20240430Compliance Filing.pdf

0IQAFIQPOWER.
RECEIVED
Tuesday, April 30, 2024 3:11 PM
IDAHO PUBLIC
Connie Aschenbrenner UTILITIES COMMISSION
Rate Design Senior Manager
caschenbrenner(a)-idahopower.com
April 30, 2024
VIA ELECTRONIC FILING
Monica Barrios-Sanchez, Secretary
Idaho Public Utilities Commission
PO Box 83720
11331 W. Chinden Boulevard
Building 8, Suite 201-A (83714)
Boise, Idaho 83720-0074
RE: Compliance Filing in Case No. IPC-E-12-27
Annual 2024 Distributed Energy Resources Status Report
Dear Ms. Barrios-Sanchez:
Pursuant to Order Nos. 32846 and 32925 in the above-mentioned case and Order
No. 34955 in Case No. IPC-E-20-30, attached for electronic filing is Idaho Power
Company's Annual Distributed Energy Resources Status Report for 2024.
If you have any questions regarding this filing, please contact Regulatory Analyst
Mary Alice Taylor at [phone] or mtaylor(a)idahopower.com.
Very truly yours,
Connie Aschenbrenner
CA/sg
Enclosures
cc: Terri Carlock, Idaho Public Utilities Commission

DISTRIBUTED ENERGY
:20 RESOURCES
ANNUAL
:2 t REPORT April 2024
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HIQAW POWER.
Introduction &Table of Contents
INTRODUCTION
Idaho Power Company ("Idaho Power" or "Company") presents its annual Distributed Energy
Resources ("DER") Status Report to the Idaho Public Utilities Commission ("Commission") as
required by Order Nos. 328461 and 329252 in Case No. IPC-E-12-27 and Order No. 349551 in Case
No. IPC-E-20-30.The report begins with a brief regulatory update on recent orders that affect the
compensation structure applicable to customers with DERs. Next, the report contains an update
on current participation levels and growth rates since the Company's last DER Status Report filed
with the Commission in April 2023. Then, the report discusses system reliability considerations
and concludes with an update on meter aggregation activity, credit transfers, and accumulated
excess net energy credits.
TABLE OF CONTENTS
Introduction.................................................................................................................................. 1
Tableof Contents.......................................................................................................................... 1
Listof Tables .................................................................................................................................2
Listof Figures................................................................................................................................2
I. Customer Generation in Idaho................................................................................................... 3
Recent Regulatory Changes..................................................................................................... 3
Current Participation and Growth Rates (Exporting Systems).................................................4
II. System Reliability Considerations..............................................................................................8
Installation Concentration versus Capacity.............................................................................8
SmartInverter Installation ......................................................................................................9
1 On page 19 of Order No. 32846, the Commission directed Idaho Power to "file an annual status report with the
Commission discussing the net metering service. The report shall discuss, without limitation, the net metering
service provisions and pricing and how distributed generation may be impacting system reliability."
Z On page 7 of Order No.32925,the Commission stated, "We expect the Company to monitor these changes and to
ensure its billing system can accommodate aggregated billing for net metering accounts when doing so becomes
cost-justified."
3 On page 11 of Order No. 34955, the Commission found "it prudent to require that the Company's annual Net
Metering Report include any known or foreseeable DER related distribution circuit issues or costs and potential
smart inverter functionality updates that could address the issues or lower the costs."
Distributed Energy Resources 2024 Annual Report Page 1

