20190401IPC to Vote Solar 1-14.pdf

An IDACORP Company
LISA D. NORDSTROM
Lead Counsel
I [e-mail]
April 1 ,2019
VIA HAND DELIVERY
Diane Hanian, Secretary
ldaho Public Utilities Commission
472 West Washington Street
Boise, ldaho 83702
Re: Case No. !PC-E-18-15
Study of Costs, Benefits, and Compensation of Net Excess Energy Supplied
by Customer On-Site Generation - ldaho Power Company's Response to
Vote Solar's First Production Request to Idaho Power
Dear Ms. Hanian
Enclosed for filing in the above matter are an original and three (3) copies of ldaho
Power Company's Response to Vote Solar's First Production Request to ldaho Power.
Also enclosed are one (1) non-confidential disk and one (1) confidential disk
containing information provided in response to Vote Solar's requests. Please handle the
confidential information in accordance with the Protective Agreement executed in this
matter.
lf you have any questions about the enclosed documents, please do not hesitate to
contact me.
Very truly yours,
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Enclosures
1221 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]
I no rd strom @ id a h opower. com
Attorney for ldaho Power Company
BEFORE THE !DAHO 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-SITE GENERATION
CASE NO. IPC-E-18-15
IDAHO POWER COMPANY'S
RESPONSE TO VOTE SOLAR'S
FIRST PRODUCTION REQUEST
TO IDAHO POWER
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COMES NOW, ldaho Power Company ("!daho Power" or "Comp?[y"), and in
response to Vote Solar's First Production Request to ldaho Power dated March 11,
2019, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO VOTE
SOLAR'S FIRST PRODUCTION REQUEST TO IDAHO POWER - 1
I
REQUEST NO. 1: Please indicate the trading date(s) on which IPC pulled ICE
Futures data underlying Attachment 8a - Workpaper 1 - Energy Price lnputs.
RESPONSE TO REQUEST NO. 1: The lntercontinental Exchange ("lCE") daily
firm Mid-Columbia ('Mid-C") Peak and Off-Peak forward index prices provided in Idaho
Power's response to the ldaho Public Utilities Commission Staffs ("Staffl') Production
Request No. 1 in Attachment 8a - Workpaper 1 - Energy Price lnputs were pulled on
August 13,2018.
The response to this Request is sponsored by Matt Larkin, Revenue
Requirement Senior Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO VOTE
SOLAR'S FIRST PRODUCTION REQUEST TO IDAHO POWER.2
REQUEST NO. 2: Please provide the ICE Futures Daily Market Reports for both
Heavy Load and Light Load hours that are the source of the Mid-C Forward Price Curve
in "Attachment 8a - Workpaper 1 - Energy Price lnputs", sheet "Monthly Mid-C Fonruard
Prices", cells C3:D158. Please provide the reports in their native PDF format, as
obtained from the ICE website ://www.theice.com/ma
RESPONSE TO REQUEST NO. 2: Throu gh its paid subscription, ldaho Power
downloads the lCE futures daily market data for monthly Mid-C forward electric prices
into an Excel database. This database is the source for the information provided in
Attachment 8a - Workpaper 1 - Energy Price lnputs, sheet "Monthly Mid-C Fonruard
Prices," cells C3:D158. The Company does not collect or retain the information in PDF
format.
The response to this Request is sponsored by Matt Larkin, Revenue
Requirement Senior Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO VOTE
SOLAR'S FIRST PRODUCTION REQUEST TO IDAHO POWER.3
REQUEST NO. 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.
RESPONSE TO REQUEST NO. 3: Because ldaho Power's access to ICE is
through a paid subscription, the Company is prohibited from providing monthly Mid-C
fonruard electric prices for the most recent 15 trading days available. However, ICE
makes its futures data for the previous seven trading days publicly available and can be
accessed via the following link: https://www.theice.com/marketdata/reports/142. As
such, ldaho Power has provided updated lCE forward monthly Mid-C Peak and Mid-C
Off-Peak index prices, the same price index used within ldaho Power's response to
Staff's Production Request No. 1 in Attachment 8a - Workpaper 1 - Energy Price
lnputs, for the most recent seven trading days available as of March 28,2019, in the
Excel file produced with this response.
