20191004IPC to Vote Solar 15-18.pdf

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An TDACORP Company
LISA D. NORDSTROM
Lead Counsel
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Enclosures
RECEIVEO
?il19 OCT -L Pll 2: l3
Lisa D. Nordstrom
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October 4,2019
VIA HAND DELIVERY
Diane Hanian, Secretary
ldaho Public Utilities Commission
1 1331 W. Chinden Boulevard
Building 8, Suite 201-A
Boise, lD 83714
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 Response to
Vote Solar's Second Production Request to ldaho 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 Second Production Request to ldaho Power.
Also enclosed is one non-confidential disk containing information provided in
response to Vote Solar's requests.
!f you have any questions about the enclosed documents, please do not hesitate to
contact me.
Very truly yours,
LISA D. NORDSTROM (lSB No. 5733)
ldaho Power Company
1221 West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
I nord strom@ idahopower. com
REC E IVE D
:li9OCT -l+ Pl'l 2: l3
ctd
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
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CASE NO. IPC-E-18-15
IDAHO POWER COMPANY'S
RESPONSE TO VOTE SOLAR'S
SECOND PRODUCTION REQUEST
TO IDAHO POWER
COMES NOW, ldaho Power Company ("ldaho Power" or "Company"), and in
response to Vote Solar's Second Production Request to ldaho Power dated September
13,2019, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
SECOND PRODUCTION REQUEST TO IDAHO POWER. 1
REQUEST NO. 15: Reference IPC's response to Vote Solar Request No. 13 in
this docket.
a. Please provide an updated version of IPC's response to Request No. 13
that includes and identifies participants in the demand response program.
b. For each customer included in load research data provided in response to
Request No. 13 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. ln Attachments 5 and 6 to IPC's response to Request No. 13 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. lf Attachment 5 data do not account for meter aggregation, please identify
each customer whose meters are aggregated and provide each customer's usage and
generation production data by meter.
RESPONSE TO REQUEST NO. 15:
a - b. Please refer to Attachments 1-6 provided on the non-confidential CD for
the updated version of ldaho Power's response to Request No. 13. These files have
been updated to include: (1) identification of customers participating in demand
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
SECOND PRODUCTION REQUEST TO IDAHO POWER - 2
response, (2) generation source, and (3) the date on which that customer's distributed
generation was interconnected.
c. Please note that any "negative" values are not used in billing, nor are they
used in any of the analyses that have been utilized in this case. Generally, the
Company has found that a negative value on a generation meter may occur due to one
of the following factors: (1) load on generation meter (such as an inverter) or (2) missing
interval data.
(1) The tariff requires generation to be interconnected "through a meter
that is separate from the retail load metering." The Company rarely encounters
instances where customers have intentionally interconnected load behind the
generation meter; however, when these instances are identified, the Company
works with the customer to relocate the load to the retail meter.
(2) When there is a missing interval that is estimated (due to a variety of
reasons), the Company's meter data will automatically be estimated if missing.
This is done by comparing the difference between the start and stop register
reads to the sum of the intervals for a day. Since the Company's network does
not bring back decimals on register reads but does bring back decimals on
interval data, it is possible to get a negative intervalvalue after estimation.
d. lnterval data for 2017 and 2018 irrigation net metering customers does not
account for meter aggregation.
e. Please refer to Attachment 5, which includes irrigation net metering
customers that transferred Excess Net Energy credits between January and March
2019. The Company has provided the 2017 -2018 hourly data for each of the service
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
SECOND PRODUCTION REQUEST TO IDAHO POWER - 3
points that received the Excess Net Energy credits, and identified the Schedule 84
service point that generated the credits. Please note that Excess Net Energy credits
transferred will be eligible to offset future energy consumption at the service point
receiving the transfer.
The response to this Request is sponsored by Jordan Prassinos, Load
Forecasting Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
SECOND PRODUCTION REQUEST TO IDAHO POWER - 4
REQUEST NO. 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 final and
redline format.
RESPONSE TO REQUEST NO. 16: ldaho Power does not possess the
information in the format requested; however, please see the folder titled "Attachment -
Response to Vote Solar's Request No. 16 - IPUC No. 29 - Tariff No. 101" on the non-
confidential CD that includes a copy of revisions Idaho Power has on file since IPUC
No. 29, Tariff No. 101 became effective on March 1, 2008, per Order No. 30508,
Genera! Rate Case No. IPC-E-07-08. Please note that Schedule 60 is not included in
the tariff because it has no historical sheets. While ldaho Power believes this is a
comprehensive set of documents, to the extent it is not comprehensive, this information
is publicly availabb at the ldaho Public Utilities Commission offices.
