protective Agreement executed in this
matter.
Very truly yours,
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Enclosures
P.O. Box 70 (83707)
'1221 W. ldaho St.
Boise, lD 83702
LISA D. NORDSTROM (lSB No. 5733)
ldaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
I nordstrom@ ida hopower. com
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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
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CASE NO. IPC-E-17-13
IDAHO POWER COMPANY'S
RESPONSE TO VOTE SOLAR'S
SEVENTH SET OF DATA
REQUESTS TO IDAHO POWER
COMPANY
COMES NOW, Idaho Power Company ("ldaho Power" or "Comp?ny"), and in
response to Vote Solar's Seventh Set of Data Requests to ldaho Power dated January
30,2018, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
SEVENTH SET OF DATA REQUESTS TO IDAHO POWER COMPANY. 1
REQUEST NO. 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."
RESPONSE TO REQUEST NO. 78:
a. The "better information" is the message that the rate structure for
residential and small general service customers with on-site generation is subject to
change and is currently being evaluated. The sentence prior to the one referenced was:
"lnforming customers today that the pricing structure in place for full requirements
customers does not work in the long-term for partial requirements customers is the first
step." The establishment of new customer classes for residential and small general
service customers with on-site generation by the ldaho Public Utilities Commission
("Commission") (as proposed by the Company in its case) is the first step.
b. As described in the Company's response to part a. above, the context of
the statements in the referenced testimony describe the long-term plan for partial
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
SEVENTH SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 2
requirements customers. If the Commission determines customers with on-site
generation should be in a separate customer class, the next step would be investigating
pricing and compensation structure for those customers based on the cost and benefits
associated with serving those customers.
The response to this Request is sponsored by Timothy E. Tatum, Vice President
of Regulatory Affairs, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
SEVENTH SET OF DATA REQUESTS TO IDAHO POWER COMPANY.3
REQUEST NO. 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.
RESPONSE TO REQUEST NO. 79:
a. & b. The Company has not taken a position on grandfathering. As stated on
page 6 of Mr. Tatum's rebuttal testimony, the Company did not request grandfathering.
The response to this Request is sponsored by Timothy E. Tatum, Vice President
of Regulatory Affairs, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
SEVENTH SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 4
REQUEST NO. 80: Reference the following statement by Mr. Tatum on page 5,
lines 21-23 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 of adoption, how each such effort becomes more
difficult with higher adoption levels, and the level of adoption at which each customer
education and communication effort becomes infeasible.
RESPONSE TO REQUEST NO. 80:
a. & b. Mr. Tatum was speaking from experience when he said that customer
education and communication are easier to facilitate with lower levels of adoption.
One forum used by the Company to communicate with and educate customers is
the use of customer workshops. lt has been ldaho Power's experience that holding a
workshop with fewer customers is easier to facilitate than with a larger number of
customers. lt is much more difficult for the Company to hold a workshop if there were
hundreds, or potentially thousands of customers interested in attending the workshop.
Another forum used to communicate with and educate customers is one-on-one,
direct communication with customers. For instance, the Company employs a limited
number of Net Metering Specialists who are available to answer questions regarding net
metering. !t becomes more difficult to accommodate more calls and thoroughly educate
customers as the number of net metering customers grows.
The response to this Request is sponsored by Timothy E. Tatum, Vice President
of Regulatory Affairs, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
SEVENTH SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 5
REQUEST NO. 81: Reference the followi ng 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
grovuth 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 grovuth of DG; and (iii) eliminates any subsidy.
RESPONSE TO REQUEST NO. 81:
a., b., & c. The Company has concluded that net metering with volumetric
rates is not sustainable, and in light of that conclusion, has asked the Commission to
establish separate classes for residential and small general service customers with on-
site generation and to initiate a process to explore the costs and benefits of serving
those classes of customers. The Company did not request a change to rates or to
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
SEVENTH SET OF DATA REQUESTS TO IDAHO POWER COMPANY.6
establish a new rate design as part of this case. The establishment of new customer
classes for residential and small general service customers with on-site generation by
the Commission (as proposed by the Company in its case) is the first step; if the
Commission determines customers with on-site generation should be in a separate
customer class, the next step would be establishing pricing for those customers.
d. One of ldaho Power's objectives regarding rate design is to establish
prices that primarily reflect the cost of the services provided. ldaho Power has not
identified rates that would send price signals to enable the grov,rth of distributed
generation ('DG') in a non-subsidized manner; however, the Company has asked that
the Commission to commence a generic docket at the conclusion of this case to
establish a compensation structure for customer-owned distributed energy resources
("DER") that reflects both the benefits and costs that DER interconnection brings to the
electric system.
