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HomeMy WebLinkAbout20161025Settlement Reply Comments.pdfLISA D. NORDSTROM Lead Counsel lnordstrom@idahopower.com October 25, 2016 VIA HAND DELIVERY Jean D. Jewell, Secretary Idaho Public Utilities Commission 472 West Washington Street Boise, Idaho 83702 Re: Case No. IPC-E-16-14 New Tariff Schedule 63, A Community Solar Pilot Program Idaho Power Company's Reply Comments Dear Ms. Jewell: An IDACORP company r,...:) = Cl"' 1-0 :::0 r.1 'T -. -l m -N 0 ', .. ~ ) .. c..r, m _ ........ C. ~C. -0 < CJ :I:: m ~1 c:, :.no .r- (/) w 0 N z Enclosed for filing in the above matter are an original and seven (7) copies of Idaho Power Company's Reply Comments. Very truly yours, ~JJ.71_~ Lisa D. Nordstrom LDN/kkt Enclosures LISA D. NORDSTROM (ISB No. 5733) Idaho Power Company 1221 West Idaho Street (83702) P.O. Box 70 Boise, Idaho 83707 Telephone: (208) 388-5825 Facsimile: (208) 388-6936 lnordstrom@idahopower.com Attorney for Idaho Power Company ECEIVED 2016 OCT 25 PM ~: 32 · -! , : . -:~ f-' _; G i..1 C ,., .· 1·.·; :·--r_,Q'.l ~,H SSION BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF IDAHO POWER ) COMPANY'S APPLICATION TO ) APPROVE NEW TARIFF SCHEDULE 63, ) A COMMUNITY SOLAR PILOT ) PROGRAM. ) ) CASE NO. IPC-E-16-14 IDAHO POWER COMPANY'S REPLY COMMENTS Idaho Power Company ("Idaho Power" or "Company") respectfully submits the following Reply Comments in response to comments filed by the Idaho Public Utilities Commission ("Commission") Staff ("Staff'), the Idaho Conservation League ("ICL"), the Snake River Alliance ("SRA"), and Sierra Club on October 18, 2016. In addition, there were four public comments received. Idaho Power appreciates the comments provided in this case and notes that all comments recommend that the Commission approve the Settlement Stipulation submitted in this matter by the parties ("Parties") on September 16, 2016. In these Reply Comments, the Company would like to clarify an issue IDAHO POWER COMPANY'S REPLY COMMENTS -1 identified in Staffs Comments and respond to the concerns raised in a public comment by Kyle Nelson. I. Cost Recovery of the Proiect if it is Not Fully Subscribed After reviewing Staffs Comments, Idaho Power contacted Staff to ensure both parties viewed the cost recovery language in the Settlement Stipulation as only providing for a pass through of the cost of under-subscription resulting from participants who elect to pay through the 24-month option but do not complete all 24 payments. Idaho Power discussed the issue with Staff members and understands that Staff is in agreement with the Company's interpretation of the Settlement Stipulation language. II. The Participant Will be Able to View Solar Production Information From a Reliable Source Through the public comment process, Kyle Nelson expressed concern over the application of losses and a participant's ability to verify the production from the community solar array as "the amount of power the solar farm produces is vital in determining the amount of credit a consumer receives."1 The Company recognizes this concern and will be providing the array's performance data on the Idaho Power website at www.idahopower.com/solar. Further, as described in the testimony of Company witness Dave Angell, on a monthly basis the project's total metered energy will be reduced by the line loss percent of 3.3 percent.2 Subsequently, each Community Solar Pilot Program ("Program") participant will receive a proportionate share of the monthly loss-adjusted energy based on their level of subscription which will be displayed on their monthly bill. Public Comment of Kyle Nelson dated 10/03/16. 