20190312IPC to Sierra Club 1-3.pdf

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LISA D. NORDSTROM
Lead Counse!
[e-mail] I ,: , --.'t,
March 12,2019
VIA HAND DELIVERY
Diane Hanian, Secretary
ldaho Public Utilities Commission
472 West Washington Street
Boise, ldaho 83702
Re Case No. IPC-E-18-15
Study of Costs, Benefits, and Compensation of Net Excess Energy Supplied
by Customer On-Site Generation - Idaho Power Company's Response to the
ldaho Sierra Club's First Production Request
Dear Ms. Hanian
Enclosed for filing in the above matter are an original and three (3) copies of ldaho
Power Company's Response to the ldaho Sierra Club's First Production Request.
Also enclosed are one (1) non-confidential disk and one (1) confidential disk
containing information provided in response to ldaho Sierra Club's requests. Please
handle the confidential information in accordance with the Protective Agreement in this
matter.
lf you have any questions about the enclosed documents, please do not hesitate to
contact me
Very truly yours,
LAJ-PM
Lisa D. Nordstrom
LDN:csb
Enclosures
1221 W. ldaho St. (83702)
P.O. Box 70
Boise, lD 83707
LISA D. NORDSTROM (lSB No. 5733)
Idaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
I nordstrom@ ida hopower. com
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UT!LITIES COMMISSION
RECEIVED
?il191{SR l2 PH 3: l9
L1 t c
IN THE MATTER OF THE PETITION
OF IDAHO POWER COMPANY TO
STUDY THE COSTS, BENEFITS, AND
COMPENSATION OF NET EXCESS
ENERGY SUPPLIED BY CUSTOMER
ON-SITE GENERATION
CASE NO. !PC-E-18-15
IDAHO POWER COMPANY'S
RESPONSE TO THE IDAHO
S]ERRA CLUB'S F!RST
PRODUCTION REQUEST
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COMES NOW, Idaho Power Company ("ldaho Power"), and in response to the
ldaho Sierra Club's First Production Request to ldaho Power Company dated February
27,2019, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE
IDAHO SIERRA CLUB'S FIRST PRODUCTION REQUEST - 1
REQUEST NO. 1: For the ten-year period of 2009 - 2018, please provide in
Excel format the date and hour-ending time of all load hours per year (8760+ data
points per year). For each of these data points, please provide the load being served
during that hour.
RESPONSE TO REQUEST NO. 1: The hourly system loads for the period 2009-
2018 are provided in the attachment produced with this response.
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 THE
IDAHO SIERRA CLUB'S FIRST PRODUCTION REQUEST.2
REQUEST NO. 2: For the period of 2012 - 2018, please provide data in Excel
format showing the number of kilowatts of nameplate capacity for new on-site
generation added within the ldaho Power service territory each month. Please display
the monthly added capacity subdivided by type of generation added (e.g. solar PV,
wind, small hydro, any others).
RESPONSE TO REQUEST NO. 2: The kilowatts direct current (DC) of
nameplate capacity for new on-site generation systems interconnected to ldaho Power's
system each month for the period 2012-2018 is provided in the attachment produced
with this response. The data includes all on-site generation systems taking service
under Schedule 6, Residential On-Site Generation; Schedule 8, Small General Service
On-Site Generation; and Schedule 84, Customer Energy Production Net Metering.
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 THE
IDAHO SIERRA CLUB'S FIRST PRODUCTION REQUEST - 3
REQUEST NO. 3: To assist in evaluating the benefits of exported energy to
avoid or defer future transmission and distribution system expenditures over the useful
life of on-site generating assets, please reference the T&D deferral slides presented at
the January 10, 2019 IRPAC meetinq.
3.1 On approximately the 7th slide, which is the third of three slides titled
"Traditional lnvestments", a total 168 projects were referenced over a "historical" period
from 2002-2018 and a "budgeted" period of 2019-2021". On approximately the 24th
slide, titled "2018 Non-Wire Alternative Analysis", 74 projects are referenced.
a. Please explain whether any of the 74 projects included in the Non-
Wire Alternative Analysis were included in the 168 projects referenced on the
"Traditional lnvestments" slide.
