20180126Aschenbrenner Rebuttal.pdf

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BEFORE THE ]DAHO PUBLIC UT]L]TIES COMMISSION
IN THE MATTER OF THE APPLICAT]ON
OE IDAHO POWER COMPANY FOR
AUTHORITY TO ESTABLISH NEW
SCHEDULES FOR RESIDENTIAL AND
SMALL GENERAL SERVICE CUSTOMERS
WITH ON-SITE GENERATION.
IDAHO POWER COMPANY
REBUTTAL TEST]MONY
OF
CONNIE G. ASCHENBRENNER
CASE NO. ]PC_E_17_13
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O. Please state your name.
A. My name is Connie G. Aschenbrenner.
O. Are you the same Connie G. Aschenbrenner
previously presented direct testimony?
A. Yes.
that
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o.Have you had the opportunity to review the
the City of Boise's witnesspre-filed direct testimony of
Stephan L. Burgos; the Idaho
Inc.'s witnesses Kevin King,
White; the Idaho Conservatlon
Clean Energy Association,
Michael- Leonard, and Stephen
11 Otto; Sierra Club's witness R
League's witness Benjamin J.
. Thomas Beach; the Idaho
12 Irrigation Pumpers Association, Inc's witness Anthony J.
13 Yankel-; the Snake River Al-liance and NW Energy Coalition's
14 witness Amanda M. Levin; Vote Solar's witness Briana Kober;
15 Auric Sol-ar, LLC's wi-tness El-ias Bishop; and the Idaho
16 Public Utilities Commission ("Commissi-on") Staff's
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( "Staff" )
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o.
testimony.
A.
witnes ses
Yes,
What
Michael- Morrj-son and Stacey Donohue?
I have.
is the purpose of your rebuttal
The purpose of my rebuttal testimony is to
22 address concerns expressed by
23 in their direct testimony. My
24 four sections.
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intervening parties and Staff
testimony is comprised of
ASCHENBRENNER, REB 1
Idaho Power Company
1 In Section I, I provide the Commission with an
2 update on customer participation j-n net metering since the
3 filing of the Application in Ju1y.
4 In Section II, I briefly discuss consumer protection
5 and provide some clarity about information rel-ated to the
6 Idaho Power Company's ("Idaho Power" or "Company")
7 stakeholder engagement in preparation of, and leadlng up
8 to, the filing of this docket.
9 In Section III, I address the concerns expressed by
10 parties regarding a class cost-of-service study (*COSS")
11 and how costs are al-l-ocated among the Company's customer
72 cl-asses.
13 In Section IV, I explain why the current rate
t4 structure for residential and small service (*R&SGS")
15 customers with on-site generation is outdated and needs to
76 be addressed.
71 I. UPDATE ON NET METERING PARTICTPATION
1B O. Please provide an update of participation in
the Company's net metering service since reported to the
Commission in the Company's Application.
A. Participation in the Company's net metering
service has continued to grow since its Application was
filed on JuLy 27 , 20L'1. Tables 1 and 2 represent updated
system counts and nameplate capacity as of December 37,
20!1 .
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ASCHENBRENNER, REB 2
Idaho Power Company
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1 Tabte 1 Idaho Net Me tems
Tab1e 2 Idaho Net Metering J.ate Capacity (in MW)
4 Q. How does the total nameplate capacity of
5 active and pending net metering systems at December 3L,
6 2077, compare to the original participation cap of 2.9
7 megawatts ("MW") as authorized by the Commission in 2002?
I A. The total- capacity of active and pending
9 systems in the Company's Idaho jurisdiction was 15.98 MW as
10 of December 31, 2011, approximately 5.5 times the original
11 cap. Figure 1 shows year-over-year instal-l-ed capacity of
L2 Idaho's net metering service since 20L2. The sol-id
13 horizontal- line represents the initial 2.9 MW cap
74 authorized by the Commission in 2002.
