20230718Staff 15-36 to IPC.pdf

CHRIS BURDIN O
DEPUTY ATTORNEY GENERAL M a.9 iIDAHOPUBLICUTILITIESCOMMISSION
PO BOX 83720
BOISE,IDAHO 83720-0074
[phone]
IDAHO BAR NO.9810
Street Address for Express Mail:
11331 W CHINDEN BLVD,BLDG 8,SUITE 201-A
BOISE,ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER )CASE NO.IPC-E-23-14
COMPANY'S APPLICATION FOR )AUTHORITY TO IMPLEMENT CHANGES TO )THE COMPENSATION STRUCTURE )THIRD PRODUCTION
APPLICABLE TO CUSTOMER ON-SITE )REQUESTOF THE
GENERATION UNDER SCHEDULES 6,8,AND )COMMISSION STAFF
84 AND TO ESTABLISH AN EXPORT CREDIT )TO IDAHO POWER COMPANY
RATE METHODOLOGY )
The Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Chris Burdin,Deputy AttorneyGeneral,requests that Idaho Power Company ("Idaho Power"or
"Company")provide the followingdocuments and information as soon as possible,but no later
than,TUESDAY,AUGUST 8,2023.
This Production Request is to be considered as continuing,and Idaho Power Company is
requested to provide,by way of supplementaryresponses,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 telephonenumber of
the person preparing the documents.Please also identify the name,job title,location,and
telephonenumber of the record holder.
THIRD PRODUCTION REQUEST
TO IDAHO POWER l JULY 18,2023
In addition to the written copies provided as response to the requests,please provide all
Excel spreadsheets and electronic files with formulas intact and enabled.
REQUESTNO.15:The Company's Revised Study Framework in Case No.IPC-E-21-
21 includes 100%and 125%of a customer's demand for determining the project eligibilitycap.
Please explain why the Company's proposed cap is based on 100%of a customer's demand and
not 125%.
REQUESTNO.16:Please explain why the proposed project eligibilitycap should
apply to all Schedule 84 customers,instead of only irrigation customers under Schedule 84.
Please provide evidence to support your answer.
REQUESTNO.17:Please explain why the Company does not propose any change to
the project eligibilitycap for Schedule 6 and Schedule 8 customers.Also,please explain why
these reasons do not apply to commercial and industrial customers under Schedule 84.
REQUESTNO.18:The Application states "[ijn evaluating the appropriateness of the
existing cap under Schedule 84 for the purpose of making its implementation recommendations
in this case,the Company considered whether the cap is undermining the intent of net metering
to allow customers to offset energy usage behind the meter."Also,Page 5 of Grant Anderson's
Direct Testimony states that "[t]he intent of net metering is to offset one's energy usage behind
the meter."Please respond to the following.
a.If the intent of net metering is to offset energy usage behind the meter,please
explain why the proposed project eligibilitycap is the greater of 100 kW and
100%demand,instead of 100%demand alone;
b.When 100 kW is greater than 100%demand,does it undermine the intent of net
metering by allowingcustomers to sell extra energy to the Company,instead of
focusing on offsetting energy usage behind the meter?;and
c.Page 119 of the Value of Distributed Energy Resources ("VODER")study stated
that Schedule 84 customers who elect to interconnect a Non-Exportingsystem are
not limited to the project eligibilitycap.If a customer can achieve offsetting
THIRD PRODUCTION REQUEST
TO IDAHO POWER 2 JULY 18,2023
energy usage through installinga Non-Exportingsystem that is not subject to the
cap,please explain whythe Company needs to set a cap for exporting systems at a
level that is potentiallyhigher than 100%of demand,
REQUESTNO.19:The Application states that "[fjor irrigation customers without a
full in-season billinghistory,a conversion factor related to the horsepower of their pump(s)at
the service point would determine the maximum demand."Please provide an example to
illustrate the process of determining the maximum demand in this scenario.
REQUESTNO.20:Please provide updates to VODER study Figure 9.1 and Figure 9.3
using the most recent twelve months of non-solar service point data.In your answer,please
provide the percentage of non-solar service points in each customer category that exceeds the
eligibilitycap.
REQUESTNO.21:Please update Table 9.1 in the VODER study using the most
current data.
REQUESTNO.22:Page 126 of the VODER study states that "increasing the cap to a
customer's demand could negatively impact the switching process during seasons or certain
times with low customer load."Please explain how the Company plans to address this issue and
how the Company plans to implement the solution.
REQUESTNO.23:Please list all the potential reliability issues associated with an
increased eligibilitycap which were identified in the VODER study and explain whether the
Company's proposal in this case has addressed all these issues.
