20190227Staff 1-7 to IPC.pdf

EDWARD JEWELL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 10446
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Street Address for Express Mail
472W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORB THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S REQUESTED SUSPENSION OF'
SCHEDULE 63 - COMMUNITY SOLAR PILOT
PROGRAM
CASE NO. IPC.E.19.O5
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
IDAHO POWER COMPANY
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Edward Jewell, Deputy Attorney General, request that Idaho Power Company (Company)
provide the following documents and information as soon as possible, or by THURSDAY,
MARCH 14,2019.1
This Production Request is continuing, and the Company is requested to provide, by way
of supplementary responses, additional documents that it or any person acting on its behalf may
later obtain that will augment the documents produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations. The Company is reminded that responses
pursuant to Commission Rules of Procedure must include the name and phone number of the
person preparing the document, and the name, location and phone number of the record holder
I Staff is requesting an expedited response. If responding by this date will be problematic, please call Staff s
attorney at [phone].
FIRST PRODUCTION REQUEST
TO IDAHO POWER
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1 FEBRUARY 27 ,2019
and if different the witness who can sponsor the answer at hearing if need be. Reference IDAPA
3r.01.01.228.
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. l: Please describe all funding sources and avenues the Company
pursued to make the program viable and achieve desired participation rates.
REQUEST NO. 2: In the Company's 2019 Community Solar Annual Report, the
Company describes working with several large customers and a municipality to potentially
purchase unsubscribed portions of the affay. Annual Report at 4. Please describe all options that
were presented to and by the Company and explain why they were not acceptable.
REQUEST NO. 3: In Case No. IPC-E-16-14, the Company described the Community
Solar Pilot Program as a learning opportunity and included customer commitment, construction,
contracting, interconnection, maintenance, and billing as learning areas. Application at 3. For
each of the above listed learning areas please describe:
. What the Company learned.
. How those lessons differed from original assumptions.
. How this program or a future program could be modified to be successful.
REQUEST NO. 4: Please explain the advantages of suspending the program rather than
cancelling it.
REQUEST NO. 5: Please provide an example of a completed Participant Agreement.
REQUEST NO. 6: Please identiff the number of applications the Company denied
since the program began accepting subscriptions. Please provide the reason for each denied
application.
FIRST PRODUCTION REQUEST
TO IDAHO POWER 2 FEBRUARY 27 ,2019
REQUEST NO. 7: For each subscriber to the Company's Community Solar Pilot
Program from 10/3l116to 01/31118, please provide the following information:
o Rate class
o Number of subscriptions purchased
o Method of payment
o Whether subscriber defaulted on payment consistent with the terms of his/her/its
agreement (Yn{)
o Whether subscriber cancelled their subscription (Y/N)
o Regardless of the subscriber's subscription date or whether the subscriber
subsequently cancelled the subscription or terminated service, did the subscriber at
any point during the time period specified above, participate in:
o Schedule 62 - Green Energy Gn{)o Schedule 84 - Net Metering (Y/N)
o Schedule 6 - Residential On Site Generation (YAI)
o Schedule 8 - General Service On-Site Generation (Y/N)
Please provide this information in a searchable Excel spreadsheet format with formulas
intact.
Dated at Boise, Idaho, tnis )1Yday of Febru ary 2019
Edward
Deputy General
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FIRST PRODUCTION REQUEST
TO IDAHO POWER J FEBRUARY 27,2019
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 27Ih DAY OF FEBRUARY 2019,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY,IN CASE NO. IPC-E-19-05,
BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
LISA D NORDSTROM
REGULATORY DOCKETS
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-mail : [e-mail]
dockets@idahopower. com
TIM TATUM
IDAHO POWER COMPANY
PO BOX 70
BOrSE rD 83707-0070
E-mail: [e-mail]
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SECRETABf
CERTIFICATE OF SERVICE