20171027Joinder in Motion to Dismiss.pdf

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Preston N. Carter (ISB No. 8a62)
Deborah E. Nelson (ISB No. 5711)
Givens Pursley LLP
601 W. Bannock St.
Boise,lD 83702
Telephone: [phone]
Facsimile: (208) 388-l 300
prestoncarter@ givenspursley.com
den@ givenspursley. com
13946-344_5.doq u19l5-21
Attorneys for Auric Solar, LLC
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR
AUTHORITY TO ESTABLISH NEW
SCHEDULES FOR RESIDENTIAL AND
SMALL GENERAL SERVICE
CUSTOMERS WITH ON-SITE
GENERATION
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
Case No. IPC-B-17-13
Aunrc SoLAR, LLC's JomoeR eNo
MpuoRaNouv rN SuppoRr or Io*ro
CI-gaN ENgRcy AssocnrloN,S MoTIoN
ro Drsvrrss
Auric Solar, LLC ("Auric Solar") files this Joinder and Memorandum in Support of
Idaho Clean Energy Association's ("ICEA") Motion to Dismiss (filed October 27,2017) under
IDAPA 3 1.01.01.256.04.
Auric Solar fully joins ICEA's Motion to Dismiss and ICEA's Memorandum in Support.
It files separately to present its unique interests as a business that would be greatly impacted by
the changes proposed in Idaho Power's pending application ("Application").
BACKGROUND
As ICEA describes, in November 2012Idaho Power sought to establish a separate class
for net metering customers. ,See Order No. 32846 at I -3 (describing the 2012 application). After
AURIC SoLAR, LLC's JoINDER AND MEMO IN Supponr or ICEA'S MoTIoN To DIsuIss - I
technical hearing and public testimony, the Commission rejected Idaho Power's request. In
relevant part, the Commission:
I ) Instructed Idaho Power that, if it wished to establish a separate customer class for
distributed energy generation, "it should do so in the context ofa general rate
case." Order No. 32846 at 9.
2) Advised Idaho Power "that it would enhance consideration of future major
program-specific changes if [Idaho Power] informed and obtained feedback from
its customers and other stakeholders" before filing an application. Id. at 5.
3) Refused to move net metering customers into a separate rate class because, among
other things, the Company's proposal was "inconsistent with State policy as
expressed in the Idaho Energy Plan" and because a separate rate class would
"discourage investment in distributed generation ." Id. at 9.
Idaho Power filed the pending Application in July 2017.The Application asks the
Commission to do what the Commission refused to do in 2013: establish a new schedule for
residential and small general service customers with on-site generation. Application at 6-7.1
Auric Solar respectfully submits that the Commission meant what it said in Order No.
32846.If Idaho Power would like to create a separate customer class, it must do so in the context
of a general rate case and only after meaningfully obtaining and considering feedback from its
customers and other stakeholders. The Application does not meet these conditions and should be
dismissed.
What's more, the current Application suffers the same flaws the Commission identified
in 20 I 3 . Idaho Power's request to create a separate customer class is still inconsistent with the
Idaho Energy Plan. Creating a separate class-particularly creating a class without indicating
how that class will be treotecl in the funre-still injects uncertainty into the market, disrupting
I The Application also requests that the Commission require smart inverters within 60 days after the IEEE publishes
an industry standard definition. Application at2.The issue ofsmart inverters can proceed separately from the issue
of rate classes.
AURIC SoLAR, LLC'S JoINDER AND MEMO II.I SuppoRr oF ICEA'S MoTIoN ro DIsn,lIss - 2
businesses and discouraging investment in distributed energy generation. The Application should
be dismissed for these reasons as well.
This is not to say that Auric Solar wants the Commission to avoid addressing the unique
benefits and costs created by distributed energy generation. Auric Solar recognizes, as the
Commission did in Order No. 32846, that distributed generation poses issues that ought be
addressed. By seeking dismissal of this Application, Auric Solar asks only that the benefits and
costs of distributed generation be addressed in an appropriate proceeding consistent with the
Commission's orders. If the Commission is not inclined to dismiss the case, Auric Solar requests
that the Commission order the parties to enter discussions with the goal of establishing a study or
other process similar to that conducted in Case No. IPC E-14-18. The results of this study may
then be used in a general rate case that meets the conditions set forth in Order No. 32846. Auric
Solar is open to working with the other parties, including Idaho Power, to agree upon an
appropriate procedure.
ARGUMENT
1. The Application does not meet the terms of Order No. 32846.
In2012,Idaho Power requested, among other things, that the Commission establish a
separate class for customers with on-site generation. The Commission refused, laying out the
steps Idaho Power must take to raise the issue a second time:
If the Company wishes to raise these issues again, then it should do
so in the context of a general rate case. We agree with the
Company that net metering customers do escape apportion of the
fixed costs and shift the cost burden to other customers in their class.
However, we find that more work needs to be done to establish the
correct customer charge for those that net meter.
Order No. 32846 at 9 (emphasis added)
AuRrc SolaR, LLC's JorNoe R AND MEMo IN SuppoRr op ICEA's MorroN ro Dtsvtss - 3
The Application does not comply with the Commission's instructions. The Application
seeks to establish a separate customer class, yet is not brought as a general rate case. The current
Application facially violates Order No. 32846.
The Commission also recognized that "more work need[ed] to be done to establish the
correct customer charges for those that net meter." Id.Idaho Power's Application and discovery
responses make clear that this work has not been done. For example, Idaho Power's Application
states that a separate customer class "will positon the Company to study [net metering]
customers, providing the data necessary to understand how this customer segment utilizes this
system." Application at 9. Yet Idaho Power admits that it can already study net metering
customers: "The Company is currently able to gather the information that is necessary to study
various segments of customers . ." Idaho Power Company's Response to the First Production
Request of the Commission Staff at 5-6 (emphasis added), attached as Exhibit l. The Company
just doesn't want to until the Commission creates a separate class: "[S]hould the Commission
decline to authorize the establishment of the requested new customer classes, the Company
would have no reason to modify its cost-of-service study or ratemaking processes." ld.
