20180126Angell Rebuttal.pdf

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BEFORE THE IDAHO PUBLIC UT]LITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
AUTHORITY TO ESTABLISH NEW
SCHEDULES FOR RESIDENTIAL AND
SMALL GENERAL SERVICE CUSTOMERS
WITH ON-SITE GENERATION.
CASE NO. IPC-E-17_13
IDAHO POWER COMPANY
REBUTTAL TESTIMONY
OE
DAV]D M. ANGELL
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O. Pl-ease state your name.
A. My name is David M. Ange11.
O. Are you the same David M. Ange11 that
previously presented direct testimony?
A. Yes.
O. Have you had the opportunity to review the
pre-filed direct testimony of the City of Boise's witness
Stephan L. Burgos; the Idaho Clean Energy Association,
Inc.'s ("ICEA") witnesses Kevj-n King, Michael Leonard, and
Stephen White; the Idaho Conservation League's (*ICL")
witness Benjamin J. Ottoi Sierra Club's witness R. Thomas
Beach; the Idaho Irrigation Pumpers Association, fnc's
wltness Anthony J. Yankel; the Snake River Al-li-ance and NW
Energy Coalition's (*SRA/NW Energy") witness Amanda M.
15 Levin; Vote Solar's witness Briana Kober,' Auric So1ar,
Utilities76 LLC's witness Elias Blshop; and the fdaho Public
77 Commission ("Commission") Staff's ("Staff") witnesses
1B Mlchael Morrison and Stacey Donohue?
have.19 Yes, I
What is the
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27 The
22 present evidence
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scope of your rebuttal testimony?
of my rebuttal testimony is to
Ioad service requirements and
residential and small general23 usage characterlstlcs of
24 service (*R&SGS")
are different than
A
o
A purpose
that the
customers who instal-l- on-site generation
that of R&SGS customers without on-slte
ANGELL, REB 1
Idaho Power Company
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generation, and to respond to various arguments raised by
intervening parties and Staff in their direct testimonies.
My testimony is comprised of three sections.
In Section I, I explain in detail, the additional-
analyses performed by the Company and how the Company has
demonstrated that the load service requirements and pattern
of use are distinctly different for residential customers
with on-site generation as compared to residential
customers without on-site qeneration.
fn Section II, I explain how the utilization of the
grid by customers with on-site generation 1s distinct and
dj-scuss the lmpacts to the grid.
In Section IIf, I explain why the proposed changes
to Schedule 12 are very minor and can easily be addressed
as part of this case. I wil-l also explain that the
Commission and Staff wiII have the opportunity to review
the Institute of Electrical and Electronic Engineers
(*IEEE") requirements before it is adopted.
I. A}IAIYSIS SUPPORTING ESTABLISHMENT OF SEPARATE CI,ASSES
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O. Did other parties agree with
Company ("Idaho Power" or "Company") that
with on-site generation are different than
customers and therefore require a separate
Idaho Power
R&SGS customers
standard R&SGS
customer cl-ass?
ANGELL, REB
Idaho Power
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Company
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Company did not
R&SGS customers
R&SGS customers
No. Several partiesl suggested that the
provide sufficient evidence to justify that
with on-site generation are different than
without on-site generation.
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O. What factors
distingulsh customers with
does the Company believe
on-site generation from those
without on-site generation?
A. The Company continues to believe that the Ioad
service requirement and the pattern of use shoul-d be used
to evaluate whether a segment of customers is different
from their current customer classification.
1. Load Servi,ce Re+l+qengq!
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13 O. How does the l-oad service requirement of a
74 customer with on-site generation differ from that of a
15 standard service residential customer?
L6 A. The load service requlrements of a customer
71 with on-si-te generation is fundamentally different than
18 that of a customer without on-site generation. Customers
L9 with on-site generation are "partial requi-rements"
20 customers. A partial requirements customer is one who
2L generates al-l- or some of their own electricity. The
22 utility provides only part of the customer's energy needs.
23 Partial- requirements customers still- require a varlety of
t. J
1 Levin DI, p. 1,
Donohue DI, p. t,
ff. 9-10; Kobor DI, p. 32,1. 18 through p. 33,
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ANGELL, REB
Idaho Power
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Company
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servj-ces from the utiJ-ity even
al-I thej-r own energy. So long
connected to the utility, they
services from the utility. As
testimony,
include:
motor loads such
though they provide some or
as these customers remain
conti-nue to take other
described in my direct
in-rush current requirements
as air conditioning
the ancillary services they require typically
capacity to meet the
for starting
compressors,
availabl-e at
supplemental services
night, and frequency
when solar is not
services to maintain
10 power quality. fdaho Power can economically provide
11 partial requirements service that al-l-ows customers with on-
1,2 site generation flexibility in meeting their energy needs
13 with the reassurance that the utility is avaj-labl-e to
74 handle al-I their el-ectrical needs should their on-si-te
15 generation be interrupted or fail.
16 0. What analyses did the Company perform to
L7 evaluate the load service requi-rement?
18 A. The Company studied the load factor for both
19 groups of customers.
20 Load Factor
27 O.Why is the load factor an important measure to
with on-site22 determine that residential customers
23 generation are different than residential customers without
on-site generation?24
ANGELL, REB
Idaho Power
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Company
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1 A. The l-oad factor is the average load divided by
2 the peak load in a specified time period. It is a measure
3 of variabil-ity of consumption; a low Ioad factor indicates
4 that load is hiqhly variable, compared to consumers with
5 steady consumption. The more consj-stent the consumption,
6 the higher the load factor. A l-ow l-oad factor identifies a
7 customer with infrequent high demand and the capacity
8 required to serve that peak demand sits idl-e for long
9 periods. Thus, customers with a lower l-oad factor use the
10 Idaho Power system capacity less efficiently and, when
11 considering the existing rate design which col-l-ects most
\2 fixed costs for system capacity, through the volumetric
13 kilowatt-hour ("kwh") charge, are subsidized by customers
L4 with higher load factors.
15 O. Pl-ease describe the load factor analysis that
16 was performed by the Company.
71 A. The Company ca1culated the monthly load
18 factors for residential customers with on-site generation
1,9 and residential customers without on-site generation who
20 were billed for energy in the 2016 cal-endar year. The
2L analysi-s inc1uded all- Idaho residential customers and al-l-
22 Idaho residential customers with on-site generatj-on. To
23 calculate the monthly average kwh, the bifled energy was
24 divided by the number of days in the biIIlng period which
25 was then divided by 24 hours. For each customer, the
ANGELL, REB 5
Idaho Power Company
1 average kWh was then divided by the segments largest kwh
2 for each billing period.