HIQAW POWER.
Introduction &Table of Contents
III. 2023 Excess Net Energy Credit Transfers ............................................................................... 10
Meter Aggregation Eligibility................................................................................................. 10
Credit Transfer Requests for Calendar Year 2023 ................................................................. 11
Credit Transfer Magnitude.................................................................................................... 12
Accumulated Excess Net Energy Credit Balances.................................................................. 13
IV. Conclusion.............................................................................................................................. 14
LIST OF TABLES
Table 1 Legacy- Idaho Active and Pending Exporting Systems as of March 31, 2024...............4
Table 2 Legacy- Idaho Active and Pending Exporting Systems Nameplate Capacity
(MW) as of March 31, 2024.........................................................................................5
Table 3 Non-Legacy- Idaho Active and Pending Exporting Systems as of March 31,
2024 ............................................................................................................................ 5
Table 4 Non-Legacy- Idaho Active and Pending Exporting Systems Nameplate
Capacity (MW) as of March 31, 2024 ..........................................................................6
LIST OF FIGURES
Figure 1 Cumulative Exporting System Counts by Customer Type, 2014— 1Q2024..................6
Figure 2 Cumulative Exporting System Capacity by Customer Type, 2014— 1Q2024................7
Figure 3 Excess Net Energy Credit Transfers by Customer Class, 2019—2023........................ 12
Figure 4 Accumulated Unused Excess Net Energy Credit Balance, 2014—2023 ..................... 13
Distributed Energy Resources 2024 Annual Report Page 2

0I0AW POWER.
Customer Generation in Idaho
I. CUSTOMER GENERATION IN IDAHO
Recent Regulatory Changes
Over the last several years, Idaho Power, as directed by the Commission, has engaged in a
series of cases related to studying the costs and benefits of on-site generation on the Company's
system. In 2019 and 2020, the Commission issued Order Nos. 34509 (Case No. IPC-E-18-15) and
34854 (Case No. IPC-E-20-26), where it established "legacy" and "non-legacy" status for
residential and small general service ("R&SGS") customers and commercial industrial and
irrigation ("CI&I") customers, respectively.4 Through their orders, the Commission found that
legacy customers will continue to participate in net energy metering (one-for-one kWh credit for
excess net energy) under certain criteria through 20451 and non-legacy customers would be
subject to future changes to the program fundamentals, including to the compensation structure
applied to excess energy. The Commission also ordered the Company undertake a
comprehensive study process before any changes applicable to non-legacy customer
compensation would be considered.'
Idaho Power undertook this study process in Case Nos. IPC-E-21-21 and IPC-E-22-22 and in
Order No. 35631 (Case No. IPC-E-22-22), the Commission found the Company had complied with
its previous orders by acknowledging the Company's October 2022 Value of Distributed Energy
Resource study. In that order, the Commission directed the Company to file a new case
requesting to implement changes to its on-site generation offering.' On May 1, 2023, Idaho
Power filed Case No. IPC-E-23-14 where it sought to implement changes to the on-site generation
offering,which included a modified compensation structure (net billing)that would be applicable
to non-legacy on-site generation customers. Under net billing, customers are compensated per
kWh exported with an avoided cost-based export credit rate ("ECR") that varies based on the
season and time of export. In Order No. 36048, the Commission approved the Company's filing,
with modifications, and authorized new program parameters take effect with non-legacy
customers' January 2024 billing period.' Accordingly, going forward the Company's DER report
will update the Commission on customer participation and aggregation activities for both legacy
and non-legacy customers.
4 Order No.34509 pg. 10 and Order No.34854 pg. 10.
5 Order No.34546 pg.9.
6 Order No.34046 pg.22.
Order No.35631 pg.28.
s Order No.36048 pg.5-6 and 18.
Distributed Energy Resources 2023 Annual Report Page 3

