20190918Vote Solar 15-18 to IPC.pdf

ldatro Public Utilities Commission
o'ffgJt',iT'S"'Y
sEP I S 2019
Boleo' ldahoBenjamin Otto (lSB No. 8292)
Tl0N6thStreet
Boise. ID 83701
Ph: [phone] x 12
Fax: [phone]
bottoiil iclalroconscrvation.org
David Bender (pro hac vice)
Earth.iustice
3916 Nakoma Road
Madison, WI 53711
Ph: [phone]
dbender(at eart hj u st i ce.o rg
Attorneys for Vote Solar
IN THE MATTER OF THE
APPLICATION OF IDAHO POWER
COMPANY TO STUDY THE COSTS,
BENEFITS, AND COMPENSATION
FO NET EXCESS ENERGY
SUPPLIED BY CUSTOMER ON.
SITE GENERATION
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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CASE NO. IPC-E-I8-I5
SECOND PRODUCTION
REQUEST TO IDAHO POWER
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
3 I .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 forrnulas intact and activated. As allowed by
IDAPA 3l .01.01.228.01, 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.
I
2nd production request to IPC September 13,2019
This production request is ongoing. Accordingly, we respectfully ask Idaho Power to
provide additional documents and information that may supplement any initial responses. Please
prove responsive data using consistent unique customer identifiers in excel format with formulas
and links intact.
15. Reference IPC's response to Vote Solar Request No. l3 in this docket.
a. Please provide an updated version of IPC's response to Request No. l3 that
includes and identifies participants in the demand response program.
b. For each customer included in load researclr data provided in response to Request
No. l3 and any update provided in response to subquestion (a), above, please
identify the date on which that customer's distributed generation was
interconnected and the generation source (i.e., solar PV, wind. hydro, etc.).
c. In Attachments 5 and 6 to IPC's response to Request No. l3 there are customers
with both positive and negative data on the "Generation" tab of the spreadsheet.
Please explain why distributed generation production is identified as having both
positive and negative values and provide an explanation of what the positive and
negative values represent.
d. Please explain how the data for irrigation net metering customers included in the
Attachment 5 data account for meter aggregation.
e. If Attachment 5 data do not account fbr meter aggregation, please identifu each
customer whose meters are aggregated and provide each customer's usage and
generation production data by meter.
16. Provide a copy of each tariff sheet that was in effect at any time, for any schedule,
between 2010 an present. Please provide in both tlnal and redline fbrmat.
17. Please provide the number of distributed generation interconnection applications
received, and the total generation capacity in kW-DC for those applications. by month
and customer rate schedule, fronr 2010 to present.
18. Please provide the number of distributed generation systems interconnected. and the total
generation capacity in kW-DC for those systems, by month and customer rate schedule,
from 2010 to present.
DATED the l3th day of September. 2019
/,s/ David Bender
David C. Bender
Earthjustice
2
2nd production request to IPC September 13,2019
CERTIFICATE OF SERVICE
I hereby certifu that on this l3th day of September I delivered true and correct copies of
the foregoing SECOND PRODUCTION REQUEST TO IDAHO POWER to the following via
the method of service noted:
First C Mail:
Diane Hanian
Commission Secretary (Original and three copies provided)
Idaho Public Utilities Commission
427 W. Washington St.
Boise. ID 83702-5983
Electronic Mail Onlv:
Idaho Power
Lisa D. Nordstrom
Timothy E. Tatum
Connie Aschenbrenner
Regulatory Dockets
Idaho Power Company
P.O. Box 70
Boise. Idaho 83707
I nordstrom@ idahopower.com
ttatum@i dahopower.com
cashen bren ner@ idahopower.com
dockets@ idahopower.com
t;LDslid js&t
David C. Bender
Earthjustice
J
2nd production request to IPC September 13,2019