20180223Aschenbrenner Surrebuttal.pdf

BEFORE THE IDAHO PUBLIC UTILITIES COMM]SSION
]N THE MATTER OE THE APPL]CATION
OE IDAHO POWER COMPANY FOR
AUTHORTTY TO ESTABLISH NEW
SCHEDULES FOR RESIDENTIAL AND
SMALL GENERAL SERVICE CUSTOMERS
W]TH ON-SITE GENERATION.
IDAHO POWER COMPANY
SURREBUTTAL TEST]MONY
OF
CONNIE G. ASCHENBRENNER
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CASE NO. IPC_E_17_13
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O. Please
A. My name
O. Are you
previously presented
A. Yes.
state your name.
is Connie G. Aschenbrenner.
the same Connie G. Aschenbrenner that
dlrect and rebuttal testimony?
o.
testimony?
A.
What is the purpose of your surrebuttal
My surrebuttaf testimony is intended to
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provide the Idaho Publ-ic Util-ities Commission
("Commission") with a final update on customer
participatlon in the Idaho Power Company's ("Idaho Power"
or "Company") net metering service and to provide
additional information to the Commission and parties in
response to certain statements made by partles in rebuttal
testimony. My testimony is comprised of two sections.
In Section I, I provide the Commission with an
update on customer participation in net metering service as
of January 31, 20L8.
In Section II, I respond to statements made by
parties related to rate design considerations regarding
customers' ability to access energy consumption data and
the capabilities of the Company's biJ-1ing system.
In Section III, I clarify the scope of the Company's
proposed modifications to Schedule 12.
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ASCHENBRENNER, SURR REB 1
Idaho Power Company
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the Company's
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on participatlon 1n
to experience rapid
growth in its net metering service since I l-ast reported
participation as of December 3L, 2077. The Company
received 95 applications during January 2078, making the
total number of active and pending systems 2,089 in Idaho
through January 31, 20L8.
Tabl-es 1 and 2 represent updated Idaho system counts
UPDATE ON NET METERING PARTICIPATION
Please provide an update
net metering service.
The Company has contj-nued
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and nameplate capacity.
Tab].e 1 Idaho Net Meter
Tab1e 2 Idaho Net Metering
Customers
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ate (in Mw)
ASCHENBRENNER, SURR REB 2
Idaho Power Company
C].ass Photovoltaic DIind Hydro/Other Tota].
Residential 7,81 4 qZ 6 1,922
Commerci-a1 &Industrial 745 5 4 154
I rrigat ion 72 1 13
Tota].2,03L 48 10 2,O89
C].ass Photovoltaic DIind Hydro/other Tota].
Res idential 72.896 0.189 0.061 L3.L46
Commercial &
Industrial 2.137 0.030 0.085 2.846
I rrigation 0.916 0.040 0.000 '0.956
Tota].16.543 0 .258 0.146 16. 948
1 The trend in number of submitted applications
2 demonstrates continued interest in net metering. The
3 number of applications submitted by month from 2016 to 20LB
4 are shown in Figure 1.
5 Figiure 1. Net Metering Applications Submitted by Month
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80
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0
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67 65 70
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36 3530 29 zs
8680
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"".o
..."..-. rA'." "t"" .."".- ."."""
r 2015 * 2017 2018
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A. Do you believe the "pending" appJ-ications
should be included in the reported system counts and
capacity?
A. Yes. In Idaho Power's experience, once an
application for a net metering system is submitted, that
system wiII generally come onl-ine within approximately five
months. Figure 2 shows, by month, the number of net
metering systems that have been energized between 2016 and
2078. The trend fol-l-ows the trend reported in Figure l;
however, it generally lags by a few months.
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ASCHENBRENNER, SURR REB 3
Idaho Power Company
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1 Figrrre 2. Net Metering Systems by Month of Operation
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80
60
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$"- ,"""
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ad.rC {e't '')- *-.":"-"T "".i"si""*'
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20t6 2017 2018
a. What has been the rate of growth in net
metering system counts and nameplate capacity since the
Company filed its 201,1 Net Metering Report?
A. In the 201-7 Net Metering Report, the Company
reported that as of March 31, 20L1, there were L,27 7 actj-ve
and pending net metering systems in Idaho. As of January
31, 2018, there are 2,089 actj-ve and pending systems in
Idaho. This represents a 64 percent increase in net
metering systems over a ten-month period.
As of March 31, 20!1, the total nameplate capacity
of active and pending systems was 9.58 megawatts ("MW") in
Idaho. The total nameplate capacity of active and pending
systems in Idaho was 16.95 MW as of January 31, 2018. This
represents a 17 percent increase in nameplate capacity over
a ten-month period.