3 Q. What did the Company's load factor analysis
4 conclude?
5 A. The Company's load factor analysis
6 demonstrated that residential customers with on-site
7 generation have notably lower load factors than residential
8 customers without on-sj-te generation. The monthly load
9 factors for both groups are provided in Figure 1.
10 Figrre 1. Averagte Monttrly Load Factor
Average Load Factor
30%
25%
20o/o
L5%
L0%
5%
o%llllr
MayFeb Mar Apr DecNovJulJunAugsepOct
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t2
13
t4
15
t6
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r Residential r Net metered
O. Please summarize your conclusions of the l-oad
factor analysis.
A. Residential customers with on-site generation
consistently have notably lower l-oad factors than
residential customers without on-site generation. In fact,
for months May through August, the l-oad factor for the
customers with on-site generation is l-ess than half of the
ANGELL, REB 6
Idaho Power Company
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residential customers without on-site generatj-on. The
Company also compared the annual load factor of both qroups
of customers. While the annual- load factor was generally
better for both groups, 2L percent for residential
customers with on-site generation and 45 percent for
residential customers without on-site generation, the
annual load factor for residential customers with on-site
generation was still less than half of the residential
customers without on-site generation.
10 2. Pattern of Usag'e
11 O. Did the Company perform additional- analyses on
12 the use patterns of resldential customers with on-site
13 generation and residential customers wlthout on-sj-te
74 generation?
15 A. Yes.
1,6 O. What analyses did the Company perform to
77 eva1uate the pattern of use of both groups?
18 A. The Company studied the load profile, system-
79 coincident demands (*SCD"), and non-coincident demands
20 (*NCD"), for both groups of customers.
2L Load Profil-e
22 O.
dld the Company initially
proflle of either group?
Regarding the load profile for both
perform any analyses of
groups,
the load23
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ANGELL, REB 1
Idaho Power Company
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A. Yes. In her dj-rect testimony, Connie A.
Aschenbrenner presented a graph comparing the average
hourly consumption of a customer with on-site generatj-on to
that of a residential- customer without on-site generati-on
on June 29, 20L6.2 I have reproduced Ms. Aschenbrenner's
graph as Figure 2.
2. Average Load Shapes for Residential.
Customers and Residentia]. Net
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10 O. Does Staff agree with the Company that
11 customers with on-site generation are different than
72 standard service customers?
13 A. No. Dr. Morrison states that "there are no
L4 meaningful differences between net metering and non-net
15 metering customers in the quantities of electricity used,
16 dj-fferences in conditions of service, time, nature, and
Figtrre
Service
Standard'Customers.
ANGELL, REB
Idaho Power
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Company
t 2 3 4 5 6 7 8 9 1011L273L4L576L7 18192021222324
Hour Ending
-Residential
Net Metering
-Residential
Standard service
-1.00
-2.00
4.00
3.00
2.00
1.003
0.00
2 Aschenbrenner DI, p. 28, Figure 3.
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pattern of use."3 Dr. Morrison goes on to say "the
distribution of indivldual consumption patterns from both
groups is nearly identical-" and "Ic]onsumption patterns of
both groups are similar . ."4
O. Do you agree with this assessment that the
consumption patterns of both groups are simifar?
A. No. I bel-ieve that the two load proflles
shown in Eigure 2 above are distlnctly dlfferent. They are
different for many reasons. The first and most obvious
dlfference is that an average customer with on-site
generation has negative consumption, meaning that energy
flows to the utility. The second difference 1s that the
customer with on-site
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demand74 for
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energy during the
difference 1s that
generation
evenlng and
the rate of
has a higher
nighttime hours.
change in usage by
the day 1s
without on-site
16 customers wi-th on-sj-te generation during
L1 s igni fi cant 1y
generation.
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of both groups
A.
larger than for customers
1B
79 Did Commission Staff study the load patterns
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of customers?
Yes. Dr. Morrison of Commission Staff
22 presented a graph comparing the consumption patterns of
3 Morrison Df, p.
a Morrison DI, p.
4, I. 25 - p. 5,
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ANGELL, REB 9
Idaho Power Company
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average residential customers with on-site generation to
that of a residential customer without on-site generation.s
O. Was the graph that Dr. Morrj-son provided
consistent with the graph that Ms. Aschenbrenner lncl-uded
1n her t.estimony to il-lustrate the hourJ-y consumption of an
average customer with on-site generation compared to an
average customer without on-site generation?
values that each plotted
difference between the two
created a fine chart and
Other than that, the
A Yes. In the
appear to be the same.only
the same.
fact,
The
10 graphs is that Ms. Aschenbrenner
11 Dr. Morrison created a bar chart.
72 charts are virtually
13 O. Did the Company perform additional- analyses to
74 study the load profile of both groups of customers?
15 A. Yes. Because the Company's initial analysis
76 focused on a single duy, the Company's summer peak duy, the
71 Company performed additional analyses to study the l-oad
18 profile of both groups over the course of a month. The
19 Company analyzed all 12 months of 2016 and has shared the
20 results for a wj-nter month, a spring month (a1so
27 representative of fall-), and a summer month in Figures 3,
22 4, and 5 respectively. For the three graphs, each hour
23 data point is the average for that hour throughout the
24 month.
ANGELL, REB 10
Idaho Power Company
s Morrison DI, p. 15, Eigure 2
1 Figure 3. January 2OL6 Average Hourly Use - I[inter Peak
January Load Profiles
-CBY
3.50
3.00
2.s0
2.00
1.50
1.00
0.s0
0.00
1'2 3 4 5 6 7 I 9 101112L3t4 1515171819202L222324
-ftssi(snfi3l -NetMetering2
3 Figure 4. ApriJ. 2OL6 Average Hourly Use - Shoulder Month
April Load Profiles
2.00
1.50
1.00
0.50
3 0.00.Y
-0.s0
-1.00
-1.50
-2.00
L234s678910 t9 20 27 22 23 24
-ftssidgn{i6l -
Net Metering
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5 Figrure 5. ,fune 2OLG Averag'e Hourly Use - Sr:mmer Month
June Load Profiles
3.00
2.00
1.00
B
-:z 0.00
L23456789 18 19 20 2t 22 23 24
-L.00
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ANGELL, REB 11
Idaho Power Company
tL2L3L4L5L617
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-2.00
-Residential -NetMetering
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U Pl-ease summarize your conclusions of the Ioad
profile analysis.
