20180322Technical Hearing Transcript Vol IV.pdf

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ORIGINAL CSB REPORTING
C e rtifrc d S h o rt h an d Rep o rt e rs
Post Office Box9774
Boise,Idatro 83707
c sbreportin g@heritagewifi . com
Ph: 208-890-5198 Fax: l-888-623-6899
Reporter:
Constance Bucy,
CSR
BEEORE THE IDAHO PUBLTC UTILITTES COMMISS]ON
IN THE MATTER OE THE APPLICATION
OF IDAHO POWER COMPANY EOR
AUTHORITY TO ESTABLISH NEW
SCHEDULES FOR RESIDENTTAL AND
SMALL GENERAL SERVICE CUSTOMERS
WITH ON-SITE GENERATION
CASE NO. IPC-E-17_T3
COMMISSIONER KRISTINE RAPER (Presiding)
COMMISSIONER PAUL KJELLANDER
COMMISSIONER ERIC ANDERSON
PLACE:Commission Hearing Room
472 West WashJ-ngton StreetBoise, Idaho
DATE:March 8, 20Lg
VOLUME IV - Pages 336 181,
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BEFORE
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CSB REPORTINGWilder, Idaho 83676
APPEARANCES
For the Staff:Sean Costel.].o
Deputy Attorney GeneraL
472 West Washington
PO Box 83720Boise, Idaho 83720-0074
Eor Idaho Power Company:Liga D. llordstro
Idaho Power Companyl22l West fdaho Street
PO Box 70
Boise, Idaho 83707-0070
For Idaho Irrigation
Pumpers Association:
ilosepb I. Preston
Echo Hawk & O1sen PILC
505 Pershing Avenue, Ste.
PO Box 6tL9Pocatello, Idaho 83205
t-00
Eor Idaho Conservation
League:
llatther A. ltykie1
Idaho Conservation League
LOz South Euclid #207
PO Box 2308
Sandpoirrt, Idaho 83864
For Auric LLC and Idaho
Clean Energy Association:Pregtoa lt. Carter
Givens Purlsey LLC
601 West Bannock Street
PO Box 2720
Boi-se, fdaho 83707-2720
For City of Boj-se:.BbigaiJ. R. Gerluaiae
Deputy City Attorney
Boise City Attorneyrs Office
105 North Capitol Blvd.
PO Box 500
Boi-se, Idaho 83701-0500
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APPEARANCES
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CSB REPORTINGWilder, Idaho 83676
A P P E A R A N C E S (Continued)
For Snake River AlLiance
and NW Energy Coalition:iloba R. Bamoad
Fi-sher Pusch LLPl0L South Capitol B1vd.Suite 701
PO Box 1308
Boise, Idaho 83701
Eor Sierra CIub:KcJ'sey Jas llrraez LLCSlerra Club
920 North Clover Drive
Boise, Idaho 83703
For Vote Solar:David BeadcrEarthjustice
3916 Nakoma Road
Madison, Wisconsin 537 1L
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APPEARANCES
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CSB REPORTING
(208 ) 890-s198
INDEX
WITNESS EXAMINAT]ON BY PAGE
Timothy E. Tatum
(Idaho Power)
Mr. Nykiel (Cross)
Ms. Nunez (Cross)
Mr. Costel-1o (Cross )Mr. Bender (Cross)
Commissioner Kj ellander
Commissioner Anderson
Commissioner Raper
Commissioner Anderson
337
342
345
346
370
314
316
382
Anthony J. Yankel
( Irrigators )
Mr. Preston (Direct)
Prefiled Direct Testimony
383
386
Connie Aschenbrenner(Idaho Power)
Ms. Nordstrom (Direct)
Prefll-ed Direct TestJ-monyPrefiled Rebutta1 Testimony
Pref 1l-ed Surrebuttal Test.
Ms. Germaine (Cross)
Mr. Carter (Cross)
Mr. Hammond (Cross)
Mr. Nykiel (Cross)
Mr. Cost.ell-o (Cross )Mr. Bender (Cross)
Ms. Nordstrom (Redirect)
4L2
4]-5
473
499
5]-4
52]-
529
535
536
541
556
David M. Ange1l
(Idaho Power)
Ms. Nordstrom (Direct)
Prefiled Direct TestimonyPrefiled Rebuttal TestimonyPrefiled Surrebuttal- Test.Mr. Costel-l-o (Cross )Mr. Bender (Cross)
Commissioner Raper
Ms. Nordstrom (Redirect)
s60
563
595
651
661
613
690
695
Ahmad Earuqui(Idaho Power)
Ms. Nordstrom (Direct)
Prefiled Rebuttal- TestimonyMr. Carter (Cross)Mr. Hammond (Cross)
Mr. Nunez (Cross)
Mr. Costello (Cross)
Mr. Bender (Cross)
Commissioner Raper
Ms. Nordstrom (Redirect)
699
102
744
141
750
753
757
777
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INDEX
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CSB REPORT]NG(208) 890-5198
EXHIBITS
NUMBER DESCRIPTION PAGE
EOR IDAHO POWER COMPANY:
9 - Annual Net Metering Status
Report
PremarkedAdmitted 4t4
10 Net Metering Customer and
Stakeholder Workshop
PremarkedAdmitted 4L4
11 Hecht letter: Solar power PremarkedAdmitted 4L4
12 - Modification
Service form
to Net Metering
Ietter
Premarked
Admitted 474
13 Modification
Service form
to Netletter Metering Premarked
Admitted 4L4
L4 A Method for Determining theRelationship between SolarIrradiance & Distributlon Feeder
Peak Loading
PremarkedAdmitted 562
15 Request No. 11 and Response PremarkedAdmitted 414
t6 Statement of Qualifications,Dr. Ahmad Earuqui
PremarkedAdmitted 701
PremarkedAdmitted 701
FOR IDAHO IRRIGAT]ON PUMPERS ASSOCIATION:
301_Untitled exhibit, sponsored by
Anthony J. Yankel
PremarkedAdmitted 385
EOR SNAKE RIVER ALLIANCE & NW ENERGY COALITION:
1005 Retail Costing and Pricing forEl-ectric, Ahmad Faruqui, Ph. D.
Marked
Admitted
748
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EXHIBITS
77 Cited Rooftop PV Cost Shift
Studies
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CSB REPORTING(208) 890-s198
BOISE, IDAHO, THURSDAY,MARCH B, 2078, 1:00 P. M
record for the
COMMISSIONER RAPER: We'11 go back on the
technical hearing in Case No. IPC-E-17-13.
We were in the middle of cross-examination of the
witness Mr. Tatum. So excited to get back on the
There was a matter of Mr. Yankel testifying before
to l-eave. I want to check on the status of where
Company
record.
he had
wetre
at. It's not typical to spl-it Company witnesses. Has
the Company and the Idaho Irrigators had an opportunity?
MS. NORDSTROM: [r{e've spoken about this
and we don't have an objection to Mr. Yanke1 following
Mr. Tatum.
COMMISSIONER RAPER: Okay.
MR. PRESTON: And Madam Chairman, I
appreciate that. I would also suggest that we talked
about possibly putting on Mr. Yankel
COMMISSIONER RAPER: You're not on a mic
either. Do you have a mic?
MR. PRESTON: Sorry. We need to invest in
more mics. I spoke wj-th Ms. Nordstrom and it was also
suggested that we could potentially do Mr. Yankel right
now. We have no preference, though.
COMMISSIONER RAPER: Yeah, I think we haveo25
336 COLLOQUY
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CSB REPORTING(208) 890-s198
TATUM (X)
Idaho Power Company
a consensus of the Bench that j-s not going to spJ-it a
witness's testimony, while I appreciate the Company's
willingness to do that. I understand that Mr. Yankel
needs to get out, but I also understand that this is a
technical hearlng that was scheduled
MR. PRESTON: We thank
the accommodations being made on our
for two days.
appreciateyou and
behal-f .
COMMISSIONER RAPER: Okay, thank you.
We11, then, in
Mr. Yankel on
furtherance of the objective of getting
continue withthestand,
of Mr.
1et's
cros s -examination Tatum and we are at Mr. Nykiel.
you, Madam Chair.MR. NYKIEL: Thank
CROSS-EXAMINATION
BY MR. NYK]EL:
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Good afternoon, Mr. Tatum.
Good afternoon.
f'm Matt Nykiel. I represent the Idahoo25
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TIMOTHY E. TATUM,
produced as a witness at the instance of the Idaho Power
Company, having been previously duly sworn to teII the
truth, resumed the stand and was further exami-ned and
testif ied as f oll-ows:
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Conservation League and I've got just two l-ines of
questions, and in the interest of time and efficiency, I
would appreciate it if you answer them concj-sely and
answer only the question I'm asking. Your counsel will
have plenty of opportunity to allow you elaborate if you
need that. The first question is Idaho Power has asked,
obviously, the Commission to reclassify a partlcular
segment of customers, and earli-er you stated that this
reclassification is the first step in addressing the
differences in usage characteristj-cs among residential
and smal1 general servj-ce customers with on-sj-te
generation; right?
A That sounds generally like what we
discussed, yeah.
O Okay, and I apologize, I'm just
reiterating a littl-e bit to lay some foundation.
A Okay.
0 And I bring this up because I want to
better understand why this first step is necessary at
this point, and you've already indicated that the
Company's application states that the reclassifj-cation
alIows Idaho Power to gather data necessary to understand
how this customer segment utillzes the Company's system;
is that right?
A We had a discussion earlier where we
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CSB REPORTING(208) B9o-s198
TATUM (X)
Idaho Power Company
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CSB REPORT]NG(208) 890-5198
TATUM (X)
Idaho Power Company
talked about the Company having data on al-.1- of its
data regarding billing j-nformation and usage for all
customers and that the Company has asked the Commission
to make what the Company believes is an important policy
decisj-on with regard to classification of customers to
inform the next steps
those next steps.
A Let me
and the analyses to be incl-uded in
just direct
can maybe dj-rect you back to the
just to refresh a little bit, and
there. Irm looking at paragraph
begj-ns with "Establishing. "
A I'm there.
a So earlier we went
read that sentence until- the next
you, if you can if I
application at page 9
let me know when you're
15 and the sentence that
over this and why don't
page where it endsyou
with ttsystem. tt
A "Establishing separate customer classes
now will posj-tion the Company to study this segment of
customers, providing data necessary to understand how
this customer segment utilizes the system. "
O Thank you; so is it right that it's the
Company's position that gathering this data is necessary
to understand how this particular customer segment
util-izes the Company's system?
