20190906Staff 13-17 to 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
SECOND PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO ROCKY MOUNTAIN
POWER
RECEIVED
?019 StP -6 $t 9: 56
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Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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The Staff of the Idaho Public Utilities Commission, by and through its attomey of record,
Dayn Hardie, Deputy Attorney General, requests that Rocky Mountain Power provide the
following documents and information as soon as possible, but no later than FRIDAY,
SEPTEMBER 27 , 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 behall 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
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER I SEPTEMBER 6,20I9
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. 13: On page 6 of the Application, the Company states that
approximately 820 customers currently participate under Schedule 135. For each Schedule 135
Customer who was connected to Rocky Mountain Power for the entire period between
January 1,2018 and December 31,2018, please provide the following information:
a. The schedule under which the net metering customer takes power;
b. The County in which the customer is located; and
c. Net hourly consumption/production data for the 2018 calendar year.
REQUEST NO. 14: Please provide the2009 Analysis of System Losses for Idaho
referred to by Company Witness MacNeil on pages 5 and 6 of his direct testimony.
REQUEST NO. 15: For each class that would be able to export energy under the
Company's proposed Schedule 136, please provide a general description of the functions of the
meter(s) that would be used under the Company's Net Billing Program. Please include the
following information :
a. The rate (monthly, hourly, by minute, etc) at which the meter can store
consumption data;
b. If the meter includes separate registers for recording imports and exports; and
c. If the meter is capable of measuring and recording demand.
REQUEST NO. 16: In the response to Staff Production Request question 2 (d), the
Company provided the "annual exported energy by customer" in an Attachment called IPUC 2
Please clarify if the column labeled o'Net Mtrng Generation Kw" represents annual exported
energy as suggested in the PR response, or if it is total generation as it is labeled.
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 SEPTEMBER 6,2019
REQUEST NO. 17: Please describe how the integration cost, assumed in the 2017 IRP,
is representative of actual costs to integrate Schedule 135 solar exports. Please include all
calculations to demonstrate how exported generation correlates with the proposed integration
charge of $0.64lMWh.
DATED at Boise, Idaho, this
t*LA day of September 2019
Dayn Hardie
Deputy Attorney General
Technical Staff: Mike Morrison (13-15)
Rachelle Farnsworth (l 6-17)
i :umisc:prodreq/pace I 9. 8dhmmrf prod req 2
SECOND PRODUCTION REQUEST
TO ROCKY MOTINTAIN POWER J SEPTEMBER 6,2019
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 6th DAY OF SEPTEMBER 2019,
SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO ROCKY MOUNTAIN POWER, IN CASE NO. PAC-E-19-08,
BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
TED WESTON
ROCKY MOUNTAIN POWER
I4O7 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84116
E-MAIL : ted.weston@pacifi corp. com
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
datareq ue st@pac if-lc orp. com
ERIC L OLSEN
ECHO HAWK & OLSEN PLLC
PO BOX 6119
POCATELLO ID 83205
E-MAIL: [e-mail]
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
7IO N 6TH ST
BOISE ID 83702
E-MAIL: [e-mail]
YVONNE R HOGLE
ROCKY MOUNTAIN POWER
1407 WN TEMPLE STE 320
SALT LAKE CITY UT 841 16
E-MAIL: [e-mail]
ANTHONY YANKEL
I27OO LAKE AVE
LINIT 2505
LAKEWOOD OH 44107
E-MAIL: [e-mail]
PRESTON N CARTER
GIVENS PURSLEY LLP
60I W BANNOCK ST
BOISE TD 83702
E-MAIL : prestoncarter@ qivenspursley. com
kendrah@ givenspursley. com
CERTIFICATE OF SERVICE
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