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ASCHENBRENNER, REB 3
Idaho Power Company
Class Photovo].taic IiIind Hy&o/other Tota1
Residential 7,1'l B 42 6 l,826
Commerci-al &Industrial 746 5 4 155
I rrlgat ion 10 1 11
Tota1 L,934 48 10 L,992
CIass Photovoltaic V[ind Ilydro/Other Total
Re s ident ial L2.t0 0.19 0.06 72 .35
Commerciaf &
Industrial-2.14 0.03 0.09 2.86
Irriqation 0.00 0.110.73 0.04
Total 1s.58 0.26 0.15 15.98
1 Figrrre 1: CumuJ-ative Iate
A. What is the significance of the 2.9 MW cap?
A. In its order authorizing the establishment of
Schedule 84, the Commission acknowledged that "the full
cost of the program may not be borne by participants" and
that " [r] aising the cap increases the level of
subsidi zaLion. "t
0. Several parties describe the negative impact
the filing is already having on the industry or will have
if the filing is approved.z Do you agree the filing has had
a chilling effect on installations in the Company's servi-ce
area?
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1 Commj-ssion Order No. 28951,, p. 12
2 Burgos DI , p . 10, l-l- . 2-3;
Leonard DI, p. 4, l-l-. 5-9, P
White DI, p. 9, l-1. 8-10 .
Kj-ng DI, p. 10, l-1 . 75-22, p . 77, f f .
1, LL. 14-L6; Bishop DI, p. 2, l-l-.
ASCHENBRENNER, REB 4
Idaho Power Company
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20L2 2013 2014 2015
r Residential r Commercial & lndustrial
20L6
:lrrigation
20t7
-Capacity
I A. No. The Company received 885 applications for
2 neL metering service during 20L7. Figure 2 compares the
3 number of applications received by month for 2016 and 20L7.
4 The trend before the filing (increase in year-over-year
5 applications on a month-by-month basis) is the same as the
6 trend post-fiIing. It is clear the filing has not had a
7 negative impact on the continued adoption of customer on-
8 site generation.
9 Figrure 2, Net Metering AppJ.ications by Month (2OL6-2OL7}:
r40
120
100
80
60
40
20
0
r23 t25
98
81 80 83
67 6s 70
53
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20t6 201,7
O. Steve Burgos claj-ms the City of Boise has
already heard from instal-Iers that "their business
decreased dramatically almost immediately after"3 the
Company submitted its Application. How do you respond to
that claim?
ASCHENBRENNER, REB 5
Idaho Power Company
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3 Burgos DI, p. '7 | l-l-. 2-3.
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A. The data simply does not support that. As
shown in Figure 2, the Company recej-ved 885 applicati-ons
during 201,7, up from 368 received during 20L6. If Mr.
Burgos has heard from any installer that thej-r busj-ness is
being negatively impacted, it may be more realistic to
attribute that to either the influx of installers to the
Idaho market or the growth in market share from a
10 number
grown
Tab]-e
particularly active
As shown in Table 3
installer, not the
be1ow, in the l-ast
Company's
in 2071.
Company's filing.
flve years, the
service area has
cations Year
was listed on 335
of installers in the
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from 18 in 2013 to 51
3: Nurnber of Insta].].ers and
Additionally, a single installer
applications in 2011, which represented 38
applicatj-ons submitted in 20L1. That same
listed on 100 applications representing 21
total- applications submitted in 2016.
percent of the
install-er was
percent of the
O. Mr. Burgos also suggests that the, "Zero-Net-
Energy Maintenance and Administration Building at the
Twenty M1l-e South Earm and could be negatlvely impacted by
ASCHENBRENNER, REB 6
Idaho Power Company
20L3 2014 2015 20L6 20L7
Installers 1B 36 3B 51
Tota].
AppJ-ications 59 701 26t 368 BB5
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the formation of a new schedule. " q Does the Company agree
with Mr. Burgos'
A. No.The Company's flling only impacts R&SGS
customers with on-site generation. The City's Zero-Net
Energy Maintenance and Administration Building is neither
residential nor small general service.
II. CONSI'MER PROTECTION AI{D STAKEHOLDER ENGAGEMENT
1. Consumer Protection
O Commission Staff witness Donohue suggests that
assessment?
10 if the Company is concerned about consumer protection, j-t
11 coul-d host a list of "Particj-pating Contractors" for solar
1,2 installers, similar to what it does for contractors who
13 install- energy efficlency ("EE") measures. Do you belleve
L4 that to be a reasonabl-e solution?
