20180223Tatum Surrebuttal.pdf

AEffi*.
An IDACORP Company
LISA D. NORDSTROM
Lead Counsel
I [e-mail]
REOEIVED
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February 23,2018
VIA HAND DELIVERY
Diane Hanian, Secretary
ldaho Public Utilities Commission
472 West Washington Street
Boise, ldaho 83702
Re Case No. IPC-E-17-13
New Schedules for Residential and Small General Service Customers with
On-Site Generation
ldaho Power Company's Surrebuttal Testimony
Dear Ms. Hanian
Enclosed for filing in the above matter please find an original and eight (8) copies
each of the Surrebuttal Testimony of Timothy E. Tatum, the Surrebuttal Testimony of
Connie G. Aschenbrenner, and the SurrebuttalTestimony of David M. Angell. One copy of
each of the aforementioned testimonies has been designated as the "Reporter's Copy." ln
addition, a disk containing Word versions of the testimonies is enclosed for the Reporter.
lf you have any questions about the enclosed documents, please do not hesitate to
contact me.
Very truly yours,
Lisa
LDN:kkt
Enclosures
RECEIVED
20lB f[B 23 Pl{ Ir: l6
'tt t-t rn.- ,',r , .' i-ULILIrJI j* : l.i'tr.:i:i il,f fu{FJISSI0N
BEEORE THE IDAHO PUBLIC UT]L]T]ES COMMISSION
IN THE MATTER OE THE APPLICATION
OF IDAHO POWER COMPANY FOR
AUTHORITY TO ESTABL]SH NEW
SCHEDULES FOR RESIDENTIAL AND
SMALL GENERAL SERVICE CUSTOMERS
WITH ON-SITE GENERAT]ON.
CASE NO. ]PC-E-17_73
IDAHO POWER COMPANY
SURREBUTTAL TESTIMONY
OF
TIMOTHY E. TATUM
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O. Please
A. My name
O. Are you
previously presented
A. Yes.
0. What is
testimony?
respond
rebuttal
to
0
d
state your name.
is Timothy E. Tatum.
the same Timothy E. Tatum that
direct and rebuttal- testimony?
the purpose of your surrebuttal
The purpose of my surrebuttal testimony is to
recommendations by intervening parties in their
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. Please describe the reconrmendations made by11
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intervening parties in rebuttal testimony.
A. Several parties continue to recommend that the
Idaho Public Ut111ties Commission ("Commission") deny Idaho
Power Company's ("Idaho Power" or "Company") request to
establ-ish separate customer classes and address only how
customers with on-site generation are compensated for the
energy they export to the grid.1
O. What is your response to these
recommendations ?
A. The parties who filed rebuttal testj-mony raise
a number of important issues related to cost-of-service,
rate design, and compensation structure that the Company
1 Beach Rebuttal, p.
Kobor Rebuttal, p. 30, 1l
2, 11. 14-15; King Rebuttal, p. 10, 1I. 2-3;
9-13.
TATUM, SURR REB 1
Idaho Power Company
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agrees are worthy of investigation and further analysls;
however, it is not necessary to explore these issues prior
to making a decision regarding separate classes for
residential and smal-l- general service customers who install
on-site generation.
The fundamental disagreement in thls case appears to
be rel-ated to the sequence of steps that should be taken
and the timing of those steps. The parties are generally
aligned with the notion that more studies related to cost-
of-service, rate design, system-impact, and/or compensation
structures for net metering service are necessary prior to
deciding the need for separate rate classifications, dS
requested by the Company in this case. Contrary to those
vj-ews, the Company believes that it is important to first
establ-j-sh whether customers with on-site generation have
load characteristics that are fundamentally different than
fufl requirements customers, and therefore, warrant a
separate cl-assification for rate design purposes.
O. Why does the Company believe that establ-ishing
separate rate classifications for residential and small
general service customers with on-site generatlon is the
appropriate
A.
first step?
Throughout this case the Company
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23 has presented
install on-24 evldence that demonstrates that customers who
25 site generati-on tend to reduce the volume of energy
TATUM, SURR REB 2
Idaho Power Company
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required from Idaho Power without a corresponding reduction
in their utilization of the e1ectric system or grid. The
problem presented by the Company in this case is that the
current rate design, which col-l-ects the vast majority of
service costs (fixed and variabl-e) on a volumetric basis,
is no J-onger appropriate for a growing segment of customers
who are making investments in technologies that resul-t in a
reduction of the volume of energy they would otherwise take
from Idaho Power. The rate design applied to net metering
customers is outdated and unsustainable into the future.