REQUESTNO.24:Please explain if gaming opportunities exist between the choice of
being an on-site customer with a nameplate above 100 kW and the choice of being a Public
Utility Regulatory Policies Act of 1978 ("PURPA")solar qualifying facility with a nameplate
above 100 kW.If so,how does the Company plan to prevent gaming?
THIRD PRODUCTION REQUEST
TO IDAHO POWER 3 JULY 18,2023
REQUESTNO.25:The proposed changes to Schedule 6,Schedule 8,and Schedule 84
include a statement that "[t]he capacity of an Energy Storage Device shall not be used to
calculate the capacity limits in this schedule."Please respond to the following:
a.Please explain why this statement is added and what potential problem this
statement is intended to address;
b.Please explain why an Energy Storage Device shall not be used to calculate the
capacity limits;and
c.Please provide an example where an Energy Storage Device is used to calculate
the capacity and explain how the Energy Storage Device changes the capacity.
REQUESTNO.26:Page 12 of Anderson's Direct Testimony states that "[t]he
Company is aware of limited circumstances where AC-coupled energy storage devices have
resulted in a customer's proposed system to exceed the project eligibilitycap."Please respond to
the following.
a.Please provide the "limited circumstances"where AC-coupled energy storage
devices have resulted in a customer's proposed system exceedingthe project
eligibilitycap;and
b.Energy storage devices typically shift the time of energy output.Please explain
why and how energy storage devices can change a proposed system's nameplate
capacity.
REQUESTNO.27:As required in Order No.32925,to be able to transfer credits
between meters under the existing Schedule 6,8,and 84,the meter has to be "located on,or
contiguous to,the property on which the Designated Meter is located"and "served by the same
primary feeder as the Designated Meter."Please explain why these requirements are removed
for non-legacy customers under the proposed Schedule 6,8,and 84.
REQUESTNO.28:The proposed Schedule 84 defines Billing Demand as "the average
kW supplied during the 15-consecutive-minute period of maximum use during the Billing
Period,adjusted for Power Factor."Please explain how Power Factor is determined and provide
an example of the Power Factor adjustment.
THIRD PRODUCTION REQUEST
TO IDAHO POWER 4 JULY 18,2023
REQUESTNO.29:Please explain why the proposed Schedule 6,Schedule 8,and
Schedule 84 change the timeframe for submitting requests to transfer Excess Net Energy credits
from "January 1 to January 31 of each year"to "December 1 and January 31 of each year".
Also,please confirm that "December 1 and January 31 of each year"intends to express
December 1 of one year through January 31 of the followingyear.
REQUESTNO.30:Do Schedule 84 customers experience revenue requirement
deficiencies similar to Schedule 6 and Schedule 8 customers?If yes,please explain how the
Company plans to resolve the issue for legacy customers and non-legacy customers,respectively.
If not,please explain why Schedule 84 customers do not experience such issue.
REQUESTNO.31:A European study (The Effect ofNet Metering Methods on
Prosumer Energy Settlements by Ziras,Calearo,and Marinelli)has shown that a smart meter
monitoringa three-phase system will yield different results if metering is tracked per phase
versus summing the results for all three phases.Please explain how the Company's smart meters
measure and aggregate a typical split-phase residential system,and a typical three-phase system.
Please explain if the aggregationmethod is changeable or if it is hardwired into the Company's
meters.
REQUESTNO.32:In its accounting for avoided line losses,the Company proposes
that customer exports will avoid some line losses but not others.Specifically,the Company
asserts that customer exports cannot avoid all transformer core losses and all secondary
distribution losses.However,it seems reasonable to assume that customer generated exports
travel only to the next home on the street,which should avoid all line losses.Please explain why
the Company believes that customer exports incur transformer core losses and secondary
distribution losses.
REQUESTNO.33:Company Witness Ellsworth states,"Starting with the 2023 IRP
and each successive IRP,the Company will evaluate and update the hours of greatest system
need that will inform the annual update to the ECR."Ellsworth at 14.Understandingthat the
greatest system need is determined by the Loss of Load Probability ("LOLP"),but that the
THIRD PRODUCTION REQUEST
TO IDAHO POWER 5 JULY 18,2023
specific hours of highest LOLP vary significantlyfrom year to year,what criteria does the
Company propose to bracket the critical hours?Will these criteria account for the rising LOLP
in the winter months?
REQUESTNO.34:Page 9 of Ellsworth's Direct Testimony states that "[t]he proposed
on-peak hours are 3pm to 11pm,June 15 through September 15,Monday through Saturday,
excluding holidays.As described in more detail in the avoided generation capacity section of my
testimony,these hours are those currentlyidentified as the hours of the Company's greatest
system need for energy and capacity."These on-peak hours correspond to those determined in
Case No.IPC-E-21-32.Since then,the Company has updated on-peak hours at least three times,
with peak data as recent as December 23,2022:IPC-E-21-35,Case No.IPC-E-22-06,and Case
No.IPC-E-22-26.Please respond to the following:
a.Please explain why the proposed hours are still "currently identified as the hours
of the Company's greatest system need for energy and capacity";
b.Please provide the latest on-peak hours identified by the Company,and the
workpapers used to support these hours;and
c.Please provide the top 100 summer hours,top 100 winter hours,and top 100
annual hours for the Company's system peak,peak net of distributed energy
resources,peak net of all variable energy resources,and highest risk hours for
2020 through 2022.
