20200911Staff 13-26 to IPC.pdf

EDWARD JEWELL
DEPUTY ATTORNEYS GENERAL DM :27IDAHOPUBLICUTILITIESCOMMISSION
PO BOX 83720
BOISE,IDAHO 83720-0074
[phone]
IDAHO BAR NO.10446
Street Address for Express Mail:
11331 W CHINDEN BVLD,BLDG 8,SUITE 201-A
BOISE,ID 83714
Attorneyfor the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER )COMPANY'S APPLICATION TO )CASE NO.IPC-E-20-30
ESTABLISH TARIFF SCHEDULE 68 --)INTERCONNECTIONS TO CUSTOMER )SECOND PRODUCTION
DISTRIBUTED ENERGY RESOURCES )REQUESTOF 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 followingdocuments and information as soon as possible,or by FRIDAY,OCTOBER 2,
2020.
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 and if
different the witness who can sponsor the answer at hearing if need be.Reference IDAPA
31.01.01.228.
SECOND PRODUCTION REQUEST
TO IDAHO POWER 1 SEPTEMBER 11,2020
In addition to the written copies provided as response to the questions,please provide all
Excel and electronic files on CD with formulas activated.
REQUESTNO.13:On page 19 of her direct testimony,Ms.Aschenbrenner states that it is
possible to identify customers who have expanded their system,or cases when they may no longer
be on-line,using Automated Metering Infrastructure (AMI),and that this can be done at a
significant cost savings relative to "rollinga truck."What is the cost savings to the Company if on-
site recertification is removed?Include with your response an Excel workbook that shows the
calculation.
REQUESTNO.14:Please provide workpapers that were used to calculate the return trip
charge of $61.Provide in excel format with formulas in intact.
REQUESTNO.15:How many billinghours are needed to do a thorough on-site
inspection prior to approval?
REQUESTNO.16:How many employees are needed for an on-site inspection?What is
the average loaded wage for an on-site inspector?
REQUESTNO.17:What is the total cost of an on-site inspection to Company,including
but not limited to,direct labor,indirect labor,all expenses,and the amount of time per inspection?
REQUESTNO.18:What is the cost of the system protection package described on pages
17 and 27 of Mr.Ellsworth's direct testimony?
REQUESTNO.19:In reference to Section 2 of Schedule 68,Application Process,please
provide the workpapers and additional information,includinga description,of how the $100
application fee was calculated.Also include within your response the workpapers,notes,approval
from management,and any discussion within the Company about the Schedule 68 proposed
application fee.
SECOND PRODUCTION REQUEST
TO IDAHO POWER 2 SEPTEMBER l1,2020
REQUESTNO.20:Please provide the costs the Company incurs to process an application.
Include with your response an Excel workpaper that includes,but is not limited to,direct labor
hours and cost,indirect labor hours and cost,and any other related expenses.
REQUESTNO.21:Please describe what takes place during a Feasibility,System Impact,
and Facility Study and include time and cost estimates for these proposed types of studies.Please
include samples of these studies.
REQUESTNO.22:Please explain the Company's rationale for not requiring existing
customers to install smart inverters.Does the Company foresee any problems that could occur
because some Schedule 68 customers are using smart inverters and others are using non-smart
inverters?
REQUESTNO.23:How does the Company foresee compensating customers with Smart
Inverter technology that can provide distribution grid benefits?
REQUESTNO.24:What will the Company do (or require)as Smart Inverter variables
and standards change?
REQUESTNO.25:Does the Company have any plans to implement IEEE 1547
communications protocols that would enable it to communicate with customer generator smart
inverters?Please explain why or why not.
REQUESTNO.26:Please explain how the Company intends to manage and modify smart
inverter reactive power and ride through settings in the event that high DER penetration rates risk
causing instability in portions of its grid.
SECOND PRODUCTION REQUEST
TO IDAHO POWER 3 SEPTEMBER 11,2020
DATED at Boise,Idaho,this llth day of September 2020.
Edward JewelL
Deputy AttorneyGeneral
i:umisc:prodreq/ipce20.30ejmm prod req2
SECOND PRODUCTION REQUEST
TO IDAHO POWER 4 SEPTEMBER 11,2020
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 11TH DAY OF SEPTEMBER 2020,SERVED THE FOREGOING SECOND PRODUCTION REQUESTOF THE
COMMISSION STAFF TO IDAHO POWER COMPANY,IN CASE NO.IPC-E-20-30,
BY E-MAILING A COPY THEREOF,TO THE FOLLOWING:
LISA D NORDSTROM CONNIE G ASCHENBRENNER
REGULATORY DOCKETS TIMOTHY E TATUM
IDAHO POWER COMPANY IDAHO POWER COMPANY
PO BOX 70 PO BOX 70
BOISE ID 83707-0070 BOISE ID 83707-0070
E-MAIL:[e-mail] E-MAIL:[e-mail]
[e-mail] [e-mail]
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
710 N 6TH STREET
BOISE ID 83702
E-MAIL:[e-mail]
SECRETARY
CERTIFICATE OF SERVICE