20201007Staff 27-28 to IPC.pdf

EDWARD JEWELL
DEPUTY ATTORNEYS GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-007 4
[phone]
IDAHO BAR NO. 10446
&$:-rjSIV*t}
iji?$ *ti -? Pfi 3: t2
;"1 ., " -., r i , s,_".,.'rt ., i., .;.i*i1-,: ; ,i i:i"; -r. +,;llii$r_&&.
Street Address for Express Mail:
II33I W CHINDEN BVLD, BLDG 8, SUITE 2OI-A
BOISE, D 83]14
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION TO
ESTABLISH TARIFF SCHEDULE 68 -
INTERCONNECTIONS TO CUSTOMER
DISTRIBUTED ENERGY RESOURCES
CASE NO.IPC.E.2O.3O
THIRD PRODUCTION
REQUEST OF THE
COM1VIISSION 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 WEDNESDAY,
ocroBER 28, 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
31.01.0t.228.
THIRD PRODUCTION REQUEST
TO IDAHO POWER
)
)
)
)
)
)
)
)
I OCTOBER 7,2020
ln 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.27: Please describe the communication protocols needed to implement
smart inverters that can communicate with the Company's SCADA system. Does the Company
currently perform distribution system modeling using compatible protocols?
REQUEST NO. 28: Please describe in detail the necessary steps the Company would have
to take to communicate with customer smart inverters. Please include details about any equipment
the Company would need to purchase and descriptions of the work that would need to be
performed, with time and cost estimates.
DATED at Boise, Idaho, this 7h day of October 2020.
S> $a*L{
Edward lerG[]
Deputy Attorney General
i:umisc:prodreq/ipce2O.3Oejmm prod req3
THIRD PRODUCTION REQUEST
TO IDAHO POWER 2 OCTOBER 7,2020
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 7th DAY OF OCTOBER 2020, SERVED
THE FOREGOING THIRD PRODUCTION REQUEST OF THE COMIVTISSION STAFF
TO IDAHO POWER COMPANY, IN CASE NO. IPC-E-20-30, BY E-MAILING A COPY
THEREOF, TO THE FOLLOWING:
LISA D NORDSTROM
REGULATORY DOCKETS
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: lnordstrom @idahooower.com
dockets @ idahopower.com
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
710 N 6TH STREET
BOISE D 83702
E-MAIL: [e-mail]
LISA YOUNG
MIKE HECKLER
IDAHO SIERRA CLUB
503 W FRANKLINE ST
BOISE D 83702
E-MAIL: lisa.young @ sieraclub.org
michael.p.heckler @ gmail.com
CONNIE G ASCT{ENBRENNER
TIMOTHY E TATUM
IDAHO POWER COMPANY
PO BOX 70
BOrSE rD 83707-0070
E-MAIL: [e-mail]
ttatum @ idahopower.com
PRESTON N CARTER
GMENS PURSLEY LLP
601 W BANNOCK ST
BOISE D 83702
E-MAIL: prestoncarter@ givenspursley.com
kendrah @ givenspursley.com
KELSEY JAE
LAW FOR CONSCIOUS LEADERSHIP
920 N CLOVER DR
BOISE ID 83709
E-MAIL: kelsey @kelseyjaenunez.com
CERTIFICATE OF SERVICE