20191206IPC to Staff 2-9.pdf

-<Effian loacoRP company
LISA D. NORDSTROM
Load Counsel
lnordstromdDidrhopowor.com
December 6, 2019
ELECTRONIC FILING
Diane Hanian, Secretary
ldaho Public Utilities Commission
11331 W. Chinden Boulevard
Building 8, Suite 201-A
Boise, ldaho 83714
Re Case No. IPC-E-18-16
Study of Fixed Costs of Providing Electric Service to Customers
ldaho Power Company's ResponsetotheSecond Produc{ion Requestof the
Commission Staff
Dear Ms. Hanian:
Attached for electronic filing is ldaho Power Company's Response to the Second
Production Request of the Commission Stafi. lf you have any questions about the
attached documents, please do not hesitate to contact me.
Very truly yours,
REC EIVED
Jl9lfc -5 Pll 3,23
Lisa D. Nordstrom
E - 4.(r**,**-
C
LDN:kh
Attachments
LISA D. NORDSTROM (lSB No. 5733)
ldaho Power Company't221 West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: (208) 3886936
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 FIXED COSTS OF PROVIDING
ELECTRIC SERVICE TO CUSTOMERS
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CASE NO. TPC-E-18-16
IDAHO POWER COMPANY'S
RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE
COMMISSION STAFF
COMES NOW, ldaho Power Company ("ldaho Powe/ or "Company"), and in
response to the Second Production Request of the Commission Staff to ldaho Power
Company dated November 15, 2019, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF - 1
REQUEST NO. 2: For the classes used to develo p the rates in Appendix I of the
Company's Fixed-Cost Study Report, please provide date ranges during which the
proposed summer and non-summer on-peak demand charges would be assessed.
RESPONSE TO REQUEST NO. 2: Consistent with ldaho Power's current
seasonal rates, the date range for the studied summer on-peak demand charges for
Residential and Small General Service customers, within the Fixed Cost Report, are
June 1 to August 31.
The response to this Request is sponsored by Christina Zwainz, Regulatory
Analyst, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PROOUCTION REOUEST OF THE COMMISSION STAFF.2
REQUEST NO. 3: Please provide the workpapers used to determine the 3:00 -
10:00 pm summer peak periods and 7:00 - 1 1 :00 am and 5:00 - 9:00 pm peak periods
described in Appendix H of the Company's Fixed-Cost Study Report.
RESPONSE TO REQUEST NO. 3: Please see the attachment provided with this
response. ldaho Power reviewed the past five complete calendar years of system level
load data (2014 - 2018) to analyze typical hours the system was g0 percent or over its
monthly or seasonal peak to guide the determination of peak hours. The system level
load data analyzed was adjusted for demand response program impact, in that the
amount of demand response reduction in load was "added back" to properly account for
demand on the system, to differentiate demand from load-serving resources. The peak
periods of 3:00 - 10:00 p.m. in the summer and 7:00 - 1 1 :00 a.m. and 5:00 - 9:00 p.m.
in the winter as described in Appendix H were validated and synthesized using several
measurements (e.9., average hourly values over past five years, average value over
past five years removing impacts of Federal Energy Regulatory Commission holidays
and weekends, and frequency distributions). The Histogram of Occurrences of Hours 90
percenl of Peak charts that are included in Appendix H are shown on the "SYrFreq"
worksheet on the attachment.
The response to this Request is sponsored by Jordan Prassinos, Load Research
and Forecasting Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF - 3
REQUEST NO. 4: Please provide the workpapers used to calculate rates for all
Base and Studied cases presented in Appendices I through L of the Company's Fixed-
Cost Study Report. Please include all supporting assumptions.
RESPONSE TO REQUEST NO. 4: Please see the attachments provided with
this response. The attachments contain the associated appendices as follows:
Attachment 1 -Appendices I
Attachment 2 - Appendices J
Aftachment 3 - Appendices K
Attachmenl 4 - Appendices L
The response to this Request is sponsored by Christina Zwainz, Regulatory
Analyst, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF - 4
REQUEST NO. 5: For each of the customer classes studied in Appendices I
through L of the Company's Fixed-Cost Study Report, please explain how the
Company's basic load charge corresponds to the NCP allocator used by the Company's
2017 CCOS study to allocate distribution plant among classes.
RESPONS E TO REQUEST NO. 5: The basic load capacity ("BLC") charge
corresponds to the non-coincident peak ('NCP') to the extent that each measurement is
made up of metered demand. The NCP assigns demand-related distribution costs to
each class, based on the demand occuning at the customer class group level, while lhe
BLC is based on demand at the individual customer level.