In other words, Idaho Power does not want to undertake the "work need[ed]" to establish
customer charges until after the Commission establishes a new customer class. Idaho Power
wants to "separate first, study later." This approach is contrary to the Commission's directions in
Order No. 32846.
In addition, in 2013 the Commission noted that input from the public was thoughtful,
thorough, and overwhelmingly opposed to Idaho Power's Application. Id. at 4. In light of public
opposition, the Commission directed Idaho Power:
[W]e advise the Company that it would enhance consideration of
future major program-specific changes if it informed and obtained
AURIC SoLAR, LLC'S JoINDER AND MEMo IN SUPP0RT oF ICEA'S MoTIoN To DIsvIIss - 4
Id. at 4.
The current Application does not meet this requirement. While Idaho Power held a
workshop in 2016 and two meetings in 2017 , these meetings were intended to announce Idaho
Power's intent and solicit feedback from attendees, not to tailor the proposal in light of public
input. Aschenbrenner Testimony at 15-24.It is not apparent from the Application that Idaho
Power actually took this feedback into account. A review of public comments filed in this
proceeding reveals the same "overwhelming opposition" that concerned the Commission in
2013. Auric Solar submits that Idaho Power must do more than go through the motions. It has to
meaningfully consider public input and shape its application accordingly. The Company has not
done so here.
In short, Idaho Power's Application seeks approval of what the Commission rejected in
2013: creation of a separate customer class "in isolation," without "full[] vet[ing]" in a general
rate case, without undertaking the work needed to establish correct customer charges, in the face
of overwhelming public opposition, without having meaningfully considered public input. Idaho
Power's Application does not meet the letter or the spirit of Order No. 32846. It should be
dismissed.
2, The Application is inconsistent with State policy and will unduly discourage
investment in distributed energy generation.
In Order No. 32846, the Commission provided several substantive reasons for rejecting
Idaho Power's request to create a separate customer class: among other things, the proposal was
"inconsistent with State policy as expressed in the Idaho Energy Plan" and "would discourage
investment in distributed generation." Order No. 32846 at 9.
AURIC SoLAR, LLC'S JoINDER AND M EMO IN SuppORT oT ICEA'S MOTION T o DIsuIss - 5
feedback from its customers and others stakeholders before
proposing them.
The current Application suffers these same flaws. The Idaho Energy Plan contains the
same language as in 2013, urging the Idaho PUC to "ensure non-discriminatory policies for
interconnection and net metering." Order No. 32846 at 6 (quoting Idaho 2012 State Energy
Plan). Idaho Power does not demonstrate how its current Application complies with the State
Energy Plan any more than its2012 application (which did not).
Creating a separate customer class will also discourage investment in distributed
generation. Particularly troubling is Idaho Power's request to create a separate class without
indicating how that class will be treated. This injects extreme uncertainty into the market, which
in turns threatens to cast a pall over the entire industry. As one member of the public aptly
summarized:
This case creates not just short-term limbo during the proceedings,
an approval of a separate rate class would create a long-term limbo
that will delay and unduly influence investment decisions in on-site
generation.
Approving Idaho Power (IPC)'s request for a separate rate class
would send a message that the rate structure for customers with
on-site generation will fundamentally change, but nobody has
any idea what to plug in as an assumption.
I am thankful that my small business is not vulnerable to this type
of disruption by a monopoly; if my customer base went on hold
while waiting for the promise of future regulation change down the
road, I wouldn't be able to cover staff and overhead while waiting.
IPC has far more oppornrnity to recover its fixed costs than we small
businesses do.
Comment of Steve White, Oct.24,2017, attached as Exhibit 2 (emphasis in original)
Rooftop solar and other distributed energy systems require significant, up-front costs that
are refurned over time. Auric Solar's business is driven by customers' evaluation of the up-front
AuRIC SoIen, LLC.S JoINoe n AND MEMO IN SUPPORTOF ICEA'S MOTION rO DISnaISS - 6
cost versus long-term retums. As Mr. White's comment accurately states, a customer cannot
engage in an informed cost-benefit analysis if that customer knows it will be treated differently
in the future, but does not know how the customer will be treated. If Idaho Power's proposal is
accepted, Auric Solar's potential customers will be placed in an untenable position of incurring a
known, substantial, up-front cost without knowing the long-term retum. An economically
rational customer will not purchase a distributed energy system under these circumstances.
Auric Solar submits that this type of uncertainty and business disruption falls squarely
within the Commission's concern about discouraging investment in distributed energy resources.
Auric Solar urges the Commission to prevent this disruption by dismissing Idaho Power's
pending Application and ordering, as it did in 2013,that any future application be carried out in a
general rate case or other proceeding that will fully evaluate the costs and benefits of distributed
energy generation, and that will provide certainty after it is over.
ALTERNATIVE RBLIEF
Auric Solar recognizes, as the Commission did in Order No. 32846, that distributed
energy generation creates unique benefits to, and burdens on, the electrical system. Auric Solar's
attempt to dismiss this case is not an attempt to avoid these issues. Auric Solar merely requests
that the issues be addressed in the appropriate context, with the appropriate facts, and in a
manner that is not unduly disruptive to it and other businesses.
If the Commission is not inclined to dismiss the case, Auric Solar respectfully requests
that the Commission order a process by which Idaho Power and the affected parties conduct a
study or other proceeding that considers the costs and benefits ofdistributed energy generation.
This process can be similar to that used in the solar integration case, Case No. IPC E-14-18,
attached to ICEA's Motion to Dismiss. The results of any such process may then be used in a
general rate case, consistent with Order No. 32846. Auric Solar therefore respectfully requests,
AURIC SoLAR, LLC'S JOINDER AND MEMO IN SUPPORT.OF ICEA'S MOTIoN To DISTIISs - 7
as an alternative to dismissal, that the Commission order the parties to come together to discuss a
timeline, methodology, source of inputs, and technical group to study the costs and benefits of
net metering and on-site generation, with the results to inform an eventual general rate case.