ASCHENBRENNER, SURR REB 4
Idaho Power Company
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II. INTERVAL DATA E BILLING SYSTEM CAPABILITIES
a. In his rebuttal- testimony, witness Beach
suggests, "hourly data are not currently recorded or
provided to customers" and that "the meters are programmed
to record only monthly net usage.'/1 Mr. Beach goes on to
say: "The utility admits that it would have to re-program
its meters and revise its billing system in order to make
such data available."2 Are the assertions made by Mr. Beach
accurate ?
A. No.
O. Why not?
A. In addition to providing daily register reads,
Idaho Power's Automated Metering Infrastructure ("AMI")
meters record hourly kil-owatt-hour readings (sometimes
referred to as hourly interval data) and a 15-minute
maximum demand for the bill month. Because AMI meters are
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I7 instafled on approximately 99 percent of residential and
18 small- service (*R&SGS") customer accounts, the Company
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its R&SGS
collects hourly interval data for 99 percent of
20 customers those with on-site generation and
2L those without on-site generation.
22 0 Do customers have access to their hourly
23 interval data?
1 Beach Rebuttal-, p
2 Beach Rebuttal-, p
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ASCHENBRENNER, SURR REB 5
Idaho Power Company
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A. Yes. AIt customers with an AMI meter have
access to their hourly interval data on Idaho Power's
website via My Account, dD online resource. Customers must
sign up for My Account to view and manage their energy
consumption.
O. How much hlstorical data is available to
customers through My Account?
A. Customers currently
interval data for the most recent
have access to hourly
60 to 90 days.
access to historicalIf a customer requests10
hourly
Company
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interval
able to
data beyond
accommodate
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the 60 to 90 days, is the
that request?
13 A Yes. In fact, the Company already does this
14 upon customer request
15 O.If the Commission lmplemented Staff's proposal
76 for net hourly billi-ng, would the Company be able to
71 all R&SGS customers with historical hourly interval
1B
Yes. The Company would be able
provide
data?
79 A
20 more data than ls currently available on its
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Company's My Account application
make these modifications. Once
22 and woufd require t.ime to
those modifications have
ASCHENBRENNER, SURR REB 6
Idaho Power Company
modification
to provide
website;
to the
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25 customers who currently have, or who are considering an
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investment in on-slte generation, so long as an AMI meter
is installed at the service location
O.Would the Company be able to lmplement net
have an AMI meter?hourly bi-J-ling for
A. Yes;however, the Company would have to
replace any existing non-AMI meters with meters capable of
providing hourly interval data. In those instances,
historical hourly intervaf data would not be available for
the approximately 1 percent of customers who do not
currently have AMI meters.
O. Is the Company's billing system capable of
billing net metering customers on a net hourly basls?
A. Not as it is currently configured,' however, if
the billing structure for net metering customers required
that net metering customers be billed on a net hourly
basis, the Company estimates it would need approximately
one year to modify j-ts metering and billing systems in
order to bill net metering customers on a net hourly basis.
O. Is the Company's billing system capable of
billing net metering customers on time-of-use (*TOU")
rates ?
if
ten months to
ASCHENBRENNER, SURR REB 1
Idaho Power Company
customers who do not
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22 A. Not as it is currently configured,' however,
23 the billing structure for net metering customers required
l4 that net metering customers be billed on TOU
Company estimates it woufd need approximately
rates, the
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modify its systems j-n order to b111 net metering customers
on TOU rates.
O. What systems would need to be modified to
implement net hourly billing or TOU rates for net metering
customers ?
A. As stated above, the existing meters are
recording the information required to implement net hourly
billing or TOU; however, the meter data collection, meter
data validation, customer billing system, and the
integration between those systems would need to be modified
to implement either net hourly bil11ng or TOU rates for net
metering customers.
III. MODIFICATIONS TO SCHEDT'LE 72 ARE MIT{OR
O. Did any of the parties who fil-ed rebuttal
testimony agree with Commission Staff's suggest.ions that
the Company's proposed modification to Schedule 12 "are not
minor, and constitute a major revi-sion to Schedul-e J2"3 and
"the proposed modification to Schedule 12 includes a large
number of revisions that were not described in the
Company' s Application or testimony"?a
A. Yes. In his rebuttal testimony, Idaho Clean
Energy Association witness King notes his appreciation for
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II.
Morrison DI, p
Morrison DI, p
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ASCHENBRENNER, SURR REB B
Idaho Power Company
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Commi-ssion Staff's recognition that "the changes to
Schedule 72 are more significant than represented by Idaho
Power in its application" and are "outside the scope of
this docket. "s
O. Would you please clarify what modifications
the Company has proposed to Schedule 12?
A. The modifications proposed by the Company are
to (1) add reference to the newly proposed Schedules 6 and
B, referred to as "Smaff On-site Generatiotr" and (2) add
the words "barring conditions beyond the Company's control-"
to the inspection process to a1low the Company additional-
tj-me to complete the on-site inspection of a newly
install-ed on-sj-te generation system when circumstances
beyond the Company's control arise.