MS. NORDSTROM: I believe that this lineo25
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CSB REPORTING(208) 890-s198
TATUM (X)
Idaho Power Company
of questj-ons has been
sure what additional
exhausted this morning. I'm not
He's tal-ked about the first step.
you're seeking to get.
He's talked about the
fact that the Company has the data, but that we need to
define what the class is before the data can be used. Is
there something more to provide here?
MR. NYKIEL: Yeah, so earl-j-er Mr. Tatum --
I was unclear. He distinguished from what I could hear
the difference between the data that the Company had on
indivj-dua1s and I wasnrt clear whether he was saying that
fdaho Power could only use that data to understand how
individuals use the system and not particular segments
and I didn't have cl-arification on that earlier and I
just wanted to,.l-ike, build a foundatlon so we get back
to there and make that clear.
COMMISSIONER RAPER: Great. Go ahead.
Thanks.
O BY Mr. NYKIEL: So I'11 just I just
want to make sure we're on the same page that it's your
position that the Company gathering this data, the
Company gathering this data, is necessary to understand
how a particular customer segment util-izes the Company's
system.
A The request is to define the segment. The
Company has, my point earlier was that the Company has,
information
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data on i-ndividual customers that can be aggregated and
segmented in an infinite number of ways. What the
Company has asked is that the Commj-ssion recognj-ze the
very different usage characteristics associated with the
segment that we've identified and recl-assify or classify
that segment for ratemaking purposes into the future.
O Okay; so just to be c1ear, it sounds like
from what frm hearing you say that the Company has the
data and the capability with or wlthout this
reclassification to understand how residential- and small-
general service customers use Idaho Power's system; is
that right?
A Yes, we have load research data that is
dedicated to that type of research.
O Okay, thank youi so just moving on to my
last set of questions, Idaho Power is requesting that the
Commission, as we've gone over, reclassify a particular
segment of customers and earlier, you described this as a
policy decisioni is that right?
A That's right.
O Okay, and Idaho Power j-s asking the
Commission to make this policy decisionr ds you describe
it, before conducting any other methods of analysis, such
as cost causation, that would justify yes or no on the
policy; is that right?
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CSB REPORTING
(208 ) B9o-s198
TATUM (X)
Idaho Power Company
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CSB REPORTING
(208 ) 890-s198
TATUM (X)
Idaho Power Company
A I testified that a cost of service study
at this point in time isnrt necessary to inform the
decision that we're asking the Commission to make, "we"
being the Company.
MR. NYKIEL: Thank you. No further
questions.
COMMISSIONER RAPER: Thank you, Mr.
Nykiel, for being clear and concj-se. We have next
Mr. Ol-sen.
MR. PRESTON: ft's Mr. Preston, Joseph
Preston.
COMMISSIONER RAPER: Oh, my apologies.
MR. PRESTON: Irm f1I1ing in for Mr.
O1sen, but I have no questions at this po j-nt.
COMMISSIONER RAPER: That's why you didn't
answer to Mr. Olsen earlier when I said it. Preston
Carter and Mr. Preston. If I screw that up, you guys
straighten me out. Ms. Nunez, Slerra CIub.
MS. NUNEZ: Thank you.
CROSS-EXAMINAT]ON
BY MS. NUNEZ:
O Mr. Tatum, if a
study did show a cost shift was
comprehensive cost-benefit
occurring, just for theo25
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CSB REPORTING
(208 ) 890-s198
TATUM (X)
Idaho Power Company
sake of argument, are there other policy approaches that
to address the fixed costtakencould potentially be
recovery j-ssues you
creating a new rate
described that do not require
clas s ?
solutions
presented
solution,
be taken
other states that used any of
that you are familiar with?
A I'm generally
think, for the Company would
information. Hers much more
on natj-ona11y in this
A I thi-nk that there are l-ots of different
that could be considered. The Company has
its, I guess
but rather a
I wouldn't even charactertze as a,
process and the steps that should
to inform those decisions.
O Are you familiar with deci-sions made in
the alternative approaches
familiar, but Dr.Faruqui, f
for thatbe a better source
one, just
there, is
cl-ass may be
necessarily a
cost shift?
A
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O Okay,
given that
it fair to
well aware of what's going
regard.
thanks.Just a final- point on this
there are potential approaches out
say that while creating a new rate
Idaho Powerr s
prerequisite
clear preference, is it not
to remedying an appropriate
littte bit more
No, 1t's not
Thanks, and
about the
a prerequisite.
we'11- talk with Dr. Faruqui a
details on that.o 25
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CSB REPORTING(208) 890-s198
TATUM (X)
Idaho Power Company
A Okay.
O One more question; so on page 26 of your
rebuttal testimony, you state that the Staff's proposed
compensatj-on method with the DSM alternative cost as an
export rate "would make a reasonable interim value for
the net excess generation. " I was just wondering if you
could please clarify whether the Company has expanded its
original request to postpone any rate changes to now
seeking a different interim compensation rate for net
meterj-ng customers?
A Yes, my
the Commission accept
Company belj-eves that
testimony was recommending that
the Staff's recommendation and the
it is a reasonable it's
further than what
case, I think, but
does partially --
the Company is recommending in
itrs a reasonable step and I
a step
this
think it
it woul-d partialJ-y address some of the
cost shift concerns that the Company has. I've al-so
testified that it's not a complete solution.
MS. NUNEZ: Thank you.
THE ViTTNESS: You're welcome.
MS. NUNEZ: No further questions.
COMMfSSIONER RAPER: We'II go right across
the front. Mr. Costello first.
MR. COSTELLO: Thank you.t 25
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CSB REPORTING
(208 ) 890-s198
TATUM (X)
Idaho Power Company
CROSS_EXAMINATION
BY MR. COSTEL],O:
O Mr. Tatum, I just have one poi-nt of
clarif icati-on I'd like to make.
A Sure.
O You stated earlier, and I may misquote
you, but approximately, usage of the system j-s masked by
the netting effect; is that correct?
A Under net metering rate design, yes. The
gross consumption of a net metering customer is masked by
the netting.
o
netting, you're
correct?
A
o
Okay; so when
referring to
you're referring to the
monthly netting; is that
Monthly netting,
And so wouldnrt
correct.
Staff's
that shift to hourly netting, wouldnrt
proposal to take
that alleviate or
wouldn't that accurately represent usage of the system or
of the grid?
A The best wou]d be instantaneous and so the
closer you get to instantaneous netting the better. As
I've mentioned, I think Staffrs proposal is a reasonable
step to addressing cost shifting; however, more needs to
be done on the rate design side of the issue, not just25
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CSB REPORTING
(208 ) 890-s198
TATUM (X)
fdaho Power Company
the compensation
MR
THE
for net excess as Staff proposed.
COSTELLO: Thank you.
WITNESS: You' re we.l-come.
COMMISSIONER RAPER: MT. BendeT.
CROSS-EXAMINATION
BY MR. BENDER:
O Good afternoon.
A Good afternoon.
0 I have just a few clarifyj-ng questions.
Fortunately, most of my questlons have already been
asked.
A
o
applicat j-on
on are based
right?
A
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A
please?
Okay.
I think you said today that your
and the load shape analyses that it's based
on net metered customers' load data; is that
Where did I testify to that?
Sitting right there this morning.
Okay, can you restate your question,
O Sure. The
this
load data on which you base
case is net metered customeryour application in
load data. That's the category of customers of load datat
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CSB REPORTING
(208 ) 890-s198
TATUM (X)
Idaho Power Company
that you're basing -- maybe I need to clarify. ft's a
comparison of net metered customer load data to non-net
metered or the entire class load data. Those are the
categories
that right?
A
of data that the application is based on; is
analysesr so
Faruqui used
Yes, it was my -- I did not prepare those
I need to clarify that. Mr. Ange1l, Dr.
the data and prepared the exhibits that do
the usage comparisons; however, my understanding of the
usage data is associated with Idaho Power customers who
are residential- and smal1 general service customers with
on-site generation and those without on-site generation,
historical- data.
O And the category of wlth on-site
generation are the customers taking service under
Schedul-e 84?
A Yes, currently all customers for Idaho
Power of Idaho Power with on-site generation currentJ-y
take service under Schedule 84.
O Which is net metering?
A That is our net metering service,
correct.
O Right, and those customers are the ones
with the bi-directj-onal- flow of electricity?
A Yes.o 25
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CSB REPORTING(208) 890-5198
TATUM (X)
Idaho Power Company
o
definition is
that right?
A
small general
f ask because the proposed cl-ass
any customer with on-site generation; is
That fits within that residential- and
service classifi-cation. I believe that I'd
have to look at the specific provisions within the
proposed
better to
generation,
are l-isted
not open
certain
schedule and Ms. Aschenbrenner woul-d
speak to this, but I do bel-ieve it
same eligibility
currentl-y exists
probably be
is the
criteria for
for Schedule
same -- we're proposing the
the new cfasslfication that
84, and that is to al-l types of on-site
of on-site generation that
schedul-e.
but
within that
types
service
O And so it would just be customers who want
a bi-directional flow of electricity?
A It would be any customer who has on-site
generation that fall into those categories. We have not
experienced any customers that fit into that category
that don't have a bi-directional fl-ow.
O Right.
A That has not been our experiencer Do.
O But the way that the proposed tariffs are
designed, a customer with, sdy, battery storage who uses
al-I of their electricj-ty on their side of the meter and
doesn't send any back to the grid, that customer would beo25
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CSB REPORTING(208) B9o-s198
TATUM (X)
Idaho Power Company
included in the new customer class as the Company
proposes it; right?
A That's correct, and f think that's
appropriate. Given the netting effect within that
service offering, they would sti11 be netting under our
proposal, they would still be netting on a monthly basis
and in order to I think j-t would stil-l- be appropriate
to segment them separately.
0 I don't understand your use of the term
"netting. " I thought we already tal-ked about how netting
is the bi-directional- which credits exports, but you're
using it to mean any offset of electricity generation
behind the meter?
A Thatrs right, yes, and I think thatrs
important to consider as well.
O And you don't have any load
customer with
data for what
a load shape for that type of battery
storage and no
A
Company having
o
I do not, oo, and
any such customer
Right, and so the
I'm not aware of the
to evaluate.
Commission has no data
exports looks like; is that right?
to compare a load shape of
customer to an average or
Ioad shape?
a storage with a solar
other non-generating customer's
A I don't know if they do or not, but theo25
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CSB REPORTTNG(208) 890-sr-98
TATUM (X)
Idaho Power Company
Company
in this
doesn't possess that and we haven't presented it
case, because we dontt possess it.
clarify where we
of di-scussion in
O f al-so wanted to
cost of service. There's a l-ot your
testj-mony and in other Company testimony about the cost
to serve and recovery of fixed costs and cost shifts;
right?
A Correct.