A.Eor a1l- three months, customers with on-site
generation had a higher demand for energy during the
10 evening and nighttime hours than customers without. on-site
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O. Do
in Figures 3, 4,
A. No.
regardj-ng Figure
different.
you believe the
or 5 are nearJ-y
than for customers
load profiles
identical- or
of each group
even similar?
Once again, for the reasons I noted
2, the load prof iles cont j-nue to be
and their rate ofgeneration
is larger
o.What other differences
in usage during the day
on-site generation.
were di-scovered in the
change
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analysis of the load profiles?
A. The obvious difference is that customers with
on-site generation have negative consumption that is
energy fl-ows to the utility. This represents the amount of
excess energy produced by the customers' on-site
generation. The Company did notice that the amount of
excess generatlon varies from month to month.
During January, as a class, the customers with on-
site generation do not generate
particular interest, the resul-ts
excess energy. Of
24 demonstrate that, not only do the
for the month of Aprj-1
customers with on-site
25 qeneration generate excess energy, they generate more
ANGELL, REB
Idaho Power
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Company
1 excess energy on a per-customer basis than in June. This
2 large spring excess occurs when the electrical market is
3 flooded with excess energy and energy prices are
4 significantly depressed. The rate of change in usage
5 during the days in April is greater than during June. It
6 also comes as no surprise that during June, customers with
7 on-site generati-on do generate excess energy. The Company
B noted that, when looking at the entire summer month, the
9 magnitude of excess energy was larger than when looking at
10 the peak day only (as was done in Figure 2) .
11 O. Why is the rate of change significant?
12 A. As described in my direct testimony, the
13 Company schedules and dispatches generation along with
14 automatlc generation control- to bal-ance generation to load
15 at every instant in time. Maintaining this bal-ance during
L6 high rate of change periods requires more generation
L1 dispatches compared to other slower changing periods.
18 Additionally, the highly economj-c hydroelectric system is
79 constrained in its abllity to balance such rapid changes
20 due to river flow ramping fimits. This constraint causes
2l the Company to dlspatch l-ess economic resources resulting
22 in higher energy costs for retail- customers.
23 System-Coincident and Non-Coincident Demands
24 (l You mentioned that an analysis was performed
customers25 on the system-coincident and NCDs of resldential
ANGELL, REB
Idaho Power
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Company
1 with on-site generation and residential- customers wj-thout
2 on-site generation. What analysis did the Company perform?
3 A. The Company calculated the 201-6 system-
4 coincident and NCDs for both groups of customers. The SCD
5 is the average demand for the customer class at the time of
6 Idaho Power's system peak. The NCD is the maximum average
7 demand for the customer cl-ass regardless of when it
8 happens. System-coincident and NCDs were calcul-ated for
9 each month.
10 O. What did you observe from your analysis of the
11 SCDs for both groups of customers?
12 A. The monthly SCD of customers with on-site
13 generation is l-ower than customers without on-site
14 generation from April through September; however, it is
15 higher than customers without on-site generation from
16 October through March. The monthly SCDs for both groups of
L7 customers are shown in Figure 6.
18 Figrrre 6. 2OL6 Systen-Coincident Denands by Month
System-Coincident Dema nd
5.00
4.00
3.00
=
2.oo
1.00
(1.00)
llr Lllltrll
Jan Feb Mar Apr May Jun
I Residential System-Coincident Demand
Jul Aug Sep Oct Nov
f NEM System-Coincident Demand
Dec
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ANGELL, REB L4
Idaho Power Company
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O. Why is the SCD an important measure when
evaluating whether a segment of customers is different from
their current customer cl-assi-fication?
A. SCDs are used to allocate costs amongst the
Company's different customer classes. Ms. Aschenbrenner
explains how costs are allocated using the SCDs. e
O. What observatj-ons are drawn from the analysis
of the NCDs for both groups of customers?
A. The NCD of customers with on-site generati-on
is higher than customers without on-site generation for al-I
12 months of the year. During the wj-nter months, the non-
coincident of customers with on-site
generation is more than 60 percent higher than the NCD of
customers without on-site generati-on. The NCDs for both
groups of customers are shown in Eigure 7.
Figrure 7. 2OLG t{on-Coincident Denands by Month
Non-Coincident Demand
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s.00
4.00
3.00
2.00
1.00
=J
Dec
ill
Sep Oct NovAug
lll
Jan Feb Mar Apr May .lun
I Residential Non-Coincident Demand
Jul
I NEM Non-Coincident Demand
6 Aschenbrenner REB, p. 12,1. 14 through p. 13, f. 2.
ANGELL, REB
Idaho Power
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o.Why is the NCD an important measure when
customers is different fromevaluating whether a segment of
their current customer cl-assification?
A The non-coincident group peak demand is used
to a1locate costs among the
classes. Ms. Aschenbrenner
Company's different customer
explains costs are allocated
using the non-coincident group peak demand.
O. Did any other parties conduct an analysis
system-coincident and NCDs for both groups?
A. Yes. Dr. Morrison of Commission Staff
of
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11 cal-culated the system-coincident and NCDs for both groups.T
L2 O. Were the resul-ts of Dr. Morrison's study
13 consistent with the results of the Company's study?
L4 A. Yes. Dr. Morrison filed a revision to his
15 direct testimony on January ll, 20L8, and with Dr.
16 Morrison's revised computation, the results of his study
71 are consistent with the results of the Company's study.
18 O. Pl-ease summarize the conclusions the Company
19 has made after having performed these various analyses.
20 A. The results of additional analyses performed
27 by the Company demonstrate that the load factor, the load
22 profile, the SCDs and the NCDs for R&SGS customers with on-
23 site generation are distinctly different than R&SGS
24 customers without on-site generation. The Company has
7 Morrj-son DI, p. 18, l. 13; p. 19, 11. 2-4.
ANGELL, REB
Idaho Power
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clearly demonstrated that the load servi-ce requirement and
different for residential-the pattern of use arq
customers wlth on-site
residential customers wi-thout on-site
distinctJ-y
generation compared to
generatlon.
AS
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II. UTILIZATION OF THE GRID
1. Impact on the Grid
0. Ms. Donohue claims that "net meterlng has
mlnimal grid impacts . ." 8 Does the Company agree with
Ms. Donohue' s statement?
A. No. Each net metering instal-l-ation has a
sma1l lmpact on the voltage management of a distribution
circuit. Low net metering penetration on a circuit is
accommodated without changes to the voltage management.
