20240806Fwd_ Schedule 84 Tariff Pushback.pdf

From: Adam Young
To: Jon Kruck
Subject: Fwd:Schedule 84 Tariff Pushback
Date: Monday,June 17,2024 11:41:21 AM
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Begin forwarded message:
From: [e-mail]
Date: May 28, 2024 at 11:10:46 AM MDT
To: "Hertling, Michael" <[e-mail]>, Aaron Pace
<[e-mail]>
Cc: VM_CG<[e-mail]>, Allen Young<[e-mail]>,
[e-mail]
Subject: RE: Schedule 84 Tariff Pushback
Michael,
Neither the PUC nor Idaho Power are bound by staff comments and recommendations.
The tariff that was submitted and approved by the PUC following the Commission's
order is the controlling document. Rule 133 of IDAPA 131.01.01 states, "When a utility
files tariffs with the Commission pursuant to an order of the Commission in a
proceeding in which other persons are party,the responsibility for reviewing the tariff
submission to determine whether it complies with the Commission's order is upon the
Commission Staff,which shall promptly report to the Commission whether the tariffs
do comply."The approved tariff clearly states that a customer may use the HP
conversion factor if either(1)the total nameplate capacity rating exceeds actual billing
demand from the most recent 12 months,or(2) billing demand is not available.Your
assertion that a larger system is allowed under 6.iii but not 6.iv is arbitrary and contrary
to the clear language in the tariff.
On top of that,we have committed over a million dollars(of which several hundred
thousand dollars have already been expended)and equipment has been ordered and is
scheduled to be delivered based on two separate emails from the Customer Generation
team approving our projects.We can't move forward based on approval from Idaho
Power just to have the rug pulled out from under us after the fact.

Adam Young
[phone]
From: Hertling, Michael <[e-mail]>
Sent:Tuesday, May 28, 2024 10:22 AM
To: Aaron Pace <[e-mail]>
Cc: [e-mail]; VM_CG <[e-mail]>; Hertling, Michael
<[e-mail]>
Subject: RE: Schedule 84 Tariff Pushback
Hi Aaron,
Thank you for the follow up and the question. I connected with our Regulatory team
regarding the Tariff guidelines and I was pointed to Staff Comments on the PUC
website regarding How Demand is determined for Schedule 84. Below is a copy of
Staff's comments from Page 33 (SKM_C36823101217030.pdf(idaho.gov):
The Company proposes different methods for determining a Schedule 84
customer's demand for purposes of conforming to the 100%eligibility cap,
depending on the following circumstances:
•A: For customers with at least 12 months of historical billing data, the
maximum billing demand from the last 12 months is used.
• 8: For new customers or those without at least 12 months of historical billing
of their own, the Company will evaluate and rely on available historical billing
data at that service point. If customers believe their demand will exceed that of
the past customer, the Company proposes requiring an analysis of the facility's
power needs performed by a professional engineer and paid by the customer.
• C: For new customers or those who neither have at least 12 months of
historical billing of their own nor have historical billing data at the service point,
the Company proposes requiring an analysis of the facility's power needs
performed by a professional engineer.
• D: For irrigation customers without a full in-season billing history, a
conversion factor related to the horsepower of their pumps at the service point
will be used to determine the maximum demand.
Page 42 of that document lists Staff's recommendation:
Below is a copy of Section Recommendation 5 regarding the determination of eligibility
cap for Schedule 84 customers:
5. Approve the proposed eligibility cap for Schedule 84 customers: the greater of
100 kW
and 100%of demand and:
a. Incorporate into Schedule 84 the Company's proposed methods used

to determine
a customer's demand relative to the Schedule 84 can.
b. Direct the Company to play a more active role to verify the need for a
professional engineer to conduct on analysis to determine a new
customer's
demand requirements.
c. Direct that the cost of such analysis should be charged to the on-site
generation
customer.
d. Incorporate into Schedule 84 the description of the Company's
proposed
treatment when a customer's demand changes, and
e. Clarify in Schedule 84 that an expanded system is still subject to the
project
eligibility cap, which is the greater of 100 kW or 100%of demand at the
service
point.
Based on Staffs recommendation and the Commission's Order we are required to use
Billing Demand to determine eligibility Cap when that data is available. I have also
included a link to the Commission's Order 3604820231229Final Order No 36048.pdf
(idaho.gov):
The Company represented that for the purpose of administering the cap,the Company
proposed using the maximum billing demand from the last twelve(12)months,measured
when the customer generation application was submitted.Id.at 22.The Company stated
that for irrigation customers without a full in-season billing history,a conversion factor
related to the horsepower of the customers'pump(s)at the service point would
determine the maximum demand. Id.
The eligibility cap for Schedule 84 customers shall be the greater of 100 kW or 100%of
demand.
In a situation where the customer anticipates utilizing the system in a different manner,
option iii. may be utilized to determine system capacity.
Please let me know if you have any other questions.
Best regards,

Michael Hertling
Renewable Energy Specialist
Idaho Power I Customer Generation
Office 208-388-2518
idahopower.com
From: Aaron Pace <aaron6Dagrioowersolar.com>
Sent: Friday, May 24, 2024 1:54 PM
To: Hertling, Michael <MHertlingPidahopower.com>
Cc: adambrentyoung(@gmail.com
Subject: [EXTERNAL] Schedule 84 Tariff Pushback
Michael,
First, I know you're not the guy calling the shots on this, but you're the messenger so
we'll start with you. Don't worry, I come in peace.
I was just on the phone with Adam Young to discuss their pump 403 and 302.The
language is clearly either/or. 1)Total nameplate capacity that exceeds actual billing
demand data from the most recent 12 months or 2) Billing Demand is not available.We
have billing demand, but the total nameplate capacity rating exceeds actual billing
demand.
The section I've copied below appears in both the Commission Secretary Cover Letter
and in the Schedule 84 tariff.We're looking for a bit of guidance where to go from here. It
seems to me like what you told me on the phone is the opposite of what was approved
in the tariff.
Thanks for your help,in advance,getting us in front of the right folks.
Regards,
Aaron Pace Mftk 1+1 801-870-7662
Chief Data 09N aaron(@aciripowersolar.com
Officer now www•agripowersolar.com
40 W Truman Ave, Salt
AgriPower Solar ® Lake City, UT 84115
0

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