15 A. No. First, the purpose of the Participating
16 Contractor l-ist that Ms. Donohue references is different.
11 The sole reason the Company maintains the list of
18 Participatlng Contractors referenced is to ensure the
79 prudent management of the Energy Efficiency Rider ("Rider")
20 funds. The Company relies on these contractors to ensure
21, that measures are installed correctly -- this enables the
22 Company to provide the Commission with reasonable assurance
23 that customer funds are spent prudently, and that in
24 exchange for those funds, the Company and its customers are
a Burgos DI, p. 6, 11. 1,4-1,6
ASCHENBRENNER, REB 1
Idaho Power Company
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receivj-ng the kilowatt-hour ("kwh") savings attributed to
the measure (s) instal-l-ed. The Company does not maintain
this list for the purpose of making "sure that its
customers participating in its EE programs are dealing with
a reputable deal-er. "s
Second, it is important to note the Company does not
warrant or guarantee the work or services performed by any
EE contractor l-isted. To suggest that hosting a list of
solar instal-l-ers l-ocated in the Company's service area
would provide assurances that customers are provided with
transparent informatj-on about the services (and associated
pri-cing) is not reasonable.
O. While Idaho Power does not believe it is
appropriate to provide endorsements of sol-ar installers,
are you aware of any lnformation availabl-e to help
customers flnd sol-ar instal]ers in the state of Idaho?
-H.Yes. The Idaho Governor's Office of Energy
entitled
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and Mineral Resources ("OEMR") provides a
"Resources for Solar Project Developmentr "
Iisting of solar instal-l-ers throughout the
websiteo
which i-ncludes a
state and in the
s Donohue DI, p. 21, 1I. 22-23.
6 https : / / oemr. idaho . govlwp-content /uploads /
ASCHENBRENNER, REB B
Idaho Power Company
20\5.72.31 ID Sofar Dev Res.pdf
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region. Idaho Power provides a link to the OEMR website on
the Company's website:7 The link is lncluded in both the
Solar Checklist and in the Frequently Asked Questions.
2 . Stakeholdel Engeg1qe4t
n Ms. Donohue claims that you suggested that
costs and benefits after"the Company's plan to
establishing separate
customers aligns with
Do you agree with Ms.
study the
10 you clai-med in your direct testimony?
11 A.No. In my direct testimony, I stated that
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rate classes
feedback from
for net metering
stakeholders ,IB
Donohue's characterization of what
"the Company's
generic docket across the
to open a
state couldwhere partles from
a discussion about
decision to ask the Commission
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participate
the benefits
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and costs of on-site
ident i fyinglquant i fying
generation was the direct
from interestedL6 result of what the Company heard
l1 stakeholders and installers durlng those meetings. "o I did
18 not claim that stakeholders and installers were aligned on
19 studying the costs
rate cl-asses.
and beneflts after establishing separate
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7 https : / / www . idahopower . com/energy/renewab]-e-enerqy / green-
choices / solar-power-opt lons /
8 Donohue DI, p. 19, 11. 14-16.
e Aschenbrenner DI, p. 24, 11. 7-13
ASCHENBRENNER, REB 9
Idaho Power Company
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In fact, I agree with Ms. Donohue that the
preference of stakeholders
understand the
at the meeting was
benefits and costs
to engage in
associateda process to
with on-site
Commission to
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Ms. Donohue also mischaracterizes the Company's
position in that meeting she claims that the "Company
made no indication that it might conduct the study after
determining the need for separate rate classes. "ro That
statement is incorrect. As representatives of the Company,
generation prior to seeking authority from the
create new customer cl-asses.
or
If the Commission determi-nes there are
the establishmentdifferences that warrant
cfasses, the Company will
classes in a future COSS
11 Mr. Tatum and I represented that the Company was
72 contempJ-ating a filing to seek authority for creation of
13 new classes as a first step toward addressing the cost
l4 shift between net metering customers and standard service
15 customers.
16 III. CI,ASS COST-OF-SERVTCE A}ID COST AI,LOCATION
71 How would the Commission's decision regarding
18 the establishment of separate customer cl-asses affect the
ratemaking processes?
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Company's COSS
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and design rates
24 classes as part of a future rate proceedlng. Shoul-d the
assign costs to
of new customer
the new customer
specific to those
ASCHENBRENNER, REB 1O
Idaho Power Company
ro Donohue Df, p. 19, 11. 20-27.