However, Iarge penetration has significant grid impacts
that require mitigation measures and is dj-scussed in my
Direct Testimony.
O. Several witnessese assert that the excess
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1B energy generated by customers with on-site generation is
t9 consumed by neighboring loads. Do you agree with this
20 assertion?
2L A. In a broad, general sense this is true. The
22 assertj-on that the excess energy is consumed by neighboring
8 Donohue DI. p. 7, 1 l. 1-8.
e Kobor DI, p
11. 18-19.
63, If. 1-8; Otto DI, p. 5, 1. 18; Beach DI, p. 24,
ANGELL, REB
Idaho Power
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Ioads assumes that neighbors are consuming in unison with
the customer's on-site generation excess producti-on.
Fiqure 4 demonstrates the difference
excess production and consumption of
site generation. The 2:00 p.m. hour
without on-site generation load at 1
production at 1.8 kwhsite generator
in on-site generation
customers without on-
reflects the customer
kWh and the excess on-
Therefore, on
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average, two
required to
with on-site
customers without on-site generation are
consume the excess generatron
When the excess
of one customer
generation.energy exceeds
11 the neighbors' consumptJ-on, which is Iikely to occur in the
L2 spring and fal-l- months, the excess flows through the
13 distribution system, and at times, to the transmission
L4 system.
15 O. Mr. Leonard cl-aims that: "There are also
L6 extremel-y good grid benefits by lowering l1ne l-osses on the
L1 distributed energy side and increasing power quality." to Do
18 you agree with his claim?
19 A. I agree that some line losses may be reduced
20 with distributed generation (*DG") as described in the
2l Company's community solar case.11 In that case, my testimony
22 identified that the transmission, substation, and
10 Leonard DI, p. 5, l-I . 2-3
tr In the l"Iatter of Idaho Power Company's Application to Approve
New Tariff Schedufe 63, A Community Solar Pilot Program, Case No. IPC-
E-16-14.
ANGELL, REB
Idaho Power
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Company
1 distribution primary losses woul-d be offset but the
2 secondary l-osses will continue to be present. This outcome
3 was determined by compari-ng the load profile of the
4 customers located near the proposed community solar project
5 to the projected sol-ar production profile. The Company
6 determined that l-ocal- customer load would consume the
7 projected sol-ar generation at all times. The existing DG
B energy production, forecasted DG production, DG locations,
9 forecasted DG locations, and annual feeder load profiles
10 would need to be analyzed to determine the proper line foss
11 allocation.
\2 I do not agree with the assertion of increased power
13 quality. Distribution cj-rcui-t voltage variability
L4 increases with DG, resulting 1n reduced power quality. In
15 fact, the Company performs voltage flicker analysis (a
16 power quality issue) during the small and large generator
11 interconnection study process when distribution system
1B interconnection is requested. This condition is described
79 in Sectlon IV of my direct testimony, 12 re1ated to the
20 request for requiring
future and described
smart inverter functionality in the
22 Does on-site generation have a similar impact
27
O.
23 to the grid as when a customer install-s an energy
24 efficiency (*EE") measure?
in the next section of this testimony.
ANGELL, REB 19
Idaho Power Company
\2 Angell DI, pp. 23-21.
1 A. No. The grid impact is different because,
2 when a customer with on-si-te generation is generating
3 excess energy, their system can stop generating at any
4 moment. When this occurs, the Company must j-nstantaneously
5 supply not only their load that was supplied by their own
6 generatj-on, but al-so the excess generation they were
7 contributing to the system. This change in the direction
B of supply will also negatively impact the distribution
9 system voltage.
10 O. How does an instantaneous loss of suppJ-y by
11 the customer with on-site generation impact the grid?
12 A. The Company and its grid must always maintain
13 the balance of generation and l-oad. When a loss of supply
14 from on-site generation occurs, the grid must supply the
15 customer load and any excess generation that was being
16 produced. As shown 1n Eigure 4, during the 2:00 p.m. peak
11 export hour, the grid may have to instantaneously supply
18 the customer energy and excess generati-on of greater than
19 2.8L kwh (assuming 1 kwh or greater energy consumption by
20 the customer with on-site generation).
2L Additionally, a change in the dj-rection of supply
22 will- change the circuit voltage. This results from voltage
23 drop the decrease in the voltage along a conductor due
24 to the flow of current through the conductor. The voJ-tage
25 at the current source location wil-l be hi-gher than other
ANGELL, REB
Idaho Power
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locations along the distribution circuit. When a customer
with on-si-te generation is sourcing current (exporting
energy) to the distribution circuit, its voltage, including
its neighbors' voltage, will be higher than other locations
on the circuit due to voltage drop. Once the customer
stops sourcing (e.9., when a cloud passes over the solar
panels), the l-ocal higher voltage immediately drops to a
l-ower voltage based on voltage drop from the substation to
the customer location. These quick changes result in
reduced power quality.
O. Several partles compare on-site generation to
EE.13 Some even suggest that on-site generation "wil-l- reduce
a customer's long-term consumption from the grid, just as
an energy efficiency measure . ."14 Do you agree that
on-site generati-on reduces a customer's long-term
consumptlon from the grid similar to that of an EE measure?
A. No. On-site generation is significantly
different than EE. On-site generation will produce energy
based on the profile of the generating resource. Solar
production varies daily and throughout the year based on
the angle of incidence of the sun to the solar panels and
weather conditions. This solar production is not related
13 Beach DI, p. 1l , ll- . '7 -8; Donohue DI, p. 18, 1l- . 2-4; Kobor DI,
p. 50, t. 20 through p. 51, 1. 1.
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ANGELL, REB
Idaho Power
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Company
1 to the energy consumed by the customer. EE measures
2 directly reduce the consumption of the el-ectrical- equipment
3 all- the time it is operating throughout the year. When the
4 equipment is runni-ng, one can count on EE occurring. The
5 efficiency does not ramp in and out of operation Iike a
6 solar generation system.
1 Q. How does the l-oad shape of a customer who
B participates in EE compare to that of a customer who
9 installs on-site generate on?
10 A. As discussed by Dr. Ahmad Faruquits of the
11 Brattl-e Group in his rebuttal testimony, the load shape of
72 customers with on-site generatlon differs significantly
13 from those of customers who participate in EE programs. I
74 previously discussed the significance of the rate of change
15 and how that impacts grid operations. The greater the rate
L6 of change, the more volatile the load shape. EE measures
71 may reduce energy use through the day or just reduce the
18 peak use periods. Either outcome is not 1ike1y to increase
19 the load volatility.
