20250515Staff Comments.pdf

RECEIVED
CHRIS BURDIN Thursday, May 15, 2025
IDAHO PUBLIC
DEPUTY ATTORNEY GENERAL UTILITIES COMMISSION
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 9810
Street Address for Express Mail:
11331 W CHINDEN BLVD, BLDG 8, SUITE 201-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )
OF IDAHO POWER COMPANY TO MODIFY ) CASE NO. IPC-E-25-06
SCHEDULE 72, GENERATOR )
INTERCONNECTIONS TO PURPA )
QUALIFYING FACILITY SELLERS, IN ) COMMENTS OF THE
CONFORMANCE WITH FERC ORDERS ) COMMISSION STAFF
2023/2023-A )
COMMISSION STAFF ("STAFF") OF the Idaho Public Utilities Commission
("Commission"), by and through its Attorney of record, Chris Burdin, Deputy Attorney General,
submits the following comments.
BACKGROUND
On February 28, 2025, Idaho Power Company ("Company") filed an application
("Application") with the Commission requesting an order modifying Schedule 72, Generator
Interconnections to the Public Utility Regulatory Policies Act of 1978 ("PURPA") Qualifying
Facility("QF") Sellers, to align with the interconnection process reforms implemented by the
Federal Energy Regulatory Commission ("FERC") in Order No. 2023/2023-A to large
generators over 20 megawatts ("MW").
The Company proposes no changes to small generator QF interconnections, 20 MW and
below, under Schedule 72, because they typically interconnect at distribution voltages and do not
STAFF COMMENTS 1 MAY 15, 2025

typically impact the transmission system. Neither does the Company propose changes to
Schedule 68, which governs the interconnection procedures and requirements for customer-
owned generation facilities.
STAFF ANALYSIS
Although it is not legally required that the Idaho jurisdictional interconnection process
governed by Schedule 72 and the FERC jurisdictional interconnection process set forth in the
Company's Open Access Transmission Tariff("OATT")be aligned (Response to Staff
Production Request No. 9), Staff believes it is reasonable to align the two processes generally,
with a proposed exception for the treatment of transmission credits. Therefore, Staff
recommends that the Commission approve the proposed changes to Schedule 72 with an
effective date coincident with the Commission's final order in this case.
The Company's Proposal
On July 28, 2023, FERC issued Order No. 2023 to update the interconnection process for
FERC-jurisdictional large generators of 20 MW or more by switching from the"first come, first
served" serial approach to a"first ready, first served" cluster approach. Instead of going through
a three-step study process of Feasibility Study, System Impact Study, and Facilities Study, as in
the old process, the new process adopted a process that includes a Request Window, Cluster
Study, Restudy, and Facility Study. The new process also includes provisions for demonstration
of site control, commercial readiness, and queue withdrawal penalties. On March 21, 2024,
FERC also issued Order No. 2023-A to affirm Order No. 2023 to clarify and revise additional
areas in Order No. 2023.
While these FERC orders will only apply to FERC-jurisdictional interconnection
customers, the Company proposes similar changes be applied to Idaho jurisdictional
interconnection customers under Schedule 72, with an exception for the treatment of
transmission credits. Specifically, the Company proposes changes that include: (1) using the
same threshold (20 MW) to distinguish large interconnections and small interconnections, (2)
requiring large QF interconnections to follow the FERC process for large interconnections, and
(3)removing transmission credits for large QFs. Staff believes the proposed changes to
Schedule 72 are reasonable for the following reasons.
STAFF COMMENTS 2 MAY 15, 2025