The response to this Request is sponsored by Matt Larkin, Revenue
Requirement Senior Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO VOTE
SOLAR'S FIRST PRODUCTION REQUEST TO IDAHO POWER - 4
REQUEST NO. 4: Please identify 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.
RESPONSE TO REQUEST NO. 4: Please see the confidentia! Excel file
provided with this response for the requested information. The confidential attachment
will be made available to those parties who have signed the Protective Agreement in
this matter.
The response to this Request is sponsored by Tim Tatum, Vice President of
Regulatory Affairs, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO VOTE
SOLAR'S FIRST PRODUCTION REQUEST TO IDAHO POWER.5
REQUEST NO. 5: Please describe any plans or protocols that IPC has in
regards to future hedging activities.
RESPONSE TO REQUEST NO. 5: ldaho Power transacts hedges in
accordance with the risk guidelines outlined in its Energy Risk Management Policy
('ERMP") and Standards ("ERMS"). The ERMP and ERMS are confidential and will be
made available to those parties who have signed the Protective Agreement in this
matter. ERMS Appendices D and F can be viewed on-site at ldaho Power's corporate
headquarters. Please contact Camila McClusky at [phone] or Tami White at
[phone] to arrange a time.
The response to this Request is sponsored by Tim Tatum, Vice President of
Regulatory Affairs, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO VOTE
SOLAR'S FIRST PRODUCTION REQUEST TO IDAHO POWER.6
REQUEST NO. 6: ln 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.
RESPONSE TO REQUEST NO.6: The Com pany posted its 2018 Marginal Cost
Analysis, including a written summary and Excel file, to the non-confidential FTP site for
Case No. !PC-E-18-16 on March 12,2019. The conceptand design of the Company's
marginal cost analysis is based on the National Economic Research Associates'
("NER,q'; marginal cost model and is used to derive energy and transmission capacity
marginal costs that are applied to allocation factors in the Company's class cost-of-
service model. Please note, the Company has not performed a NERA-based review on
distribution marginal costs in the state of ldaho.
The response to this Request is sponsored by Matt Larkin, Revenue
Requirement Senior Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO VOTE
SOLAR'S FIRST PRODUCTION REQUEST TO IDAHO POWER - 7
REQUEST NO. 7: Please provide PDF copies of ldaho Power's completed
FERC Form 1 filings from 1995 to 2018, or the most recent year submitted.
RESPONSE TO REQUEST NO. 7: The 2017 Federal Energy Regulatory
Commission ("FERC") Form 1 filing is the most recent year submitted. The FERC
Form 1 filings for 1995 through 2017 are provided in Attachments 1 through 23,
respectively, produced with this response.
The response to this Request is sponsored by Tim Tatum, Vice President of
Regulatory Affairs, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO VOTE
SOLAR'S FIRST PRODUCTION REQUEST TO IDAHO POWER. S
REQUEST NO. 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. AnnualTransmission Peak Demand (kW)
d. Annual Distribution Substation Peak Demand (kW)
e. Annual Distribution Primary Peak Demand (kW)
f . Annual Distribution Secondary Peak Demand (kW)
RESPONSE TO REQUEST NO. 8:
a-c. Idaho Power's transmission system peak is calculated monthly and
reported annually within the publicly available ldaho Power FERC Form 1 report. The
peak data is located on page 400; column b indicates the monthly peak megawatts.
Please see the attachments provided with the Company's response to Vote Solar's
Request No. 7 above for the FERC Form 1 filings for 1995 through 2017 .
d. Distribution substation peak demand is collected by distribution substation
transformer and peak season (summer and winter) and are provided in the confidential
attachment produced with this response. Reasonably accurate information is available
for transformers that are included in ldaho Power's Supervisory Control and Data
Acquisition ("SCADA") system. Where SCADA does not exist, the peak demand is
calculated manually, only as needed, to ensure transformer capacity is sufficient to
serve anticipated peak demand.
The peak demand and peak season for the distribution substation transformers
are contained in the confidential attachment produced with this response. Data is
IDAHO POWER COMPANY'S RESPONSE TO VOTE
SOLAR'S FIRST PRODUCTION REQUEST TO IDAHO POWER - 9
provided for summer 1995-2018; the winter 2018-2019 data is not yet available. Not all
transformers have data through 2018 (e.9., when there was no need to calculate the
peak demand manually or when a transformer has been replaced with a new
transformer). ln addition, the requested years predate some distribution substation
transformers; therefore, the data is not available for all transformers in all years.
e-f. ldaho Power does not track distribution primary or distribution secondary
peak demand.
