20190311Vote Solar 1-14 to IPC.pdf

Benjamin Otto (ISB No. 8292)
710 N 6'h Street
Boise,ID 83701
Ph: [phone] x12
Fax: [phone]
botto@idahoconservation. org
Attorney for Vote Solar
IN THE MATTER OF THE )
APPLTCATION OF IDAHO POWER )
COMPANY TO STUDY THE COSTS, )
BENEFTIS, AND COMPENSATION OF )
NET EXCESS ENERGY SUPPLIED BY )
CUSTOMER ON-SITE GENERATION )
IPC-E-18-1s
Vote Solar 1" production request to IPC
t
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
COMES NOW Vote Solar, with the following production requests. Along with the
answer to each question, please provide any supporting documents, workpapers, calculations, or
information sources Idaho Power relies upon to support its answer. As required by IDAPA
31.01.01.228.02, please indicate the witness who can answer question regarding the response and
who will sponsor the response at any hearing. If any responses include Excel spreadsheets or
other electronic files, please provide them with all formulas intact and activated. As allowed by
IDAPA 31.U.01.228.01, if the volume of any response indicates it would be more feasible to do
so Vote Solar agrees to the Company depositing the response in an electronic depository.
This production request is ongoing. Accordingly, we respectfully ask Idaho Power to
provide additional documents and information that may supplement any initial responses.
1. Please indicate the trading date(s) on which IPC pulled ICE Futures data underlying
Attachment 8a - Workpaper 1 - Energy Price Inputs.
2. Please provide the ICE Futures Daily Market Reports for both Heary Load and Light
Load hours that are the source of the Mid-C Forward Price Curve in "Attachment 8a -
Workpaper I - Energy Price Inputs", sheet "Monthly Mid-C Forward Prices", cells
CASENO. IPC-E-I8-15
VOTE SOLAR
FIRST PRODUCTION REQUEST TO
IDAHO POWER
I
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March ll,2019
3. Please provide updated information for the ICE Futures Reports used within the
"Attachment 8a - Workpaper 1 - Energy Price Inputs" file based on the most recent 15
trading days available. .
4. Please identiff all fuel hedging activities and expenditures (if any) by IPC during each of
the last ten years. For each hedging product purchased in the last ten years, please provide
the trade date, start date, end date, price, volume, and any other information available
regarding the hedging product purchased.
5. Please describe any plans or protocols that IPC has in regards to future hedging activities
6. In the meeting on February 26,2019 Mr. Tatum referenced an existing NERA-derived
marginal cost of service assessment on T&D costs. Please provide the most recent version
of that assessment including any underlying workpapers in Excel format with formulas
and links intact.
7. Please provide PDF copies of Idaho Power's completed FERC Form 1 filings from 1995 to
2018, or the most recent year submitted.
8. Please provide the following peak demand information for 1995 to 2018:
a. Summer Transmission Peak Demand (kW)
b. Winter Transmission Peak Demand (kW)
c. Annual Transmission Peak Demand (kW)
d. Annual Distribution Substation Peak Demand (kW)
e. Annual Distribution Primary Peak Demand (kW)
f. Annual Distribution Secondary Peak Demand (kW)
9. Please provide any available information regarding the marginal unit providing energy
during each hour of20l7 and 2018.
10. Please provide data on market purchases for energy including volumes, product attributes
(day ahead, hour ahead, etc.), delivery point and prices during 2017 and20lB.
1 1. For each customer class analyzed in the provided cost of service study please provide the
date and time of the customer class's non-coincident peak.
12. Please identify the date and time of each of the 12 system monthly peaks identifies in the
provided cost of service study.
13. Please provide all load research data available for IPC's net metering customers including
hourly usage data for 2017 and 2018. For each customer please identifi, the rate schedule
on which the customer takes service, use a unique identifier and avoid providing any
personally identi$.ing information. If available, please provide information on the
installed solar capacity associated with each net metering customer.
IPC-E-18-15
Vote Solar 1" production request to IPC
2 March ll,2019
C3:Dl58. Please provide the reports in their native PDF format, as obtained from the ICE
website (https ://www.theice.com/marketdata/reports).
14. Please provide all load research data available for IPC's non-net metering customers
including hourly usage data for 2017 and 2018. For each customer please identifir the rate
schedule on which the customer takes service, use a unique identifier and avoid providing
any personally identifting information
DATED the 1l'h day of March2}l9.
Benjamin J. Otto
Local Council for Vote Solar
Idaho Conservation League
IPC-E-18-1s
Vote Solar 1't production request to IPC
3 March ll,2019
CERTIFICATE OF SERVICE
I hereby certifr that on this 1 l'h day of Mar ch 2Ol9I delivered true and correct copies of
the foregoing FIRST PRODUCTION REQUEST TO IDAHO POWER to the following via the6^fumethod of service noted:
Hand Delivery Mail:
Diane Hanian
Commission Secretary (Original and three copies provided)
Idaho Public Utilities Commission
427 W. Washington St.
Boise, ID 83702-5983
Electronic Mail Only:
Benjamin I. Otto
com
Vote Solar
Briana Kobor, Vote Solar
[e-mail]
David Bender, Earthjustice
[e-mail]
Al Luna, Ealrthjustice
aluna@qarlh iwliee. org
Nick Thorpe, Earthjustice
nthorpe@earthj ustice.org
City of Boise
Abigail R. Germaine
Deputy CityAttorney
Boise City's Attorney's Office
agermaine@citFofboise. org
Idaho Sierra Club
Kelsey fae Nunez
Kelsey fae Nunez LLC
Kelsey@kelseyj arnunez. com
ZackW aterman, Sierra Club
Mike Heckler, Sierra Club
Zack.waterman@sierraclub. org
[e-mail]
Idaho Clean Energt Associaiton
Preston N. Carter
Givens Pursley LLP
prestoncarter@givenspursely. com
March ll,2019
IPUC
Sean Costello
Deputy Attorney General
Idaho Public Utilities Commission
Sean. [e-mail]. gov
Idaho Power
Lisa D. Nordstrom
Timothy E. Tatum
Connie Aschenbrenner
[e-mail]
[e-mail]
[e-mail]
[e-mail]
Idaho Irrigation Pumpers Association
Eric L. Olsen
Echo Hawk & Olsen PLLC
[e-mail]
Anthony Yankle
[e-mail]
IDAHYDRO
C. Tom Arkoosh
Arkoosh Law Offices
Tom. [e-mail]
[e-mail]
Rorky Mountain Power
Ted Weston
Yvonne R. Hogle
Ted.weston@pacifi corp. com
IPC-E-18-15
Vote Solar 1" production request to IPC
4