Dated: October 27,2017 .
GIVENS PURSLEY LLP
r)
*..*:*
Preston N. Carter
Givens Pursley LLP
Attorneys for Auric Solar, LLC
AURIC SoLAR, LLC'S JOINNEN AND MEMO IN SUPPONT Or ICEA'S MOTION rO DISNaISS - 8
CERTIFICATE OF SERVICE
I certify that on October 27,2017, a true and correct copy of the AuRrc SoLaR, LLC's
JorNorcR lNo Memo rN SuppoRr or ICEA's MorIoN ro Drsnrss was served upon all parties
of record in this proceeding via the manner indicated below:
Commission Staff
Diane Hanian, Commission Secretary
Idaho Public Utilities Commission
472 W . Washington Street
Boise, ID 83702
Diane. ho lt(0puc. idaho. eov
(Original and 7 copies provided)
Sean Costello, Deputy Attorney General
Idaho Public Utilities Commission
472W. Washington Street (83702)
P.O. Box 83720
Boise, lD 83720-0074
[e-mail]. sov
Electronic Mail
Lisa D. Nordstrom
Idaho Power Company
1221 West Idaho Street(83702)
P.O. Box 70
Boise, ID 83707
lnordstrom@ idahopower. com
dockets@idahopower. com
Matthew A. Nykiel
Benjamin J. Otto
Idaho Conservation League
P.O. Box 2308
102 E. Eluclid, #207
Sandpoint, ID 83864
m nyk i el(Oi dahoconservation. o rg
botto(D idahoconservation.org
Briana Kobor
Vote Solar
360 22"d Street, Suite 730
Oakland, CA94612
briana(Ovoteso I ar. or g
Hand Delivery & Electronic Mail
Electronic Mail
Timothy E. Tatum
Connie Aschenbrenner
Idaho Power Company
1221 West Idaho Street(83702)
P.O. Box 70
Boise, ID 83707
[e-mail]
caschenbrenner(Oidahopower. com
Abigail R. Germaine
Boise City Attomey's Office
150 N. Capitol Blvd.
P.O. Box 500
Boise, ID 83701-0500
aeerma i nefiDc i tyo fbo ise. org
Vote Solar
c/o David Bender
Earthjustice
3916 Nakoma Road
Madison, WI 53711
db ender(rD earthj u sti c e. or g
AURIC SoLAR, LLC'S JoINoe n AND MEMo IN St,rppOnr.OF ICEA'S MoTIoN rO DISn,{ISS - 9
Electronic Mail (continued)
Idaho Irrigation Pumpers Association, Inc.
c/o Eric L. Olsen
Echo Hawk & Olsen, PLLC
505 Pershing Ave., Suite 100
P.O. Box 6119
Pocatello, ID 83205
elo@,echohawk.cqnq
Elias Bishop
Auric Solar,LLC
2310 s. 1300 w.
West Valley city, UT 841l9
Elias.bishop@ auricsolar. com
Idaho Clean Energy Association
c/o David H. Arkoosh
Law Office of David Arkoosh
P.O. Box 2817
Boise, ID 83701
dav id@arkoo shlarv- pqm
Zack Waterman
Idaho Sierra Club
503 W. Franklin Street
Boise, ID 83702
Za ch. w aterman (d s i errac lub. o r g
Snake River Alliance NW Energy Coalition
c/o John R. Hammond Jr.
Fisher Pusch LLP
l0l South Capital Blvd., Suite 701
Boise, ID 83702
[e-mail]
Anthony Yankel
12700 Lake Avenue, Unit 2505
Lakewood, OH44107
tony(rDyankel.net
Idahydro and Idaho Clean Energy Association
clo C. Tom Arkoosh
Arkoosh Law Offices
802 W. Bannock Street, Suite 900
P.O. Box 2900
Boise,ID 83701
[e-mail]
Erin .com
Sierra Club
c/o Kelsey Jae Nunez
Kelsey Jae Nunez LLC
920 N. Clover Drive
Boise,ID 83703
kelsey@kelseyj aenunez. com
Michael Heckler
3606 N. Prospect Way
Garden City, ID 83714
Michael.p.heckl er(@ gmail. com
Snake River Alliance
wwilson@ snakeriveralliance. org
NW Energy Coalition
diego(r?nwenergy.org
AURIC SOLAR, LLC'S JOINDER AND MEMO IN SuppoRr oF ICEA'S MoTIoN ro DIsvIss - IO
Electronic Mail (Continued)
Intermountain Wind and Solar, LLC
c/o Ryan B. Frazier
Brian W. Burnett
Kirton McConkie
50 East South Temple, Suite 400
P.O. Bo 45120
Salt Lake city, UT 841I I
[e-mail]
[e-mail]
Intermountain Wind and Solar, LLC
c/o Doug Shipley
Dale Crawford
1952 West 2425 South
Woods Cross, UT 84087
do u e(a i mwi ndandso I ar. com
[e-mail]
/ *_-*-; d/_r>_
Preston N. Carter
AuRIc SoIeR, LLC'S JOINDER AND MEMo IN SUPP0RT oF ICEA'S MoTIoN r.o DIsv|ss - I 1
trlXhtl T
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LISA D. NORDSTROM (lSB No. 5733)
ldaho Power Company
1221 West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
lnordstrom(Oidahopower. cqm
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES 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'S
RESPONSE TO VOTE SOLAR'S
FIRST SET OF DATA REQUESTS
TO IDAHO POWER COMPANY
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COMES NOW, ldaho Power Company ("ldaho Power" or "Company"), and in
response to Vote Solar's First Set of Data Requests to ldaho Power Company dated
September 27 ,2017, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
FIRST SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 1
1
i
tsEOUEST,.lrl0. {: Please produce your responses to all discovery requests
served on you by any other party and your responses to each such request.