The response to this Request is sponsored by Kimberly Towell, Executive
Assistant, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
SECOND PRODUCTION REOUEST TO IDAHO POWER - 5
REQUEST NO. 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, from 2010 to present.
RESPONSE TO REQUEST NO. 17: Please see the attachment to this response
provided on the non-confidential CD for the number of distributed generation
interconnection applications received in ldaho, and total generation capacity, by month
and rate schedule, from 2010 to August 2019.
The response to this Request is sponsored by Patti Best, Customer Generation
Program Specialist, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
SECOND PRODUCTION REQUEST TO IDAHO POWER - 6
REQUEST NO. 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.
RESPONSE TO REQUEST NO. 18: Please see attachment to this response
provided on the non-confidential CD for the number of distributed generation systems
interconnected in ldaho, and total generation capacity, by month and rate schedule,
from 2010 to August 2019.
The response to this Request is sponsored by Patti Best, Customer Generation
Program Specialist, ldaho Power Company.
DATED at Boise, ldaho, this 4th day of October 2019.
LISA
Attorney for ldaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
SECOND PRODUCTION REQUEST TO IDAHO POWER. T
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 4th day of October 2019 ! served a true and
correct copy of IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
SECOND PRODUCTION REQUEST TO IDAHO POWER upon the following named
parties by the method indicated below, and addressed to the following:
Commission Staff
Edward Jewel!
Deputy Attorney General
ldaho Public Utilities Commission
11331 W. Chinden Boulevard
Building 8, Suite 201-A (83714)
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, Idaho 83701
ldaho Conservation League and NW
Energy Coalition
Benjamin J. Otto
ldaho Conservation League
710 North 6th Street
Boise, Idaho 83702
NW Energy Coalition
F. Diego Rivas
NW Energy Coalition
1 101 8th Avenue
Helena, Montana 59601
ldaho lrrigation Pumpers Association, !nc.
Eric L. Olsen
ECHO HAWK & OLSEN, PLLC
505 Pershing Avenue, Suite 100
P.O. Box 6119
Pocatello, ldaho 83205
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tavlor. pestell@arkoosh. com
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IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
SECOND PRODUCTION REQUEST TO IDAHO POWER - 8
Anthony Yankel
12700 Lake Avenue, Unit 2505
Lakewood, Ohio 44107
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Vote Solar
Briana Kobor
Vote Solar
358 South 700 East, Suite 8206
Salt Lake City, Utah 84102
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David Bender
Earthjustice
3916 Nakoma Road
Madison, Wisconsin 537 1 1
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Al Luna
Nick Thorpe
1625 Massachusetts Avenue, NW, Suite 702
Washington, DC 20036
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nthoroe@earth iustice.orq
City of Boise
Abigai! R. Germaine
Deputy City Attorney
Boise City Attorney's Office
150 North Capitol Boulevard
P.O. Box 500
Boise, ldaho 83701-0500
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ldaho Clean Energy Association
Preston N. Carter
GIVENS PURSLEY LLP
601 West Bannock Street
Boise, ldaho 83702
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IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
SECOND PRODUCTION REQUEST TO IDAHO POWER - 9
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
lndustrial Customers of ldaho Power
Peter J. Richardson
RICHARDSON ADAMS, PLLC
515 North 27th Street (83702)
P.O. Box 7218
Boise, ldaho 83707
Dr. Don Reading
6070 Hill Road
Boise, ldaho 83703
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m ichael. p. [e-mail]
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IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
SECOND PRODUCTION REQUEST TO IDAHO POWER - 1O
Micron Technology, lnc.
Austin Rueschhoff
Thorvald A. Nelson
Holland & Hart, LLP
555 Seventeenth Street, Suite 3200
Denver, Colorado 80202
Jim Swier
Micron Technology, !nc.
8000 South FederalWay
Boise, ldaho 83707
lndividual
Russell Schiermeier
29393 Davis Road
Bruneau, ldaho 83604
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[e-mail]
aclee@ hol land hart. com
q lqarqan o-amari@ hol land hart. com
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v ,^r4tlo
berly T Assistant
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
SECOND PRODUCTION REQUEST TO IDAHO POWER - 1,I