b. For any of the 168 projects that were not in the Non-Wire
Alternative Analysis group, please provide the following data for each such project,
including data of the type shown in the first four columns of the table on the second
slide titled "2018 Non-Wire Alternative Analysis"
i. Location
ii. ln-Service Date
iii. Category (substation or distribution)
iv. Traditional Solution (cost)
v. Season in which any peak load/low voltage conditions
occurred causing need for the investment
3.2 On approximately the 24th slide, titled "2018 Non-Wire Alternative
Analysis", 74 projects are referenced. Of those 74 prqects, 3 were given "ln-depth
IDAHO POWER COMPANY'S RESPONSE TO THE
IDAHO SIERRA CLUB'S FIRST PRODUCTION REQUEST - 4
Analysis" and 71 were deemed to have "Failed Criteria". For each of the 74 projects,
please provide the following data
a. lts location
b. Whether it was a substation growth project or a distribution groMh
project
c. The month and time of day (hour ending) of the peak load for each
project
d. The rate of annual peak load groMh projected for each project
e. The date by which the upgrade must be completed to
accommodate the projected grov'rth
f. The number of years of deferral a non-wire alternative was
estimated to be capable of providing on each project
g. The estimated amount of potential deferral savings for each project
h. The estimated "traditional solution" cost of the project
RESPONSE TO REQUEST NO. 3:
3.1 a. Seven of the 74 projects included in the Non-Wire Alternative Analysis
were included in the 168 projects referenced on the "Traditional lnvestments" slide.
b. The requested information for the remaining 161 projects that were not in
the Non-Wire Alternative Analysis is provided in confidential Attachment 1 produced
with this response.
3.2 The requested information for the 74 projects that were included in the
Non-Wire Alternative Analysis is provided in confidential Attachment 2 produced with
this response.
IDAHO POWER COMPANY'S RESPONSE TO THE
IDAHO SIERRA CLUB'S FIRST PRODUCTION REQUEST. S
The confidentia! attachments will be made available to those parties who sign the
Protective Agreement in this matter.
The response to this Request is sponsored by Dave M. Angell, Senior Manager,
Transmission and Distribution Planning, ldaho Power Company.
DATED at Boise, ldaho, this 12th day of March 2019.
LI D. NO
Attorney for ldaho Power Company
IDAHO POWER GOMPANY'S RESPONSE TO THE
IDAHO SIERRA CLUB'S FIRST PRODUCTION REQUEST - 6
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 12th day of March 2019 I served a true and
correct copy of IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO SIERRA
CLUB'S FIRST PRODUCTION REQUEST upon the following named parties by the
method indicated below, and addressed to the following:
Commission Staff
Sean Costello
Deputy Attorney General
ldaho Public Utilities Commission
472 West Washington Street (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
ldaHydro
C. Tom Arkoosh
ARKOOSH LAW OFFICES
802 West Bannock Street, Suite LP 103
P.O. Box 2900
Boise, ldaho 83701
ldaho Conservation League
Benjamin J. Otto
ldaho Conservation League
710 North 6th Street
Boise, ldaho 83702
ldaho lrrigation Pumpers Association, !nc.
Eric L. Olsen
ECHO HAWK & OLSEN, PLLC
505 Pershing Avenue, Suite 100
P.O. Box 6119
Pocatello, ldaho 83205
Anthony Yankel
12700 Lake Avenue, Unit 2505
Lakewood, Ohio 44107
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erin. [e-mail]
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IDAHO POWER COMPANY'S RESPONSE TO THE
IDAHO SIERRA CLUB'S FIRST PRODUCTION REQUEST. T
Vote Solar
Briana Kobor
Vote Solar
358 South 700 East, Suite 8206
Salt Lake City, Utah 84102
David Bender
Earthjustice
3916 Nakoma Road
Madison, Wisconsin 537 1 1
Al Luna
Nick Thorpe
1625 Massachusetts Avenue, NW, Suite 702
Washington, DC 20036
City 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
GIVENS PURSLEY LLP
601 West Bannock Street
Boise, ldaho 83702
ldaho Sierra Glub
Kelsey Jae Nunez
KELSEY JAE NUNEZLLC
920 North Clover Drive
Boise, ldaho 83703
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nthorpe@earthj ustice. orq
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IDAHO POWER COMPANY'S RESPONSE TO THE
IDAHO SIERRA CLUB'S FIRST PRODUCTION REQUEST - 8
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Zack Waterman
Michael Heckler
ldaho Sierra Club
503 West Franklin Street
Boise, ldaho 83702
PacifiCorp d/b/a Rocky Mountain Power
Yvonne R. Hogle
Rocky Mountain Power
1407 West North Temple, Suite 320
Salt Lake City, Utah 84116
Ted Weston
Rocky Mountain Power
1407 West North Temple, Suite 330
Salt Lake City, Utah 84116
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michael.o [e-mail]
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Christa , LegalAssistant
IDAHO POWER COMPANY'S RESPONSE TO THE
IDAHO SIERRA CLUB'S FIRST PRODUCTION REQUEST - 9