RESPONSE TO REQUEST NO. 1: To date, the only discovery propounded in
this case is the ldaho Public Utilities Commission ("Commission") Staffs First
Production Request to ldaho Power which was provided to all parties on October 11,
2017. As a matter of course, copies of ldaho Power's responses to discovery requests
in this case will be provided to the parties.
The response to this Request is sponsored by Kimberly Towell, Executive
Assistant, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
FIRST SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 2
REQUEST N0. 2: Reference Application, page 4, paragraph 4. Please describe
and quantify an on-site generation customer's "respective share for... grid-related
services," including but not limited to how the "respective share" relates to the
customer's actual contribution to class loads used to allocate costs in a cost-of-service-
study.
RESPOI_ISE TO REQUEST NO. 2: The context of the statement referenced on
page 4, paragraph 4, was how the existing retail rate designs currently applicable to
residential and small general service net metering customers were structured to collect
the costs associated with the grid under the assumption that customers would only need
one-way services provided solely by the utility. ln his testimony, Mr. Tatum describes
that this pricing structure does not work for customers with on-site generation because
when the existing rate structure is applied against monthly net consumption, customers
with on-site generation may pay less than their share of grid-related services they
require while receiving credit for their respective kilowatt-hour ('kWh") of production at
the full retail rate.
Please see the response to Vote Solar's Data Request No. 17 for the
quantification of the estimated revenue requirement for the residential net metering
customer segments.
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 - 3
I
l
:
REQUEST NO. 3: Reference Application, page 5, paragraph 7. Please provide
all analyses showing, confirming, or in any way supporting your assertion that net
metering service acts as a regressive wealth transfer from lower-income to higher-
income customers in your service territory, including your definitions of "lower-income"
and "higher-income" as used in this paragraph, and all income data for the residential
customers taking service under Schedule 84, Customer Energy Production Net
Metering, that you relied on to make the assertion regarding the transfer of wealth from
lower-income to higher-income customers.
RESPONSE TO REQUE$T NO. 3: ldaho Power does not gather income
information for its customers and has not performed an analysis according to income
level. The discussion on page 5, paragraph 7, of the Application was a reference to Mr.
Tatum's testimony. ln his testimony, Mr. Tatum referenced an October 2016 Public
Utilities Fortnightly article when he stated that others in the industry have concluded that
the net metering policy is regressive in nature and that the subsidy from non-solar to
solar customers constitutes a regressive wealth transfer from lower-income customers
to higher-income customers. Mr. Taturn expressed that ldaho Power shares this
concern
The response to this Request is sponsored by Tim Tatum, Vice President of
Regulatory Affairs, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
FIRST SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 4
t
REQUEST NO. 4: Please identify, by date, time and substation, each instance
when customer-sited distributed generation connected to your distribution system
caused a backflow at a distribution substation.
RESPONSE TO REQUEST NO. 4: Jamieson circuit 012 experiences reverse
power flow due to customer-sited distributed generation. ldaho Power has consistent
measurement history since May 16, 2017, on this distribution circuit. Since that date,
there have been 84 instances where the reverse power flow condition has occurred.
See Attachment 1 for the date and time when reverse power flow has occurred.
Additionally, there are seven substations where customer-sited distributed
generation has contributed to reverse power flow conditions. These stations have both
customer-sited distributed generation and Public Utility Regulatory Policies Act of 1978
("PURPA") contracted distributed energy resources ("DER"). Table 1 below provides
the PURPA DER in-service date and number of customers with on-site generation. The
dates and times of reverse power flow are shown in Attachment 2.
Table 1 - PURPA DER ln-service Dates
Substation PURPA DER
ln-service Date
Customers with
On-Site Generation
CARO Feb 10, 2017 4
OCHD Feb 11,2017 6
MORA Feb 8,2017 12
SCSU Apr 5,2017 1
CACK Jan 19,2017 1
NYSA Feb 20,2017 7
VALE Nov 1, 2016 5
The response to this Request is sponsored by David M. Angell, Transmission
and Distribution Planning Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
FIRST SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 5
REQUEST NO. 5: Reference Angell Direct at 11-13.
(a) Please confirm that the negative loads for the "Net Zero Net Metering
Customer" flow to, and serve the load of, another customer on the distribution system,
(b) Please confirm that by serving the load of another customer on the
distribution system, the "Net Zero Net Metering Customer" negative loads reduce the
cumulative load placed on the distribution substations and all equipment upstream of
the substation, including the substation distribution transformers, the transmission
system, and generation.
(c) Please confirm that (i) the "Exported Net Excess" energy depicted in
Figure 2 represents electricity that is delivered to another customer and is, therefore,
also contained in that customer's delivered load for the same "Hour Ending" and (ii)
some or all of the kW depicted as "Exported Net Excess" in Figure 2 is also contained in
the kW depicted as load for the "Standard Service" customer.
RFSPONS-E TO REQUEST NO. 5:
(a) Not necessarily. While it could be true in many instances, there are times
when the excess energy will flow to the transmission system. The flow to the
transmission system will occur when large amounts of distributed generation is present
on the distribution circuit.
(b) No. The "Net Zero Net Metering Customer" will reduce the instantaneous
load of the distribution substation and the equipment upstream when the customer is
producing power. However, it does not mean that the distribution substation and
upstream equipment will experience a reduced peak load. The peak load will only be
reduced if there is a coincidence of customer power production and load on the
d istribution substation.
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
FIRST SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 6
(c)
i. Not necessarily. The "Exported Net Excess" energy represents the
amount of energy the "Net Zero Metering Customer' is injecting back into the
distribution system and it is independent of another customer's load. The total
"Exported Net Excess" energy of customers and other distributed resources may
be sold in the wholesale market during conditions where this generation when
combined with ldaho Power's minimum required generation level for reliable
operation exceeds ldaho Power's system load.
ii. No. Figure 2 only refers to the amount of energy the "Net Zero
Metering Customer" is injecting back into the distribution system compared to the
load used by a Standard Service customer at the same time. The two customers
are nearby each other, however, it does not represent that some or all the
"Exported Net Excess' energy is consumed by that customer.