HIQAW POWER.
Customer Generation in Idaho
Current Participation and Growth Rates (Exporting Systems)
As of December 31, 2023, Idaho Power's On-Site Generation ("Exporting Systems")9 consisted
of 17,930 total active and pending systems with a cumulative nameplate capacity of 167.98
megawatts ("MW") in its Idaho service area. During the calendar year 2023, active and pending
Exporting Systems increased by 4,065 (a 29 percent increase) and an incremental nameplate
capacity of 40.55 MW. All new systems interconnected in 2023 were solar photovoltaic ("PV").
During the first quarter of 2024, the Company added 466 active Exporting Systems with an
aggregate nameplate capacity of 4.11 MW. Additionally, In the first quarter of 2024 there were
677 pending applications with an additional 11.58 MW of nameplate capacity. At the end of the
first quarter of 2024, Idaho Power had 18,396 active and pending Exporting Systems,
representing a 16 percent growth rate since the same time last year.
Legacy Systems
Table 1 provides the total number of active and pending Exporting Systems in the Company's
Idaho jurisdiction by resource type and customer class for customers with legacy status.
Table 1 Legacy- Idaho Active and Pending Exporting Systems as of March 31,2024
Customer Segment Solar PV Wind Hydro/Other Total
Schedule 6
Residential On-Site Generation 5,073 22 6 5,101
Schedule 8
Small General On-Site Generation 44 - 4 48
Schedule 84
Commercial & Industrial 162 - - 162
Irrigation On-Site Generation 207 - - 207
Total Idaho 5,486 22 10 5,518
Table 2 provides the total nameplate capacity of active and pending Exporting Systems in the
Company's Idaho jurisdiction by resource type and customer class for customers with legacy
status.
s On-Site Generation includes all Exporting Systems under the terms of Schedule 6,8,or 84,designed to provide the
transfer of electric energy to the Company.
Distributed Energy Resources 2023 Annual Report Page 4

HIQAW POWER®
Customer Generation in Idaho
Table 2 Legacy- Idaho Active and Pending Exporting Systems Nameplate Capacity(MW) as of
March 31, 2024
Customer Segment Solar PV Wind Hydro/Other Total
Schedule 6
Residential On-Site Generation 39.64 0.10 0.07 39.81
Schedule 8
Small General On-Site Generation 0.30 - 0.09 0.39
Schedule 84
Commercial & Industrial 5.62 - - 5.62
Irrigation On-Site Generation 19.50 - - 19.50
Total Idaho 65.01 0.10 0.16 65.33
Note:Totals may not sum due to rounding.
Non-Legacy Systems
Table 3 provides the total number of active and pending Exporting Systems in the Company's
Idaho jurisdiction by resource type of customer class for customer with non-legacy status.
Table 3 Non-Legacy- Idaho Active and Pending Exporting Systems as of March 31, 2024
Customer Segment Solar PV Wind Hydro/Other Total
Schedule 6
Residential On-Site Generation 12,695 1 1 12,697
Schedule 8
Small General On-Site Generation 33 - - 33
Schedule 84
Commercial & Industrial 93 - - 93
Irrigation On-Site Generation 55 - - 55
Total Idaho 12,876 1 1 12,878
Distributed Energy Resources 2023 Annual Report Page 5

HIQAW POWER.
Customer Generation in Idaho
Table 4 provides the total nameplate capacity of active and pending Exporting Systems in the
Company's Idaho jurisdiction by resource type and customer class for customers with non-
legacy systems.
Table 4 Non-Legacy- Idaho Active and Pending Exporting Systems Nameplate Capacity(MW)as of
March 31,2024
Customer Segment Solar PV Wind Hydro/Other Total
Schedule 6
Residential On-Site Generation 96.31 0.002 0.004 96.31
Schedule 8
Small General On-Site Generation 0.29 - - 0.29
Schedule 84
Commercial & Industrial 4.19 - - 4.19
Irrigation On-Site Generation 5.97 - - 5.97
Total Idaho 106.75 0.002 0.004 106.76
Note:Totals may not sum due to rounding.
Total Systems
Figures 1 and 2 detail the cumulative Exporting System counts and nameplate capacity,
respectively, by customer class in the Company's Idaho jurisdiction for both customers with
legacy and non-legacy status, from 2014 through the first quarter of 2024 (including pending
applications).
Figure 1 Cumulative Exporting System Counts by Customer Type, 2014—1Q2024
20,000
18,000
16,000
�14,000
012,000
U
E10,000
y 8,000
cn 6,000
4,000
2,000
2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 1Q2024
■Residential ■Commercial & Industrial ■ Irrigation
Distributed Energy Resources 2023 Annual Report Page 6

