20190329IPC to Staff Supplemental 1.pdf

An IDACORP Company
LISA D. NORDSTROM
Lead Counsel
[e-mail]
March 29,2019
VIA HAND DELIVERY
Diane Hanian, Secretary
ldaho Public Utilities Commission
47 2 \N est Wash i ngton 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 - ldaho Power Company's Supplemental
Response to the First Production Request of the Commission Staff
Dear Ms. Hanian
Enclosed for filing in the above matter are an original and three (3) copies of Idaho
Power Company's Supplemental Response to the First Production Request of the
Commission Staff.
Also enclosed is one (1) copy of a disk containing the supplemental information
being produced in response to Staff's Request No. 1.
lf you have any questions about the enclosed documents, please do not hesitate to
contact me.
Very truly yours,
3Iffi*.
%^*t^,
Lisa D. Nordstrom
LDN:csb
Enclosures
'122'l W ldaho St. (83702)
P.O. Box 70
Boise, lD 83707
LISA D. NORDSTROM (lSB No. 5733)
ldaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
lnordstrom@ idahopower. com
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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-SlTE GENERATION
CASE NO. IPC-E-18-15
IDAHO POWER COMPANY'S
SUPPLEMENTAL RESPONSE
TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION
STAFF
)
)
)
)
)
)
)
)
)
COMES NOW, ldaho Power Company ("ldaho Power" or "Company") and
supplements its response to the First Production Request of the Commission Staff to
ldaho Power Company dated November 21,2018, as follows:
IDAHO POWER COMPANY'S SUPPLEMENTAL RESPONSE TO
THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF - 1
REQUEST NO. 1: ln Order No. 34046, the Commission ordered "an ldaho
Power specific on-site generation docket to study the costs and benefits of net metering
on ldaho Power's system, proper rates and rate design, alongside the related issues of
compensation for net excess energy." See Order No. 34046 a|22. Please provide all
relevant studies and reports conducted by the Company or on its behalf within the last 3
years.
SUPPLEMENTAL RESPONSE TO REQUEST NO. 1: In preparation of its
response to Vote Solar's First Production Request in Case No. IPC-E-18-15, ldaho
Power discovered a portion of the original load research data utilized to develop the
preliminary class cost-of-service study provided in the Company's response to Staffs
Request No. 1 in Case Nos. IPC-E-18-15 and IPC-E-18-16 did not conform to the
methodology described in the accompanying Attachment 4 to the initial response.
Specifically, the 2017 normalized load research data utilized to prepare the cost-of-
service study did not include the adjustment to remove the impact of demand response
programs as described in Attachment 4.
Additionally, in its review, the Company determined that the class data initially
relied upon for Schedule 6 and 8 customers included all months of service, which
encompasses the first partial month of service if applicable. To be consistent with the
Company's established load research sampling methodology, data collection should
only begin during the first complete calendar month of service under the rate schedule.
This effort ensures consistent treatment of customer classes for the derivation of
system-coincident and group-coincident demands.
IDAHO POWER COMPANY'S SUPPLEMENTAL RESPONSE TO
THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF - 2
The Company is providing all impacted workpapers that have been updated from
the preliminary class cost-of-service study with this supplemental response.
The response to this Request is sponsored by Connie Aschenbrenner, Rate
Design Senior Manager, ldaho Power Company, and Matt Larkin, Revenue
Requirement Senior Manager, ldaho Power Company.
DATED at Boise, ldaho, this 29th day of March 2019.
SA NOR
Attorney for ldaho Power Company
IDAHO POWER COMPANY'S SUPPLEMENTAL RESPONSE TO
THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF - 3
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 29th day of March 2019 I served a true and
correct copy of IDAHO POWER COMPANY'S SUPPLEMENTAL RESPONSE TO THE
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF upon the following
named parties by the method indicated below, and addressed to the following:
Gommission Staff
Edward Jewell
Deputy Attorney General
ldaho Public Utilities Commission
472 West Washington Street (83702)
P.O. Box 83720
Boise, Idaho 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 and NW
Energy Coalition
Benjamin J. Otto
ldaho Conservation League
710 North 6th Street
Boise, ldaho 83702
F. Diego Rivas
NW Energy Coalition
1101 8th Avenue
Helena, Montana 59601
ldaho lrrigation Pumpers Association, lnc.
Eric L. Olsen
ECHO HAWK & OLSEN, PLLC
505 Pershing Avenue, Suite 100
P.O. Box 6119
Pocatello, ldaho 83205
_Hand Delivered
_U.S. Mail
_Overnight Mail
_FAXX FTP SiteX Email eelurard.iewell@puqjdaho-gav
_Hand Delivered
_U.S. Mail
_Overnight Mail
_FAXX FTP SiteX Email [e-mail]
eri [e-mail]
_Hand Delivered
_U.S. Mail
_Overnight Mail
_FAXX FTP SiteX Email [e-mail]
_Hand Delivered
_U.S. Mail
_Overnight Mail
_FAXX FTP SiteX Email [e-mail]
_Hand Delivered
_U.S. Mail
_Overnight Mail
_FAXX FTP SiteX Email [e-mail]
IDAHO POWER COMPANY'S SUPPLEMENTAL RESPONSE TO
THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF - 4
Anthony Yanke!
12700 Lake Avenue, Unit 2505
Lakewood, Ohio 44107
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 CIean Energy Association
Preston N. Carter
GIVENS PURSLEY LLP
601 West Bannock Street
Boise, ldaho 83702
_Hand Delivered
_U.S. Mail
_Overnight Mail
_FAXX FTP SiteX Email [e-mail]
_Hand Delivered
_U.S. Mai!
_Overnight Mail
_FAXX FTP SiteX Email [e-mail]
_Hand Delivered
_U.S. Mail
_Overnight Mail
_FAXX FTP SiteX Email [e-mail]
_Hand Delivered
_U.S. Mail
_Overnight Mail
_FAXX FTP Site
x Email aluna@earth iustice.orq
nthorpe@earthi ustice.org
_Hand Delivered
_U.S. Mail
_Overnight Mail
_FAXX FTP SiteX Email [e-mail]
_Hand Delivered
_U.S. Mail
_Overnight Mail
_FAXX FTP SiteX Email [e-mail]
IDAHO POWER COMPANY'S SUPPLEMENTAL RESPONSE TO
THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF - 5
Idaho Sierra Club
Kelsey Jae Nunez
KELSEY JAE NUNEZLLC
920 North Clover Drive
Boise, ldaho 83703
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
_Hand Delivered
_U.S. Mail
_Overnight Mail
_FAXX FTP SiteX Email [e-mail]
_Hand Delivered
_U.S. Mail
_Overnight Mail
_FAXX FTP SiteX Email [e-mail]
michael. p. heckler@qmail. com
_Hand Delivered_U.S. Mail
_Overnight Mail
_FAXX FTP SiteX Email [e-mail]
_Hand Delivered
_U.S. Mail
_Overnight Mail
_FAXX FTP SiteX Email [e-mail]
rry,a Assistantfl
IDAHO POWER COMPANY'S SUPPLEMENTAL RESPONSE TO
THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF - 6