The response to this Request is sponsored by Timothy E. Tatum, Vice President
of Regulatory Affairs, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
SEVENTH SET OF DATA REQUESTS TO IDAHO POWER COMPANY. T
REQUEST NO. 82: Reference the followin g 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.
RESPONSE TO REQUEST NO. 82: Idaho Power is aware of four instances
when the Commission approved transition periods.
1. Utah Power and Liqht lrriqation Load Manaqement Proqram (effective
transition period of 2 irrigation seasons):
o ln the Matter of the Application of Utah Power and Light Company for
Approval of lts Proposed Electic Rate Schedu/es and Electic Servrce
Regulations, Case No. U-1009-96, Order No. 13979 at3-4 (June 15, 1978).
o ln the Matter of the Application of Utah Power & Light Company for Authoity
to lncrease lts Rates and Charges, Case No. U-1009-107, Order No. 16400
at 12-13 (April 14, 1981).
o ln the Mafter of the Application of Utah Power & Light Company for Authoity
to lncrease /fs Rafes and Charges, Case No. U-1009-107, Order No. 16550
(on rehearing) (June 1981).
2. Alternate Distribution Service (1-year transition period): ln the Matter of
the Application of ldaho Power Company for Approval of a Paftial Requirements Taiff
and Altemate Distribution Seruice Taiff in the Sfafe of ldaho, Case No. !PC-E-89-04,
Order No. 22887 at 11-13 (December 28, 1989).
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
SEVENTH SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 8
3. Separation of Commercialand Industrial Customers (effective transition
period of 4 years):
o ln the Matter of the Application of ldaho Power Company for Authority to
lncrease /fs Rafes and Charges for Electric Service in the Sfafe of ldaho,
Case No. U-1006-265A, Order No. 21365 at 44-45 (July 29, 1987).
o ln the Mafter of the Petition of ldaho Power Company for Clarification of the
Sfafus of Tariff Schedu/es 18 and 79, Case No. IPC-E-88-03, Order No.
22041 al3-4 (July 25, 1988).
o ln the Matter of the Application of ldaho Power Company for Approval of a
Contract Demand Charge for Taiff Schedule No. 19, Discontinuance of Tariff
Schedule No. 18, and lmplementation of Changes to Tariff Schedule No. 71 ,
Taiff Schedule No. 9, and General Rules 7 and 14 to Make Ihese Taiff
Schedu/es Compatible to Tariff Schedule No. 79, Case No. IPC-E-92-07,
Order No. 24406 at 34 (July 7, 1992).
4. lndustrial Time of Use Rates (6-month transition period): ln the Matter of
the Application of ldaho Power Company for Authority to lncrease lts lnterim and Base
Rafes and Charges for Electric Seruice, Case No. IPC-E-03-13, Order No. 29505 at 61
(May 25,2004).
The response to this Request is sponsored by Lisa D. Nordstrom, Lead Counsel,
ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
SEVENTH SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 9
REQUEST NO. 83: Reference the following statement by Mr. Tatum on page
14, lines 12-15 of his rebuttal testimony: "ldaho Powerdoes 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. ldentify 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.
RESPONSE TO REQUEST NO. 83:
a. The sentence prior to the one referenced was: "lnforming customers today
that the pricing structure in place for full requirements customers does not work in the
long-term for partial requirements customers is the first step." The establishment of new
customer classes for R&SGS customers with on-site generation by the Commission (as
proposed by the Company in its case) is the first step; if the Commission determines
customers with on-site generation should be in a separate customer class, the next step
would be establishing pricing for those customers.
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
SEVENTH SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 1O
b. ldaho Power does not perform a cost-of-service study for each individual
customer it serves; therefore, the Company is unable to quantify the number of
individual customers from which it fails to collect the costs incurred to serve.
c. One of ldaho Power's objectives regarding rate design is to establish
prices that primarily reflect the cost of the services provided. While the Company is not
currently proposing pricing changes for net metering or standard service customers as
part of its proposal, ldaho Power will continue to evaluate and propose modifications to
the rate design of all customer classes in future rate case proceedings.