The response to this Request is sponsored by David M. Angell, Transmission
and Distribution Planning Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
FIRST SET OF DATA REQUESTS TO IDAHO POWER COMPANY. T
REQUE$T.NO.6: Reference Angell Direct at 12 lines 9-10. Please confirm that:
(1) "daily absolute demand requirements of the two customers are similar" refers to the
individual customer's maximum daily peak, not to the demand during the system peak
hour; and (2) that the "Net Zero Net Metering Customer" had a lower demand during the
system peak hour on June 29,2016, than the "Standard Service Residential Customer".
RESP9,NSE,"rQ REQUESr,,N9. 6:
(1) No. The daily absolute demand requirements refers to the mathematical
absolute value of the hour demands of the two customers.
(2) Yes, the "Net Zero Net Metering" Customer had a lower demand during
the system coincident peak hour.
The response to this Request is sponsored by David M. Angell, Transmission
and Distribution Planning Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
FIRST SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 8
REQUEST NO. 7: Reference Angell Direct page 15, line 5 to page 18, line 2 and
Exhibit 14.
(a) Please provide the date and hour of the Company's system peak during
each of the last ten (10) years.
(b) For each of the date and hours of system peak for the last ten (10) years,
provide the solar irradiance in "Standardized Units" and the "Load - lrradiance" in
"Standardized Units" similar to that used in Figures 3 and 4.
(c) Provide the date and hour of peak load, and the load, during the last five
(5) years for each distribution substation in your system that serves residential and
small general service ("R&SGS') customers.
RESPONSE TO REQUEST NO. 7:
(a) ldaho Power System peak is provided in Table 1 below. The time
represents the end of hour at which it was measured.
Table
Year
2007
2008
2009
2o1o
2011
2012
2013
2014
2015
2016
2017
I - ldaho Power: Date
Jul 13 4:00 pm
Jun 30 3:00 pm
Jul22 8:00 pm
Jun 28 7:00 pm
Jul 6 8:00 pm
Jul12 4:00 pm
Jul 2 4:00 pm
Jul B 6:00 pm
Jun 30 4:00 pm
Jun 28 7:00 pm
Jul 7 5:00 pm
System Peak
Peak (MW) I
3,193
3,414
3,031
2,930
2,973
3,245
9,407
3,184
3,402
3,299
3,422
:
!
I
:
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
FIRST SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 9
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(b) Figures 3 and 4 were created by comparing the load of a specific feeder
with the solar irradiance measured close to the feeder head by a specific sensor
recently installed by ldaho Power for the study that was attached as Exhibit No. 14 to
Mr. Angell's testimony. The study only gathered data for the summer of 2013.
lrradiance data from the sensor is not available outside the summer o12013 timeframe.
The same study cannot be completed for a system peak since the service territory of
ldaho Power extends from Eastern Oregon to Eastern ldaho and the load - irradiance
relationship will be meaningless.
(c) ldaho Power measures and maintains load data of for each substation
transformer. Please see the Attachment for the substation transformer peak load,
dates, and times.
The response to this Request is sponsored by David M. Angell, Transmission
and Distribution Planning Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
FIRST SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 1O
REQUESf NO. 8: Reference Angell Direct, page 19, lines 4-7. Please produce
the lntegrated Resource Plan analysis for on-site generation additions for the service
areas for the most recent three (3) lntegrated Resource Plans.
RESPONSE TO REQUEST NO. 8: The 2017 lntegrated Resource Plan ("lRP')
is the only IRP that includes an analysis of on-site generation. A description of how the
on-site generation is incorporated in the load forecast is located on pages 35 and 36 of
the 2017 IRP Appendix A: Sales and Load Forecast. Page 20 of the Attachment, the
IRP Advisory Committee Economy, Sales and Load Forecast presentation, provides
additional information on this analysis.
The response to this Request is sponsored by David M. Angell, Transmission
and Distribution Planning Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
FIRST SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 11
REQUEST NO. 9: Reference Aschenbrenner Direct at 15. Please produce the
2016 Annual Net Metering Status Report and all similar reports for the years 2A12
through present except for the document filed as Exhibit I with your testimony in this
case
RESP-ONqE TO, REQUEST NO. 9: ln 2013, the Commission issued Order Nos.
32846 and 32925, directing ldaho Power to file an annual Net Metering Status Report.
The first report was filed in 2014. Please see Attachments 1 - 3 for the 2014, 2015, and
2016 Net Metering Status Reports.
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.12
REQUE NO. 10: Reference Aschenb renner Direct at 28 note 14.
(a) Please produce the cost-of-service study from the Company's last general
rate case.
(b) Please produce the workpapers for the cost-of-service study from the
Company's last general rate case in native, unlocked, electronic format with formulas
intact.
(c) To the extent the Company's last cost-of-service study allocated costs
based on system peak (at any level of the system), multiple coincident peaks (i.e., 3CP,
4CP or 12CP), and/or class noncoincident peaks, please provide the date and time
(hour ending) of each such peak and noncoincident peak for each class.
RESPON.S__E_.TO REQUEST NO. 1o:
(a) Please see Attachments 1 and 2 containing the cost-of-service study from
the Company's last general rate case, Case No. IPC-E-11-08 ("2011 GRC'). Please
note these files reflect a modification that was made in the course of 2011 GRC to
correct a data entry error related to one of the allocation factors in the Company's initial
filing; therefore, the study provided in these attachments will not exactly tie to the
publicly-available study posted on the Commission's website in the 2011 GRC.
Attachment 26 provides instructions for linking the two modules of the study provided as
Attachments 1 and 2.
(b) Please see Attachments 3 through 25 for the workpapers for the cost-of-
service study filed in the Company's 2011 GRC,
(c) Please see Attachment2T for the date and time (hour ending) of the 2010
monthly system coincident peaks and the monthly non-colncident peaks for each class.