20 This is in contrast to a customer who instal-l-s on-
2t site generation -- which would increase the volatil-ity of
22 the customer's load profile. This can be explained by
23 looking at both the level of demand (kW) placed on the
24 system and the amount of energy (kwh) consumed over time.
1s Faruqui REB, p. 10, 1. 8 through p. 13, I. 3
ANGELL, REB
Idaho Power
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Company
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When a
energy
demand
reduce
not the
( kilowatts
the amount
case with
customer installs an EE measure to reduce their
consumption, they may reduce both the instantaneous
(*kW") ) that they place
of energy consumed over
a customer who reduces
on the grid and
time. This is
their
an
energy
on-si-teconsumption
generation
cal-l-ed upon
requirement
using on-site
system is not
to provide
is the same
generation. When
generati-ng, and the utility is
the energy, the customer's load
as it was before the on-site
10 generatlon
generally
placed on
generat j-on
system was installed. In other
no reduction of the instantaneous
words, there is
demand11
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customer with
(kl/i)
on-sitethe utility's system. The
does, however, reduce the amount of
74 they consume from the Company but not achieve
energy (kwh)
any reduction
15 in total energy use.
. Other than having different i-mpacts on the
1B
grid, what other differences exist between customers who
reduce their energy usage by installing EE measures and by
install-j-ng on-site generation?
A. A customer with on-site generation has the
opportunity to net thelr bill-ed energy all the way to zero
whj-l-e st111 util-izing the grid; whereas, a customer who
reduces their energy consumption by instal-l-lng EE measures
is not able to do that unl-ess they consume no energy from
the utility for the entj-re month.
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Idaho Power
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assertion that
Did any parties disagree with you in your
customers with on-site generation who net
zero are not the same as a vacation hometheir usage
with no kwh
A.
disagrees.16
to
usage in a month?
Yes. Commission Staff witness
She suggests that, because both
Donohue
groups of
customers withcustomers are subsidized by other customers,
on-site generation who net
different than a vacation
their usage to zero are not
home with no kWh usage in a
10 month.
11 a)
72 vacation home
In what ways
wlth no kwh
does
usage
the Company assert that a
is different than a net
13
14
15
zero customer, a customer who generated either the same
amount or more energy from their system than they consumed
over the course of the month?
A. In addition to the differences listed by Ms.t5
71 Aschenbrenner in her direct testimony, ll
1B substantial differences in the services
19 provides the
course of the20 month. The Company provides no services to
2L the vacant home that consumes no energy. However, in
the customer with on-site
not generating or is not
22
16 Donohue DI, p. 16, 11 . 1,8-25 .
17 Aschenbrenner DI, p. 30, I. 8. - p. 31. l-. 13
there are
that the Company
vacant home and net zero customer over the
addition to providing
generation when their
energy to
system is
ANGELL, REB
Idaho Power
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generating enough energy to meet their demand, the Company
also provides regulated voltage for inverter operation,
motor starting current, and energy balancj-ng when the
customer is generating electricity.
2. Excess Generation
O. Ms. Donohue suggests that "most of the energy
produced [by net metering customers] is consumed on-site
rather than pushed back onto the 9rid. "te Does the Company
agree that most of the energy produced by customers with
on-site generation is consumed on-site rather than flowing
back onto the grid?
A. Yes. However, the Company performed an
analysi-s to quantify how much energy generated from
residential on-site generation flowed onto the grid.
Figure 9 provides the monthly net consumption and the
excess generation produced by the 565 net metering
customers who had 12 months of billing data during 20L6.
The graph also incfudes the monthly percentage of excess
generation as compare to the net consumption. As you can
?"", there are months when the residential customers with
on-site generation generated in excess of 60 percent of
their net consumptj-on.
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18 Donohue DI, p. J, 1I. 8-9
ANGELL, REB 25
Idaho Power Company
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1 Figure 9. 2OL6 Net Consr:mption and Excess Generation
TOLG Residential Net Consumption and Excess Generation
t,400
L,200
1,000
800
500
400
200
Jan Feb Mar
r Excess Generation
-g3
=
70o/o
60%
s0%
40%
30%
20%
L0%
o%I ilil
Aug SeptApr May Jun
IConsumption
Oct Nov Dec
-
Percentage Net Consumption
Jul
2
3
4
5
6
1
8
9
O. How much excess generation does the average
resj-dential customer wj-th on-site generation exchange with
the grid each month?
A. The Company's analysis shows that, in January
and December, the average resj-dential- customer with on-site
generation consumes most of their generation and has very
little excess generatlon; however, for the remaining
months, particularly April through September, customers
have anywhere from 678 to 1,005 kwh of excess generation
per month. Table 2 lists the average excess generation
produced by a residential customer with on-site generation,
by month.
ANGELL, REB 26
Idaho Power Company
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1 TabJ.e 2. Average Monthly Excess Generation per Customer
Average Excess
Generation (kllh)
January
February
March
April
May
June
July
August
September
October
November
December
Month
0
336
480
1,005
936
113
618
693
759
321
161
0
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3. Net Zero Customers
a. Ms. Donohue references Dr. Morrison's analysis
showing that only about 11.5 percent of customers with on-
site generation are net zero.te Do you agree wlth the
resul-ts of his analysis?
A. I agree that on an annual basis, there are
approximately 11.5 percent of customers with on-site
generation who are net zero; however, that number does not
represent the number of customers with on-site generation
who are nearly net zero or who are net zero on a monthly
basis.
O. Has the Company performed an analysis of the
14 number of customers with on-site generation who are net
15 zero on a monthly basis?
1,6
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11
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1e Donohue DI, p. 19, l-l-. 4-'7
ANGELL, REB
Idaho Power
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Company
1 A. Yes. Using the same 2076 dataset for the 565
2 residential- net metering customers who had 12 months of
3 bilfing data during 20!6, the Company calculated that, for
4 three of the 72 months, more than 40 percent of customers
5 with on-site generatj-on netted their usage to zero and for
6 an additional- four months, more than 30 percent of
7 customers with on-site generation netted their usage to
8 zero. Figure 10 shows the percentages of net zero
9 customers for each month.