The response to this Request is sponsored by Paul Goralski, Regulatory Analyst,
ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF - 5
REQUEST NO. 6: For each of the customer classes studied in Appendices I
through L of the Company's Fixed-Cost Study Report, please provide the date, time,
and magnitude (kW or MW) of the class Non-CoincidenlPeak used in the 2017 CCOS
Study.
RESPONSE TO REQUEST NO. 6 : Please see the table below for non-
coincident peak date, time, and magnitude used in the 2017 Class Cost-of-Service
Study for Schedule 1, Schedule 7, and Schedule 95.
Customer Class Date Time Magnitude (kW)
Schedule 1 6t20t20't7 '19:00 1,314,595
Schedule 7 1t6t2017 10:00 31,320
Schedule 9S 8t28t2017 16:00 657,339
The response to this Request is sponsored by Paul Goralski, Regulatory Analyst,
ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF - 6
REQUEST NO.7: On page 7 of the Company's Fixed Cost Study Report, the
Company describes how the basic load charge is measured. For each of the customer
classes studied in Appendices I through L, please provide the following:
a. The number of customers for whom at least one peak used to calculate
that customer's Basic Load Charge coincided with the class Non-CoincidenlPeak
Period used in the 20'17 COS study.
b. lf available, please provide this information for the top 100 class non-
coincident peaks for the year 2017.
RESPONSE TO REQUEST NO.7:
a. The requested information is not available. The non-coincident peak day
and time for customer classes 1, 7, and 95 are based on a calendar month, normalized
measurement, while the individual customer peak data used to develop the BLG charge
is based on actual, historical billing demands as reported by billing month, consistent
with other customer classes that have a BLC rate component. Comparison between the
dates and times of non-coincident peak and customer individual peaks would be based
on different, unmatched data sets.
b. The requested information is not available.
The response to this Request is sponsored by Paul Goralski, Regulatory Analysl,
ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF. T
REaUEST NO. 8: For each of the customer classes studied in Appendices I
through L of the Company's Fixed-Cost Study Report, please provide the following for
each year from 2012 through 2018 (inclusive):
a. Total energy (kWh or MWh) billed to each customer class.
b. Total demand (kW or M\0 that would have been billed under the
Company's proposed on-peak demand charge.
c. Total BLC (kW or MW) that would have been billed under the Company's
proposed on-peak demand charge.
RESPONSE TO REQUEST NO. 8:
a. Please see the table below for total energy in kilowatt hours ("kWh") billed
to each customer class within Appendices I through L of the Company's Fixed Cost
Report, for the years2012 -2018.
20tz 2013
t01
r07
20L4 2015
4,850,934,s8s 5,102,500,887 4,8t8,7 L2,815 4,736,250,603
L47,228,L50 143,591,928 134,410,382 130,989,354
3,173,58s,904 3,168,331,971 3,197,489,865
4,962,340,650
2018
4,917 ,220,080
73L,47 4,754
3,240,r90,21L
t01 4,706,9L4,387
t07 130,041,302
t09s
134,786,748
3,L64,778,345 3,209,275,9t3
b. Please see the table below for total 60-minute, on peak demand in
kilowatts ("k\Af) for Schedules 'l and 7 for the years 20'14 - 2OL8.
2074
8,551,428
224,658 225,373 2r8,978
The 2012 and 2013 total 60-minute, on peak demand is not available for Schedules 1
andT.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF. S
2015
t01 8,772,9t5
20t7
9,039,376
2016
8,805,466
2018
8,935,233
t07 226,6s7 224,r25
I
I
T-T t
tGrs 3,090,667,325
2016 20L7
c. Please see the table below for total 60+ninute, BLC in kW for Schedules 1
and 7 for the years 2014 - 2018.
2014 2015 2016 20L7 2018
t01 42,798,674 43,135,837 43,397,885 45,984,370 44,7t6,7r0
t07 1,403,907 1,391,580 1,416,896 7,507,7t7 L,415,408
The 2012 and 2013 total 60-minute BLC is not available for Schedules 1 and 7.
Schedule 9S rate design did not use hourly BLC, but rather 1S-minute BLC. Please see
the table below for total BLC in kW for Schedule 95.