The response to this Request is sponsored by Timothy E. Tatum, Vice President
of Regulatory Affairs, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
SEVENTH SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 11
REQUEST NO. 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.
RESPONSE TO REQUEST NO, 84:
a. Please see the Company's response to Vote Solar's Request No. 81.a-c.
b. Please see the Company's response to Vote Solar's Request No. 81.d.
The response to this Request is sponsored by Timothy E. Tatum, Vice President
of Regulatory Affairs, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
SEVENTH SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 12
REQUEST NO. 85: Reference the following statements by Mr. Tatum on page
16, lines 5-9 and page 19, 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 "l 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. lf 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.
RESPONSE TO REQUEST NO. 85:
a. & b. No. ldaho Power's request in this case is based on the belief that
customers with on-site generation are fundamentally different than full requirements
customers; that the load service requirements and pattern of use for R&SGS customers
with on-site generation is distinctly different from that of customers in their current
customer classification.
The response to this Request is sponsored by Timothy E. Tatum, Vice President
of Regulatory Affairs, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
SEVENTH SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 13
REQUEST NO. 86: Reference the discussion of the Fixed Cost Adjustment
("FCA') mechanism on pages 18 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. lf 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.
RESPONSE TO REQUEST NO. 86:
a. & b. The FCA largely addresses fixed cost recovery lost due to reductions in
energy usage per customer in the R&SGS customer classes, regardless of the reason.
However, because fixed cost recovery under the FCA is tracked using a flat rate per unit
of energy, the tiered rate structure applicable to the Company's R&SGS customer
classes does not perfectly align actual fixed costs collected with allowed fixed cost
recovery. The Company's FCA mechanism does not address fixed cost recovery for all
customers, the FCA only applies to the R&SGS classes.
c. The Company is uncertain of what is meant by "shifting the collection of
revenue" and cannot differentiate that from "cost shifting." The Company is therefore not
able to answer this question.
The response to this Request is sponsored by Timothy E. Tatum, Vice President
of Regulatory Affairs, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
SEVENTH SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 14
REQUEST NO. 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 17 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 1Oth 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 10th
percentile of individual customer peak hour usage.
RESPONSE TO REQUEST NO. 87:
a. This dataset is not available because ldaho Power does not track which of
its customers have natural gas service; therefore, the requested analysis does not exist
and cannot be provided.
b., c., & d. The requested analysis does not exist and therefore cannot be
provided. Parties were however provided 2015 and 2016 residential load research
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
SEVENTH SET OF DATA REQUESTS TO IDAHO POWER COMPANY. 15
samples in response to Vote Solar's Request No. 27. The strata definitions were also
provided along with the hourly data that provides a weather zone (regional),
classification for each sample point.
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
SEVENTH SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 16
REQUEST NO. 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. lf 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.
RESPONSE TO REQUEST NO. 88: ln Mr. Faruqui's rebuttal testimony, the use
of the term "DG customers" refers to R&SGS customers with on-site generation who are
net metered. The empirical data contained within Mr. Faruqui's rebuttal testimony is
focused on residential DG customers.
The response to this Request is sponsored by Dr. Ahmad Faruqui, Energy
Economist, Brattle Group.
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
SEVENTH SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 17
REQUEST NO. 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 ldaho Power's service territory
d. Please provide the proportion of lower income customers to non-lower
income customers in ldaho Power's service territory and, for each category, the
percentage of customers with distributed generation in ldaho Power's service territory.
e. Please provide all empirical evidence from ldaho Power's service territory
that supports the assertion that any alleged "cross-subsidy" is from "a disproportionately
large share of lower income customers."
RESPONSE TO REQUEST NO. 89:
a. Dr. Faruqui was making a conceptual point. No quantification was
performed.
b. Studies quantifying the magnitude of the cross-subsidy are discussed in
Section V of Dr. Faruqui's rebuttal testimony. Citations to the studies are provided in
Exhibit No. 17 to Dr. Faruqui's rebuttal testimony.
c. The reference to "lower income customers" is based on the general
observation from three separate studies that there is an inverse relationship between
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
SEVENTH SET OF DATA REQUESTS TO IDAHO POWER COMPANY. 18
rooftop solar photovoltaic ("PV") adoption and household income. Those studies are
discussed and cited in Section V of Dr. Faruqui's rebuttal testimony
d. ldaho Power does not gather income information for its customers and is
therefore is not able to provide the requested information.
e. The statement is based on empirical observations from studies across the
U.S., as described in the responses to prior questions in this data request.