2 Angell Direct Testimony, p. 12 IDAHO POWER COMPANY'S REPLY COMMENTS - 2 Ill. CONCLUSION Idaho Power appreciates the opportunity to respond to comments filed in this case and would like to reiterate its appreciation of the collaborative effort between the Company, Commission Staff, and other parties to consider and discuss the merits of the Company's Application and to reach mutually agreeable terms for the Program. Idaho Power respectfully requests that the Commission issue an order in a timeframe that will allow the Company to launch its marketing campaign prior to the holiday season. DATED at Boise, Idaho, this 25th day of October 2016. ~&.~a.,?~ ISAD.NORDSROM Attorney for Idaho Power Company IDAHO POWER COMPANY'S REPLY COMMENTS -3 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 25th day of October 2016 I served a true and correct copy of IDAHO POWER COMPANY'S REPLY COMMENTS upon the following named parties by the method indicated below, and addressed to the following: Commission Staff Daphne Huang Deputy Attorney General Idaho Public Utilities Commission 472 West Washington (83702) P.O. Box 83720 Boise, Idaho 83720-007 4 Idaho Conservation League Benjamin J . Otto Idaho Conservation League 710 North Sixth Street Boise, Idaho 83702 Industrial Customers of Idaho Power Peter J. Richardson Gregory M. Adams RICHARDSON ADAMS, PLLC 515 North 2ih Street (83702) P.O. Box 7218 Boise, Idaho 83707 Dr. Don Reading 6070 Hill Road Boise, Idaho 83703 Idaho Irrigation Pumpers Association, Inc. Eric L. Olsen ECHO HAWK & OLSEN, PLLC 505 Pershing Avenue, Suite 100 P.O. Box 6119 Pocatello, Idaho 83205 ___x_ Hand Delivered __ U.S.Mail __ Overnight Mail FAX X Email daphne.huang@puc.idaho.gov __ Hand Delivered ___x_ U.S. Mail __ Overnight Mail FAX ___x_ Email botto@idahoconservation.org __ Hand Delivered ___x_ U.S. Mail __ Overnight Mail __ FAX ___x_ Email peter@richardsonadams.com greg@richardsonadams.com __ Hand Delivered ___x_ U.S. Mail __ Overnight Mail FAX ___x_ Email dread ing@mindspring.com __ Hand Delivered ___x_ U.S. Mail __ Overnight Mail __ FAX ___x_ Email elo@echohawk.com IDAHO POWER COMPANY'S REPLY COMMENTS - 4 Anthony Yankel 12_700 Blake Avenue, Unit 2505 Lakewood, Ohio 44107 Snake River Alliance Ken Miller, Energy Program Director Snake River Alliance 223 North Sixth Street, Suite 317 P.O. Box 1731 Boise, Idaho 83701 Sierra Club Zack Waterman Director, Idaho Sierra Club 503 West Franklin Street Boise, Idaho 83702 Michael Heckler 3606 North Prospect Way Garden City, Idaho 83714 City of Boise City Elizabeth A. Koeckeritz Deputy City Attorney Boise City Attorney's Office 150 North Capitol Boulevard P.O. Box 500 Boise, Idaho 83701-0500 Kyle Nelson 2554 S. Waterbury Lane Boise, ID 83702 __ Hand Delivered _x_ U.S. Mail __ Overnight Mail __ FAX _x_ Email tony@yankel.net __ Hand Delivered _x_ U.S. Mail __ Overnight Mail __ FAX _x_ Email kmiller@snakeriveralliance.org __ Hand Delivered _x_ U.S. Mail __ Overnight Mail __ FAX _x_ Email Zack.Waterman@sierraclub.org __ Hand Delivered _x_ U.S. Mail __ Overnight Mail __ FAX _x_ Email Michael.P.Heckler@gmail.com __ Hand Delivered _x_ U.S. Mail __ Overnight Mail __ FAX _x_ Email ekoeckeritz@cityofboise.org __ Hand Delivered _x_ U.S. Mail __ Overnight Mail __ FAX __ Email trucktiva@gmail.com IDAHO POWER COMPANY'S REPLY COMMENTS -5