20240723Decision Memo.pdf

DECISION MEMORANDUM
TO: COMMISSIONER ANDERSON
COMMISSIONER HAMMOND
COMMISSIONER LODGE
COMMISSION SECRETARY
LEGAL
WORKING FILE
FROM: MICHAEL LOUIS
COMMISSIONER HAMMOND
COMMISSIONER LODGE
LEGAL
WORKING FILE
FROM: MICHAEL LOUIS
DAYN HARDIE
DATE: DULY 23,2024
RE: IN THE MATTER OF REVISIONS TO SCHEDULE 84,LARGE
GENERAL, LARGE POWER,AND IRRIGATION ON-SITE
GENERATION, TARIFF ADVICE NO. IPC-TAE-24-02.
BACKGROUND
In Case No. IPC-E-23-14 Idaho Power("Company")requested that the project eligibility
cap for on-site generation commercial, industrial, and irrigation customers taking service under
Schedule 84 be set at the greater of 100kW or 100 percent of demand at the service point. On
December 29, 2023, the tariff modifying the eligibility cap was approved in Order No. 36048.
On December 29, 2023, January 10, 2024, and January 12, 2024, the Company filed tariff
revisions in conformance with Order No. 36048. On January 23, 2024, the Commission
approved the Company's tariff schedules in Order No. 36067.
On June 17, 2024, the Company filed Tariff Advice No. IPC-TAE-24-02 proposing to
update Schedule 84. The Company's proposal is intended to clarify the language in Schedule 84
to better reflect the intent of Order No.36048.
On July 3, 2024, the Company made a Supplemental Filing updating and replacing the
proposed tariff sheet, in its entirety, that was originally filed on June 17, 2024 ("Supplemental
Filing").
DECISION MEMORANDUM - 1 - JULY 23, 2024

STAFF ANALYSIS
Staff has reviewed the proposed changes to Tariff Sheet No. 84-2 contained in Schedule
84, Large General, Large Power, and Irrigation On-Site Generation filed by the Company
through the Supplemental Filing. Staff recommends approving the updated language contained
in the Supplemental Filing to avoid confusion regarding how a customer's demand is determined
and to ensure compliance with the Commission-approved eligibility cap.
The Commission approved an eligibility cap for Schedule 84 customers that"shall be the
greater of 100kW or 100% demand." Order No. 36048 at 7. However, the current language in
the tariff could be misinterpreted to allow customers to install generation capacity that exceeds
future billing demand when it is not reflective of future customer operations and is erroneously
based on a single component rather than the customer's overall system.
Staff believes the proposed language clarifies any potential customer confusion and
ensures the Commission's intent is fulfilled. First, the cap will be based on the greater of 100%
of the greatest monthly billing demand during the most recent 12-month period or 100 kW, if
historic billing demand is available or when billing demand reflects future customer operations.
Only when billing demand is not reflective of future operation will one of the alternative
methods be employed to derive a future demand estimate.
Two of the methods rely on historical billing data and the third method requires the
customer to obtain an estimate from a licensed professional engineer. Staff believes these three
methods should provide an accurate estimate reflecting future billing demand to ensure
customers install a system that conforms to the parameters of the updated tariff. However, the
fourth method, which is of concern to Staff under the existing tariff, has been modified requiring
the customer to submit documentation of all relevant equipment in their system and for the
Company to determine the estimated demand based on known engineering principles and
conversion factors.
STAFF RECOMMENDATION
Staff recommends that the Commission approve the proposed changes to Schedule 84
included in the Supplemental Filing, as filed, with an effective date upon issuance of the order.
DECISION MEMORANDUM - 2 - JULY 23, 2024

COMMISSION DECISION
Does the Commission wish to approve the proposed changes to Schedule 84, as filed,
with an effective date upon issuance of the order?
Micht/el L
Commission Staff
I:\Uti1ity\UDMEM0S\TAE-E-24-02 Decision Memo.docx
DECISION MEMORANDUM - 3 - JULY 23, 2024