O And then in your rebuttal, surrebuttal-
testj-mony, and here today, f thought I heard you say that
you're asking the Commission create new customer classes
without consideration of cost of service.
A That's correct.
O Okay, but you also testified that the
Commission can consider cost of service when creating new
customer classes.
A Absolutely.
O And the cases and orders that wef ve tal-ked
about already today all included consideration of cost of
service in the consideration of new customer classes?
A I think it was more in the I would read
it as in the
cl-ass, which
was described
context of rate setting in that new customer
is not what we're proposing now. I think it
a1l- as establishinq classes and rates at
We're suggesti-ng, the Company is
are on
the same time.I 25
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CSB REPORTING(208) 890-s198
TATUM (X)
Idaho Power Company
suggesting, a segmented approach and this first step does
not need to be informed by a class cost of service.
Before rates are implemented, I wou1d very much suggest
that we have a cl-ass cost of service to inform any
different rate structure or dj-fferent rate design or
compensation structure.
O So your clarification is that the prior
orders and court cases invo1ved settj-ng rate classes and
rates at the same time?
A I think the context of the discussion was
pointing to that approach rather than what the Company is
suggesting. The Company is suggesting one step, not that
all of those steps wouldn't be taken prior to any change.
It's just in this case, it is that first step.
O And rates are set based on costs as one of
the components of
that; right?
A Not
rate setting; you'd agree with me on
always, but I think that would be our
preference,
0
y€s, the Company's preference.
So i-n those other cases where rate classes
a cost of service study was available to
and rates were set, costs were considered in those cases;
is that fair?
A Where rates were set as part of a prior
inform; isCASC,
thato25
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CSB REPORTING
(208 ) 890-s198
TArUM (X)
ldaho Power Company
MS. NORDSTROM:I'm going to object.
and whether cost ofabout hypothetical-s
considered in unnamed cases that haven't been
This
How can this witness answer this question?
MR. BENDER: He
COMMISSIONER RAPER: Go ahead.
MR. BENDER: He cites in his testimony an
Order and a case that were asked about earlier,
Homebuilders and an
i-s talking
service was
specified.
testimony,
about those
testimony.
the line of
Order number, whj-ch I
back and forth we had,
can find in his
I thought, was
his
and the
two cites that he provided j-n
COMMISSIONER RAPER: Can you give him a
to continueplace in his testimony to refer to
questioning?
BY MR. BENDER: So Mr. Tatum, you have
your rebuttal testimony in front of you?
A I do.
MR. BENDER: Trm not going to be able to
find it on the spot.
COMMISSIONER RAPER: If you were to ask
with a 1itt1e more specificity about what you're getting
at and why -- oh, look, a helpful attorney.
O BY MR. BENDER: A11 righti so your
surrebuttal on page 3, Iines 1l- to 13, cites
in order
O
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CSB REPORTING(208) 890-s198
TATUM (X)
Idaho Power Company
"historically, " and then it talks about a ratemaking
process. Do you recall- that?
A
o
A
o
Yes.
Okay,
Yes,
That
and that ci-tes to Order 26180?
Footnote 2
case involved rate setting that
need to have classes estab]ished to
looked at cost as part of it, as part of the process of
setting customer cl-asses; is that faj-r?
A You know, Ird have to look back at that
Order and read exactly what it said with regard to the
specj-fic context that you're asking this questi-on. I can
speak to the intent of the testimony, which is to
describe what process has been put in pIace. My
experience with class cost of service studj-es and rate
design is that you
then study the cost
experience and I've
that approach with
wj-tness presenting
Commission as weII,
of serving that cl-ass.
applied that approach
It's been my
and have fil-ed
this Commission and have been a
that information in front of this
so there are rate cases where we've
customer classes, that we start with a customer
class had already been established, and we do
presented
class, the
a cost study that
particular cl-ass.
is ultimately recommended
then looks at the cost to serve that
It then informs the rate design that
for the Commission'so25
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CSB REPORTTNG
(208 ) 890-s198
TATUM (X)
Idaho Power Company
consideration.
O So to recap, the Commission can consider
cost of service of your testimony is they don't need
to and you're asking them to create a class in this case
without consj-deri-ng cost of service?
A I think thatrs a fair
O In your testimony at
places, you referred to the question
Commission as whether customers with
recap.
several different
before the
on-site generation
requirementsf ul-1are fundamentally different than
customers.
A Yes, based on the
their usage characteristics.
nature of their usage,
O Right, and you paraphrase that several-
different places as whether they're distinctly different,
whether they're fundamentally different, but that's the
same general concept; right?
A I think thatrs right, yes.
O So the threshold is fundamentally
different and based on usage characteristics?
A The difference is based on their usage
characteristics as compared to the broader residential-
and sma11 general service classes.
O But nowhere in your testimony or in the
Company's case that I can find do you provj-de a threshold25
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CSB REPORTING(208) 890-s198
TATUM (X)
Idaho Power Company
of where a difference goes from just normal diversity
within a large customer cl-ass to fundamentatly di-f ferent.
A No, I haven't identified that threshold,
but we have suggested that regardless of where you draw
that threshold, werve passed it with regard to their
usage characteristics.
O If I'm looki-ng for an objective,
non-dj-scriminatory basis to carve out one class and not
others or r for example, I think your testimony today was
the Company is considering creating other customer
classes in the futurer So if I'm wanting to apply a
consistent standard in those future cases for when to
carve out a separate class, therers no threshold
objective standard presented by the Company in this case
that I coul-d apply?
A Well, what can be applied is a review of
the information, the data, the charts that the Company
has prepared and presented that demonstrates a
sj-gnificant disparity that warrants consideration of a
di-f f erent class. There are dif f erent threshol-ds that are
applied to segment customer cfasses
current tariff. We have thresholds
within the Company's
based on energy
demand. Weconsumption. We have
have threshol-ds based
threshol-ds based on
on or cl-assifications based on end
use.I 25
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CSB REPORTING
(208 ) 890-s198
TATUM (X)
Idaho Power Company
In this case, we're identifying a
customer, a segment of customers, who elects to have
their own on-site generatj-on, to supply their own
generation that resul-ts j-n dramatically different
characteristics that we think warrant a different
cl-assr ds well as likely we are at least pointing
a different rate structure in the future.
usage
rate
towards
O Let me back up a l-ittle bit.
identified a class based on whether
You said
they have
but then
you've
on-site generation. That's the
A Residential and
definition,
small general with on-site
generation is the designation.
O And then you're justifying segmenting that
group based on a difference in load characteristj-cs, and
I'd agree with you that you created a standard for the
definition, but what Irm asking for is where i-s the
standard for the threshold? When has that group crossed
the distinctly different threshold as opposed to some
difference, but yet within the natural- distribution,
dj-versity distribution, in a rate class of, you know,
roughly a hal-f million people?
A I think one distinction can be when they
installed on-site generation that lnterconnected to Idaho
Powert s system.
O You're giving me the definition for theo25
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CSB REPORTING(208) 890-s198
TATUM (X)
fdaho Power Company
class sti11, not the threshold for when that cl-ass is
sufficiently dj-fferent to justify segmenting them out.
A I'm giving you the cause and the effect.
The cause is on-site generation and the different usage
characterj-stics is the result. The result is problematic
when applied to the current rate design for those
customer cl-asses on a netting at the retail rate, So it
is different usage characterlstics resulting from the
instal-lation of on-slte generation. Mr. Angell and
Dr. Earuqui have both presented information under that
designation that shows the disparity in usage
characteristics .
O
I agree
They show
with you
the difference in the load
on that, but they don't identify,shape,
unless you can teIl me where I can find it, they don't
some differenceidentify the threshoJ-d, so there's
between an average of one group and an average of another
group, a subgroup, actually, and thatrs whatrs in their
testj-mony; is that right?
A The difference is physical. It's a
generation of energy that offsets consumption and doesn't
allow for, under a one meter approach doesn't al-l-ow for,
the measurement of the true consumption and util-ization
of the Idaho Power's servi-ces. Thatrs what we've
presented in this case. That's the threshold and we'veo25
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CSB REPORTING(208) 890-5198
TATUM (X)
fdaho Power Company
demonstrated that when you look at that class or that
segment, they have distinctly different usage
characteri-stics .
O Right, and j-t's that last part If m asking
about. How do we know that that is distinctly different
as opposed to within the so if we l-ook at the
resj-dential cl-ass as a whoIe, right, within that, there
will be lots of different Ioads. There will be high
users and low users; right?
A Yes.
A There wiII be seasonal users and
year-round users; you agree with that?
A Sure, y€s.
O Therers electrj-c heat and
who have other natural- gas or wood heat.
different load shapesi do you agree with
A I ag.ree there will be lots
load shapes within the residential group,
o
million Iines,
Right, and j-f
there's people
Those will have
that?
of different
yes -
we graphed all of them, half
like spaghetti and every
have a different l-oad shape;
it would look
single
do you
customer is going to
agree with that?
A Sure, sure.
O So within
A I would say that when you look at theo25
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CSB REPORTING(208) 890-s198
TATUM (X)
Idaho Power Company
cl-ass as a whol-e, that's
information on the class
have on-site generation,
what we've presented is
as a whole. Customers who don't
we've shown their load profile,
on-site generation,with customers who havecompared it
and they're very different and that's
we're trying to make. Each individual
to have his or her
We donrt design or
customer basis. We
shape that
rates on
the point that
customer is going
will be different.
an individual
own load
implement
do it on a segmented basis for
administratj-ve efficiency. What we're suggesting here is
the segmentation that we've discussed quite a bit and I
think I've answered what the Company is proposing as the
distinguishing characteristics .
O On-site generation being the
distinguishing characteristic?
A Absolutely, and thatrs the title of the
servj-ce schedul-e that we've proposed, residential
customers with on-site generati-on.
O And theyrll have a different average than
the other half million customers on average?
A Absolutely, yeah, and that's the
lnformation that Mr. Angell presented that they do have a
different average hj-storicaIIy.
O I think we agreed that other subgroups, if
we parceled out that residential class into other25
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CSB REPORTING
(208 ) 890-s198
TATUM (X)
Idaho Power Company
subgroups, they woul-d
the entire group as a
that?
also have a different average than
whol-e average; do you agree with
A Yes, you could segment j-n an infinite
number of ways and potentially come up with different
I don't bel-ieve that I'veaverages.
that would
average. I suppose
you can sl-i-ce it a
suggest that those other
seen any information
segmented averages
the cl-ass overa]I
segment gets, perhaps
would be dramatically different than
the smal-ler the
number of different ways, yeS.
O And to your €ye, you haven't seen any
thatrs dramatically different; right? That's your
testimony?