The response to this Request is sponsored by Dr. Ahmad Faruqui, Energy
Economist, Brattle Group.
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
SEVENTH SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 19
REQUEST NO. 90: Reference the following statement by Dr. Faruqui on page 8,
lines 13-16 of his rebuttal testimony: "l 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 ldaho Power.
b. Please provide all data relied on in the above:referenced analysis, in the
format it was provided by ldaho Power to Dr. Faruqui.
RESPONSE TO REQUEST NO. 90:
a. Hourly average consumption of DG customers before the installation of
DG was calculated in several steps.
(1) The DG customer dataset was partitioned into two subsets, the first
reflecting load of customers who would later install DG but had not yet done so,
by using data on the date of DG installation (the second subset reflects net load
of customers after the date of DG installation).
(2) Two panel data regressions were estimated using the pre-
installation subset, one each using data for summer months only and non-
summer months only, as defined in Section lV of Dr. Faruqui's rebuttal testimony.
Each regression used the hourly load reading observations as the dependent
variable and 23 indicator variables for each of hours 2 through 24 as explanatory
variables (with the first hour excluded as it was represented by the constant
term). The regressions were estimated with two-way fixed effects, that is, with a
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
SEVENTH SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 20
separate fixed effect for each customer and a separate fixed effect for each day
of the sample to control for customer-invariant and time-invariant confounding
effects.
(3) The estimated coefficients on the hour 2 through hour 24 indicatory
variables were each added to the estimated coefficient on the constant term.
These yielded the average consumption during these hours for DG customers
before the installation of DG; the average consumption during the first hour is
equal to the estimated coefficient on the constant term in the regression.
(4) The estimated average consumptions were plotted for both summer
and non-summer time periods.
b. The data provided by ldaho Power to Dr. Faruqui for the above-referenced
analysis is provided on the confidential CD. The confidential CD will be provided to
those parties that have executed the Protective Agreement in this matter.
The response to this Request is sponsored by Dr. Ahmad Faruqui, Energy
Economist, Brattle Group.
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
SEVENTH SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 21
REQUEST NO. 91: Reference Dr. Faruqui's Table 1 on page 10 of his rebuttal
testimony. Please identify:
a. The total number of non-DG residential class customers with a load factor
of 11o/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 14o/o or less during all months; and
d. The load factor of irrigation customers during summer months, winter
months, and all other months.
RESPONSE TO REQUEST NO. 91:
?., b., c., & d. The requested analysis has not been performed and therefore
cannot be provided.
The response to this Request is sponsored by Dr. Ahmad Faruqui, Energy
Economist, Brattle Group.
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
SEVENTH SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 22
REQUEST NO. 92:Please provide:
a. All customer data and documentation provided to Dr. Faruqui, in the
format that it was provided by ldaho Power, as referenced on page 11, lines 14-16 of
his rebuttal testimony: "For EE customers, ldaho 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.
RESPONSE TO REQUEST NO. 92:
a. The customer data and documentation provided to Dr. Faruqui is provided
in Attachment 1 on the confidential CD. The confidential CD will be provided to those
parties that have executed the Protective Agreement in this matter.
b. The R-code output and charts are provided in Attachment 2 to this
request.
The response to this Request is sponsored by Dr. Ahmad Faruqui, Energy
Economist, Brattle Group.
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
SEVENTH SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 23
REQUEST NO.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.
RESPONSE TO REQUEST NO. 93:
a. There were no studies, determinations, orders, or any other references
that were not included in Figure 5 of Dr. Faruqui's rebuttal testimony.
b. lnternet searches were conducted to identify studies or regulatory filings
which report the under-recovery of utility costs due to existing compensation
mechanisms for residential customers with rooftop PV.
c. Please see Dr. Faruqui's response to Vote Solar's Data Request No. 89.b.
The response to this Request is sponsored by Dr. Ahmad Faruqui, Energy
Economist, Brattle Group.
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
SEVENTH SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 24
REQUEST NO. 94: ldentify, describe, and provide a copy of all analyses and
workpapers for each assessment of actual ldaho 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.
