20220803Staff 1-25 to IPC.pdf

RILEY NEWTON
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, TDAHO 83720-0074
[phone]
IDAHO BAR NO. II2O2
Street Address for Express Mail:
I1331 W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
i r-1I t_
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IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION TO
COMPLETE THE STUDY REVIEW PHASE
OF THE COMPREHENSIVE STUDY OF
COSTS AND BENEFITS OF ON.SITE
CUSTOMER GENERATION & FOR
AUTHORITY TO IMPLEMENT CHANGES
TO SCHEDULES 6, 8, AND 84
CASE NO.IPC.E-22-22
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO IDAHO POWER COMPANY
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Staff of the Idaho Public Utilities Commission, by and through its attomey of record,
Riley Newton, Deputy Attorney General, requests that Idaho Power Company ("Company")
provide the following documents and information as soon as possible, but no later than
WEDNESDAY, AUGUST 24,, 2022.
This Production Request is to be considered as 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 or information produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name, job title, and telephone number of
the person preparing the documents. Please also identifu the name, job title, location, and
telephone number of the record holder.
FIRST PRODUCTION REQUEST
TO IDAHO POWER 1 AUGUST 3,2022
In addition to the written copies provided as response to the requests, please provide all
Excel spreadsheets and electronic files on CD with formulas intact and enabled.
REQUEST NO. l: Please answer the following for Measurement Intervals:
a. Please provide Schedule 84 Net Billing analysis data for non-legacy systems with a
single-meter interconnection for the hourly and real-time or "instantaneous"
measurement intervals.
b. Please provide additional explanation and supporting data as to why Schedule 84 two-
meter interconnection measurement interval analysis was not provided.
REQUEST NO. 2: Please answer the following for recovery of Export Credit Rate
("ECR") expenditures:
a. Does the Company include kilowatt-hours ("kWh") generated and consumed for
legacy and non-legacy on-site customer-generators in the PCA? If so, please provide
the impact to the 2021-2022 PCA if removed.
b. Order No. 35284 at 14 states "[O]ne question to study is whether all customers or just
on-site generation export customers or another class of customers should bear the
export credit costs." Please identi$ where in the Value of Distributive Energy
Resources ("VODER") study this question was analyzed. If this was not analyzed in
the VODER study, please provide the Company's analysis.
c. Please provide a bill impact analysis for Schedule 6, 8, and 84 if customer-generators
are subject to recovery of their own ECR.
REQUEST NO.3: Please answer the following for the compensation structure:
a. Please provide Schedule 84 bill impacts using Net Billing - Hourly measurement
interval and compensation structure using the Study example ECR of $0.03781.
b. Did the Company perform a bill impact analysis of Schedule 84? If not, why not? If
so, please explain how the Company dealt with the two-meter configuration and
provide the analysis?
FIRST PRODUCTION REQUEST
TO IDAHO POWER 2 AUGUST 3,2022
REQUEST NO. 4: Order No. 35284 requires the study to "[a]nalyze the pros and cons
of setting a customer's project eligibility cap according to a customer's demand as opposed to
predetermined caps of 25 kilowatt ("kW") and 100 kW". The Order also requires the study to
expand the analysis at 125%o of customers' demand. Please respond to the following.
a. Please identify where the pros and cons of setting a cap according to a customer's
100% and l25o/o demand as opposed to predetermined caps of 25 kW and 100 kW are
located in the VODER study. If this was not provided in the VODER study, please
provide them.
b. Please identi$ where the 100% cap analysis is located in the VODER study. If this
was not provided in the VODER study, please provide it.
c. Please identiff where the l25Yo cap analysis is located in the VODER study. If this
was not provided in the VODER study, please provide it.
REQUEST NO. 5: Please provide a histogram (10 kW intervals) showing the number of
non-solar residential customers with demand peaks greater than 25 kW.
REQUEST NO. 6: Please provide a histogram (100 kW intervals) showing the number
of non-solar Commercial, Industrial, and Irrigation ("CI&I") customers with demand peaks
greater than 100kW.
REQUEST NO. 7: The VODER study asserts that larger customer generation systems
inject more risk. The VODER study also describes thresholds that trigger additional analysis for
Public Utility Regulatory Policies Act of 1978 ("PURPA") project interconnections (> 2
megawaff ("MW") and/or exceeds l5% of the distribution line section / p.100). This implies that
projects below that threshold are small enough to be considered safe to the overall system.
Please explain if systems below these PURPA thresholds are small enough to be considered safe
for Schedule 6, 8, and 84 customers. If not, please explain what thresholds might be considered
safe for each customer generation class and the basis used to identiff these thresholds.
FIRST PRODUCTION REQUEST
TO IDAHO POWER J AUGUST 3,2022
REQUEST NO. 8: Page 97 of the VODER study states that"a customer can choose to
sell their renewable energy as a Qualified Facility ("QF") to Idaho Power under Schedule 86 for
Exporting Systems larger than 100 kW." Please respond to the following.
a. Please explain why a customer that chooses to sell their renewable energy as a QF is
limited to Schedule 86 rates.
b. Please explain why a customer that chooses to sell their renewable energy as a QF is
not eligible for other rate options such as published avoided cost rates.