A Dramatically different other than those
that have been demonstrated as different having on-site
generation.
O Right, but you haven't identified the
yardstick that we can use to say net metering customers
are above the l-j-ne, that's dramatically different. These
other load shapes which are different than the entire
group as a who1e are different, but they donrt rise to
the 1eve1 of being dramatically different, distinctly
different, or fundamentally different to justify a new
load cfass.
A Yeah, and, aIso, I think it's important toI25
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CSB REPORTING
(208 ) 890-s198
TATUM (X)
Idaho Power Company
point out that none of them have on-site generation.
own l-oadThey I re
service.
not generating a portion of their
They're taking 100 percent of their service
from Idaho Power. I think thatrs an important
distinctlon. f't's the distinction that we're asking the
Commission to consider.
O You also discussed in your rebutta1 pages
21, and 22, you kind of summarize the Company's case on
the load characteristic dj-fferences; right?
A Can you repeat the page?
O Rebuttal pages 20 to 22. You're talking
about pattern of use differences.
A
Mr. Ange11's
o
Dr. Faruqui's
discussion?
A
o
Yes, I
analyses
summarized what my understanding of
demonstrated.
Then going
analysis as
on to page 23, you summarize
well as part of that same
at the top of page 23.
so you looked at l-oad factor,
coincident demand, Ioads at
the l-oad
l-oad categories
inform cost
profile, the system
non-coincident demand or
you looked at; right?
A Those are
that or usage
assignment for
categories
Yes,
And
the group
NCD. Those are the categories
categories, yesr
that are used to
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O And in all of those analyses that the
Company did, the Company uses the exported electricj-ty
from net metered customers to reduce thelr group load; 1s
that right?
A I didn't perform the analysis, but that's
my understanding and the reason for that is that's the
way that those customers are biIled. They're bil-l-ed on a
net basis, so not including exports or their own
generation woul-dn't give an accurate pj-cture with regard
to how those customers are billed. This is about bilJ-ing
at the end of the day.
O If we wanted to know what those customers
look like from their imports, the electricity they
receive from the Compdny, and we caII that their load and
we want to compare that, what they've recej-ved from the
Company, to loads received from the Company by customers
without on-site generation, the Company's analyses in
this case do not make that comparison; is that fair?
A The Company doesn't -- we mentioned this
earlier, the Company doesn't measure that. The Company
only measures net consumptj-on.
O The Company only measures net consumption
and bil1s on a monthly basis?
A Thatrs correct.
O But you have bi*directional- metering?
CSB REPORT]NG(208) 8e0-s198
TATUM (X)
Idaho Power Company
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CSB REPORTING
(208 ) 890-s198
TATUM (X)
Idaho Power Company
A
metering that
that capture
o
into someone's
Bidirectional- metering? We don't have
captures gross consumption. We have meters
net consumption.
Do your meters capture el-ectri-city flowing
house on one channel and el-ectricity
flowing out of the house on another channel?
A No.
O They don't?
A I don't believe so, nor and I'm not the
expert on metering, but what I do know is that our meters
are capturing and recording net consumption, not gross
consumption, so we would have to have a separate meter,
physically have a separate meter, measuring consumption
and then a separate meter measuring generation in order
to know what the customer's utilization is of our system
on a monthly basis.
O So you only measure the net, the meter
only records the net?
A
o
A
basis, but it's
monthly netting
O
That's right.
And what time
WeII, w€ have
not used for
period is that recording?
net recordings on an hourly
billing purposes. We use a
approach.
Let's tal-k about the data you have, the
Ioad data you have.a 25
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CSB REPORTING(208) 890-s198
TATUM (X)
Idaho Power Company
A I think when
granularity of data and how
f'm not testifying to that.
testimony of Mr. Angel1.
you're getting
it's measured
That's why we
into the
and metered,
presented
O So all your testimony previously today
where you said you don't measure gross load or net load,
we should just assume that was all talking about monthly
billing?
A That's how we bitl net metering customers,
on a net monthly basis.
O And you do not know if the Company records
load data on an inflow and outflow basis on an hourly
basis or even a smaller time period?
A No, we record the data on a net hourly
basis, netr so consumption net of generation on an hourly
basis i-s recorded. There isn't an outf]ow and inflow
recorded separately in our meters.
O Do you know if your meters are capable of
that?
A I donrt know if they're capable of it or
not, but that is not the way that they're utilized
today.
O So we would know at least on an hourly
basls if there's a net import or net export for that
hour?o 25
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CSB REPORTING(208) 890-s198
TATUM (X)
Idaho Power Company
A We have data that would tell us that, yes,
but we wouldn't know what the actual hourly consumptj-on
is. We wou1d only know the net hourly consumption or net
generation for that matter.
O And so if we
net and look at just those
hourly net was positiver so
right ?
wanted to compare an hourly
hours where the customer's
from the Company durj-ng that
they were consuming power
hour on a net basis;
net consumers
Okay.
So we could look at that?
Yes, you could look at whether they were
or net generators on an hourly basis
the Company's records.
And so we could
A
o
A
according to
o look at just those hours
and compare it to loads ofwhere they were a net consumer
the non-on-site generation residential- and small- general
service class?
A You could make that comparison. I think
it would have to be done carefully, because it would
still- not show gross consumption on an hourly basis. It
would only show net consumption on an hourly basis;
whereas, the non-net metering customer would show gross
consumption on an hourly basis. Thatrs an important
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CSB REPORTING(208) 890-s198
TATUM (X)
Idaho Power Company
O I understand, because thatrs the metering
limits that we're dealing with; right?
A
currently have
it's a limit.
ftrs the metering practice that we
in p1ace. I'm not going to agree that
I don't know if it's a l-imit or not. I
just know that's how we measure it,
consumption and generation.
a Right, and the only
make this distinction is that's not
Company did. The Company looked at
there was gross
in the load for
A
load we're still
how we measure
reason I'm trying to
the analysis the
exports, hours where
exports net exports and included that
the net metered customer class?
The Companyrs analysis was to l-ook at a
talking about load factor; correct?
O Sure, we can talk about load factor.
A WelI, that's where we started. I'm just
wondering if we're still- there cn load factor.
O Well, we were talking about load factor
and then l-oads at system coincident and non-coincident.
Those were the three categories I thought we had talked
about and within that, we're tal-king about how those
analyses were done.
A
Ange11. He
view of his
Again, that
conducted those
conclusions, but
would be better asked of Mr.
analyses.
if you're
f summarized my
asking about thet25
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CSB REPORTING
(208 ) 890-5198
TATUM (X)
Idaho Power Company
detailed methods and the underlying data, he wiII be
available for cross-examination. You're wel-come to ask
him questions. If you want to hear my understanding of
the resul-ts and why they were j-mportant for this
Commj-ssion to consider, I'm happy to share that.
O We}1, I was asking you, because you shared
the results in your testimony, f was just asking you if
you knew how the analysis was done.
A I just described generally how j-t was
done, I think, to a pretty sufficient level- of detail.
O And how it was done was looking at
exports?
A Looking at the measured imports net and
measured exports net to determine what the customer's or
what that group's, in the case of load factor what that
group's, Ioad factor is as it relates to how we bill them
on a net basj-s. They're billed on the basj-s of net
consumption and net generation. We apply the retail rate
to those measurements on a monthly basis.
O The load shapes are based on hourly
data?
A I believe the load shapes were based on
hourly data,yes.
Ino
Ioad
those hourly data used to create the
Company' s shapes, hours with net exportso25
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MS. NORDSTROM: I would ask that these
questions be directed to the witness that actually
performed the data or performed the analysj-s. Mr. Tatum
has explained his understanding and he was providing a
summary of the points that resul-ted from the analyses
conducted, but when we're getting into this granularity
of how studies were performed, I think it's appropriate
to ask it of the wj-tness that performed the analysis.
MR. BENDER: He presents the results in
his testimony. We just talked about how they're done. I
thought this was just a clarifying questj-on. I thought
we had already walked through how it was done. It's done
hourly. Itrs done on a net basis and I think --
THE WITNESS: I've clarified as much as I
can clarify based on what I understand Mr. Ange11
performed or the analysis he performed, but he w111 be
avaj-l-able to clarify in great detail for you as soon as
he comes up.
MR. BENDER: Thatfs fine.
COMMISSIONER RAPER: I thinK that the
information that yor:'re looking for is from a different
witnessr so to the extent that you're unfamiliar with
kind of how this goes, I don't think you've been before
us, whether you've been before other commissions, but
Mr. Tatum, if another expert testified in more detail,
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oftentimes they will
answers. I beli-eve
also beli-eve that Mr. Tatum
to the best of his ability
questions, so can you wrap
MR. BENDER:
his statement now that he
defer to the witness that has the
that you will get your answers, but I
don't need to probe any further, so
COMMISSIONER RAPER:
has testified multipl-e times
in an attempt to answer your
it up in a pretty bow?
That's fine. I'l-l- just take
testified what he knows, so I
thank you.
Thanks.
is not an attempt
Room to inhibit
as such. Thank
MR. BENDER: I won't ask any other
questions as weII. Thank you.
COMMISSIONER RAPER: It
by this court or anyone in the Hearing
your ability to ask questions, sir.
MR. BENDER: Not taken
you.
COMMISSIONER RAPER: Thank you, Mr.
Carter, for helping with the document. I think that that
exhausts until we get to redirect, are there any
questions from the Commissioners?
COMMISSIONER KJELLANDER: I have one,
maybe two, hopefully just one.
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EXAMINAT]ON
BY COMMISSIONER KJELLANDER:
O It does sort of connect to what Mr. Bender
was getting at. I guess I'd like some clarification. As
I've l-istened to the testimony, it appears that much of
the argument I've heard or read for a separate customer
class focuses on the two-way of rooftop and metering
customers, and so letrs assume, and I'm going to use t.he
word "assume" because I can, I'm a Commissioner, 1et's
assume that I buil-t a brand new home and my mlnimum l-oad
is 50 kW and I have a 40 kW maximum solar panel system
that's buiLt with this property, and it's never going to
exceed my minimum Ioad, and so I'm never going to be
putting energy j-nto the grid, so f'm not reaIly impacting
it from a bi-directional basis. Am I considered a net
metering customer under the new scenario that's being
l-aid out for the di-fferent customer cl-ass?
And I guess as part
just so I can make it seem like one
scenario any different than me just
of that same question
question,
being very
how is that
good at
again,energy
since
or two-way?
A
efficiency and demand-side management,
I'm not with anything in a bi-directj-onal- fashion
Okay; so I guess the way that I wou1dI25
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answer that question is with on-site generation being
measured through one meter, when we net as we do on a
monthly basj-sr w€ donrt get a good picture of how, 1n
your scenarj-o how, that customer or to the extent that
that customer is using the grid throughout the month,
because once that generation is layered on top of the
consumption data, it could net to zero.