10 Figure 10. Percent of Net Zero Customers by Month in 2016
Percent of Net Zero NEM Customers
(by month)
t00%
90%
80%
70%
60%
s0%
40%
30%
20%
to%
o%ll
.Ju I sep
I
Dec
I
Nov
I
Oct
I
AugJan Feb Mar Apr May Jun11
L2
13
t4
15
16
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4. Two-ttay Flow is Distinct to Customers with On-Site
Generation
O. Do any partj-es disagree with your assertion
that customers with on-site generation have a two-way
rel-ationship with the grid?
A. Yes. Ms. Levin of SRA/NW Energy suggests
that: "With advanced metering infrastructure ("AMI"), any
customer can have a two-way relationship with the grid.
ANGELL, REB 28
Idaho Power Company
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AMI al-l-ows all customers, and any of their "smart" (grid-
enabled) devices, to follow and track customer usage,
system conditions, and energy prices and respond to this
information . ."20
O. Do you agree with Ms. Levin that this "two-
way" fl-ow of j-nformation is the same as the "two-way" flow
of energy?
A. No. AMI allows the utility two-way
communication with customer meters and, depending on the
technol-ogy deployed, may provide the customer with
information as Ms. Levin described. The customer may even
act based on the information provided. However, the
customer is not in a two-way relationship with the grid.
The customer is simply making informed energy use cholces
that may decrease or increase their demand. This 1s not at
aI] simil-ar to the production of energy by R&SGS customers
with on-site generation whose production is driven by daily
solar irradiance, not information that might be provided by
an electric uti11ty.
O. Do any other parties disagree with you that
customers with on-site generation use the grid in a bi-
directional manner?
A. Yes. Sj-erra Club witness Mr. Beach suggests
that the Company's thinklng is flawed. He claims that:
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[W]hen a sol-ar customer exports power tothe utility, it is the sol-ar customer
20 Levin DI, p. 4, ll. 13-16 (emphasis in original).
ANGELL, REB 29
Idaho Power Company
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that 1s providing a service generation
to the utility. Once the exported
power passes the DG customer's meter, the
utility takes title to the exported
power.It is the utility that delivers
the exported DG power to the DG
customer's neighbors. It is the utilitythat is compensated by the neighbors for
the service that the utility provides in
deliverj-ng the DG exports to them. Thus,it is the utility and the neighboring
customer that use the distribution systemto deliver the DG exports. The DG
customer is in no way responsible for the
delivery of their exported power, has no
control- over who receives their exports,and receives no compensatlon for the
delivery of the exports.zl
0. Do you agree wj-th Mr. Beach that it is the
utility that is utilizing the grid when a solar customer
exports power to the utility?
A. Mr. Beach is correct in the DG customer has no
responsibility for the grid or the delivery of energy
through the grid. However, the DG customer rel-ies on the
grid voltage for the inverter to produce alternating
current for the export of energy and the grid's ability to
receive and distribute this energy to other loads while
maintaining a balance between energy and load. Further, my
statement of "uses the grid in a bi-directional manner"zz
pertains simply to the ability to receive power from the
grld and supply power to the grid at any time, collectively
21 Beach DI, p. 2A, 11. 15-24 (emphasis in originat) (footnote
omitted)
22 AngeII DI, p. 10, fI. 22-23.
ANGELL, REB
Idaho Power
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referred to as "exchange. " The R&SGS customers with on-
site generation exchange more energy with the grid than a
R&SGS standard service customer.
O. Did the Company perform analysis to assess
when R&SGS customers wlth on-site generation exchange more
energy with the grid?
A. Yes. The Company analyzed the hourly exchange
for al-l 565 net metering customers who had 12 months of
billing data during 2016 and compared that to the exchange
of the residentlal customers without on-site generation.
The Company analyzed aII 72 months of 20L6 and has shared
the resul-ts for a winter month, a spring month (al-so
representative of fall), and a summer month in Figures 17,
72, and 13 respectively. For the three graphs, each hour
data point is the average of the absol-ute value for that
hour throughout the month. The abso1ute value of each hour
captures the amount of the energy exchange, regardl-ess of
whi-ch direction the energy is flowing.
A comparison of Figures l!, 12, and 13 with Figures
3, 4, and 5, respectively, reveal the export of energy
during the daylight hours when net metering customers are
exporting to the grid. The net metering customers on
average are consistently exchanging more energy with the
grid every hour of each month. This energy exchange, when
combined with their l-ower foad factor, results in less
efficient use of grid capacity.
ANGELL, REB
Idaho Power
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1 Figure 11. ilanuary 2OL6 Average Hourly Energy Exchang'e
January Average Energy Exchange
Bv
3.s0
3.00
2.50
2.00
1.50
1.00
0.s0
0.00 ilr ilililililil1
L 2 3 4 5 5 7 8 9 101172731415t677 1819202L222324
I Residential r Net Metered
2
3 Fig.nre 12. April 2OL6 Average Hourly Energy Exchange
April Average Energy Exchange
3.00
2.s0
2.00
! r.so
ilililililil
1234s6
ilililililil
1.00
0.s0
0.00
7 8 9 1011t2L3t415L6t7 18192021222324
r Residential I Net Metered
4
tr E.igure 13. June 2OL6 Averag'e Hourly Energ'y Exchange
June Average Energy Exchange
3.00
2.50
2.OO
illlllllililr
! r.so
ilililililililr
1.00
0.50
0.00
1 2 3 4 5 6 7 I 9 1011121314L51617 1819202L222324
I Residential I Net Metered
6
ANGELL, REB 32
Idaho Power Company
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O. Did Mr. Beach conduct any analyses to support
his argument that it is not the customer with on-site
generatJ-on that 1s utilizing the grid when generating
excess energy?
A. No. However, Mr. Beach descrj-bes a study to
determine the distribution benefits provided by DG. The
study cal-culated a peak capacity allocation factor for L2
substations' 20L6 l-oads and combined this factor with two
Boise sol-ar profiles. The study concludes that 0.22 kW and
0.31 kW of marginal distribution capacity costs can be
avoided by one kW of south-facing and west-facing solar DG,
respectively. z:
O. Do you agree with Mr. Beach's conclusions from
this analysis?
A. No. Mr. Beach's conclusion of marginal
distribution capacity costs avoidance from DG solar is
inconsistent with the Company provided substation capacity
and 2016 load data. I be]ieve this is due to the
generalized summation approach used withln the study which
discounts the capacity and loading of a single substation.
For example, the !2 substations' 20L6 non-coincident peak
l-oad hours are only 70 percent of the total installed
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Idaho Power Company
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23 Beach DI, p. 30, I. 14 - p. 31, 1. 2.
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1 capacity. Based on this, one could conclude that no
capacity additions are required.
