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Home My WebLink About20240703Reply Comments.pdf RECEIVED Wednesday, July 3, 2024 IDAHO PUBLIC _ ROCKY MOUNTAIN 1407 W.North1Temple,Suite C0 OMISSION POWER. Salt Lake City,UT 84116 A DIVISION OF PACIFICORP July 3, 2024 VIA ELECTRONIC DELIVERY Commission Secretary Idaho Public Utilities Commission 11331 W. Chinden Blvd Building 8 Suite 201A Boise, ID 83714 RE: CASE NO. PAC-E-23-17 IN THE MATTER OF ROCKY MOUNTAIN POWER'S APPLICATION TO COMPLETE THE STUDY REVIEW PHASE OF THE COSTS AND BENEFITS OF ON-SITE CUSTOMER GENERATION Attention: Commission Secretary Pursuant to Commission Order No. 36160 providing public notice of the processing of the Application by Modified Procedure and establishing the procedural schedule please find Rocky Mountain Power's Reply Comments in the above referenced matter. Informal inquiries may be directed to Mark Alder, Idaho Regulatory Manager at(801) 220-2313. Very truly yours, a1__D Joe Ateward9k_) Senior Vice President, Regulation Joe Dallas (ISB# 10330) PacifiCorp, Senior Attorney 825 NE Multnomah Street, Suite 2000 Portland, OR 97232 Email:joseph.dallaskpacificorp.com Attorney for Rocky Mountain Power BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF ROCKY MOUNTAIN ) POWER'S APPLICATION TO COMPLETE ) CASE NO. PAC-E-23-17 THE STUDY REVIEW PHASE OF THE ) COSTS AND BENEFITS OF ON-SITE ) REPLY COMMENTS OF CUSTOMER GENERATION ) ROCKY MOUNTAIN POWER Pursuant to Rule 202.01(d) of the Rules of Procedure of the Idaho Public Utilities Commission ("Commission") and the Commission's April 23, 2024, Notice of Modified Procedure,Notice of Virtual Public Workshop, and Notice of Customer Hearing, Rocky Mountain Power a division of PacifiCorp (the "Company") hereby submits reply comments in the above- referenced case. I. BACKGROUND I. On June 29, 2023, the Company submitted an application requesting the Commission issue an order acknowledging that its on-site generation study("Study") satisfies the requirements of Order No. 34753. On July 31, 2023, the Commission issued a Notice of Application and a Notice of Intervention Deadline, and the Idaho Irrigation Pumpers Association ("IIPA") subsequently intervened. After discussions with Commission Staff, the Company submitted a supplement to the Study on February 8, 2024. Page 1 2. On April 23, 2024, Commission Order No. 36160 in addition to providing notice of the public workshop and public hearing, authorized processing of the Application by Modified Procedure,and established the procedural schedule allowing persons who would like to file written comments to have until June 13,2024, and providing the Company until July 3, 2024,to file reply comments. 3. On June 13, 2024, Staff filed comments. No comments were filed by the IIPA. In their comments, Staff recommended the Commission: acknowledge that the Study complies with Order No. 34753; direct the Company to submit a proposed Export Credit Rate ("ECR") within six months of the final order of this case; and direct the Company to include in the ECR filing detailed analysis and justification using AMI data to support the Company's decision regarding the 100 kW non-residential customer cap. IL REPLY COMMENTS 4. The Company appreciates Staff's review of the Study and its recommendations incorporated into the supplement to the Study. The Company will submit a proposed ECR within six months of the final order in this case. The Company will also include an analysis and justification for the 100 kW non-residential customer cap using AMI data. 5. Based on the Study, Staff makes several recommendations regarding the Company's eventual proposed ECR. Staff advises balancing accuracy, transparency, and rate stability when proposing an ECR. Staff also made recommendations for avoided energy value, avoided capacity value, and other avoided cost: Page 2 Avoided Energy Value Staff suggests in its comments that the Company consider time or seasonal differentiation in its ECR to reflect varying energy values accurately. Staff also recommends the differentiation should be balanced with the need for simplicity and transparency in the rate design. Avoided Capacity Value Staff recommends this value should be compensated during peak periods when capacity costs are avoided, incentivizing customers to shift consumption patterns. Staff recommends a uniform approach for all customers and regular updates to the ECR based on the Company's Integrated Resource Plan("IRP"). Other Avoided Costs The study examined other avoided costs, including transmission and distribution, line losses, and environmental values. While these components are relatively minor, Staff believes they should still be accurately reflected in the ECR. Staff recommends transmission and distribution values should be updated with each new IRP,while line loss values should be recalculated only after new studies. Staff notes that Renewable Energy Credit ("REC") sales are potentially a quantifiable environment component and should be considered in an ECR. Finally, Staff recommends that integration costs,necessary for balancing non-firm energy, should align with Qualified Facility ("QF") pricing. 6. The Company believes that it can incorporate Staff's recommendations in its proposed ECR. However, the Company believes that this current case is not the best forum for making final determinations on each of the issues described above. While the Study provides a good starting point for how each of these issues will be evaluated,the Company's future proposed ECR filing will be the best phase for determining the details of each component of the ECR, and the appropriate process and timing for incorporating updates. Page 3 III. CONCLUSION 7. The Study provides a detailed analysis of the cost and benefits for on-site customer generation. The Company agrees to submit an ECR filing within six months of a Commission order and will use AMI data to support its non-residential customer cap in its upcoming ECR filing. Based on the foregoing, the Company respectfully requests that the Commission issue an order acknowledging that its Study satisfies the requirements of Order No. 34753. DATED this 3rd day of July 2024. Respectfully submitted, ROCKY MOUNTAIN POWER Joe Dallas (ISB# 10330) PacifiCorp, Senior Attorney 825 NE Multnomah Street, Suite 2000 Portland, OR 97232 Email: joseph.dallas(&,pacificorp.com Attorney for Rocky Mountain Power Page 4 CERTIFICATE OF SERVICE I hereby certify that on this 3rd day of July 2024, I caused to be served, via electronic mail a true and correct copy of Rocky Mountain Power's Reply Comments to the Application to Complete the Study Review Phase of the Study of the Costs and Benefits of On-Site Customer Generation to the service list in Case No. PAC-E-23-17 to the following: Service List Idaho Irrigation Pumpers Association,Inc. Eric L. Olsen Lance Kaufman, Ph.D. ECHO HAWK& OLSEN, PLLC 2623 NW Bluebell Place 505 Pershing Ave., Ste. 100 Corvallis, OR 97330 P.O. Box 6119 E-mail: lance&ae isg insi hg t.com Pocatello, Idaho 83205 elo&echohawk.com Commission Staff Claire Sharp Deputy Attorney General Idaho Public Utilities Commission 11331 W. Chinden Blvd., Bldg No. 8, Suite 201-A(83714) PO Box 83720 Boise, ID 83720-0074 caire.shaM(kpuc.Idaho.gov Rocky Mountain Power Mark Alder Data Request Response Center Rocky Mountain Power PacifiCorp 1407 West North Temple, Suite 320 825 NE Multnomah, Suite 2000 Salt Lake City, Utah 84116 Portland, OR 97232 mark.alder(kpacificorp.com datarequestgpacificorp.com Joseph Dallas Rocky Mountain Power 825 NE Multnomah, Suite 2000 Portland, OR 97232 joseph.dallas(4pacificorp.com Dated this 3rd day of July 2024. Linda Norton Sr. Administrative Service Coordinator, Regulation Page 1 of 1