Justification
First, the Idaho-jurisdictional interconnection process governed by Schedule 72 was
designed to mirror the FERC-jurisdictional interconnection process set forth in the Company's
GATT. The proposed changes will ensure continued alignment of the Company's State and
Federal interconnection processes. Both processes use the following steps: submission of an
initial application, payment of required deposits, documenting study agreements, completion of
the three-step study process (Feasibility Study, System Impact Study, and Facilities Study), and
the completion of a Generator Interconnection Agreement. In addition, both old and new
processes are administered on a non-discriminatory basis. Response to Staff Production Request
No. 1.
Second, by adopting the FERC interconnection process for large generators, speculative
interconnection requests will be reduced, and the number of withdrawals and subsequent re-
studies will be decreased for large PURPA QFs in Idaho. FERC Order No. 2023 imposed
requirements of commercial readiness and stringent demonstrations of site control to improve
interconnection certainty. Responses to Staff Production Request Nos. 2 and 14.
Third, request withdrawals in the "first come, first served" serial approach typically lead
to cascading re-studies and queue backlogs, while withdrawals in the "first ready, first served"
cluster approach will not. In the "first come, first served" serial approach, interconnection
requests are studied and placed in the order they are received, where a later request is studied
based on the assumption that upgrades associated with an earlier request will be in service.
Therefore, if the earlier request withdraws, the later request must be re-studied to determine the
new network upgrades. As a result, cascading re-studies and queue backlogs are created, which
subsequently increase cost uncertainty and development times. Response to Staff Production
Request No. 2, 13, and 15. In the "first ready, first served" cluster approach, interconnection
requests are accepted once a year during a 45-day window. Response to Staff Production
Request No. 7. Then these requests are studied together as a cluster with equal priority.
Withdrawals in this process will not lead to cascading re-studies and queue backlogs, which
increase cost certainty and shorten development times. Response to Staff Production Request
No. 2, 13, and 15.
Fourth, from a practical perspective, it would be difficult to maintain two different
approaches at the same time, and doing so could result in unfair treatments, unfair cost
STAFF COMMENTS 3 MAY 15, 2025

allocations, and low processing efficiency. Responses to Staff Production Request Nos. 9 and
14.
Fifth, it is reasonable to use the same 20 MW threshold to divide large interconnections
and small interconnections in both the FERC interconnection process and the Schedule 72
interconnection process. Currently, the FERC interconnection process uses a threshold of 20
MW, while the Schedule 72 interconnection process uses a threshold of 30 MW. Staff believes
that it is reasonable to align the thresholds at 20 MW to avoid confusion and prevent scenarios
when interconnection requests between 20 MW and 30 MW are subject to two different
treatments. For example, without the Company's proposal, large projects under FERC will use
the cluster approach, while small projects under Schedule 72 would be required to use the serial
approach.
Sixth, despite aligning the two processes generally, it is reasonable to remove
transmission credits for large QFs under Schedule 72. FERC-jurisdictional interconnection
customers are provided reimbursement for the initial investment of Network Upgrades through
transmission credits under the FERC crediting policy. However, it is reasonable for PURPA QFs
to be responsible for the initial investment of Network Upgrades, which is consistent with the
current practice.
Given the six reasons discussed above, Staff recommends that the Commission approve
the proposed changes to Schedule 72 with an effective date coincident with the Commission's
final order in this case.
STAFF RECOMMENDATION
Staff recommends that the Commission approve the proposed changes to Schedule 72
with an effective date coincident with the Commission's final order in this case.
Respectfully submitted this 15th day of May 2025.
-V-- k,^,
Chris Burdin
Deputy Attorney General
Technical Staff. Yao Yin
I:\Utility\UMISC\COMMENTS\IPC-E-25-06 Comments.docx
STAFF COMMENTS 4 MAY 15, 2025

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 6tY OF MAY 2025,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN CASE
NO. IPC-E-25-06, BY E-MAILING A COPY THEREOF TO THE FOLLOWING:
DONOVAN E. WALKER GENERATOR INTERCONNECTION
LISA O'HARA IDAHO POWER COMPANY
IDAHO POWER COMPANY PO BOX 70
IPC DOCKETS BOISE ID 83707
PO BOX 70 E-MAIL:
BOISE ID 83707 generatorinterconnection ra idahopower.com
E-MAIL: dwalker adahopower.com
lohara Laidahopower.com
dockets(cr idahopower.com
PATRICIA JORDAN, ECRETARY
CERTIFICATE OF SERVICE