1 Commission decli-ne to authori-ze the establishment of the
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requested new customer classes, the Company would have no
reason to modify its class COSS or ratemaking processes
specific to net metering customers. The Company woul-d
continue to al-locate costs to the residential and smal-l-
general service customer cl-asses that exlst today.
O. Do you agree with Commission Staff witness Dr
Morrison's characterizationtt of how costs are allocated in
the Company's COSS?
A. No.
O. Please explain.
A. In his testimony, Dr. Morrison discusses the
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Company's use of
coincident demand
allocate costs to
system-coincident demand
(*NCD"), and individual
("SCD"), non-
peak demands to
Dr. Morri-soncustomer classes. While
accurately
allocation
describes how the Company utilizes NCDs in the
of distribution pIant, hi-s discussion of SCD and
individual- peak demands does not reflect the actual
met.hodofogy acknowledged in the Company's most recent
general rate case ("GRC"), Case No. IPC-E-11-08.
O. Pl-ease define the SCD and NCD.
A. As described in Mr. David M. Angell's Rebuttal
Testimony, rz the SCD 1s the average demand for the customer
11 Morrison DI, pp. 18-19.
12 Angel1 REB, p. 14, Il- . 4-9 .
ASCHENBRENNER, REB 11
Idaho Power Company
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class at the time of Idaho Power's system peak. The NCD is
the maximum average demand for the customer c1ass,
regardless of when it happens. Both the SCD and the NCD
are calcul-ated for each month.
O. How was Dr. Morrison's discussion of SCD
inaccurate?
A Dr. Morrison suggested
used to
that, "the Isystem]
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coincident peak factor Iis]
generation and transmission
with the concept that SCDs
generation and transmission
allocate fixed
costs,
statement because 1t suggests that
used to allocate these costs. This
costs tt73 Whlfe I agree
are used to allocate flxed
I find fault with hls
there is just one SCD
is incorrect.
ASCHENBRENNER, REB 12
Idaho Power Company
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15 costs?
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A. SCDs are used to allocate demand-rel-ated
generation and transmission costs among the Company's
different customer cl-asses. Demand-related generation
costs associated with serving base and intermediate l-oad
are all-ocated using L2 monthly SCDs, while demand-rel-ated
generation costs associated with serving summer peak load
are all-ocated based on the sum of the three SCDs in the
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summer months (June, Ju1y, and August). Transmission-
related costs are aflocated utilizing 12 monthly SCDs.
O. With regard to the use of individual customer
peak demands, was Dr. Morrison correct when he stated,
"individual peak loads are important determinants of costs
that the Company expends on distribution p1ant, and in
particular, on the costs of secondary transformers and
service drops?"ta
A. No. Individual peaks are not used to al-l-ocate
costs in the Company's COSS.
O. Given that several- of Dr. Morrison's
I2 assumptions were
characteri zatlon
j-ncorrect, was his overal-l-
13 correct that "sIightIy less generation and
L4 transmission plant cost"l: would have been allocated to
15 residentlal customers wlth on-site generation?
full- cl-ass COSS wlth16Without performing a
L1 these customers separated into a distinct class, Dr.
18 Morrison's statement cannot be verified.
19 O. Please explain.
20 A. The Company performed an analysis of the cost
27 to serve residential- customers with on-site generation for
22 inc1usion in the 2076 Net Metering Status Report.16 It
1a Morrison DI, p. 19, ff. 7-10.
1s Morrison DI, p. 18, l-. 18.
16 Aschenbrenner DI, Exhj-bit 9.
ASCHENBRENNER, REB 13
Idaho Power Company
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shoul-d be noted that this analysis was not a full class
COSS that the Company typically performs in a GRC filing,
but rather an analysis util-izinq currently approved costs
to estimate the cost to serve customers with on-site
generatlon.
For this analysis, the Company calculated the
monthly SCD and NCD for the residential segment of
customers with on-site generation.l? Using the same
costs for residential customers from the 20L7 GRC,
per-unit
and
10 multiplying them by the SCD and NCD for the residential
customers with on-site generation, an esti-mate of the
revenue requirement for residential customers with on-site
generation was determined.