Even though you as a customer took
services from the grid aII month 1ong, our bil-Iing data
suggests that you didn't at all. t{ith energy efficiency,
if you reduced your consumption to near zero, the
util-ization of the grid over that month would be near
zero, because there's no netting. There's no consumption
that's bej-ng overlaid or I mean no generation that's
being overlaid onto the consumption, and so the it is
the netting that is problematic from a billing
perspective when werre using volumetric rates as the
basis of collection of costs.
O I guess Irm really not tracking with you
on that one point there, so l-et's say that I get reaIly
good at conservation, as wel-l as energy efficiency and
demand-side management, and fet's say that I finally
figure out how to talk to Al-exa and I have al-l- the smart
stuff I can possibly have and it's smart enough to the
point where when I leave I say, "Alexa, turn off anything
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that has anything remotely related to phantom power, " and
she somehow understands me and everything gets shut off,
except for whatever the bare mj-nimum is.
Let's assume I have the most energy
efficient water heater that's on demand, so f don't have
to keep anything fired up in order to keep that water
hot, especially slnce nobody is home, and then when I
come back in I say, "Alexa, kick on the stuff I needr "
and I've basicall-y gone TO zero during that time of the
dry, which, oh, by the wdy, just happens to be when we
see the curves associated with when sol-ar is. Again, if
I'm not putting anything into the grld, how am I any
different than somebody in five to six years who is going
to be extraordinarily efficient based on the technology
that supposedly is coming down the pike? I guess frm
wondering if in fact that's considered to be net metering
when in fact I'm not touching tl-re grid in any two-way or
bi-directional flow why that shoul-d be characterized as
something unJ-quely different than what we're likely to
see going forward.
A Yes, I think the difference is -- weII, if
a customer is completely disconnected from the grid, then
they're not taking service from us, obviously, so it
would be a non-issue, but those who are connected and
taking service under net metering as it exists today,
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during that hour or two that you suggested you might be
gone, Lf the generation over that two-hour period exactly
matched the consumption, it woul-d suggest that there was
no utilization of the system even though there was during
that period, so letrs say they used -- they had
consumption of 1-0 kilowatt-hours over a two-hour period
and generation of 10 kilowatt-hours over that same time
period, the measurement for bil-l-ing purposes under net
metering would be zero, and because we compensate at the
full- retail rate, that customer would have been
compensated for that energy based on the cost of Idaho
Powerrs system rather than the value of the energy that
they producedr So we have a problem from a rate design
perspective applied to net measurement of consumption and
generation, so when I tal-ked earlier about masking the
actual- util-ization of the system, that example, I think,
illustrates what Irm talking about j-s you'd have l-0
kilowatt-hours worth of consumption that at the same
time consumption that required the wires and poles and
generation units to be there to exist to serve them and
yet, because we offset with that l-0 kil-owatt-hours, the
customer would pay nothing for those poIes, wires,
generation stations that were actually there serving them
during that two-hour period.
COMMISSIONER KJELLANDER: Yeah, I'm not
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Idaho Power Company
going to
leave it
get the answer to my questi-onr so I'm going to
a1one. Thanks.
COMMISSIONER RAPER: Commissioner
Anderson.
EXAMTNATION
BY COMMISSIONER ANDERSON:
O Thank you, Mr. Tatum, very much. You
mentioned that this j-s rea1Iy about billing at the end of
the day and I fol-low that and when I try to look at this
thing, I try to find out what's the perfect world, then,
if it's about billing and trying to figure out the proper
way to do that, and the methodology that we're using i-s
volumetric billing and when you're using volumetric
bi11ing, so much of that is hidden in kW. Itrs in the
amount of usager so am I wrong in thinking that to fix
this problem, if everybody across the entire class paid
the same fixed rate in a base, that would sofve what the
cost of the plant is? Wouldn't that solve that problem,
and then the kilowatt usage going in or out wouldn't
matter if everybody paid the same amount for the fixed
cost of plant?
A Through a fixed charge rather than a
vofumetric charge, I thinl< that would address it, yes.25
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Idaho Power Company
O Okay, thank you, but that's what I'm
having a hard getting my arms around, because that seems
simple to me and maybe itrs not. Itrs probably very
complicated, but if you have a number that's out there,
$60 bi1lion or whatever the number is, and you divide it
by the numbers of each cl-ass individually and you put
that on their bill, you've so1ved al-l the problems of
trying to do volumetric col-l-ection. I mean, you don't
have that anymore. You're charging the same amount for
every kilowatt. There's no hrdden fixed cost in any
kilowatts; is that correct?
a different wdy, I think, that
unbundled our current volumetricyou're describing,
rate desi-gn and had
ATo put it
if we
higher fixed charges or demand
charges or some combination for al-1 customer classes,
then, y€s, there wouldn't be, I don't think there would
be, as great a need to pursue a separate class. I think
that the Company recognizes that that coul-d be
challenging and there may be other policy reasons why the
Commission may consj-der not going that route for all
customer classes or for the residential class.
O And I agree with you and I think the
sticker shock is probably part of that, but itrs not
uncommon in other utilities to have a base rate and then
charge a metered rate on top of that. With watert25
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Idaho Power Company
companies or
monthly fee,
but
A
a solution,
sewer distrj-cts or things,
a plant fee, and then they
they have a
charge for usage,
I woul-d agree with you that that could be
much.
EXAMINATION
BY COMM]SSIONER RAPER:
O SoI have a coupJ-e and I 'm go j-ng to try
think that PauI was trying to get out,and get out
so both of our heads are j-n the same place, which shoul-d
scare everyone in the room, so I think the distinction
here in my mj-nd and it gets sort of glossed over as you
talk about what everyone perceives to be the larger
issues, but there's net metering and therers on-site
generation, and in my mind -- I ' lI eventually have a
question, I promlse, Lisa could a customer so waJ-t,
first question, 1et me back up, al-I of the solar portion
that residential and smal1 general service are putting on
the system, those are on the customer side of the meter;
correct?
A Yes.
yes.
COMMISSIONER ANDERSON :
what I
Thank you very
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O Okay; so could a customer have sol-ar on
his roof and be offsetting his bills by utiliztng that?
Maybe it's an old system, whatever, ri-ghtr so it doesn't
given him enough to actually selI back into the grid,
coul-d a customer have solar and be utiliz:ng that to
offset their bill without Idaho Power knowing about it?
A I believe so. I mean, Mr. Angel1 is
probably more
O I thought you might put me off to Mr.
Ange11.
A Yeah, I bel- j-eve that that's the case;
however, on an instantaneous basis, the chances, fry
understanding at least the chances, of always directly
offsetting consumption and not utilizing the grid is very
unlikely, and so the longer period of time we go 1n
measuring on a net consumption and generati-on basis, the
more we mask what the actual utilization of the system
was over that period of time. We donrt know -- we know
that the customer is using the grid when they're not 100
percent offsetting their consumption, and so it isn't a
true measurement of what they're actually utiliz1ng i-n
terms of grid servj-ces.
O How is it a mask if everything is on the
customer side of the meter and the meter is not moving?
I see a mask, as you've defined it and as everyone has
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Idaho Power Company
discussed, I see a mask as this and this. Then it masks
what the forward movement on the meter was, because itts
of utilization ofbacking up.
distribution and transmission services and everything
else thatrs coming across the wire.
If everything on the customer side of the
meter is where the solar is dt, then am I wrong to think,
and you can put me off to Mr. Angell if you'd like, but
am I wrong to think that it doesn't move? It sits firm,
because what's coming through the wires, a non-technical
definition, what's coming through the wires from the
solar PV array is being directly utillzed in the home.
It never moves the meter. Is that a wrong assumption for
how it works?
Therers a mask
just that you can't see it when you're measuring it
It isn't that the entire
basis,
Itrs
on
even an hourly interval.
hour even if j-t measured at net zero, there were
positives and negatj-ves going on throughout the entire
hour, and I think Mr. Angell would probably be better,
you know, and he would not maybe use this as the
description and have a more technical- description, but
there's instantaneous exchange of energy thatrs requirj-ng
the grid to bal-ance the load and enable the customer to
A WeII, I think on a
there is that back and forth sort
moment-by-moment
of i-nteracti-on.
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have that interaction with the grid and have their
generation and consumption being offset.
The grid is necessary to do that; however,
by netting on a longer interval than instantaneous
doesn't allow for a measurement to be taken in which
billing can be provided without two separate meters. If
we had two separate meters, you can do that. The
Company's not proposing to do two separate meters, but I
think that's what it woul-d take in order to probably
measure 100 percent consumption and 100 percent of
generation, so I think the point is that there's grid
utilizati-on going on even in that scenario that the
Company woul-dn't recover the costs of that utilizatj-on
from that customer, but rather other customers.
O So in my mind, and apparently, I'm looking
at it wrong and I'l-1 ask Mr. AngelJ- for cl-arification
when he gets on the stand, but in my mind, if everything
is on the customer si-de of t.he meter thatrs
solar-on-sj-te-related and they're not putting anything
back into the grid, I see that as the vacation home where
someone is not there. It's waiting and the system is
sitting waiting to be uti-lized, but it's a vacation home
where nothing is turned on and nothing is being utilized
and it's just sort of stopped waiting there at the plug,
right, waiting for you to plug something in, and so what
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Idaho Power Company
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I hear you telling me is that's not the scenario, that
there's stil1 give and take on the meter.
A That's right, and I think Mr. Ange11 can
really give you a much better description, but I think
you've hit it on the head. It is utilizaL:-on, continuous
util-ization, of the grid that at the end of the day could
show a measurement that suggests no utilization at aII,
and the example that you gave with the vacation homer we
know because there's not on-site generation, the
measurement 1s accurate and there was no utj-lization and,
therefore, the billing reflects that there wasn't.
A One more, I think, and it goes to
Commissioner Andersonrs question about billing. I heard
a lot about billing and the compensation for the net, and
without regard to Staff's suggestion to use avoided cost,
because I don't want you to think I'm going there, f'm
not, if a customer is a net metering customer, but they
pay on a regular residential and small customer class
tariff for everything that they utilize, and I know we
might be looking at the two-meter scenario here,
possibly, I don't know what the meters do either, if you
were to bill everything that way and have a separate
tariff that was related stri.ctly to compensation for the
energy from the net metering customers that's being put
back on the grid, whether, you know, in theory, it's
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Idaho Power Company
being
right,
credi-ted to them or whatever, so this is straight,
all customers are customers that take
share, because
they're paying
then they're paying their fair
energy, so
theyr re
for thepaying their customer charge,
util-ization of the kil-owatts that they use, and then the
compensation for what they generate takes into account
both the costs and benefits of that PV system, that
rooftop sol-ar being a part of the system, Irve heard you
say that there are multiple ways to skin this cat, is
that a way that you think would balance out what we're
calling cost shifting between the customers, but still
adequateJ-y account for the costs and benefits of a net
metering system? That was super convol-uted if you could
fo11ow.