Analysis of the load data of each substation reveafs
specifics that are l-ost in the generalized approach of the
study. Six of the L2 substations serve predominately
irrigation customers who have a consistent 2A-hour load
profile during the irrigation season. Two of the
substations supply winter peaking 1oads. Based on the
Company's and the electric utility industry's experience
with solar and battery DG technology, eight of the 12
substation capacity upgrades would not be avoided by solar
DG or sofar with battery DG. First sofar DG cannot provide
power to supply irrigation load through the night nor
supply the wlnter morning peak loads of the winter peaking
substations. Additionally, sol-ar combined with batteries is
not an economically viable option to supply loads lasting
more than four hours based on present and near-term battery
technology.
Mr. Beach's generalized approach 1ike1y overstates
the real-izable capacity avoidance. It shou1d also be noted
that the discussion regarding the vafue of DG is beyond the
scope of this docket. In Order No. 33946, the Commission
denied ICEA's alternate recornmendation to decide the value
of DG prior to addressing reclassification of R&SGS
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ANGELL, REB 34
Idaho Power Company
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customers with on-sj-te generation. Idaho Power has
requested that the Commission open a generic docket at the
concl-usi-on of this case where stakeholders and other
util-ities can collaborate to assess the benefits and costs
that DG brings to
O. Were
the efectric system.
there any other suggestions made by Mr.
addre s s ?Beach that you would like to
A. Yes. Mr. Beach mischaracterlzed a statement
from my direct testimony. Mr. Beach claimed that I
asserted:
any distribution benefits will be limited
to the five-year period in whlch Idaho
Power plans distribution upgrades and
expansiorts."2q To clarify, the statementI made was "fdaho Power is able to
forecast distribution circuit and
substation capacity requirements with
some certainty five years into the
future. This planning horizon period
allows the Company to investigate optionsto avoid facility overloads, select more
cost-effective options, and design and
construct improvements to meet the
ldentified overloads.2s
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from customers
that distribution benefits
27
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resulting
Iimited to
with on-site generation will be
benefit determination
ANGELL, REB 35
Idaho Power Company
29 is outside
a five-year period as such
the scope of this docket.
30
2a Beach DI, p. 27 ,
2s Angell DI, p. 18,
r1.24-25.
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Pl-ease summarize the impact that customer on-
site generation has on the grid.
A. Customer on-site generation is not l1ke EE.
The grid must be abl-e to absorb excess generation when
supplied, supply the customer's 1oad, and replace the
excess generation when call-ed upon, aII whil-e minimiztnq
distribution circuit voltage variability to maintain
customer power qual-ity.
III. MODIFICATIONS TO SCHEDT'LE 72
10 1. Smart Inverter Requirenent
11 0. Do parties support the Company's proposal to
L2 require al-l new net metering customers to use smart
l-3 inverters within 60 days folfowing the adoption of an
L4 industry standard definition of smart inverters as deflned
15 by the IEEE?
A.fn general, yes. Mr. Otto of ICL recommends
71 the Commisslon approve Idaho Power's request to requr-re
standard18 smart inverters according to industry
79 definitions.26
20 Do any parties oppose the Company's proposal
76
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O.
to requj-re
inverters
al-l- new net meteri-ng customers to use smart
within 60 days foflowing the adoptj-on of an
ANGELL, REB
Idaho Power
36
Company
26 Otto DI, p. 10, 11. 14-15.
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1 industry standard definltion of smart inverters as defined
2 by the IEEE?
3 A. Yes. Staff witness Dr. Morrison opposes the
4 Company's proposed smart inverter requirement.
5 Q. Why does Dr. Morrison oppose the smart
6 inverter requirement for all- new net metering customers?
7 A. Dr. Morrison states that, "the Company is
8 requesting that Commission adopt IEEE L547 and IEEE 7547.L
9 before these standards have been released"zr and the Company
10 "didn't provide any hard information about either of the
11 proposed smart meter Iinverter] standards."28
72 O. Will the Commission and Staff have the
13 opportunity to review the fEEE 7547 and IEEE 7541.7
L4 standards before approving them?
15 A. Yes. The Company's request regarding the
inverter requirement was that the Commlsslon order the
Company to submit a compllance filing in the form of a
tariff advice wlthin 60 days of the adoption of the revj-sed
IEEE standards, or 60 days of the concl-usion of this case,
whichever occurs later. Thls tariff advice will- seek to
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2L modify its interconnection tariff to require that customers
smart inverter that meets22with on-site generation install
the requirements deflned in the
a
revlsed IEEE standards.
27 Morrison Df, p
28 Morrison DI, p
16- 18 .
1_a
ANGELL, REB 31
Idaho Power Company
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The Commission and Staff woul-d have the opportunity to
review the standard in the tariff advice filing.
0. Should the current lack of a defined standard
by IEEE prevent the Commission from adopting the Company's
inverter proposal?
A. No. The current Iack of a defined standard by
IEEE should not prevent the Commission from acknowledging
that smart inverters provide functionalj-ty that is
necessary to support the ongoing stability and reliability
of the distribution system and that the industry adoption
of a smart inverter requirement will help mitlgate circuit
voltage deviation.
2. Other Minor Revisions to Schedule 72
O. The Company has requested to modify Schedule
12 as part of this case. Do any parties object to the
proposed changes to Schedul-e 12?
A. Yes. Staff witness Dr. Morrison states that
the Company's proposed modificatj-ons to Schedule 72 are not
minor and would constitute a major revision to the tariff.
He goes on to suggest that "the Company's proposed
modifications to Schedul-e 12 go far beyond the scope of its
application . ."2e
O. Do you agree with Dr. Morrison's suggestion
that the proposed revisions are major?
2e Morrison DI, p. 21, 11. 20-22
ANGELL, REB
Idaho Power
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A No. The proposed revisions to Schedule 12 are
in fact very minor. Most of the revislons to Schedule 72
are to incorporate the defined terms
interconnectlon requirements between
necessary
Schedule
to sync the
10 proposed
revi s ion
Schedules 6 and B were removed, there is only one
11 under Section 2, step 5. A11 other revisions are
12 due to the addition of proposed schedules 6 and B. None of
13 the proposed revisions affect any other energy providers
14 who are subject to Schedul-e 12.