The resul-ts of that analysis determined that (1)
production plant costs associated wlth servi-ng base and
intermediate l-oad increased because they are all-ocated
using an average of 72 monthly SCDs, (2) production plant
costs associated with serving peak load decreased because
these costs are allocated using an average of the three
monthly SCDs occurring in June, Ju1y, and August, (3)
transmission costs increased because they are allocated
using an average of L2 monthly SCDs, and (4) distribution
rr The method used to cal-cufate the system-coinci-dent and NCDs wasprovided in response to a data request provi-ded to Vote Sol-ar (Vote
Sol-ar Request No. 71b), can be found as Exhibit 15.
ASCHENBRENNER, REB ].4
Idaho Power Company
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costs increased because class NCDs are used to allocate
distribution costs. With multiple al-Iocation factors
moving in different directions, Dr. Morrison's statement of
what would have occurred had the Company prepared a ful-l-
class COSS cannot be verified.
0. Did the Company perform an additional analysis
of the SCD and NCD for residential- customers with on-site
generatj-on and for residential customers without on-site
generation?
10 A Yes
11 Company's analysls
provides the resufts of theMr. Ange1l
of the SCD and NCD for both groups in
of customers72 his rebuttal- testimony.re In summary, the SCDs
13 with on-site generation
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are lower from April through
customers without on-site generation
through March. The NCDs of
September
but hlgher
customers
than that of
from October15
I6 with on-site generation is hlgher than that of
for all L2 months ofL1 customers without on-site generation
the year.
O How does cost allocation highlight the need to
separate
service
these customers into a distinct class for cost of
purposes ?
A. As I previously discussed, demand-rel-ated
costs are al-l-ocated to customer classes utllizing a
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18 AngelI REB, p.74,11.10-17, p.15, ]1.1-75.
ASCHENBRENNER, REB 15
Idaho Power Company
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1 combi-nation of monthly system colncident demands and NCDs.
2 When anal-yzing these allocation factors for customers with
3 on-site generation, certain factors increased whil-e others
4 decreased, thus making j-t difficul-t to determine the net
5 impact to the cost determination for this group of
5 customers. Consequently, in predicting the results of a
7 new COSS, Dr. Morrison was limited to using phrases such as
8 " Ithe new study] would 1ike1y have allocated slightly less
9 generation and transmission plantr "le and "it is difflcul-t
10 to determine whether it would have all-ocated more or l-ess
11 distribution plant cost . ."2a Separating these
12 customers into their own cl-asses for cost al-l-ocation
13 purposes would aflow the Company, other interested parties,
1,4 and ul-timately the Commi-ssion to determine the actuaf cost
15 to serve customers with on-site generation.
16 IV. RATE DESIGTiI
71 u Why is it
different
necessary to have separate customer
79 on-site generation?
A. As describedzt20 by Mr. Ange11, a customer with
2L on-site generatlon is a "partj-al requirements" customer.
18 classes and a rate structure for customers with
1e Morrison DI, p
20 Morrison DI, p
21 Ange11 REB, p.
18, 11. 17-18.
19, rt-. 15-16.
3, l-. 18 through p. 4, 1. 15
ASCHENBRENNER, REB 16
Idaho Power Company
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O. What is a partial requirements customer?
A. A partial requirements customer generates al-]
or some of their own annual energy needs, while still
relying
services
on the utility for a variety of services. These
are described by Mr. Angell in his direct
testlmony.zz Partial requi-rements service is
give customers ffexibility i-n meeting some of
availabfe to
their energy
utilityneeds whil-e also providing the reassurance that the
is available to handle al-I their el-ectrical needs should
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inadequate
O.
require a
A.
to meet their
Why would a
different rate
be interrupted, fail-, or is
demand.
partial requirements customer
structure?
I4 Idaho Power's current consumption-based rates
15 were designed for R&SGS customers who require fulI
L6 requirements from the ut111ty. The
coflect costs in a bundled fashion
rates are designed to
L1 that includes recovery
1B of generation,
related costs
transmission, distribution and customer-
L9 primarily through a volumetric rate.
20 Current rate desiqns were not developed for a
2I partial requirements customer, such as a customer who
of thelr own electricity.22 generates aII or some
22 Angell DT, p. 4, I1. 6-11
ASCHENBRENNER, REB 17
Idaho Power Company
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O. Does the current rate structure for R&SGS
customers with on-site generation provide a reasonable
opportunity for the utility to recover from those customers
the costs of serving them?