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 - 13
REQUEST NO. 11: Reference Aschenbrenner Direct at 31, lines 17-24. Please
provide all studies and other evidence that supports your contention that energy
efficiency measures are called upon at all hours and are, therefore, "always delivering
energy reduction."
F,,FSP9,NSE T-9, B,qOUESJ NO. 11: To clarify, the full context of the statement
made in Ms. Aschenbrenner's testimony was: "a customer who installs an energy
efficiency measure is reducing their reliance (and lowering the cost to serve) in every
hour that measure is called upon. That is, the energy efficiency measure is always
delivering energy reduction." However, different energy efficiency measures use energy
at different hours of every day. For example, an energy efficient refrigerator will use
less energy than a standard refrigerator at all hours of the day, while an energy efficient
clothes washer will use less energy than a standard clothes washer when that clothes
washer is in use, which can happen at any hour of any day.
Listed below are the studies and other evidence known to the Company that
support the statement that energy efficiency measures are reducing their reliance in
every hour that measure is called upon.
r ldaho Power's third-party Energy Efficiency Potential Study
o https ://www. id a hopower. com/E ne rqvEfficiencv/reports". cfm
End-Use Load and Consumer Assessment Program (ELCAP) study
o https://elcap.nwcouncil.orq/Documents/Electric%20EnerW%20Use%20_Sinqle
%20Family.pdf
a
a
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
FIRST SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 14
Northwest Energy Efficiency Alliance's (NEEA) Residential Building Stock
Assessment: Metering Study
o https://neea.orq/docs/default-source/reports/residential-building-stock-
alisessment-meteri ng:gtt {dv. odf?sfvrsn=6
End-Use Load Research in the Pacific Northwest
o h ttps ://co nd u itnw.q r-q/ la vallt-s/C on d u iUFi le H a n d le r. a sh x? ri{= 3 2 8 O
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ldaho Power's Demand-Side Management 2016 Annual Report, Supplement 1;
Cost-Effectiveness, pages 1 -8
o http s ://www. id a h opowe r. com/E nergvEfficiency/repo rts. cfm
ldaho Power's lntegrated Resource Plan, Appendix C, Technical Report, pages
71-82
o httpsi/./yylu.idahopower.com/AboutUs/PlanninqForFuture/irp/default.cfm
Translating Aggregate Energy Efficiency Savings Projections into Hourly System
lmpacts
o http:/lwww.enerov.ca.oov/20l6publications/CEC-200-2016-007/CEC-200 ,
2016-007.pd1
State of the Art of Energy Efficiency: Future Directionso hfip"S;//#rnp,lbl.gqv/$itesldelaultlfiles/st-art-energyj?ffic-end-use.load-shape-
data.rdf
. Regional Technical Forum's Business Case for End-Use Data Collection
o https:/lrtf,nwcouncil.ot'g/subcommittee/business-case-end-use-data-collection
The response to this Request is sponsored by Connie Aschenbrenner, Rate
Design Manager Regulatory Affairs, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
FIRST SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 15
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REQUEST NO. 12: Reference Aschenbre nner Direct at 33, lines 1-2
(a) Please identify each distribution system component that you contend net
metering customers utilize when they "are exporting energy to the grid."
(b) State whether you contend that a net metering customer's utilization of the
grid to export electricity is separate from, and in addition to, the nearby customer's use
of the distribution system to receive a net metering customer's export electricity.
(c) lf a net metered customer's export electricity flow is used to serue a
nearby customer's load, and is, therefore, part of the nearby customer's import flow of
electricity, please explain how you propose to assign costs to that flow of electricity to
avoid double counting the same flow of electricity as both the net metering customer's
export flow and the non-net metering customer's import flow.
RESPONSE TO BEQUEST NO. 12:
(a) Net metering customers, when exporting energy, utilize and rely on the
electric grid just like energy consuming customers. All energy consuming customers
require voltage for their electrical devices to draw power and function. Net metering
customers require grid provided voltage for a gridtied inverter to convert direct current
to alternating current electricity in synchronism with the grid. The grid voltage is
supplied by generators located throughout the grid and transmitted through the
transmission and distribution systems. The net metering customers export energy only
when their generation exceeds their load. This export condition may not align with the
local or ldaho Power's system load. Thus, the grid operators must accommodate the
extra energy by adjusting the dispatch of ldaho Power's generation. The net metering
customer utilizes more than just the distribution system components, they use the entire
grid from the generation, substations, and transmission lines.
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
FIRST SET OF DATA REOUESTS TO IDAHO POWER COMPANY - 16
(b) Yes, it is separate from another customer's use of the grid. Referring to
the response in (a) above, the net meeting customer, when exporting, interacts with the
grid in a different manner than an energy consuming customer.
(c) ldaho Power is not proposing a cost assignment methodology in this case.
The response to this Request is sponsored by David M. Angell, Transmission
and Distribution Planning Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
FIRST SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 17
LEQ_UEST NO. 13: Reference Aschenbrenner Direct at 33, lines 16-21. Please
provide the methodology that you contend should be applied to determine a net
metering customer's "appropriate amount of costs" and the methodology you contend
should be applied to determine the amount of billing that would reflect a net metering
customer's "utilization of the grid."
RESPON,$E TO RE9UEST NO. 13: The Company is not proposing a cost
assignment methodology as a part of this case. The Company has recommended that,
in order to establish a methodology that determines the appropriate amount of costs
and accurately reflects their utilization of the grid, the Commission establish a formal
process by which a comprehensive review of the compensation structure for customers
with on-site generation can be analyzed and vetted collaboratively with interested
partles. ldaho Power believes this would best be done through a collaborative process
where stakeholders and other utilities can participate.
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 - 18
REQUEST NO. U: Reference Aschenbrenner Direct at 34-35 and Table 3.
Please provide the 2016 hourly load data, in native, unlocked, electronic format wlth
formulas intact, for the net zero residential customer and the "Nearby Residential"
customer used for the comparison of rates paid in Table 3.