REQUESTNO.35:Page 27 of Ellsworth's Direct Testimony states that "Idaho Power
expects to complete its next VER Integration Study,if necessary,followingthe completion of the
2025 IRP."Please explain what prevents the Company from conducting the next VER
Integration Study after the completion of the 2023 IRP.Also,please identify what would or
would not make the VER Integration Study necessary.
REQUESTNO.36:Please provide the "IPC Loss Factor.xlsx"excel file imported by
the MATLAB script PDF provided in Response to Production Request No.4.
THIRD PRODUCTION REQUEST
TO IDAHO POWER 6 JULY 18,2023
DATED at Boise,Idaho,this gL day of July 2023.
Chris Burdin
Deputy AttorneyGeneral
Technical Staff:Yao Yin (15-31)
Matt Suess (32-35)
Jason Talford (36)
i:umise:prodreq/ipce23.14cbjjt prod req 3
THIRD PRODUCTION REQUEST
TO IDAHO POWER 7 JULY 18,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 186 DAY OF JULY 2023,SERVED
THE FOREGOING THIRD PRODUCTION REQUESTOF THE COMMISSION
STAFF TO IDAHO POWER,IN CASE NO.IPC-E-23-14,BY MAILING A COPY
THEREOF,POSTAGE PREPAID,TO THE FOLLOWING:
LISA D NORDSTROM TIMOTHY TATUM
MEGAN GOICOECHEA ALLEN CONNIE ASCHENBRENNER
IDAHO POWER COMPANY GRANT ANDERSON
PO BOX 70 IDAHO POWER COMPANY
BOISE ID 83707-0070 PO BOX 70
E-MAIL:[e-mail] BOISE ID 83707-0070
[e-mail] E-MAIL:[e-mail]
[e-mail] [e-mail]
[e-mail]
ERIC L OLSEN LANCE KAUFMAN PhD
ECHO HAWK &OLSEN PLLC 2623 NW BLUEBELL PLACE
PO BOX 6119 CORVALLIS OR 97330
POCATELLO ID 83205 E-MAIL:[e-mail]
E-MAIL:elo echohawk.com
MARIE CALLAWAY KELLNER BRAD HEUSINKVELD
ID CONSERVATION LEAGUE ID CONSERVATION LEAGUE
710 N 6TH ST 710 N 6TH ST
BOISE ID 83702 BOISE ID 83702
E-MAIL:[e-mail] E-MAIL:[e-mail]
C TOM ARKOOSH MICHAEL HECKLER
ARKOOSH LAW OFFICES COURTNEY WHITE
PO BOX 2900 CLEAN ENERGY OPPORTUNITIES
BOISE ID 83701 3778 PLANTATION RIVER DR
E-MAIL:tom.arkoosh arkoosh.com STE 102
.BOISE ID [e-mail] ..-E-MAIL:[e-mail]
[e-mail]
KELSEY JAE
LAW FOR CONSCIOUS LEADERSHIP
920 N CLOVER DR
BOISE ID 83703
E-MAIL:[e-mail]
CERTIFICATE OF SERVICE
AUSTIN RUESCHHOFF JIM SWIER
THORVALD A NELSON MICRON TECHNOLOGY INC
AUSTIN W JENSEN 800 SOUTH FEDERAL WAY
HOLLAND &HART LLP BOISE ID 83707
555 17TH ST STE 3200 E-MAIL:[e-mail]
DENVER CO 80202
E-MAIL:[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
DARRELL EARLY WIL GEHL
DEPUTY CITY ATTORNEY ENERGY PROGRAM MANAGER
BOISE CITY ATTORNEY'S OFFICE BOISE CITY DEPT OF PUBLIC WORKS
PO BOX 500 PO BOX 500
BOISE ID 83701-0500 BOISE ID 82701-0500
E-MAIL:[e-mail] E-MAIL:weehl citvofboise.org
boisecÏ[e-mail]
ABIGAIL R GERMAINE KATE BOWMAN REG DIR
ELAM &BURKE PA VOTE SOLAR
PO BOX 1539 299 S MAIN ST STE 1300
BOISE ID 83701 PMB 93601
E-MAIL:[e-mail] SALT LAKE CITY UT 84111
E-MAIL:kbowman votesolar.org
SECRETARY
CERTIFICATE OF SERVICE