A. No. A customer who installs on-site
generation does so with the intent to offset their own
usage and el-lminate the volume of energy they consume from
Idaho Power. Recovering fixed costs through a vol-umetric
rate simply does not work for this segment of customers.
O. Some parties23 suggest the flaws you describe
with the residential- pricing are inherent for all R&SGS
customers who reduce usage and the Company's filing is
discriminatory in that it singles out R&SGS customers with
on-site generation. How do you respond to that contention?
A. I disagree. The degree to which customers
76 with on-site generation have
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the opportunity to off-set
to all customers who reducetheir usage is
usage. Applying
some or al-l of
on the utility
inherent to all
not inherent.
vol-umetri-c rates to customers
their own electricity, and who
for aII of their energy needs,
customers who reduce usage.
who generate
do not rely
is afso not
22 The Company is proposing to establ-ish separate
23 customer classes for R&SGS customers with on-site
23 Kobor DI, p. 38, I. 22, p. 39, lI. 6-1,6; King DI, p. 11,1. 9;
Donohue DI, p. 13, fI. 72-74.
ASCHENBRENNER, REB 1B
Idaho Power Company
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generation because the load service requirements and usage
characteristics of R&SGS customers who install on-site
generation are different than that of R&SGS customers
without on-site generatj-on. Mr. Angell presents evidence
that demonstrates the load service requirements and usage
characteristics of R&SGS customers who install- on-site
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separate
Brattle Group in
11 empirical evidence that customers with on-site generation
12 differ significantly from that of the standard service
13 customer. zs
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15
generatlon are in
customers without
customer
o
A
fact di-fferent than that of R&SGS
on-site generation and therefore require
classes.zq Dr. Ahmid Faruqui of the
his Rebuttal Testimony also provides
Please summarize your rebuttal
76 The number of R&SGS customers
testimony.
choosing to
Ll install on-site generation continues to grow in Idaho
18 Power's service area. The Company believes that addressing
L9 the issue of separate cl-asses today is in the best interest
20 of customers in the long term. In this case, the Company
2L has demonstrated that the load service requirements and the
22 usage characteristics of R&SGS customers who install on-
2a Angel1 REB, p. 4, 1. 20 through p
p. 13, 1. 10, p. 14, 11. 10-17, p. 15, 11
p. 12, I. 6 through
ASCHENBRENNER, REB 19
Idaho Power Company
'7, l. 9,
7-15.
25 Faruqui REB, p. '7, l. 14. - p. 15, l-. 6.
1
2
3
4
5
6
7
d
9
site generation are different than that of R&SGS customers
without on-site generation. These differences justify the
need to establish separate rate classes to provide a
reasonable opportunity to recover the cost of service from
those customers.
0. What is your recommendation for the
Commission?
A. I
authorizing the
Production Net
11 R&SGS customers
closure of ScheduJ-e 84,
Metering Service, to new
with on-site generation,
Customer Energy
service for Idaho
and the
of customers
recommend that the Commission issue an order
10
12 establishment of two new classifications
13
74
15
76
71
1B
19
20
27
ZZ
ZJ
24
25
26
applicable to
o.
A.
R&SGS customers wlth on-sj-te generation.
Does this conclude your testimony?
Yes, it does.
ASCHENBRENNER, REB 2O
Idaho Power Company
1
2
3
4
5
6
7
I
9
ATTESTATION OF TESTIMONY
STATE OF IDAHO
SS.
County of Ada
Tt Connie G. Aschenbrenner, 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 Rate
Design Manager of Regulatory Affairs and am competent to be
a witness in this proceeding.
I declare under penalty of perjury of the laws of
the state of ldaho that the foregoing rebuttal testimony is
true and correct to the best of my information and belief.
DATED this 26th day of January, 2078.
?yu-t
Conn ie G.chenbrenner
SUBSCRIBED AND SWORN to before me this 26th day of
January, 20L8.
o
Ytr,N ary for Idaho
10
11
72
13
t4
15
t6
t1
18
t9
20
2t
ZZ
Z3
24
25
26
27
Residlng a I"!c
My commission ex res: /
l->/v/x
.f
ASCHENBRENNER, REB 21
Idaho Power Company
r-a(-
atralrO
$OTrteI
2B
OF ID
t l, ) i4 tar.l lt
..r ' 'r--t
-ts. -{\r, I:1 .\,1
;I
i,.rt.tnt*
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
GASE NO. IPC-E-17-13
IDAHO POWER COMPANY
ASCHENBRENNER, REB
TESTIMONY
EXHIBIT NO. 15
REQUEST NO. {7: Reference Aschenbrenner Exhibit 9 at 6 of 18.