The confidential attachment will be made available to those parties who have
signed the Protective Agreement in this matter.
The response to this Request is sponsored by Dave Angell, Transmission and
Distribution Planning Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO VOTE
SOLAR'S FIRST PRODUCTION REQUEST TO IDAHO POWER - 1O
REQUEST NO. 9: Please provide any available information regarding the
marginal unit providing energy during each hour of 2017 and 2018.
RESPONSE TO REQUEST NO. 9: ldaho Power can identify which resources
were on-line in each hour of the year but is not able to specify which unit is the marginal
generating unit during each hour. Because ldaho Power's system is predominantly
hydro based and hydro resources are essentially zero-variable cost resources, the
dispatch of hydro generating units varies based on operational parameters and
opportunity costs rather than a dispatch cost. For this reason, ldaho Power cannot
identify the margina! unit providing energy during each hour.
The response to this Request is sponsored by Matt Larkin, Revenue
Requirement Senior Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO VOTE
SOLAR'S FIRST PRODUCTION REQUEST TO IDAHO POWER - 11
REQUEST NO. 10: Please provide data on market purchases for energy
including volumes, product attributes (day ahead, hour ahead, etc.), delivery point and
prices during 2017 and 2018.
RESPONSE TO REQUEST NO. 10: Please see the confidential Excel file
provided in response to this Request. The confidential attachment will be made
available to those parties who have signed the Protective Agreement in this matter.
The response to this Request is sponsored by Matt Larkin, Revenue
Requirement Senior Manager, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO VOTE
SOLAR'S FIRST PRODUCTION REQUEST TO IDAHO POWER - 12
REQUEST NO. 11: For each customer class an alyzed in the provided cost of
service study please provide the date and time of the customer class's non-coincident
peak.
RESPONSE TO REQUEST NO. 11: The dates and times of the non-coincident
peak for each customer class analyzed in the cost-of-service study are set forth in the
attachment provided in response to this Request. The referenced cost-of-service study
and impacted workpapers were provided in the attachments to the Company's
supplemental response to Staffs First Production Request filed on March 29,2019.
The response to this Request is sponsored by Dave Angell, Transmission and
Distribution Planning Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO VOTE
SOLAR'S FIRST PRODUCTION REQUEST TO IDAHO POWER - 13
REQUEST NO. 12: Please identify the date and time of each of the 12 system
monthly peaks identifies [src/ in the provided cost of service study.
RESPONSE TO REQUEST NO. 12,,The dates and times of the system-
coincident peak for each month of 2017 are set forth in the attachment provided in
response to this Request. The referenced cost-of-service study and impacted
workpapers were provided in the attachments to the Company's supplemental response
to Staffs First Production Request filed on March 29,2019.
The response to this Request is sponsored by Dave Angell, Transmission and
Distribution Planning Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO VOTE
SOLAR'S FIRST PRODUCTION REQUEST TO IDAHO POWER - 14
REQU ESLNO.tI_ll: Ptease provide all load research data available for IPC's net
metering customers including hourly usage data for 2017 and 2018. For each customer
please identify the rate schedule on which the customer takes service, use a unique
identifier and avoid providing any personally identifying information. lf available, please
provide information on the installed solar capacity associated with each net metering
customer.
RESPONSE TO REQUEST NO. 13: Please see the following attachments
provided with this response for the 2017 and 2018 load research data for ldaho Power's
net metering customers:
o Attachment 1: ldaho 2017 Residential Service On-Site Generation;
o Attachment 2: ldaho 20'18 Residential Service On-Site Generation;
o Attachment 3: ldaho 2017 Small General Service On-Site Generation;
o Attachment 4: ldaho 2018 Small General Service On-Site Generation;
o Attachment 5: ldaho 2017 and2018 lrrigation Net Metering; and
. Attachment 6: ldaho 2017 and 2018 Large General Service Net Metering.