RESPONSE TO REQUEST NO. 14: Please see the Attachment for the hourly
load data for the net zero residential customer and the "Nearby Residential" customer
used for the comparison of rates paid in Ms. Aschenbrenner's Testimony, Table 3.
The response to this Request is sponsored by David M. Angell, Transmission
and Distribution Planning Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
FIRST SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 19
REQU NO. 15:Reference Aschenbrenner Direct at 36, lines 8-17.
(a) Please identify where in Mr. Tatum's testimony intra-class subsidies other
than the one you contend exists for net metered customers are discussed.
(b) Please identify all intra-class subsidies that exist within the R&SGS
customer classes.
RESPoNSE rQ RF*O.llFgr No. 15:
(a) On pages 4 and 5 of his testimony, Mr. Tatum explains that the current
pricing structure applicable to residential and small general service customers does not
perfectly align costs incurred with prices paid for each individual customer but that
overall this rate structure has worked for customers who receive one-way service from
ldaho Power.
(b) ldaho Power has not performed the requested analysis.
The response to this Request is sponsored by Tim Tatum, Vice President of
Regulatory Affairs, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
FIRST SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 20
REQUEST NO. 16: Reference Aschenbrenner Exhibit 9 at pp 5-6 of 18. Please
define an "inappropriate cost shifting," including but not limited to:
(a) Whether you contend that any reduction in volumetric energy use by a
customer since the last rate case test year constitutes an "inappropriate cost shift";
(b) Whether you contend that revenue collection from an individual customer
should match that customer's contribution to the class loads at the peak periods used
for allocating revenue requirement to the class; and
(c) The qualities and attributes of a near-term "cost shift" that make it an
"inappropriate cost shift" rather than an appropriate "cost shift."
RESPONSE T_O,,JRF9UEST NO. 16: The existing retail rate design currently
applicable to residential and small general service net metering customers was
structured to collect the costs associated with the grid under the assumption that
customers would only need one-way services provided solely by the utility. This pricing
structure does not work for customers with on-site generation because when the
existing rate structure is applied against monthly net consumption, customers with on-
site generation may pay less than their share of grid-related services they require while
receiving credit for their respective kWh of production at the full retail rate. The net
monthly meter read is not representative of the customer's usage of the system.
(a) No.
(b) No. Mr. Tatum addresses this on page 4 of his testimony, beginning with
line 22.
(c) The cost shift that results from the combination of net metering and the
current rate design, coupled with the substantial grov'rth in the Company's net metering
service, results in the potential for an inappropriate cost shift. Mr. Tatum discusses this
again in his testimony on page 6, lines 13-25.
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 - 21
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REQUEST NO. 17: 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.
RESP-ONSE TO REQUEST NQ. 117:
(a) Please see Attachments 1 and 2 for the workpapers used to derive the
estimated cost shift in2015 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 2015 - 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 IDAHO POWER COMPANY - 22
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 for 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
REQUEST NO. 18: Reference Tatum Direct at 13, lines 15-25.
(a) Please explain the difference between reduction in customer usage that
results in "unduly reduc[ing] collection of class revenue" and reduction in customer
usage that results in acceptable reduction of collection of class revenue.
(b) Please confirm that "fixed" costs are "transfer[red]" to other residential
customers after a reduction in class revenue collection due to net metering, as
described on lines 21-25, only when rates are reset in subsequent general rate cases,
and only to the extent that the residential class's allocated revenue requirement is not
reduced by the same or greater amount.
RESPONSE TO REQUEST NO. 18:
(a) The collection of class revenue is unduly when the reduction in usage is
due to a resulting net monthly meter read that does not accurately represent the
customer's utilization of ldaho Power's system. As explained on page 4, lines 17-22, of
Mr. Tatum's testimony, the existing retail rate designs currently applicable to residential
and small general service net metering customers were structured to collect the costs
associated with the grid under the assumption that customers would only need one-way
services provided solely by the utility.
This is in comparison to a customer whose reduction in usage is due to less
energy being consumed or even no energy being consumed. ln this case, the number
used to bill this customer more closely aligns with the degree to which the customer
used ldaho Power's system.
(b) This statement is inaccurate. A reduction in fixed costs collection due to
net metering is shifted to other customers annually through the Company's Fixed Cost
Adjustment mechanism.
The response to this Request is sponsored by Tim Tatum, Vice President of
Regulatory Affairs, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
FIRST SET OF DATA REQUESTS TO IDAHO POWER COMPANY.24
REQUEST NO. 19: Reference Tatum Direct at 18, lines 11-18. Please identify
ldaho's policies on cost causation and how you contend net metering rates should be
structured to provide price signals that reflect those policies.
RESPONSE TO REQU,EST NO. 19: ln the Company's most recent fully-litigated
general rate case, IPC-E-08-10, the ldaho Public Utilities Comrnission ("Commission")
approved ldaho Power's filed 3CP/12CP class cost-of-service study methodology,
which was generally guided by principles detailed in the Electric Utility Cost Allocation
Manual, published January 1992, by the National Association of Regulatory Utility
Commissioners. The Company selected a 3CPl12CP method that used allocators
derived from the three summer (June, July, August) unweighted coincident peaks and
all 12-month unweighted coincident peaks (3CP/12CP) to assign demand-related costs
to the various customer classes. To the extent that ldaho has a policy on cost
causation, ldaho Power believes it exists in the Commission's publicly available orders.
ldaho Power has not proposed how rates should be structured for net metering
customers in this case. However, ldaho Power's primary goal in designing fair and
appropriate rate structures is to reflect the cost to serve customers in each rate class.
The response to this Request is sponsored by Tim Tatum, Vice President of
Regulatory Affairs, ldaho Power Company.
DATED at Boise, ldaho, this 18th day of October 2017.
1
LISA
Attorney for ldaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
FIRST SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 25
CERTIFICATE OF SERVICE
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
Benjamin J. Otto
ldaho Conservation League
710 N. 6th st.
Boise, ldaho 83702
Matthew A. Nykiel
ldaho Conservation League
102 South Euclid #207
P.O. Box 2308
Sandpoint, ldaho 83864
ldaho lrrigation Pumpers Association, !nc.