Historically, the first step in the rate-making
process has been to establish different classifications of
customers based on the tj-me, nature, and pattern of use.2 A
cost-of-service study is then performed to determine proper
assignment of costs to each of the respective customer
cl-asses. Once the cost to serve each class of customers 1s
determined, the final- step is to determine the appropriate
rate design for each class. The Company j-s recommending
that this longstandlng ratemaking process be applied to
these circumstances.
o.Why does the Company feel it is
to understand the
unnecessary to
22 conduct the generic docket,benefits and
2 On page 7 of Order No. 26180, the Commission described cfass
differentiating characteristics identified in fdaho State Homebuil-dersv. Washington Water Power, 107 Idaho 415, 420, 690 P.2d 350, 355
(1984).
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TATUM,
Idaho
SURR
Power
REB 3
Company
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costs that dlstributed generation interconnecti-on brlngs to
the electric system, prior to a determination on rate
cl-assifications in the current case?
A The question at the center of this case is
whether customers with on-site generation are
different than ful-I requirements customers.
has presented evidence that the load service
residential- and
fundamentally
The Company
requ j-rements
smalI general
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and usage characteristics of
service customers who instal-]
substantially different than
general service customers
determination of customer
on the cost to serve those
on any benefits
provide to the
on-site generation are
that of residential- and small
without on-site generation. The
is not dependent
is it dependent
clas s i fication
customers, nor
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74 a customer's excess net energy exports may
15 system.
Please summarizeL6 how the Company's current
classes relates to the77 request for separate customer
18 Company's long-term plan for residential- and smal-I general
79 service customers with on-site generation.
20 A The Company has concl-uded that net metering
2L with volumetric rates is not sustainable, and in light of
establish22 that conclusion, has asked the Commission to
23 separate
customers
classes for residential- and small generaf servj-ce
with on-site generation and to initiate a
()
25 to explore the costs and benefits of serving those
process
clas ses
TATUM, SURR REB 4
Tdaho Power Company
1 of customers. If the Commlssion determines customers wlth
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on-site generation
the next step would
should be in a separate customer cJ-ass,
be
compensation structures
to investlgate pricing and
for those customers based on the
cost and benefits associated with serving those customers.
O. Does this concl-ude your testimony?
A. Yes, it does.
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TATUM, SURR REB 5
fdaho Power Company
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ATTESTATION OF TESTIMONY
STATE OF IDAHO
qq
County of Ada
I, Timothy E. Tatum, 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 Vice
President of Regulatory Affairs and am competent to be a
witness in this proceeding.
f declare under penalty of perjury of the laws of
the state of Idaho that the foregoing surrebuttal testimony
is true and correct to the best of my information and
belief.
DATED this 23'd day of February 2078.
Timothy E.atum
SUBSCRIBED AND SWORN to before me this 23'd day of
February 2018.
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K.To --K"*I;YL -6^u-tt
Notdry iu{)ic for Idaho
Residing 5t Boise, Idaho
My commission expires z 72/20/20
TATUM, SURR REB 6
Idaho Power Company
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itt lI
:o'
I HEREBY CERTIFY that on the 23rd day of February 2018 I served a true and
correct copy of SURREBUTTAL TESTIMONY OF TIMOTHY E. TATUM upon the
following named parties by the method indicated below, and addressed to the following:
Commission Staff
Sean Costello
Deputy Attorney General
Idaho Public Utilities Commission
47 2 W est Wash i ngton (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, Idaho 83864
Benjamin J. Otto
ldaho Conservation League
710 North 6th Street
Boise, Idaho 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 25Os
Lakewood, Ohio 44107
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CERTIFICATE OF SERVICE
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 1 1
Briana Kobor
Vote Solar
986 Princeton Avenue S
Salt Lake City, Utah 84105
Gity 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 Glean 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, ldaho Sierra Club
503 West Franklin Street
Boise, ldaho 83702
Michael Heckler
3606 North Prospect Way
Garden City, Idaho 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, Idaho 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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