The response to this Request is sponsored by Dave Angell, Transmission and
Distribution Planning Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO VOTE
SOLAR'S FIRST PRODUCTION REQUEST TO IDAHO POWER - 15
REQUEST NO. 14: Please provide all load research data available for IPC's
non-net metering customers including hourly usage data for 2017 and 2018. Foreach
customer please identify the rate schedule on which the customer takes service, use a
unique identifier and avoid providing any personally identifying information
RESPONSE TO REQUEST NO. 14: Please see the following attachments
provided with this response for ldaho Power's 2017 and 2018 load research data for
non-net metering customers:
o Attachment 1. ldaho 2017 Residential Sample;
o Attachment 2: Idaho 2018 Residential Sample;
. Attachment 3: ldaho 2017 Small General Service Sample;
. Attachment 4: ldaho 2018 Small General Service Sample;
. Attachment 5: ldaho 2017 lrrigation Sample;
. Attachment 6: ldaho 20lS lrrigation Sample;
o Attachment 7: ldaho 2017 Large General Primary Service;
. Attachment 8: ldaho 2018 Large General Primary Service;
. Attachment 9: ldaho 2017 Large General Secondary Service Sample;
. Attachment 10: ldaho 2018 Large General Secondary Service Sample;
o Attachment 11: ldaho 2017 Large General Transmission Service;
. Attachment 12: ldaho 2018 Large General Transmission Service;
. Attachment 13: ldaho 2017 Large Power Primary Service;
. Attachment 14: ldaho 2018 Large Power Primary Service;
o Attachment 15: Idaho 2017 Large Power Secondary Service;
o Attachment 16: ldaho 2018 Large Power Secondary Service;
IDAHO POWER COMPANY'S RESPONSE TO VOTE
SOLAR'S FIRST PRODUCTION REQUEST TO IDAHO POWER - 16
o Attachment 17: ldaho 2017 Large Power Transmission Service;
o Attachment 18: ldaho 2018 Large Power Transmission Service;
o Attachment 19: ldaho 2017 Special Contract 1;
o Attachment 20: ldaho 2018 Special Contract 1;
o Attachment 21: ldaho 2017 Special Contract 2;
o Attachment22: ldaho 2018 Special Contract 2;
. Attachment 23: ldaho 2017 Special Contract 3; and
o Attachment24: ldaho 2018 Special Contract 3.
The response to this Request is sponsored by Dave Angell, Transmission and
Distribution Planning Manager, ldaho Power Company.
DATED at Boise, ldaho, this 1st day of April 2019.
D
Attorney for ldaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO VOTE
SOLAR'S FIRST PRODUCTION REQUEST TO IDAHO POWER - 17
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 1st day of April 2019 I served a true and correct
copy of IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S FIRST
PRODUCTION REQUEST TO IDAHO POWER upon the following named parties by the
method indicated below, and addressed to the following:
Commission Staff
Edward Jewell
Deputy Attorney General
!daho 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
Idaho Conseryation League and NW
Energy Coalition
Benjamin J. Otto
ldaho Conservation League
710 North 6th Street
Boise, Idaho 83702
F. Diego Rivas
NW Energy Coalition
1101 8th Avenue
Helena, Montana 59601
Idaho lrrigation Pumpers Association, lnc.
Eric L. Olsen
ECHO HAWK & OLSEN, PLLC
505 Pershing Avenue, Suite 100
P.O. Box 6119
Pocatello, ldaho 83205
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erin.cecil@arkoosh. com
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IDAHO POWER COMPANY'S RESPONSE TO VOTE
SOLAR'S FIRST PRODUCTION REQUEST TO IDAHO POWER - 18
Anthony Yankel
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 11
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
Idaho Clean Energy Association
Preston N. Carter
GIVENS PURSLEY LLP
601 West Bannock Street
Boise, ldaho 83702
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nthorpe@ea rth i ustice. orq
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IDAHO POWER COMPANY'S RESPONSE TO VOTE
SOLAR'S FIRST PRODUCTION REQUEST TO IDAHO POWER - 19
ldaho 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
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m ichael. p. heckler@smail. com
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Ch
IDAHO POWER COMPANY'S RESPONSE TO VOTE
SOLAR'S FIRST PRODUCTION REQUEST TO IDAHO POWER - 20