20L2 2013 20t4 20L5 2016 20t7 2018
r(x)s 13,361,553 t4,884,209 13,923,435 t3,979,479 14,128,825 L4,337,002 14,351,513
The response to this Request is sponsored by Christina Zwainz, Regulalory
Analyst, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REOUEST OF THE COMMISSION STAFF - 9
2013 2014 2015 2015 20L7 2018
t09s 10,153,999 10,295,259 L0,4r8,87s ro,576,5s2 10,602,075 70,742,48s 70,733,223
Schedule 95 did not use an on-peak demand within the studied rate, rather the
studied rate structure used demand based on the average of the two highest billed
demand readings. Please see the table below for total demand in kW for Schedule 95.
I zorzI
REQUES T NO.9: On pages 28 through 31 of its Fixed Cost Report, the
Company proposes a three part, tiered rate structure.
a. Please explain how the Company would implement its proposed summer
demand charge using existing AMI meters and AMI infrastructure.
b. Please explain any changes to either the Company's meters or
infrastructure that would be needed in order to implement this rate structure.
RESPONSE TO REQUEST NO.9:
a. ldaho Power's advanced metering infrastructure (?Ml") system collects
additional data from the AMI meters that enables the Company to inform cost-based
rate designs. The hourly kilowatt-hour reading can be used as a 60-minute maximum
demand. The Company would need to evaluate changes necessary to the billing
system before ldaho Power could incorporate 60-minute, on peak demand and BLC
charges for Residential and Small General Service customers.
b. Approximately one pere,ent of customers in ldaho Powe/s ldaho service
territory have non-AMl meters and less than half a percent of customers are scheduled
to have non-AMl meters at the end of 2020. ln order to implement a three-part rate
structure with 60-minute demand and BLC for all Residential and Small General Service
Customers, the Company would need to reprogram non-AMl meters to pull hourly
demand or add load profile dala meters on each of the non-AMl meters.
The response to this Request is sponsored by Christina Zwainz, Regulatory
Analyst, ldaho Power Company.
DATED at Boise, ldaho, this 6h day of December 2019.
D.
Attorney for ldaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PROOUCTION REQUEST OF THE COMMISSION STAFF. 1O
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 6th day of December 2019 I served a true and
correct copy of IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF upon the following named
parties by the method indicated below, and addressed to the following:
Commiesion Staff
Edward Jewell
Deputy Attorney General
ldaho Public Utilities Commission
11331 W. Chinden Blvd
Building 8, Suite 201-A (83714)
P,O. Box 83720
Boise, ldaho 837 2O-0A7 4
ldaHydro
C. Tom Arkoosh
ARKOOSH LAW OFFICES
802 West Bannock Street, Suite LP 103
P.O. Box 2900
Boise, ldaho 83701
ldaho Gonservation League and NW
Energy Coalition
Benjamin J. Otto
ldaho Conservation League
710 North 6th Street
Boise, ldaho 83702
NW Energy Coalition
F. Diego Rivas
NW Energy Coalition
1 101 8th Avenue
Helena, Montana 59601
ldaho lrrigation Pumperc Association, lnc.
Eric L. Olsen
ECHO HAWK & OLSEN, PLLC
505 Pershing Avenue, Suite 100
P.O. Box 61 19
Pocatello, ldaho 83205
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IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF - 11
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Anthony Yankel
12700 Lake Avenue, Unit 2505
Lakewood, Ohio44107
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 5371 1
Al Luna
Nick Thorpe
1625 Massachusefts 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
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IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REOUEST OF THE COMMISSION STAFF. 12
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Sierra Club
Kelsey Jae Nunez
KELSEY JAE NUNEZ LLC
920 North Clover Drive
Boise, ldaho 83703
Zack Waterman
Michael Heckler
ldaho Sierra Club
503 West Franklin Street
Boise, ldaho 83702
Avista Corporation
David J. Meyer
Avista Corporation
1411 East Mission Avenue, MSC 27
P.O. Box3727
Spokane, Wash i ngton 99220-37 27
Patrick D. Ehrbar
Avista Corporation
1411 East Mission Avenue, MSC 27
P.O. Box 3727
Spokane, Washington 99220-3727
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 841'tG
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michael.p. [e-mail]
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ioe.miller@ corp.com
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IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REOUEST OF THE COMMISSION STAFF - 13
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lnduatrial CustomoE of ldsho Power
Peter J. Richardson
RICHARDSON ADAMS, PLLC
515 North 27s Street (83702)
P.O. Box 7218
Boise, ldaho 83707
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Dr. Don Reading
6070 Hill Road
Boise, ldaho 83703
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lndividual
Russell Schiemeier
29393 Davis Road
Bruneau, ldaho 836(X
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m rly , Executive Assistant
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF - 14