A Yes.
COMMISSIONER RAPER: Perfect. That is all
I have. Do you have any redirect, Ms. Nordstrom?
MS. NORDSTROM: I do not.
COMMISSIONER RAPER: Oh, sorry.
COMMISSIONER ANDERSON: I don't think Mr.
Tatum has been up here long enough.
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fdaho Power Company
EXAMINATION
BY COMMISSTONER ANDERSON:
O Just a quick question.
that would reflect to the vacation home
This is something
Would you agree or disagree, then, that
cost, is that vacation home paylng their
A No, they're not.
scenario, then.
the $5.00 fixed
fair share?
O So if you add a fj-xed cost that was
divisible by the total amount of plant by members, on
every member in the class, that woul-d fix this problem,
all problems for billing, wouldn't it?
A If we had a fixed charge, like a fixed
monthly charge, that had was an amount equal to the
fixed cost to serve that customer class and then have an
energy charge thatrs refl-ective of just the variable
energy cost, then, y€s, yes, that would address the
problem that we're it's another method that coul-d be
used to address the problem.
COMMISSIONER ANDERSON: Thank you.
COMMISSIONER RAPER: Any redirect to
Mr. Anderson's question?
MS. NORDSTROM: No.
COMMISSIONER RAPER: I believe that this
wi-tness can step down.o 25
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YANKEL (Di)
Irrigators
THE WITNESS: Thank you.
(The witness left the stand. )
COMMISSIONER RAPER: So we are going to
move to Mr. Yankel.
MR. PRESTON:
COMMISSIONER
sdy, Mr. Preston, would you
MR. PRESTON:
Thank you.
RAPER: ActualJ-y, I should
l-ike to call your witness?
Yes, thank you, Madam Chair.
proceed?
Absolutely, please.
We woul-d cal-l Mr. Anthony Yankel.
COMMTSSIONER RAPER: Thank you
ANTHONY J. YANKEL,
produced as a witness at the instance of the Idaho
Irrigation Pumpers Association, having been first duly
sworn to tell- the truth, was examined and testified as
f ol-l-ows:
MR. PRESTON: May I
COMMISSIONER RAPER:
DIRECT EXAMINATION
BY MR. PRESTON:
O Good afternoon.
A Good afternoon.o 25
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O lr{ould you please state your full name and
spe11 your last name?
A Anthony J. Yankel, Y-a-n-k-e-l.
O And Mr. Yankel, what is your address?
A L2700 Lake Avenue, Unit 2505, Lakewood,
Ohio, 44L07.
O Thank you. Are you the same Anthony J.
Yankel that previously submitted testj-mony on behal-f of
the Idaho Irrigation Pumpers Association on December
22nd, 20L7, along wlth Exhibit 301?
A Yes.
O And if I asked you t.he same questions
today, would your answers contained in your prepared
testimony be the same today?
A Yes, they would.
O Do you have any corrections or other
adjustments that you wj-sh to make to your previously
submitted prepared testimony?
A No, I do not.
MR. PRESTON: Madam Chair, I'd move that
according to Rules of Procedure 266 that Mr. Yankel's
prepared testimony that has been previously distributed
to all parties be incorporated into the transcript at
this time.
COMMISSIONER RAPER: Without objection,
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YANKEL (Di)
Irrigators
Mr. Yankel-'s testimony, direct testimony, will be spread
across the record as if read.
MR. PRESTON: And I'd also move that
Exhibit 301 be admitted into evidence.
COMMISSIONER RAPER: If there's no
objection, we will admit Exhibit 301 into evidence, and I
may need someone to give it to me if there are any
questions on it. I don't think I have a copy. You're
good for now.
MR. PRESTON: Okay, thank you.
(Idaho Irrigation Pumpers
Association Exhibit No. 301 was admitted into evidence. )
(The following pr.efiled direct testimony
of Mr. Anthony Yankel is spread upon the record. )
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O. PLEASE STATE YOUR NAME, ADDRESS, AND
EMPLOYMENT.
A. I am Anthony J. Yankel-. I am President of
Yankel and Associates, Inc. My address is L2700 Lake Ave
Suite 2505, Lakewood, Ohio, 44]-07 .
O. WOULD YOU BRIEFLY DESCRIBE YOUR EDUCATIONAL
BACKGROUND AND PROFESSIONAL EXPERIENCE?
A. I received a Bachelor of Science Degree in
Electrical Engineering from Carnegie Instj-tute of
Technology in 1969 and a Master of Science Degree in
Chemical Engineering from the University of Idaho in
1-972. Erom 1,969 through L972, T was employed by the Air
Correction Divi-sion of Universal Oil- Products as a
product design engineer. My chief responsibil-ities were
in the areas of design, start-up, and repair of new and
existing product l-ines for coal-fired power plants. From
1,973 through !977, I was employed by the Bureau of Air
Quality for the Idaho Department of Health & Welfare,
Division of Environment. As Chief Engineer for the
Bureau, my responsibil-ities covered a wide range of
investigative functions. From 1918 through June L979, I
was employed as the Director of the Idaho Electrical
Consumers Office. In that capaci-ty, I was responsible
for al-1 organizational- and technical aspects of
advocating a variety of positions before various
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governmental bodies that represented the j-nterests of the
electrical consumers in the State of Idaho.From JuIy
in the firm ofL979 through October 1980, f
Yanke1, Eddy, and Associates.
been in business for myself.
Professional- Engineer in the
was a partner
Since that time, I have
I have been a registered
of Ohio and Idaho. I
Federal Energy
states
have presented testimony before the
Regulatory Commission (EERC),
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as well- as the State Public Utility Commissions of Idaho,
Montana, Ohio, Pennsylvania, Utah, and West Virginia.
O. ON WHOSE BEHALF ARE YOU TESTIFYING?
A. f am testifying on beha1f of the Idaho
Pumpers Association, Inc. (IIPA).Irrj-gatJ-on
o.
A.f have reviewed
PLEASE SUMMARIZE YOUR TESTIMONY
Idaho Power's ("the Company")
case. I agree that the number
on Schedul-e 84 (Customer Energy
Service) are growing rapidly. I
direct testimony in this
of Net Metering customers
Production, Net Metering
further agree that Schedule 84 has moved from the
experimental- stage and that it is now time to address the
costs and benefits that are uni-que to that schedule. The
Company has presented a number of concerns/problems with
the way Schedul-e 84 costs and benefits are treated. The
Company's proposal is that a Workshop be initiated to
address these concerns/problems. I agree with that
proposal.
My testimony will address some additional
concerns/problems with the way Schedule 84 is
implemented. I also recommend that a Workshop, to
address these concerns/problems, be initiated as soon as
possible.
The Company has proposed two new rate schedules
for Net Metering customers-Schedu1e 6 for Resj-dentiaLo25
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customers and Schedul-e
f do not disagree that
appropriate, but it is
8 for Small Commercial customers.
these new schedules may be
premature to establish such rate
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schedules at this time.
wi-II have a better idea
appropriate rate design
Overwiew of
After the Workshop, all parties
of cost-of-service and
for Net Metering customers.
Present Schedule 84
brief history of Net Metering onaO. Please give
the Company's system.
A. According to
initiated in 1983 for
the Company,
one customers
Net Metering was
that install-ed a
solar generation system. This initial offering contained
in Schedule 86 (Cogeneration and Small Power Production
Non-Firm) charged this customer retail rates for all net
energy del-ivered to the customer and paid the customer at
retail rates for all net excess energy that the customer
put into the Company's system.
As a result of Case IPC-E-95-15, the pricing
structure for Net Metering customers was changed to a
formula rate in order to recover certain non-generation
costs assocj-ated with Net Metering customers.
In Case IPC-E-01-39, Schedule 84 was created to
separate Net Metering customers from Schedule 85.
Additionally, the formula rate was abandoned, because it
was too cumbersome to apply to multiple customers. The
rate went back to chargj-ng simple retail rates for usage
greater than generation and crediting the excess net
energy (generation that was greater than usage) to offsetI25
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future bil1ed kWh consumption. Schedul-e 84 has not been
materially modified since.
O. What rationale was employed in Schedu1e 86 and
later in Schedul-e 84 with respect to Net Meteri-ng
customers ?
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A. The Net Metering portion of Schedul-e 86 (and
ultimately Schedule 84) was designed as an experimental-
rate that would facilitate the development of smaI1,
distributive resources. By employing a simple watt-hour
meter and using standard retail- rates, administrative and
metering cost were kept 1ow and the rate design was
easily understood by customers. A possible subsidy was
expected, but was considered to be insignificant if the
number of Net Meterlng customers remained low.
O. Have things changed since Net Metering was
introduced over 30 years ago?
A. Yes. First, one of the main drj-ving forces for
the existing rate design for Net Metering customers was
the cost of metering. With only watt-hour meters being
the standard for measuring energy usage for smaller
customers 30 years d9o, and with watt-hour meters having
the ability to run backwards, it would have been too
expensive to use more sophisticated metering at the time.
Additionally, there was an administrative cost burden
associated with calcul-ations using this more
sophisticated meterj-ng. Today, vj-rtuaIly all residential
and sma11 commercial customers have AMI metering standard
and the associated metering cost j-s standard as well-.
The need for using a simple rate design to accommodate a
watt-hour meter no longer exi-sts. It is possible to now
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implement more sophisticated rates.
Second, the use of sofar based generation has
begun to grow rapidly in the Company's service territory.
Consequently, the number of Net Metering customers on the
Company's system i-s suddenly growing very rapidly.
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It is now time to go from an experimental rate that was
designed to facilitate the growth of smal-l-, distributive
generation, to cost-of-servj-ce and a rate design that
refl-ects the contributi-on of these customers to the
system's costs and benefits.
0. Why do Net Metering customers need to have this
cost-of-service review and an appropriate rate design
developed?