REQUEST NO. 9: Page 99 of the VODER study states that "[m]odifications to the
project eligibility cap would require an evaluation of the interconnection requirements and
consider specific rules to ensure that ldaho Power is able to administer its customer generation
offering that is consistent for all customers with a project eligibility cap set at a percentage of a
customer's demand." Please answer or provide the following
a. An action plan (including specific steps, the objectives that would be accomplished in
each step, and amounts of time needed for each step) to perform this evaluation.
b. An implementation plan (including specific steps and amounts of time needed for
each step) to implement a modified cap determined by the evaluation.
c. Please explain what the Company envisions regarding a modified framework for
allowing larger customer generation over the current caps while protecting the safety
and reliability of the Company's system. Specifically, does the framework consist of
multiple thresholds triggering more studies and higher levels of controls, as the risks
to safety and reliability of the Company's system increase? Please explain.
REQUEST NO. 10: Page 101 of the VODER study states that there is currently no
option to switch off larger customer generation projects remotely and that there are two solutions
to this issue. Please provide the following.
a. Please provide the specific potential consequences of not providing a remote cut-out
switch.
b. Please describe the criteria and the overall decision process that would be used to
determine if a remote switch is needed by an individual project.
FIRST PRODUCTION REQUEST
TO IDAHO POWER 4 AUGUST 3,2022
c. If a switch is needed, please describe how it would be implemented and provide an
estimate of the cost.
REQUEST NO. 11: Pages 101-102 of the VODER study discusses the definition of a
customer's demand for purposes of a system size cap and state a customer's demand can be
defined in a variety of ways. Please provide and define the appropriate variable(s) that would
need to be measured in each definition of "demand" for determining demand-related caps that
would ensure the Company's system remains safe and reliable.
REQUEST NO. 12: Page 102 of the VODER study states that customers without
historical usage data could be incentivized to overestimate their demand to maximize the system
size installed under a demand-related cap. Please explain what mechanism(s) may be necessary
to sufficiently prevent or mitigate the issue (such as verification steps, potential penalties, ECR
adjustments, etc.). In addition, please provide estimated costs of implementing the
mechanism(s).
REQUEST NO. 13: Pages l0l and 102 of the VODER study discuss changes in system
ownership and provides an example where a business owner could have a maximum hourly
demand of 50 kW when s/he installs a generation system, but a new owner may only operate
with a maximum hourly demand of 25 kW. Please respond to the following.
a. Please explain whether this situation could increase the exported amount.
b. Please explain whether this situation could cause any safety or reliability issues to the
Company's system.
c. Please explain what mechanism(s) is(are) necessary to sufficiently address issues
caused by change ofownership.
d. Please provide the estimated costs of implementing the mechanism(s).
FIRST PRODUCTION REQUEST
TO IDAHO POWER 5 AUGUST 3,2022
REQUEST NO. 14: Appendix 4.8 provides data to estimate the value of non-firm
energy relative to firm energy. Please answer the following:
a. Please clarifu the significance of the HL and LL designations, the significance of
Schedule A purchases and Schedule B purchases, and how each ofthe above pertain
to the Appendix's purpose.
b. Please explain why l2 of the 25 HL purchases are duplicated as LL purchases (same
date, prices, and price ratios), which gives them double-weight in determining the
non-firm discount rate.
REQUEST NO. 15: Please provide summer (June 15 - September 15) load curve data
that excludes Schedule 6, 8, & 84 exports. Using this data as the basis, identifu a logical On-
Peak time window for the Export Credit Rate program. If this window differs from the Demand
Response Program hours (3 to I I p.m., Monday through Saturday, excluding holidays), provide
analysis of the pros and cons of each window.
REQUEST NO. 16: Order No. 35284 at 16, states the VODER study should "evaluate
peak-hour pricing or another variable pricing mechanism so on-site generators who invest in
storage canrealize the value of their investment when they export stored energy." Please
identify where in the VODER study this was analyzed. If this was not analyzed in the VODER
study, please provide the Company's analysis.
REQUEST NO. 17: Please explain the method used to average the pricing data in
Appendices 4.2 and 4.3. The '2019-2021Avg' spreadsheet averages the corresponding data
from the 2021,2020,and2019 tabs. However, it aligns Friday, January 1,2021, with Friday,
January 3,2020, with Friday, January 4,2019, and maintains this differential through the entire
year. At the end of the year - because of the differential - the last few days of 2021 are averaged
with blank data cells in2020 and2019. Please veriff if the intent is to align the data by days of
the week. Please clari$ the intent and correct the appendices if needed, including Appendices
4.6 and 4.7 that use this data.
FIRST PRODUCTION REQUEST
TO IDAHO POWER 6 AUGUST 3,2022
REQUEST NO. 18: In reference to Appendices 4.2 and 4.3, please explain whether
2020 eneryy prices are significantly anomalous to the price trends occurring over a longer
period. If so, discuss possible altematives such as removing the year 2020s data from the
average or including an alternate year.