RESPONSE TO REQUEST NO. 94: Dr. Faruqui reviewed the testimony
provided by ldaho Power witnesses and intervenors, as well as ldaho Power's 2016
Annual Net Metering Status Report.
The response to this Request is sponsored by Dr. Ahmad Faruqui, Energy
Economist, Brattle Group.
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
SEVENTH SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 25
REQUEST NO. 95: Reference the following statement by Dr. Faruqui on page
27, lines 19-21 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 ldaho Power's service
territory that Dr. Faruqui relied upon to conclude that there exists a "significant 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 ldaho Power's service territory and if so, provide all such
analyses, documentation, and workpapers by Dr. Faruqui.
RESPONSE TO REQUEST NO. 95:
a. Dr. Faruqui referred to ldaho Power's 2016 Annual Net Metering Status
Report in his assessment of the cost shift.
b. No. Dr. Faruqui did not perform an analysis to quantify the level of cost
shift from DG customers being billed under the current residential rates with net
metering in ldaho Power's service territory.
The response to this Request is sponsored by Dr. Ahmad Faruqui, Energy
Economist, Brattle Group.
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
SEVENTH SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 26
REQUEST NO. 96: Please provide, in unlocked Excel file format, with al!
formulas intact, the data that form the basis for Ms. Aschenbrenner's Table 1 and Table
2 on page 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.
RESPONSE TO REQUEST NO. 96: Please see the attachment to this Request
for the data that supports Table 1 and Table 2 on page 3 of Ms. Aschenbrenner's
rebuttal testimony.
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
SEVENTH SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 27
REQUEST NO. 97: Reference Mr. Angell's discussion of load factor in his
rebuttaltestimony 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).
RESPONSE TO REQUEST NO. 97:
a. Load factor is not used to determine or allocate costs of service to
customers in the Company's cost-of-service study methodology. Load Factor is a
measure of the utilization rate of electrical energy usage and is effective in determining
differences in usage characteristics; therefore, the load factor is an important measure
when evaluating the differences between R&SGS customers with on-site generation
and those without on-site generation.
b. The load factor is indeed the ratio of average load to a peak load. The
Company's load factor analysis was not used for cost-assignment purposes, it was
performed to illustrate the differences in the utilization rate of electrical energy usage.
The load factor analysis results were one of many factors to conclude that the load
service requirements and pattern of use are distinctly different for residential customers
with on-site generation as compared to residential customers without on-site generation.
The response to this Request is sponsored by Connie Ashenbrenner, Rate
Design Manager, and Dave M. Angell, Senior Manager, Transmission and Distribution
Planning, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
SEVENTH SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 28
REQUEST NO. 98: Please provide your hourly system loads for each of the
months represented in Figures 3 through 5 of Mr. Angell's rebuttal testimony.
RESPONSE TO REQUEST NO. 98: The hourly system loads for January, April,
and June 2016 are provided in the attachment to this request.
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
SEVENTH SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 29
REQUEST NO. 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.
RESPONSE TO REQUEST NO. 99:
a. The Company's Pl data historian stores the DG production, the
hydroelectric, and coal plant production. The examples provided in part b. of this
response display the drop in DG production, constrained hydro production response,
and the Jim Bridger plant production increase as described in my testimony. The
variation in DG and hydro-electric generation conditions make it impossible for the
Company to automate the generation of a report for each month in the last five years;
therefore, the Company is supplying several examples of DG production ramping down,
hydro-electric generation limited by constraints, and the increase of coal generation
output. Table 1 below provides the estimated increased costs due to hydro-electric
generation limitations for the examples provided in part b. For the purpose of this
analysis, the dispatch cost of the Jim Bridger plant on February 14,2018, was used as
the price of coal to estimate the incremental energy cost in each hour.
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
SEVENTH SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 30
Table 1. lncremental Energy Costs
Date Daily Cost
6t17t2017 $ 10,920.12
6t19t2017 $ 151 ,086.14
6t27t2017 $ 31,913.13
6t30t2017 $ 10,142.94
7t15t2017 $ 25,188.39
11t20t2017 $ 82,432.18
1t25t2018 $ 130,807.94
2t5t2018 $ 38,691.59
Total $ 481,182.43
b. Examples of the generation dispatch for several days in 2017 and 2018
are provided in the attachment on the confidential CD. The confidential CD will be
provided to those parties that have executed the Protective Agreement in this matter.