A. IPCo has presented a strong set of reasons why
on-sj-te generation customers require the same facilities
as other customers that simply take one-way service, but
do not pay the fuII cost of those facilities. Basically,
on-site generation customers require the use of the
Company' s generation, transmi-ssj-on, and distribution
system. On-site generation customers, especially those
relying on solar, reduce their need for energy from the
export
During
excess energy during certain hours of
those hours, these on-site
Company or
the day.
customers
additional-
facilities
generation
to purchase
excess energy back into
times when the customer
the Companyrs system.
is generating and is
purchasing enerqy from the Company, the demand for
from the Company is reduced from what it otherwise
be. Durlng other hours of the duy, these on-site
may use the company's
energy/power from the Company, or to send
During the
al-so
energy
woul-d
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generation customers are not generating, and thus, take
energy/power from the Company in a manner that is the
same as if they
There
cost-of-service
did not have on-site generation.
that determi-neare standard methods
for these non-generation hours. However,
as to how to determine cost-of-there are questions
servi-ce for those hours when these customers are both
generating and purchasing some energy and when they are
putting
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excess
problem
reflects
generation back
is to determine
into the
a proper
system. An even larger
rate design that
the total cost-of-service for these customers.
Under the present rate design, the net amount
of energy purchased in a month (energy provided by the
Company less energy generated on-site) is priced at the
same tariff rate used for customers that do not have
on-site generation. The problem with this treatment of
on-site generation customers is most easily demonstrated
by the customer that during a given month produces as
much excess generation into the Company's system as the
amount of energy it separately receives from the Company.
When the amount of energy given back to the system during
a given month j-s equal to the amount of energy consumed
during that month, the net amount is zero (a net-zero
customer). In such a case (under the present rate
schedule and rate design), the customer would only pay
the customer charge, wj-th no palrment made to reflect the
fact that the generation, transmission, and distribution
facilities were all used to support the energy being
brought to the customer as wel-l- as distributing the
excess energy that is made at other times.
It is intuitively obvious that such a customer
is essentially paying nothing for its use of the
generation, transmission, and distribution system foro25
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every hour during the month. Although the Company
provided a great deal of information in its fili-ng, this
hearing is not the forum to address that issue. It will
take more effort than what has been put into this case.
The Company's
address these
recommendation to establish a Workshop to
l_ssues l_s on poj-nt. Given the recent rapid
I recommend that a new caserise in on-site generatJ-on,
be initiated, and a Workshop started as soon as possible.
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O. Should this Workshop just focus on costs and
problems with on-site generatj-on that have already been
mentioned by the Company?
A. No. Certainly, the costs and problems wlth
on-site generation that have already been mentioned by
the Company should be further reviewed and quantified. I
assume that additional problems wil-l- come to light and
they will need to be investJ-gated and addressed as well-.
I am aware that there are also system benefits associated
with on-site generation that have not been addressed in
the Company's direct testimony. I assume that these
benefits will be brought up by other parties. These
benefits will need to be investigated and addressed as
well. The entire cost-of-servlce (cost and benefits)
needs to be addressed and then an appropriate rate design
must be developed that recovers costs (less benefits) in
a manner that is understandable by all parties, including
the customers.
Additiona]. Problems
O. Are there other problems with the present
customers on Schedule 84 that were not addressed in the
Company's filing, but require consideration?
A. Yes. The Company's filing brought up several
problems that need to be addressed with respect to the
customers on Schedule 84. The Company did not try to
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address or quantify these problems in a detai1ed manner,
but presented them as issues that support the need for a
Workshop for all stakeholders to thoroughly address those
issues. I want to add the following additional issues
that need to be addressed:
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Homoge
O. Are the customers on Schedul-e 84 homogeneous?
A. No. Most of the discussion in the Company's
caser dS well as the discovery requests and responses,
deal- with on-site generatJ-on that is sol-ar based. In
fact, Schedule 84 is not limited to generation based upon
solar. Solar based generation facil-ities have unique
characteristics that are predictably the same from
facility to facility. Solar generation only takes place
when the sun is shining and the more the sun shines or
its energy is captured, the more it will generate. This
means that solar generation is available every day during
daylight hours-depending upon the available solar
radiation. This also means that solar is not available
during nightti-me hours
when the sun is rising,
and is l-ess/minimally available
setting, or obscured by clouds.
Exhibit 301 lists the annual net metered kwh
for 563 Schedule 84 customers from 2016.7 At least four
of those customers had excess energy being
IPCo system during more than just daylight
example:
put into the
hours. For
Customer 35 had excess for 100 continuous hours
between Jan. 26 and 31
Customer 13 had excess for -711 continuous
hours between Feb.1 and 6225
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Customer 352 had excess for 449 continuous
hours between Jan. 1 and 19
Customer 535 had excess for 32 contlnuous hours
between Jan. 8 and 10
1 Data from IPCo Response to Vol-t Sol-ar's Request No. 59, Attachment
2, Tab Original reflecting usage of all net metering customer for
which 12 months of data was avai.Iable for 20L6.a 25
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Over 99% of the customer data from 2076 appears to be
solar bases. It would be best to address this 99?. of the
Net Metering customers and to separate/remove the
outliers that are not solar based. Although these four
customers listed have self-generatJ-on, the magnitude of
the generation consistently exceeds their internal loads
during al-most all hours and not just when the sun is
shining. The net result is that these customers act more
like Cogenerator and SmaII Power Producers. The Workshop
should consj-der pricing these customers Iike that used
for Schedul-e 86 customers.
Generation During Times of System PeakE
O. Do sol-ar facilitj-es under Schedule 84 generate
during all of the Company's system peaks?
A. No. There is little or no generation that
takes place during some of the monthly winter system
peaks. For example, because of the timing of the monthly
system peaks, the following winter peaks would have
litt1e, if dny, sofar radiation, and thus, there would be
l-itt1e or no solar generation:
Eebruary 2, 201,6 8:00 a.m.
November 30, 2016 7:00 p.m.
December L9, 2016 9:00 a.m.
Add to this fact that there often is more cl-oud cover
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Iess, and thus, solar generation is less during the
morning and late afternoon hours.
2 onfy 3 hours did not have excess generation
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O. In this case, is there a way to qualify the
lack of solar radiation during the winter months compared
to the summer months?
A. Yes. Exhibit 301 ranks these 563 Schedul-e 84
customers from 2016 by the annual amount (far left two
columns) of excess net energy each customer puts into the
system, down to the highest amount that the customer used
above the amount generated (highest amount of excess net
energy down to the highest net amount consumed). The
Exhibit also lists, by month, the same ranking of
customers from highest amount of, excess net energy down
to the highest net amount consumed. It can be seen from
the Exhibit that there are fewer customers with excess
net energy during the winter months than during the
sunmer months. The followj-ng table lists the number of
customers each month that provided more net energy for
the system than was consumed by the customer:
TSle I
Number of Customers With Excess Ge,neration
Mar Apr May June July Aug SePt
96 232 239 175 155 152 174
L7.1o/o 4L.n6 42.5% 3t.l% 27.50/6 27.trA 3O.9%
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Jan Feb
Cust. 10 55
% !.8% 9.8%
Oct Nov Dec
63283
1L-2% 5.O% O.5%
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From Table 1 it can be seen that net-excess energy is
produced by 108 or less of the Net Metering customers
during the four winter months-dropping as 1ow as 0.5t
during December. The Companyrs cost-of-service study in
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the last rate case segregated production demand and
energy costs into Summer (June, Ju1y, and August) and
Non-Summer (the other nine months). The Workshop should
develop a
demand and
more granular differentiation of production
for the Solar Net Meteringenergy costs
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customers, because the number of customers generating
excess are significantly different between the various
9-months that the Company defined as Non-Summer.
O. Are there any other differences in the monthly
patterns of the Net-Metering customers that needs to be
addressed in the Workshop?
A. Yes. Simil-ar to the number of customers that
have net excess energy in any given month, the amount of
net excess energy by month is something that needs to be
addressed. Table 2 lists the amount of excess net energy
(MWh) that was put into the system by these same 563
customers during each month in 2016:
Jan
10.1
Feb
2L.7
Mar Apr
37.4 1L8.2
Table 2
Excess Net Energy (MWh)
May June July Aug
L22.5 93.8 8L.7 72.3
Sept Oct
7t.9 24.8
Nov Dec
20.2 LL.4
This monthly pattern of excess Net Energy, along with
present rate design results i-n j-nappropriate cost
shifting. Presentlyr. all excess net energy in a given
month is camied forward into the future and not
compensated for in the month it was generated. The
excess net energy is used to offset future kWh purchased
energy/usage by a given customer. Erom Table 2 it can be
seen that the highest months of excess net energy are
April and May. These are the months when wholesale powert25
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costs are at their l-owest and there are times when there
is so much excess energy in the regj-on that Idaho Power
must pay others to take the excess energy (negative sal-e
price). It is inapproprj-ate that during these times of
Iow energy costs that some of the Net Metering customers
would be banking their
offset to their usage
excess net energy to save it as an
high costduring the
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sunrmer months or some other time in the future.
Hopefully, this can be addressed in the Workshop.
Recomendations
O. Do you have any specific reconrmendations that
would correct the probl-ems that you have cited?
A. No. The Company has pointed out a number of
problems in its direct case and has not made specific
recommendations regardj-ng the resolution of those
problems. I assume that other parties will raise
concerns regarding other costs and/or benefits of Net
Metering. In the aggregate, all of these
concerns/problems shoul-d be addressed in a Workshop and
cost-of-service methodologies and rate designs that
appropriately address these problems/concern should be
developed.
O. Should the new Schedules proposed by the
Company be lmplemented at this time?
A. No. The Company has proposed two new rate
schedules for Net Metering customers-Schedule 6 for
Residential customers and Schedul-e 8 for SmalI Commercial-
customers. I do not disagree that these new schedules
may be appropriate, but it is premature to establish such
rate schedul-es at this time. After the Workshop, aII
parties will have a better idea of approprJ-ate rate
schedul-es and rate design for Net Metering customers.o 25
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A
Does this conclude your direct testimony?
Yes.
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(The following proceedings were had in
open hearing. )
MR. PRESTON: At this time I would present
Mr. Yankel for cross-examination.
COMMISSIONER RAPER: Ms. Germaine.
MS. GERMAINE: No questions.
COMMISSIONER RAPER: Thank you.
MR. HAMMOND: I'11 go next.
COMMISSIONER RAPER: Mr. Carter loses his
opportunity. He was No. 2.
MR. HAMMOND: Can I move up, then?
COMMISSIONER RAPER: We'11 come back to
Mr. Carter. Yes, Mr. Hammond.
MR. HAMMOND: I don't have any questions.
Thank you.
COMMISSIONER RAPER: Mr. Nykiel.
MR. NYKIEL: No questj-ons. Thank you.
COMMISSIONER RAPER: Mr. Carter, do you
have any questions of this witness?
MR. CARTER: No.
COMMISSIONER RAPER: Ms. Nunez.
MS. NUNEZ: No questions.