15 IV. CONCLUSION
76 Pl-ease summarize your rebuttal testimony.
L1 In response to the direct testimony of other
: explained in detail the additlonal18 witnesses, I have
L9
12 and the
newly proposed Schedules 6 and 8 and to make one minor
revision to all-ow the Company additional time to complete
the on-site inspection of a newly instal-led on-site
generation system when circumstances beyond the Company's
control- arise (e.9., large snowfal-I) . If the addltlon of
analyses performed by the Company. The Company provided
additionaf analyses 1n the following areas:
o Customers with on-site generatj-on are partial
requirements customers and therefore their load
service requirements are different than full
requirements customers .
n
A
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Idaho Power
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o The l-oad profile of customers with on-site
generation is distinct from the foad profile of
customers without on-site generation.
. . The rate of chanqe in usage by customers with on-
site generation during the day is significantly
larger than customers without on-sj-te generation.
o Customers with on-site generation have notably
l-ower load factors than customers without on-site
generation.
o The system-coincident and NCDs for customers with
on-site generation are different than customers
without on-site qenerati-on.
In summary, the results of additional analyses
performed by the Company demonstrate that the foad factor,
the load profile, the SCDs and the NCDs for R&SGS customers
with on-site generation are distinctly different than R&SGS
customers without on-site generation. The Company has
clearly demonstrated that the load service requirements,
and the pattern of use, are distinctfy different for
residential customers with on-site generation as compared
to residential customers without on-site generation. I
have explained that the two-way flow of energy is distinct
to customers with on-site generation and have al-so
explained the l-imited scope of revisions to and the process
10
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15
L6
t1
1B
79
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27
))
)')
24
ANGELL, REB
Idaho Power
40
Company
25
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2
3
4
5
6
1
B
9
of approving the proposed revisions to Schedule 12 and
smart inverter requirement.
O. What is your recommendation for the
Commission?
A. I recommend that the Commission issue an order
to establ-ish two new classiflcations of customers
applicable to R&SGS customers with on-sj-te generatlon, to
approve the proposed revisions to Schedule f2, and to
acknowledge that smart inverters provide functionality that
is necessary to support the ongoing reliability of the
distribution system by ordering the Company to amend its
applicable tariff schedules to require the instalfation and
operation of smart i-nverters for all new customer-owned
10
11
72
13
74
15
76
71
1B
79
20
2L
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25
of
generator
adoption
inverters
O
A
lnterconnections within 60 days following the
deflnition of smart
your testimony?
AS
an industry standard
defined by the IEEE.
Does this conclude
Yes, it does.
ANGELL, REB 47
Idaho Power Company
26
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2
3
4
5
6
't
I
9
ATTESTATION OF TESTIMONY
STATE OF IDAHO
SS.
County of Ada
I, David M. Angell, having been duly sworn to
testify truthfully, and based upon my personal knowledge,
state the following:
I am employed by Idaho Power Company as the Senior
Construction and amManager of T&D Engineering and
10 competent
I
to be a witness in this proceeding.
perjury of the l-aws of11declare under penalty of
12 the state of Idaho that the foregoing rebuttal
of my information
testimony is
and bel-ief .13 true and correct to the best
74 DATED this 26th day of January, 2018.
15
(
76
l1 David M. AngelI
1B SUBSCRIBED AND SWORN to before me this 26th day of
79 January, 2078.
20
2t
22
23
24
No ary c for Idaho
Residing a Bo
My commission e
25
26
21
ANGELL, REB
Idaho Power
42
Company
goTAiy
Purulc-a(,
t(.
,,rgOF
28
)
)
)
r]a g
.'r'l'' l
\l ,.$
,l:
!:l s1 I
CERTIFICATE OF SERVICE
! HEREBY CERTIFY that on the 26th day of January 2018 I served a true and
correct copy of REBUTTAL TESTIMONY OF DAVID M. ANGELL upon the following
named parties by the method indicated below, and addressed to the following:
Gommission Staff
Sean Costello
Deputy Attorney General
!daho Public Utilities Commission
472 West Washington (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
ldahydro
C. Tom Arkoosh
ARKOOSH IAW OFFICES
802 West Bannock Street, Suite 900
P.O. Box 2900
Boise, ldaho 83701
ldaho Gonseruation League
Matthew A. Nykiel
ldaho Conservation League
102 South Euclid #207
P.O. Box 2308
Sandpoint, ldaho 83864
Benjamin J. Otto
ldaho Conservation League
710 North 6th Street
Boise, ldaho 83702
ldaho lrrigation Pumpers Association, lnc.
Eric L. Olsen
ECHO HAWK & OLSEN, PLLC
505 Pershing Avenue, Suite 100
P.O. Box 6119
Pocatello, Idaho 83205
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Anthony Yankel
12700 Lake Avenue, Unit 2505
Lakewood, Ohio 44107
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Auric Solar, LLC
Preston N. Carter
Deborah E. Nelson
GIVENS PURSLEY LLP
601 West Bannock Street
Boise, ldaho 83702
Elias Bishop
Auric Solar, LLC
2310 South 1300 West
West Valley City, Utah 84119
Vote Solar
David Bender
Earthjustice
3916 Nakoma Road
Madison, Wisconsin 537 11
Briana Kobor
Vote Solar
986 Princeton Avenue S
Salt Lake City, Utah 84105
City of Boise
Abigail R. Germaine
Deputy City Attorney
Boise City Attorney's Office
150 North Capitol Boulevard
P.O. Box 500
Boise, ldaho 83701-0500
ldaho Clean Energy Association
Preston N. Carter
Deborah E. Nelson
GIVENS PURSLEY LLP
601 West Bannock Street
Boise, ldaho 83702
Sierra Club
Kelsey Jae Nunez
KELSEY JAE NUNEZLLC
920 North Clover Drive
Boise, ldaho 83703
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Tom Beach
Crossborder Energy
2560 9th Street, Suite 213A
Berkeley,CA 94710
Zack Waterman
Director, Idaho Sierra CIub
503 West Franklin Street
Boise, ldaho 83702
Michael Heckler
3606 North Prospect Way
Garden City, ldaho 83714
Snake River Alliance
NW Energy Coalition
John R. Hammond, Jr.
FISHER PUSCH LLP
101 South Capito! Boulevard, Suite 701
P.O. Box 1308
Boise, ldaho 83701
lntermountain Wind and Solar, LLC
Ryan B. Frazier
Brian W. Burnett
KIRTON McCONKIE
50 East South Temple, Suite 400
P.O. Box 45120
Salt Lake City, Utah 84111
Doug Shipley
lntermountain Wind and Solar, LLC
1953 West2425 South
Woods Cross, Utah 84087
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()
Ki T , Executive istant