HIQAM POWER® -
Customer Generation in Idaho
Figure 2 Cumulative Exporting System Capacity by Customer Type, 2014—1Q2024
200
180
160
140
120 I
100
c� ■
co
80
v 60
40
20 — — — - ■
2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 1Q2024
■Residential ■Commercial & Industrial ■Irrigation
Distributed Energy Resources 2023 Annual Report Page 7

UIQAW POWER.
System Reliability Considerations
II. SYSTEM RELIABILITY CONSIDERATIONS
There are 691 electrical distribution circuits in the Company's service area. Considering all
customer-owned on-site generation installations across all jurisdictions, all rate classes, and all
resources, as of March 31, 2024, there were 17,719 active, customer-owned on-site generation
systems. These systems total approximately 161 MW on 526 distribution circuits—compared to
15,133 active operational systems totaling approximately 139 MW across 485 distribution circuits
on March 31, 2023.
Installation Concentration versus Capacity
The circuits containing the greatest number of customer-owned on-site generation systems
are in Ada and Elmore County,with the densest concentrations in southeast and south Boise and
north Mountain Home.
The largest number of customer-owned on-site generation systems connected on a single
distribution circuit is 255, with a total rated capacity of 1,660 kilowatts ("kW"), compared to 222
systems with a total capacity of 1,433 kW in 2022. This circuit primarily serves residential
customers in Boise.
The distribution circuit in Idaho with the greatest customer-owned on-site generation
capacity has not changed from 2022. That circuit still has 29 solar PV systems with a total rated
capacity of 2,723 kW (average system size over 90 kW). This circuit primarily serves agriculture
and rural customers in the Magic Valley with a summer peak load of approximately 7,100 kW.
The distribution circuit in Idaho with the second-highest customer-owned on-site generation
capacity has 64 solar PV systems with a total rated capacity of 1,921 kW (average system size is
30 kW) and with 15 larger solar PV systems on it accounting for 1,400 kW of the feeder's total
capacity. This circuit also serves agriculture and rural customers in the Magic Valley and with a
summer peak load of approximately 19,400 kW.
The number of circuits with total customer-owned on-site generation capacity greater than
1,000 kW increased from 16 to 19 circuits in 2023. Eleven of the circuits are in the Magic Valley
with one circuit serving a single industrial customer and all others serving irrigation and rural
customer loads. The other eight circuits include five in Ada County, two in Canyon County, and
one in Elmore County that primarily service residential customers. The average system size for
these eight feeders is 7.3 kW. As a comparison, Idaho Power had one distribution circuit with
more than 1,000 kW of generation capacity on a single distribution feeder in 2020.
The customer-owned on-site generation connected capacity on the Company's distribution
system continues to grow and has increased year-over-year from 3.6 to 4.7 percent of the total
system peak load. The Company has managed the impacts on these circuits, when necessary, by
Distributed Energy Resources 2023 Annual Report Page 8

HIQAW POWER.
System Reliability Considerations
requiring customer-funded distribution upgrades pursuant to Rule H and, in more rare instances,
requiring customer-funded substation upgrades.
Smart Inverter Installation
All new systems applying to interconnect are required to install smart inverters10 to support
the distribution system's ongoing stability and reliability. As of January 1, 2024, Idaho Power
requires inverters to comply with the IEEE 1547-2018 certification11 which meet all smart inverter
requirements as defined by the Institute of Electrical and Electronics Engineers ("IEEE").The IEEE
Standard 1547 establishes the technical standard for interconnection and interoperability of
distributed energy resources and Idaho Power is an active participant in the review process of
this standard which is currently being updated and revised.
10 Order No. 34955 issued in Case No. IPC-E-20-30 approved Schedule 68, effective March 23, 2021. Schedule 68
requires smart inverter functionality to be enabled for all new applications for customer generation.
11 Underwriters Laboratories Standard for Safety 1741 — Inverters, Converters, Controllers and Interconnection
System Equipment for Use with Distributed Energy Resources,Supplement B.
Distributed Energy Resources 2023 Annual Report Page 9

