HomeMy WebLinkAbout20240617Tariff Advice Revision to Schedule 84.pdf a_10AW POWER.
CONNIE ASCHENBRENNER RECEIVED
Rate Design Senior Manager 2024 June 17 PM 4:47
caschenbrenner(aD-idahopower.com
IDAHO PUBLIC
UTILITIES COMMISSION
VIA ELECTRONIC FILING
June 17, 2024
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg 8,
Suite 201-A (83714)
PO Box 83720
Boise, Idaho 83720-0074
Re: Tariff Advice No. IPC-TAE-24-02
Revisions to Schedule 84, Large General, Large Power, and
Irrigation On-Site Generation
Dear Commission Secretary:
Idaho Power Company's ("Idaho Power" or "Company") hereby submits a
proposed administrative update to Schedule 84, Large General, Large Power, and
Irrigation On-Site Generation ("Schedule 84").
On May 1, 2023, Idaho Power submitted an application in Case No. IPC-E-23-14
requesting the Commission, in part, approve a modified project eligibility cap for
commercial, industrial, and irrigation ("CI&I") customers applying to take service under
Schedule 84. More specifically, the Company requested that the Schedule 84 project
eligibility cap be set at the greater of 100 kW or 100 percent of demand at the service
point for CI&I customers.
The Company's application (as modified by the Company's revised proposal filed
on November 16, 2023) was approved by the Commission on December 29, 2023,
through Order No. 36048. On December 29, 2023, January 10, 2024, and January 12,
2024, the Company filed tariff revisions for the Commission's review and acceptance in
IPC-E-23-14 in conformance with Order No. 36048. On January 23, 2024, the
Commission issued Order No. 36067 approving the Company's tariff schedules.
As Idaho Power has gained experience administering the modified project eligibility
cap for Schedule 84, it has come to the Company's attention that, as currently written, the
tariff language addressing how a Schedule 84 customer's demand is determined for
purposes of conforming to the 100 percent eligibility cap is ambiguous. Specifically, after
describing in paragraph 5(b)(ii) the cap as the greater of "the greatest monthly Billing
Demand established during the most recent 12-month period at the time of applying for
interconnection, which includes and ends with the most recent Billing Period," or 100 kW,
paragraph 6 lists methods for determining demand in instances where a customer seeks
Commission Secretary
Idaho Public Utilities Commission
June 17, 2024
Page 2
to interconnect a system that either (1) has a nameplate capacity rating that exceeds
actual billing demand or (2) billing demand data is unavailable. The language in
paragraph 6 was initially proposed by the Company in its January 10, 2024, compliance
filing and was intended to clarify how the project eligibility cap would be administered in
instances where historical demand was not reflective of expected future demand and/or
where there was no historical demand (e.g., a plant expansion or a new service point).
However, the Company understands that, as currently written, this provision has been
interpreted to mean that a Schedule 24 customer could apply to interconnect a system
that is the "greater of either the historical demand or a conversion factor applied to the
nameplate horsepower of their irrigation system's motor — even in instances of where
historical billing demand exists. That interpretation is not consistent with the record
established in IPC-E-23-14, nor does the Company believe it reflects the intent of
Commission Order No. 36048.
Accordingly, the Company submits this tariff advice to ensure the tariff language is
reflective of the Commission's decision in Order No. 36048. The following tariff sheet
identifies the proposed modifications:
First Revised Sheet No. 84-2 Cancelling Original Sheet No. 84-2
Idaho Power respectfully requests the proposed updates be accepted, with an
effective date of July 17, 2024.
If you have any questions regarding this filing, please contact Regulatory Analyst
Ashley Herrera at (208) 388-2656 or aherrera@idahopower.com.
Very truly yours,
&M-IQ &,"La MUAI
Connie Aschenbrenner
Rate Design Senior Manager
CGA:sg
Enclosures
Idaho Power Company First Revised Sheet No. 84-2
Cancels
I.P.U.C. No. 30, Tariff No. 101 Original Sheet No. 84-2
SCHEDULE 84
LARGE GENERAL, LARGE POWER, AND IRRIGATION
ON-SITE GENERATION SERVICE
(Continued)
APPLICABILITY (Continued)
ii. Single-Meter Interconnection (applicable to new applicants effective
December 2, 2020): Owns and/or operates a Generation Facility interconnected to the
Customer's individual electric system on the Customer's side of the Point of Delivery, thus
all energy received and delivered by the Company is through a single meter.