The response to this Request is sponsored by David M Angell, Senior Manager,
Transmission and Distribution Planning, ldaho Power Company.
I
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
SEVENTH SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 31
REQUEST NO. 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.
RESPONSE TO REQUEST NO. 100: Please see the attachment to the
Company's response to Vote Solar's Request No. 63 for the workpapers to support
Table 1 and Table 2 in Ms. Aschenbrenner's rebuttal testimony.
Please see Attachment 1 provided to this request for the workpapers to support
Figure 1, Figure 2, and Table 3 in Ms. Aschenbrenner's rebuttal testimony.
Please see Attachment 2 to this request provided on the confidential CD for the
workpapers to support Figure 1 in Mr. Angell's rebuttal testimony. The confidential CD
will be provided to those parties that have executed the Protective Agreement in this
matter.
Please see Attachment 3 to this request for the workpapers to support Figure 2 in
Mr. Angell's rebuttal testimony.
Please see Attachment 4 to this request for the workpapers to support Figure 3,
Figure 4, and Figure 5 in Mr. Angell's rebuttaltestimony.
Please see Attachment 5 to this request for the workpapers to support Figure 6
and Figure 7 in Mr. Angell's rebuttal testimony.
Please see Attachment 6 to this request for the workpapers to support Figure 9
and Table 2 in Mr. Angell's rebuttal testimony.
Please see Attachment 7 to this request for the workpapers to support Figure 10
in Mr. Angell's rebuttal testimony.
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
SEVENTH SET OF DATA REOUESTS TO IDAHO POWER COMPANY - 32
Please see Attachment 8 to this request for the workpapers to support Figure 11,
Figure 12, and Figure 13 in Mr. Angell's rebuttal testimony.
Please see Attachment 9 to this request for the workpapers to support Figure 2 in
Dr. Faruqui's rebuttal testimony.
Please see Attachment 2 to the Company's response to Request No. 92 for the
workpapers to support Figure 3 in Dr. Faruqui's rebuttal testimony.
Please see Attachment 10 to this request for the workpapers to support Table 1
in Dr. Faruqui's rebuttal testimony.
Please see Attachment 11 to this request for the workpapers to support Figure 4
in Dr. Faruqui's rebuttal testimony.
Please see Attachment 12 to this request for the workpapers to support Figure 5
in Dr. Faruqui's rebuttal testimony.
The response to this Request is sponsored by Connie Aschenbrenner, Rate
Design Manager, Idaho Power Company.
DATED at Boise, ldaho, this 20th day of February 2018.
LISA NORDSTR
Attorney for ldaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
SEVENTH SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 33
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 20th day of February 2018 I served a true and
correct copy of IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
SEVENTH SET OF DATA REQUESTS TO IDAHO POWER COMPANY upon the
following named parties by the method indicated below, and addressed to the following:
Gommission Staff
Sean Costello
Deputy Attorney General
ldaho Public Utilities Commission
472 West Washington (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
ldahydro
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
ldaho 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, ldaho 83205
X Hand Delivered
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eri n. cecil@arkoosh. com
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_FAXX Email [e-mail]
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
SEVENTH SET OF DATA REQUESTS TO IDAHO POWER COMPANY.34
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 84119
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
Gity of Boise
Abigail R. Germaine
Deputy City Attorney
Boise City Attorney's Office
150 North Capitol Boulevard
P.O. Box 500
Boise, ldaho 83701-0500
ldaho Clean Energy Association
Preston N. Carter
Deborah E. Nelson
GIVENS PURSLEY LLP
601 West Bannock Street
Boise, ldaho 83702
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den@o ivenspu rsley. com
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den@q ive nspu rslev. com
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
SEVENTH SET OF DATA REQUESTS TO IDAHO POWER COMPANY.35
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, California 947 10
Zack Waterman
Director, ldaho Sierra Club
503 West Franklin Street
Boise, ldaho 83702
Michael Heckler
3606 North Prospect Way
Garden City, ldaho 83714
Snake River Alliance
NW Energy Goalition
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
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wwi lson @snakeriveral I iance. orq
[e-mail]
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[e-mail]
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
SEVENTH SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 36
Doug Shipley
lntermountain Wind and Solar, LLC
1953 West2425 South
Woods Cross, Utah 84087
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r
Kim rly Towe Assistant
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
SEVENTH SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 37