O. How do you respond to Dr. Morrison's
suggestion that there are "a large number of revisions that
were not described in the Company's Application or
testimony?"e
A. I disagree with Dr.
characterization. The changes to
very minor. I can see that at a
Morrison's
Schedule 12 are in fact
glance, it may
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22 there are addltlonal and substantial revisions;
appear that
however,
23 most of the revlsions shown in "mark-up" form are due to
s King Rebuttal, p
6 Dr. Morrison DI,
o 't .t o_'T nU, II. U aV.
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ASCHENBRENNER, SURR REB 9
Idaho Power Company
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formatting changes. These formatting changes resul-t when
the page break occurs in a dlfferent Iocation and causes
the text to be moved from one page to the next.
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o.
Schedule 72
A.
Schedules 6
relevant to
approved.
Schedules 6
referenced.
The
Do you believe that the proposed changes to
this docket?are outside the scope of
No. Adding reference to the newly proposed
and B is in fact very much necessary and
this case if the proposed new schedules are
The proposed changes accommodate the addition of
and B where previously only Schedule 84 was
other revisi-on, to all-ow the Company additional
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time to complete the on-site inspection of a newly
instal-Ied on-site generation system when circumstances
beyond the Company's control arise, is very mj-nor. The
need for thi-s flexibility became evident during the 2076-
20L7 wj-nter which brought heavy snows and icy conditions
throughout the Company's service area.
O. Did the Company share with instal-l-ers and
Commission Staff that the Company was considerlng a
modification to Schedul-e 12 that would allow the Company
additional- time to complete the on-sj-te inspection of a
newly installed on-site generation system when
circumstances beyond the Company's control- arise?
A. Yes.
ASCHENBRENNER, SURR REB 1O
Idaho Power Company
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O. Did anyone express concern with this
modification?
A. No.
O. Are any of the proposed changes to Schedule 12
related to the Company's request for the Commission to
acknowledge
is necessary
reliability
request ?
A.
0
A
that smart inverters provide functionality that
to support the ongoing stability and
of the distribution system smart inverter
10 No. In this case, the Company requested that
the Company to submit a compliance
a tariff advice within 60 days of the
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12 filing in the form of
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adoptj-on of the revised fnstitute of Electrical and
Electronic Engineers standards, or 60 days of the
conclusion of this case (whichever occurs later) if it
agrees that smart inverters provide functionality that 1s
necessary to support the ongoing stability and reliability
of the distribution system.
IV. CONCLUSION
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20 Please summarize your surrebuttal testimony.
2t The continued pace at which R&SGS customers
22 are instal-l-ing on-site generation underscores the
23 importance of addresslng the Company's net metering service
24 now.
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ASCHENBRENNER, SURR REB 11
Idaho Power Company
1 Idaho Power's AMI meters currently collect both
2 hourly interval data and daily register reads for 99
3 percent of its R&SGS customers. Further, customers
4 currently have access to this hourly intervaf data on Idaho
5 Power's website via the My Account application.
6 While the Company's billing system is not currently
7 configured to bil-l- R&SGS net metering customers on a TOU or
8 net hourly basis, TOU or net hourly billing for R&SGS
9 customers with on-site generation can be accomplished in
10 approximately one year.
11 The proposed changes to Schedule 72 are relevant to
L2 this case, and while the modifications may appear to be
13 substantial, they are in fact very mj-nor.
14 O. Does this conclude your testimony?
15 A. Yes, it does.
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ASCHENBRENNER, SURR REB 12
Idaho Power Company
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ATTESTATION OE TESTIMONY
STATE OE IDAHO
SS.
County of Ada
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I, 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 l-aws of
the state of Idaho that the foregoing surrebuttal testimony
is true and correct to the best of my information and
belief.
DATED this 23rd day of Eebruary, 20L8.
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Connie G. Aschenbrenner
SUBSCRIBED AND SWORN to before me this 23'd day of
February, 2018.ZU
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Y(.o Lr<-u
No ry Pub or ldaho
Residing a Bolse, Idaho
My commission expiresz 72/20/20
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ASCHENBRENNER, SURR REB 13
Idaho Power Company
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aututc-a-
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OF ID
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CERTIFIGATE OF SERVICE
I HEREBY CERTIFY that on the 23rd day of February 2018 I served a true and
correct copy of SURREBUTTAL 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 Conservation 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
Idaho 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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x Email sean.costello@puc. idaho.qov
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erin. cecil@arkoosh. com
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X Email mnvkiel@idahoconservation.o rg
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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 1 1
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, !daho 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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den@o ive nspu rsley. com
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x Email prestoncarter@qivenspu rsley.com
den@q ive nspu rslev. com
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Tom Beach
Crossborder Energy
2560 9th Street, Suite 213A
Berkeley,CA 94710
Zack Waterman
Director, ldaho 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
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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wwi lson @snakeriverall iance orq
[e-mail]
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rly ll, Executive Assistant