6. The Generation Facility must have a total nameplate rating equal to or less than the
greater of: (a) the greatest monthly Billing Demand established during the most recent 12-month period
at the time of applying for interconnection, which includes and ends with the most recent Billing Period,
or (b) 100 kW. The capacity of an Energy Storage Device shall not be used to calculate the capacity
limits in this schedule.
a. Subject to the Company's discretion and approval, for a Customer applying to
interconnect a Generation Facility (1) where Billing Demand is not available, or (2) where the
Billing Demand is not reflective of future operations, the customer may provide evidence that the
proposed Generation Facility meets the applicability of this schedule in accordance with one of
the following:
i. If previous billing data is available for the premises and the Customer's
electrical needs are similar to the previous customer, the Company may rely on available
historical Billing Demand at the premises not to exceed the previous 12 months.
ii. If the Customer has another account in the Company's service area with
similar electrical needs, the Company may rely on available historical Billing Demand
from that account not to exceed the previous 12 months.
iii. The Customer can have a third-party professional engineer provide
analysis and documentation detailing the electrical load requirements for the Customer
which support an increase in demand expected to occur within the next 12 months.
iv. For a Customer taking retail service under Schedule 24, the Customer
may submit documentation of the horsepower ("HP") of the irrigation equipment (motors
and/or pumps). Based on the submitted documentation the Company will determine the
maximum continuous HP and a conversion factor of 1 HP to 0.8kW will be used to define
the demand for the Point of Delivery.
7. Legacy Status for eligible Exporting Systems will terminate on December 1, 2045.
8. The Legacy Status of the Exporting System is transferable to a subsequent Customer at the
premises for which a valid on-site generation service is in effect. Each Customer of a Legacy System
taking service under Schedule 84 will be responsible for complying with the terms and conditions of the
on-site generation service in effect for that premises.
9. A Legacy System that is offline for over six (6) months or that is moved to a different site
shall forfeit Legacy Status of the Exporting System.
IDAHO Issued by IDAHO POWER COMPANY
Issued —June 17, 2024 Timothy E. Tatum, Vice President, Regulatory Affairs
Effective—July 17, 2024 1221 West Idaho Street, Boise, Idaho
Advice No. 24-02
Idaho Power Company 9rigiRal First Revised Sheet No. 84-2
Cancels
I.P.U.C. No. 30, Tariff No. 101 Fofth Revosed0riginal Sheet No. 84-2
SCHEDULE 84
LARGE GENERAL, LARGE POWER, AND IRRIGATION
ON-SITE GENERATION SERVICE
(Continued)
APPLICABILITY (Continued)
ii. Single-Meter Interconnection (applicable to new applicants effective
December 2, 2020): Owns and/or operates a Generation Facility interconnected to the
Customer's individual electric system on the Customer's side of the Point of Delivery, thus
all energy received and delivered by the Company is through a single meter.
6. The Generation Facility must have a total nameplate rating equal to or less than the
greater of: (a) the greatest monthly Billing Demand established during the most recent 12-month period
at the time of applying for interconnection, which includes and ends with the most recent Billing Period,
or (b) 100 kW. The capacity of an Energy Storage Device shall not be used to calculate the capacity
limits in this schedule.
6a. Subject to the Company's discretion and approval, f4or a Customer applying to
interconnect a Generation Facility (1) where Billing Demand is not available, or (2) where the
Billing Demand is not reflective of future operations, the customer may provide evidence with a
total naFneplate GapaGity rating that eXGeeds aGtual boiling dernand data frern the most FeGent 12
m,,,enth? er (2) BillingDemand is net available must provide eviden^Gthat the proposed
Generation Facility meets the applicability of this schedule in accordance with one of the
following:
i. If previous billing data is available for the premises and the Customer's
electrical needs are similar to the previous customer, the Company_, at its diSGretie,
may rely on available historical Billing Demand at the premises not to exceed the
previous 12 months.
ii. If the Customer has another account in the Company's service area with
similar electrical needs, the Company, at its disGretk), may rely on available historical
Billing Demand from that account not to exceed the previous 12 months.
iii. The Customer can have a third-party professional engineer provide
analysis and documentation detailing the electrical load requirements for the Customer
which support an increase in demand expected to occur within the next 12 months.
iv. For a Customer taking retail service under Schedule 24, which on!
SeWi^oc motor lead the Customer may submit documentation of the horsepower ("HP")
of the irrigation equipment (motors and/or pumps). Based on the
submitted documentation the Company will determine the maximum continuous HP and
a conversion factor of 1 HP to 0.8kW will be used to define the demand for the Point of
Delivery.
7. Legacy Status for eligible Exporting Systems will terminate on December 1, 2045.
8. The Legacy Status of the Exporting System is transferable to a subsequent Customer at the
premises for which a valid on-site generation service is in effect. Each Customer of a Legacy System
IDAHO Issued by IDAHO POWER COMPANY
Issued —June 17, 2024 Timothy E. Tatum, Vice President, Regulatory Affairs
Effective—July 17, 2024 january 1 20Zz4 1221 West Idaho Street, Boise, Idaho
Advice No. 24-02
Idaho Power Company Oral First Revised Sheet No. 84-2
Cancels
I.P.U.C. No. 30, Tariff No. 101 Fifth ReyosedOriginal Sheet No. 84-2
taking service under Schedule 84 will be responsible for complying with the terms and conditions of the
on-site generation service in effect for that premises.
9. A Legacy System that is offline for over six (6) months or that is moved to a different site
shall forfeit Legacy Status of the Exporting System.
IDAHO Issued by IDAHO POWER COMPANY
Issued —June 17, 2024 Timothy E. Tatum, Vice President, Regulatory Affairs
Effective—July 17, 2024 january 1, 2024 1221 West Idaho Street, Boise, Idaho
Advice No. 24-02