HIQAW POWER.
2023 Excess Net Energy Credit Transfers
III. 2023 EXCESS NET ENERGY CREDIT TRANSFERS
Meter Aggregation Eligibility
Schedule 6, Residential Service On-Site Generation ("Schedule 6"), Schedule 8, Small General
On-Site Generation ("Schedule 8"), and Schedule 84, Large General, Large Power, and Irrigation
On-Site Generation ("Schedule 84") provide for customers with Exporting Systems to submit
requests to transfer excess net energy credits by January 31 of each year. The Company applies
the following criteria12 from Schedules 6, 8, and 84 (collectively referred to as "aggregation
criteria") to all requests received:
i. The account subject to offset is held by the customer; and
ii. The meter is located on, or contiguous to, the property on which the Designated Meter13
is located. For the purposes of the tariff, contiguous property includes property that is
separated from the premises of the Designated Meter by public or railroad rights of way;
and
iii. The meter is served by the same primary feeder as the Designated Meter at the time the
customer files the application for the Exporting System;14 and
iv. The electricity recorded by the meter is for the customer's requirements; and
v. For customers taking service under Schedule 1 or Schedule 7, credits may only be
transferred to meters taking service under Schedule 1 or Schedule 7. For customers taking
service under Schedule 9, Schedule 19, or Schedule 24, credits may only be transferred to
meters taking service under Schedule 9, Schedule 19, or Schedule 24.
In November of 2023, prior to the credit transfer window opening on December 1, Schedule
6,Schedule 8,and Schedule 84 customers with an excess net energy balance were sent a postcard
reminding them of the meter aggregation process, a list of important things to note about the
transfer process, the deadline for them to apply, a phone number to contact, and the website
with the requirements and an online form. This postcard was sent to a total of 9,431 customers.
The Company also posted a message on all Schedule 6, Schedule 8, and Schedule 84 customer
12 The aggregation criteria were established by Order No. 32925 in Case No. IPC-E-12-27.
13 Schedules 6, 8, and 84 define the Designated Meter as the retail meter physically connected to the Exporting
System.
14 Schedules 6, 8, and 84 define an Exporting System as"a Customer-owned DER under the terms of Schedule 6, 8,
or 84,which is designed to provide for the transfer of electric energy to the Company."
Distributed Energy Resources 2023 Annual Report Page 10

HIQAM POWER.
2023 Excess Net Energy Credit Transfers
bills issued during the month of December informing them of when the transfer window closes
and provided a link to a webpage where customers could find more information. Lastly, on
January 16, 2024, the Company sent an email reminder to 80 customers who submitted transfer
requests in 2022 but had not yet submitted a request for 2023.The email reminded the customer
of the meter aggregation process and deadline and provided a link for them to submit a transfer
request.
Credit Transfer Requests for Calendar Year 2023
In Order No. 32925, the Commission directed Idaho Power to keep it apprised of the number
of customers choosing to transfer excess net energy credits under the meter aggregation rules.15
As of the application deadline, January 31, 2024, the Company received 372 applications for
transfer, representing a 20 percent increase from the previous year. The applications were
reviewed during February against the aggregation criteria.
The Company determined that 306 of the requests were eligible for transfer based on the
aggregation criteria. The total amount transferred was 13,626,674 kilowatt-hours ("kWh")
generated from Exporting Systems taking service under Irrigation (81 percent), Large General (10
percent), Residential (8 percent), and Small General (1 percent) rate schedules. The 13,626,674
kWh were transferred to customers taking service under Irrigation (77 percent), Large General
(14 percent), Residential (9 percent), and Small General (less than 1 percent) rate schedules.16
The Company received 66 applications that were ineligible for transfer based on the
following:
• 5 applications requested to transfer to non-compatible rate schedules
• 49 applications were duplicate requests
• 8 applications requested a transfer to a meter that was not on contiguous property
• 4 applications were not on the same feeder
The Company sent letters to all customers whose requests were ineligible for transfer explaining
the reason for the denial.
is While Order No. 36048 issued in IPC-E-23-14 directed the Company to update its transfer rules for non-legacy
customers,the change did not impact credit transfers requested in advance of January 31,2024.Accordingly, next
year's report will delineate between kWh aggregation applicable to legacy customers and financial credit
aggregation applicable to non-legacy customers.
1a Totals may not sum due to rounding.
Distributed Energy Resources 2023 Annual Report Page 11