REQUEST NO. 19: Order No. 35284 at 17, states the VODER study should "evaluate
firmness of energy for individual customers compared to firmness as a combined class and
evaluate firmness of energy for customers with energy storage devices compared to those
without energy storage devices." Please identi$ where in the VODER study this was analyzed
If this was not analyzed in the VODER study, please provide the Company's analysis.
REQUEST NO.20: Please provide the following regarding the Effective Load-Carrying
Capacity ("ELCC") factor in Section 4.2 of the Study:
a. Appendix 4.12 lists the ELCC value for 2020 as 4.320o/o and for 2021 as 10.918%.
Please explain why these values varied so significantly from year to year. Explain the
rationale for averaging the two years, especially if 2020 was anomalous.
b. Please explain why the ELCC result for the Net Hourly scenario of 3.420% is less
than half of the Real-Time scenario result of 7 .619%.
REQUEST NO.21: Please provide the following regarding the National Renewable
Energy Laboratory ("NREL") 8760 capacity factor in Section 4.2 of the Study:
a. The underlying data for derivation of the NREL 8760 capacity values (i.e., the top
100 hours of Load-Duration Curve ("LDC"), Net Load-Duration Curve ("NLDC"),
and the difference.)
b. Appendix 4.12 lists the NREL 8760 value as 8.014% for 2020 and 12.6080/o for 2021
Please explain why these values varied significantly from year to year. Explain the
rationale for averaging the two years, especially if 2020 was anomalous.
c. Please explain why the NREL 8760 result for the Net Hourly scenario of 6.1790/o is
nearly half of the Real-Time scenario result of 10.311%.
FIRST PRODUCTION REQUEST
TO IDAHO POWER 7 AUGUST 3,2022
REQUEST NO.22: Although the NREL capacity factor was 35olo larger than the ELCC
factor, the ELCC factor was used for all subsequent scenarios and analyses. Please provide the
rationale for using the ELCC factor.
REQUEST NO. 23: Order No. 35284 at 18, states that the VODER study should
evaluate the "potential differences between customers with and without storage" with respect to
avoided capacity costs. Please identifu where in the VODER study this was analyzed. If this
was not analyzed in the VODER study, please provide the Company's analysis.
REQUEST NO. 24: Please explain why the Nameplate Capacity value of 64.11 MW
was used to calculate the Avoided Capacity Cost. Please provide any workpapers supporting this
value.
REQUEST NO. 25: In Table 4.8 of the VODER study, combined transmission,
distribution, and transformer losses are displayed as a percentage of total load, which implies that
they are all load-dependent. However, pages 58 and 59 of the VODER study, assert that
transformer losses are constant and not avoidable for customer-generated exports, and therefore
ignores those losses. Please provide a detailed explanation as to why transformer losses are not
being counted.
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DATED at Boise, Idaho, tUis J day ofAugtst2022
Riley Newton
Deputy Attorney General
i:umisc:prodreq/ipce2?.22mtnc prod req I
FIRST PRODUCTION REQUEST
TO IDAHO POWER 8 AUGUST 3,2022
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 3'd DAY OF AUGUST 2022, SERVED
THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
TO IDAHO POWER COMPAN-Y, IN CASE NO. IPC-E-22-22, BY E-MAILING A COPY
THEREOF, TO THE FOLLOWING:
LISA NORDSTROM
MEGAN GOICOECHEA ALLEN
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: lnordstrom@i dahooower.com
m goicoecheaallen@ idahopower. com
docketsfr) i dahopower. com
C TOM ARKOOSH
AMBER DRESSLAR
ARKOOSH LAW OFFICES
PO BOX 2900
BOISE ID 8370I
E-MAIL: [e-mail]
ambe r. d re ss lar(@arkoos h. c o m
KELSEY JAE
LAW FOR CONSCIOUS LEADERSHIP
920 N CLOVER DR
BOISE ID 83703
E-MAIL : kelsey@,kelseyj ae.com
ERIC L OLSEN
ECHO HAWK & OLSEN PLLC
PO BOX 6l 19
POCATELLO ID 83205
E.MAIL:wk.con-r
TIMOTHY TATUM
CONNIE ASCHENBRENNER
GRANT ANDERSON
IDAHO POWER COMPANY
PO BOX 70
BOISE rD 83707-0070
E-MAIL : [e-mail]
casch enbrenner@. idahoporver. com
MICHAEL HECKLER
COURTNEY WHITE
CLEAN ENERGY OPPORTUNITIES
3778 PLANTATION RIVER DR
SUITE 102
BOISE ID 83703
E-MAIL:
mike(@c I eanenergyopportuni t ies. corn
[e-mail]
ELECTRONIC ONLY
ERIN CECIL
E-MAIL: [e-mail]
LANCE KAUFMAN PhD
48OI W YALE AVE
DENVER CO 80219
E-MAIL: [e-mail]
.com
J" /1,A,-,-.-
SECRETARY
CERTIFICATE OF SERVICE