(a) Please provide the methodology, assumptions, calculations, and
workpapers supporting the "estimated cost shift" as of the end of 2015 and as of the end
of 2016. Please provide all responsive calculations and workpapers in native, unlocked,
electronic format with formulas intact.
(b) Please describe the basis for, and how you calculated, that the 366
residential net metered customers were responsible for a total annual revenue
requirement of $464,266.67 and that the 566 residential net metered customers were
responsible for a total annual revenue requirement of $665,969.
RESPONSE TO REQUEST NO. {7:
(a) Please see Attachments 1 and 2 for the workpapers used to derive the
estimated cost shift in 2015 and 2016.
(b) To quantify the estimated cost shift occurring in 2015, the Company first
identified how many residential net metering customers had 12 months of billing data
during 2415 - this data set contained 366 customers. Using a methodology similar to
that used to assign costs during a general rate case, the Company estimated the ldaho-
jurisdictional revenue requirement for those 366 net metering customers and compared
that to the base rate revenue collected from those customers during 2015.
To determine the estimated residential net metering revenue requirement, the
Company started with the residential customer class's functionalized and classified
revenue requirement authorized in the Company's 2011 GRC. Other subsequent
increases/decreases to the residential class revenue requirement authorized by the
ldaho Public Utilities Commission since the 2011 GRC were added or subtracted to
quantify an "adjusted" residential class revenue requirement. From that class level
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
FIRST SET OF DATA REQUESTS TO TDAHO POWER COMPANY - 22
Exhibit No. 15
Case No. IPC-E-17-13
C. Aschenbrenner, IPC
Page 1 of2
revenue requirement, a functionalized and classified unit cost was determined, as
detailed in Column 12 of the "Annual NM Rev Req" tabs contained in Attachment 1.
The Company then utilized the residential net metering segment's Advanced
Metering lnfrastructure ("AMl") data to determine the segment's average monthly kWh
usage, system coincident demand, and non-coincident demand tor 2015. Demand at
the time of the monthly system peak (System Coincident kW) and the average energy
consumed by month (Average Monthly kwh) were determined based on the average of
each customer's positive consumption in every hour, or zero in the event that a
customer was a net producer of electricity in a given hour. Demand at the time of the
group non-coincident demand (Non-Coincident kW) was determined based on the
absolute value of the average usage in that hour.
Once the 2015 net metering usage was determined, these values were multiplied
by the per-unit costs listed in Column 12 to determine the estimated 2015 net metering
revenue requirement of $464,532, as detailed in Column 14 of Attachment 1.
The estimated revenue requirement was compared to the total base rate revenue
collected from those 366 customers to determine the estimated cost shift.
To quantify the estimated cost shift occurring in 2016, the Company first
identified how many residential net metering customers had 12 months of billing data
during 2016 - this data set contained 570 customers. Using the same methodology
described above, the Company updated its analysis with 2016 billing and AMI data to
determine the net metering customer segment's estimated functionalized and classified
revenue requirement of $665,969 and compared that to the total base rate revenue
collected from the 570 customers to determine the estimated cost shift.
The response to this Request is sponsored by Connie Aschenbrenner, Rate
Design Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
FIRST SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 23
Exhibit No. '15
Case No. IPC-E-17-13
C. Aschenbrenner, IPC
Page 2 of 2
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 26th day of January 2018 I served a true and
correct copy of REBUTTAL TESTIMONY OF CONNIE G. ASCHENBRENNER upon the
following named parties by the method indicated below, and addressed to the following:
Commission Staff
Sean Costello
Deputy Attorney General
ldaho Public Utilities Commission
472 West Washington (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
ldahydro
C. Tom Arkoosh
ARKOOSH LAW OFFICES
802 West Bannock Street, Suite 900
P.O. Box 2900
Boise, ldaho 83701
ldaho Gonseruation League
Matthew A. Nykiel
!daho 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, ldaho 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, Idaho 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 Club
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 Capitol Boulevard, Suite 701
P.O. Box 1308
Boise, ldaho 83701
Intermountain 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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