HIQAM POWER®
2023 Excess Net Energy Credit Transfers
Credit Transfer Magnitude
Following the implementation of the excess net energy credit transfers authorized by the
Commission in Order No. 32925, the Company has experienced growth in the magnitude of
excess net energy transfers, most notably within the irrigation class. The Company transferred
approximately 206,000 excess net energy credits in 2014 (the first year of meter aggregation),
increasing to over 13.6 million in 2023. Compared to 2022, total kWh transfers decreased over
5.6 million or 29 percent. While residential kWh transfers saw a 32 percent increase between
2022 and 2023, all other customer classes saw a decrease in kWh credit transfers, including a 34
percent decrease in irrigation transfers. Annual availability of irrigation credit balances will vary
depending on a combination of factors which can include weather and commodity pricing for
energy intensive crops. Figure 3 shows the total excess net energy credit transfers for the last
five years (2019 through 2023) by customer class.
Figure 3 Excess Net Energy Credit Transfers by Customer Class, 2019—2023
25,000,000
20,000,000 19,263,396
15,000,000 13,626,674
10,000,000
5,000,000 4,627,989
2,118,709 3,241,836
2019 2020 2021 2022 2023
■Residential ■Commercial ■Irrigation
Distributed Energy Resources 2023 Annual Report Page 12

HIQAM POWER.
2023 Excess Net Energy Credit Transfers
Accumulated Excess Net Energy Credit Balances
After the implementation of the kWh crediting for excess net energy authorized by the
Commission in Order Nos. 32846 and 32872 in January 2014, the Company has accumulated
significant unused kWh credit balances.11,18 The excess net energy credit balance at the end of
2014 was approximately 0.5 million, increasing to approximately 34.8 million kWh credits at the
end of 2023. Figure 4 shows the accumulated excess net energy credit balance for 2014 through
2023.
Figure 4 Accumulated Unused Excess Net Energy Credit Balance,2014—202319
40
34.8
35
30 28.9
0 25
20 17.1
3: 15 11.3
10 7.6
5 4.3
0.5 ■
0
2014 2015 2016 2017 2018 2019 2020 2021 2022 2023
17 In Order No.32846,the Commission stated, "we find it fair,just,and reasonable for the kWh credit to indefinitely
carry forward to offset future bills as long as the customer remains on the net metering service at the same
generation site.Allowing the credits to carry forward indefinitely ensures that customers will be able to use their
credits when they need them and thus receive the benefits of their systems."
18 Pursuant to Order No. 36048, the Commission approved the Company's request to convert all non-legacy
customers' unused kWh credits to a financial credit on December 31, 2024.The change will be reflected in next
year's annual DER status report.
19 The accumulated excess net energy credit balance represents all unused credits as of December 31. It does not
reflect the potential reduction due to future offset at the premise generated or transferred to another meter for
offset.
Distributed Energy Resources 2023 Annual Report Page 13

HIQAW POWER.
Conclusion
IV. CONCLUSION
The continued expansion of on-site generation on Idaho Power's system highlights the
evolution of the Company's electrical grid and the importance of evaluating service provisions
and pricing to ensure safe, reliable, and fair-priced electricity. Idaho Power will continue to
monitor customer generation and keep the Commission informed of its impact on system
reliability.
The 2025 report will contain additional elements related to: (1) meter aggregation (as 2024
will be the first-year non-legacy customers will be eligible to transfer financial credits), and (2)
updated reporting requirements related to the quantity and cost of all upgrades for on-site
generation customers, along with an approximation of their associated ongoing operations and
maintenance costs.20
20 March 28, 2024,compliance filing,submitted to the Commission in Case No. IPC-E-23-14.
Distributed Energy Resources 2023 Annual Report Page 14