Eric L. Olsen
ECHO HAWK & OLSEN, PLLC
505 Pershing Avenue, Suite 100
P.O. Box 6119
Pocatello, ldaho 83205
X Hand Delivered
_U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
_Hand DeliveredX U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
erin. cecil@arkoosh. com
_Hand DeliveredX U.S. Mail
_Overnight Mail
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_Overnight Mail
-FAX
X Email [e-mail]
_Hand DeliveredX U.S. Mail
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_FAXX Email [e-mail]
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
FIRST SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 26
I HEREBY CERTIFY that on the 18th day of October 2017 I served a true and
correct copy of IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S FIRST
SET OF DATA REQUESTS TO IDAHO POWER COMPANY upon the following named
parties by the method indicated below, and addressed to the following.
Anthony Yankel
12700 Lake Avenue, Unit 2505
Lakewood, Ohio 44107
Auric Solar, LLC
Preston N. Carter
Deborah E. Nelson
GIVENS PURSLEY LLP
601 W. Bannock Street
Boise, ldaho 83702
Elias Bishop
Auric Solar, LLC
2310 S. 1300 W.
West Valley City, Utah 841 19
Vote Solar
David Bender
Earthjustice
3916 Nakoma Road
Madison, Wisconsin 537 1 1
Briana Kobor
Vote Solar
360 22nd Street, Suite 730
Oakland, California 94612
Gity of Boise
Abigail R. Germaine
Deputy City Attorney
Boise City Attorney's Office
150 N. Capitol Blvd.
P.O. Box 500
Boise, ldaho 8370't -0500
ldaho Clean Energy Association
C. Tom Arkoosh
ARKOOSH LAW OFFICES
P.O. Box 2900
Boise, ldaho 83701
_Hand DeliveredX U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
_Hand DeliveredX U.S. Mail
_Overnight Mail
-*FAXX Email [e-mail]
den@g ive nspursley. com
_Hand DeliveredX U.S. Mail
_Overnight Mail
_FAXX Email elias"bishop(&auric^solar.com
_Hand DeliveredX U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
_Hand Delivered
X - U.S. Mail
_Overnight Mail
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erin..cecil@a rkoosh.qom
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
FIRST SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 27
David H. Arkoosh
Law Office of David Arkoosh
P.O. Box 2900
Boise, ldaho 83701
Sierra Club
Kelsey Jae Nunez
KELSEY JAE NUNEZLLC
920 North Clover Drive
Boise, ldaho 83703
Zack Waterman
Director, ldaho Sierra Club
503 West Franklin Street
Boise, Idaho 83702
Michael Heckler
3606 North Prospect Way
Garden City, ldaho 83714
Snake River Alliance
NW Energy Goalition
John R. Hammond, Jr.
FISHER PUSCH LLP
101 South Capitol Boulevard, Suite 701
Boise, ldaho 83702
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
X U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
_Hand DeliveredX U.S. Mail
_Overnight Mail
_FAXX Email kelsey@kqlgqyjaenunez,com
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. X - Email [e-mail]
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_FAXX Email miqhegl,[e-mail]
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llnf ilson tCIsn qkef,i_ygfallg nF.olg
[e-mail]
_Hand DeliveredX U.S. Mail
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_FAXX Email rft,Azi"e.r:[e-mail]
[e-mail]
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
FIRST SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 28
Doug Shipley
Dale Crawford
lntermountain Wind and Solar, LLC
1952 West 2425 South
Woods Cross, Utah 84087
_Hand DeliveredX U.S. Mail
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_FAXX Email [e-mail]
[e-mail]
Towe Assistant
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
FIRST SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 29
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Diane Holt
From:
Sent:
to:
Steve White <[e-mail]>
Tuesday, October 24,2017 3:56 PM
Diane Holt
comment on case IPC-E-17-13Subiect:
Hello,
Please submit the below comment on the above-referenced case
As a Chartered Financial Analyst with a career in investment advising, I would like to ensure the PUC recognizes the
harmful impact of this filing. lf approved, a separate rate class would create long-term uncertainty which changes the
economics of investing in on-site generation. This case creates not just a short-term limbo during the proceedingt an
approval of a separate rate class would create a long-term limbo that will delay and unduly influence investment
decisions in on-site generation.
ln my role, I often counsel people who are considering investing in on-site generation. Like installers, I routinely make
assumptions on the probability of future rate changes to forecast a return on lnvestment. For any investment in general,
the higher the risk, the higher the return must be to motivate someone to invest. Approvlng ldaho Power (lPC)'s
request for a separate rate class would send a message that the rate structure for customers wlth on-site generation
will fundamentally change, but nobody has any idea what to plug in as an assumption. The uncertainty created by
such a policy decision is toxic - it increases the return customers need to see to overcome the uncertainty, and it forces
installers to win or lose projects based on the aggressiveness of their rate change assumptions relative to other installers
responding to the same RFP.
The impact could be a death knell to the fledgling solar installer industry in this state. These companies are staffed by
young, competent engineers and installers-and now this flling threatens their industr/s future and their individual
employment. When considering projects with economic benefits spanning 25+ years, customers have the flexibility to
wait for more visibility on rate design. Small businesses, however, need to make payroll. I am thankfulthat my small
business is not vulnerable to this type of disruption by a monopoly; if my customer base went on hold while waiting for
the promise of future regulatlon changes down the road, I wouldn't be able to cover staff and overhead while waiting.
lPC has far more opportunity to recover its fixed costs than we small businesses do,
Some uncertainty is normal; this is not. lf IPC has not provided sufficient cost/benefit analysis to establish what
customers should assume when investing in on-site generation, then the PUC does not have enough information to
conclude that the current rate design is fundamentally wrong and unstable.
Commissioners, please do not allow IPC to put this unnecessary and unfounded burden on small business. Please
protect the interests of small business and individual customers against destructive attempts like this.
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