20190712Staff 1-12 PAC.pdf

DAYN HARDIE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 9917
IN THE MATTER OF THE APPLICATION OF
ROCKY MOUNTAIN POWER TO CLOSE THE
NET METERING PROGRAM TO NEW
SERVICE & IMPLEMENT A NET BILLING
PROGRAM TO COMPENSATE CUSTOMER
GENERATORS FOR EXPORTED
GENERATION.
CASE NO. PAC-E-19-08
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO ROCKY MOUNTAIN
POWER
REC E IVED
20t9 JUL I 2 AH ll: h5
i,ii.l-i,l itruJLlc.l ; i,i riIS C0l'{l'llSSlON
Street Address for Express Mail:
472W, WASHINGTON
BOISE, IDAHO 83702-5918
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIBS COMMISSION
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The Staff of the ldaho Public Utilities Commission, by and through its attomey of record,
Dayn Hardie, Deputy Attomey General, requests that Rocky Mountain Power provide the
following documents and information as soon as possible, but no later than FRIDAY,
AUGUST 2,2019.
This Production Request is to be considered as continuing, and Rocky Mountain Power 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
FIRST PRODUCTION REQUEST
TO ROCKY MOI.]NTAIN POWER JULY I2,2OI91
the person preparing the documents. Please identify the name, job title, location, and telephone
number of the record holder.
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. 1: Please provide an example of the worksheet(s)/exhibit(s) that would
be submitted with an ECAM filing if the proposal is approved.
REQUEST NO. 2: Please provide a worksheet(s) in Excel with executable formulas
intact that shows for each current Idaho Schedule 135 customer:
a. generation type;
b. annual generation in kWh and dollars;
c. annual consumption in kWh and dollars; and
d. net annual generation in kWh and dollars.
REQUEST NO. 3: Please explain how the Results of Operations report information was
used to develop the NEM COS Study submitted in this filing.
REQUEST NO. 4: Please explain why the 2018 Results of Operations report was not
used in development of the NEM COS Study submitted in this filing.
REQUEST NO. 5: Please provide copies of Orders in other jurisdictions where a
methodology similar to what the Company has proposed for valuing exported energy of net
metering customers has been approved and implemented.
REQUEST NO. 6: Please explain how the Company's meter functionality can support
the net billing proposal made in this filing. Specifically, please explain how all energy exported
and all energy delivered by customers under Schedule 136 be measured in real time or
instantaneously.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 JULY 72,2019
REQUEST NO. 7: Please explain why the Company's proposal did not include a
capacity credit.
REQUEST NO. 8: Please provide the workpapers supporting a $2.1I/MWhr line loss
value
REQUEST NO. 9: Please explain why the Company proposes to use the SAR
methodology for determining the avoided cost of energy rather than other options, such as
demand-side management avoided cost pricing or Mid-C market prices.
REQUEST NO. 10: Please provide workpapers supporting Ms. Steward's claim on
page 4 of her direct testimony that "The primary driver of the cost shift is that net metering
customers are compensated at the full retail rate for excess output from their onsite generation."
REQUEST NO. 11: Mr. McNeil claims on page l0 of his direct testimony that
"[h]igher hourly energy prices imply higher costs for integration . . ." Please explain why it
would cost more to integrate customer generation at peak or at times the energy prices are higher
when the energy produced by customers at that time would lessen peak load requirements.
REQUEST NO. 12: Please provide Exhibits I - 4 and 6 - 9, in Excel format with
executable formulas intact.
DATED at Boise, Idaho, ttris lr2( day of July 2019
Dayn
Deputy Attorney General
i:umisc:prodreq/pace I 9.8dykkrf prod req I
FIRST PRODUCTION REQUEST
TO ROCKY MOLINTAIN POWER JULY I2,2OI9J
CERTIFICATB OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS |2th DAY OF JULY 2079, SERVED
THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
TO ROCKY MOUNTAIN POWER, IN CASE NO. PAC-E-I9-08, BY MAILING A
COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
TED WESTON
ROCKY MOUNTAIN POWER
1407 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84116
E-MAIL : led.westoq@pac ifi pqre.qqm
DATA REQUEST RESPONSE CENTER
E.MAIL ONLY:
datarequest@pacifi corp. com
ERIC L OLSEN
ECHO HAWK & OLSEN PLLC
PO BOX 6119
POCATELLO ID 83205
E-MAIL: elo@,echohawk.com
YVONNE R HOGLE
ROCKY MOUNTAIN POWER
1407 WN TEMPLE STE 320
SALT LAKE CITY UT 841 16
E-MAIL: yvonne.hoele@pacifi corp.com
ANTHONY YANKEL
I27OO LAKE AVE
UNIT 2505
LAKEWOOD OH 44107
E-MAIL: [e-mail]
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SECRETry
CERTIFICATE OF SERVICE