COMMISSIONER RAPER: Thank you.
MR. COSTELLO: No questions.
MR. BENDER: No questions.I 25
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CSB REPORTING
(208 ) 890-s198
Yankel
Irrigators
COMMfSSIONER RAPER: Any questions from
the Commissioners?
Any redirect?
MR. PRESTON: For fear of being beat
afterwards, no.
COMMISSIONER RAPER: It wou]d be
redundant, tru1y, at this point. Mr. Yanke1, thank you
for being available.
THE WITNESS: Thank you for having me.
COMMISSIONER RAPER: Now you can make your
plane.
THE WITNESS: Thank you.
(The witness left the stand. )
MR. PRESTON: Madam Chair, may I request
that Mr. Yankel be released at this point in time?
COMMISSIONER RAPER: Without any objection
from anyone else in the room, seeing as how they had no
questions, you are excused.
MR. PRESTON: Thank you.
COMMISSIONER RAPER: You know, Iet's do a
quick, l-ike, 10
testimony, how
correct it's
2220.
minutes before we go back
is -- phonesis that, so it
2:13, w€'11 be back on the
to Company
are al-ways
record at
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CSB REPORTING
(208 ) 890-s198
ASCHENBRENNER (Di)
Idaho Power Company
COMMISSIONER RAPER: Ms. Nordstrom, would
you l-ike to call your next Company witness?
COMMISSIONER RAPER: f would. I cal-f
Connie Aschenbrenner to the stand.
COMMISSIONER RAPER: Thank you.
CONNIE ASCHENBRENNER,
produced as a wj-tness at the instance of the ldaho Power
Company, having been first duly sworn to te1l the truth,
was examined and testified as follows:
DIRECT EXAMINATION
BY MS. NORDSTROM:
O Good afternoon.
A Good afternoon.
O Please state your name and spe11 your last
for the record.
A Connie Aschenbrenner,
A-s-c-h-e-n-b-r-e-n-n-e-r .
a By whom are you employed and in what
capacity?
A Idaho Power Company, rate design
manager.
O Are you the same Connie Aschenbrenner thato25
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CSB REPORTING(208) 890-sl-98
ASCHENBRENNER (Di)
Idaho Power Company
filed dj-rect testimony on July 27th, 2017, and prepared
Exhibit Nos. 9 through 13?
A Iam.
o
January 26th,
A
o
Did you al-so file rebuttal testimony on
2078, and prepared Exhibit No. 15?
r did.
Did you file surrebuttal testimony on
20L8, with no additional exhibj-ts?
r did.
And did you cause to be filed corrected
February 23rd,
A
a
pages L4 and
15th, 20L7?
15 to your direct testimony on September
A Yes.
O Do you have any further corrections or
changes to your testimony or exhibits?
A No, I do not.
O Ms. Aschenbrenner, if I were to ask you
the questions set out in your prefiled testimony today,
would those answers be the same?
A Yes, they wouId.
MS. NORDSTROM: Thank you. I tender this
witness for cross-examination.
COMMISSfONER RAPER: Do you want to spread
her testimony across the record?
MS. NORDSTROM: I do.I 25
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CSB REPORTING(208) 890-s198
ASCHENBRENNER (Di)
Idaho Power Company
THE WITNESS: You don't want me to read
ir?
COMMISSIONER RAPER: No. Without
obj ection,
rebuttal,
and admit
record.
we wil-l- spread Ms. Aschenbrenner' s direct,
if read,
into the
and surrebuttal- across the record as
Exhj-bits 9 through 13 and Exhibit 15
(Idaho Power Company Exhibit Nos. 9 -13 &
15 were admitted into evidence. )
(The foll-owing prefiled direct, rebuttal,
and surrebuttal testimoni-es of Ms. Connie Aschenbrenner
are spread upon the record. )
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CSB REPORTING
(208 ) 890-5198
ASCHENBRENNER, DI 1-
Idaho Power Company
O. Pl-ease state your name and business address.
A. My name is Connie G. Aschenbrenner. My
business address is L22L West Idaho Street, Boise, Idaho.
O. By whom are you employed and in what capacity?
A. I am employed by Idaho Power Company ("Idaho
Power" or "Company") as the Manager of Rate Design in the
Regulatory Affairs Department.
O. Please describe your educational background.
A. In May of 2006, T received a Bachel-or of
Business Administration degree in Finance from Boise
State Universi-ty in Boise, Idaho.
Master of Busi-ness Administration
In 201.1., I earned a
degree from Boise State
attended the electricI haveUniversity. In addition,
utility ratemaking course The Basics: Practical-
Regulatory Training for the ELectric Industry, a course
offered through New Mexico State University's Center for
Public Utilities.
a. Please describe your work experience with ldaho
Power.
A. 7n 201,2, I was hired as a Regulatory Analyst in
the Company's Regulatory Affairs department. My primary
responsJ-bilities included support of the Company's
Commercial and Industrial customer class's rate design
and general support of tariff rules and regulations. In
201-5, T assumed responsi-bilities associated witht25
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residential and small general service ("R&SGS") rate
design as wel-I as
CSB REPORT]NG(208) 890-s198
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ASCHENBRENNER, DI 1A
Idaho Power Company
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activlties associated with demand-side management
activj-ties. Tn 201,6, I was promoted to a Senior
Regulatory Analyst and my responsibilities expanded to
include the development of complex cost-rel-ated studies.
In 201'7, T was promoted to my current position of Manager
of Rate Design for fdaho Power. I am currently
responsible for the management of the rate design
strategies of the Company as well- as the oversight of aII
tariff administration.
O. How is your testimony organized?
A. The fj-rst section of my testj-mony will detail-
the history of the Company's net metering service from
its inception to the implementation of Schedul-e 84,
Customer Energy Production, Net Metering Servlce
("Schedu1e 84") currently in p1ace, specifically
highliqhting discussions regarding cost shifting caused
by the current resj-dential rate deslgn. The second
section wil-l provide the Idaho Public Utilities
Commissj-on ("Commission") with updated net metering
partlcipatj-on and growth rates. The third section of my
testimony will discuss the Company's stakeholder and
customer outreach efforts in 201,6 and 2017. The fourth
section will describe the Companyrs request for
establishment of new customer classes for R&SGS customers
wi-th on-site generation. The fifth section of my
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CSB REPORTING
(208 ) 890-s198
ASCHENBRENNER, DI 2
Idaho Power Company
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testj-mony wiII describe the Company's request to
implement two new tariff Schedules, Schedule 6,
Residential Service On-Site
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CSB REPORTING(208) 890-s198
ASCHENBRENNER, DI 2A
Idaho Power Company
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CSB REPORTING(208) 890-5198
ASCHENBRENNER, DI 3
Idaho Power Company
Generation, ("Schedul-e 6") and Schedule 8, Smal-1 General
Service On-Site Generatj-on, ("Schedul-e 8") and close
Schedu1e 84 to new servj-ce for Idaho R&SGS customers upon
the adoption
sixth section
communication
of Schedules 6 and 8
of my testimony wiII
And fina1ly,
describe the Company's
efforts as they relate to
I. HISTORY
this filing.
O. Please provide a general description of net
metering service.
A. Net metering service is offered by the Company
to provide for the transfer of electricity to the Company
from customer-owned generation facilities with the intent
of offsetting all or a portion of a customer's energy
usage.
O. How long has Idaho Power offered net metering
service?
A. Pursuant to Section 270 of the Public Utility
Regulatory Policies Act of L978 (PURPA), the Company
first offered net metering service to suppliers of
non-firm energy of less than 100 kilowatts ("kW") to
offset all or a portion of their retail loads through
Schedul-e 86, Cogeneration ancl Sma11 Power Production
Non-Eirm Energy, ("Schedu1e 86"), under Option C,
approved by Commission Order No. 18358 issued i-n October
1983. In that case (Case
the
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CSB REPORTING(208) 890-s198
ASCHENBRENNER, DI 4
Idaho Power Company
No. U-1006-200), Schedule 86 was modified to accommodate
one customer with an installed photovoltaic ("PV")
system.
O. How was the Company's net metering servj-ce
structured at the time of its initial offering?
A. The net metering servj-ce established in 1983
was designed to provide customers the ability to offset
all or a portion of their usage with their own
generation. Idaho Power charged customers the fu11 retail
rate for net energy consumed and credited the ful-I retail
rate for excess net generation delivered to the Company.
O. Did the Company propose any modifications to
its net metering service after it was established in
1983?
A. Yes. In October of L995,
in Case No. IPC-E-95-15
the Company filed an
requesting to modifyapplication
the terms of
formula-based rate was
Schedule 86. As part
approved in
of this case, a
Order No. 26150 to
al1ow the Company to recover certain non-generation costs
from net meterlng customers. When the formula rate was
created, the Companyrs net metering service still
consisted of a single customer wj-th an installed PV
system; therefore, the Companyrs formula rate proposal
was specifically designed for PV systems. It was
anticipated that when other types of self-generation wereI25
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introduced, new formula rates would be created for those
specific generation types.
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CSB REPORTING(208) 890-s198
ASCHENBRENNER, D] 4A
Idaho Power Company
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a. Was net metering service further modified
followj-ng the conclusion of Case No. lPC-E-95-15?
A. Yes. In February of 2002, the Commj-ssion
issued Order No. 28951, j-n Case No. IPC-E-01-39 creating
Schedule 84 specifically for net metering service and
removing it from Schedule 86, which now addressed
non-firm cogeneration and small power production without
a retail sal-es offset option. As part of that Order,
pricing associated with the Company's net metering
service was modified to remove the previously-described
formula rate.
O. What were the driving factors for creating
Schedule 84 and removing net metering servj-ce from
Schedule 86?
A. At the time Schedule 84 was implemented in
2002, there was one customer takrng service under the net
metering provisicn of Schedule 86 and two customers who
had requests pending. The Schedul-e 86 formula rate was
impractical because the rate required a manual billing
process that was complex and time intensive, and was only
designed to accommodate PV install-ations. Through the
creation of Schedule 84, pricing was simplified for net
meterj-ng customers by eliminating the formula rate
component of customers' bills and applying the full
retail rate to net usage or generation. This allowed the
CSB REPORTING(208) 890-5198
ASCHENBRENNER, DI 5
Idaho Power Company
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Company to use its existing billing system, a single
meter, and
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CSB REPORTING
(208 ) 890-s198
ASCHENBRENNER, DI 5A
Idaho Power Company
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CSB REPORTING(208) 890-s198
ASCHENBRENNER, DI 6
Idaho Power Company
resulted in a charge or credit at a rate consj-stent with
a customer's respective standard service rate class. It
al-so all-owed the Company to more easily expand its net
generationmetering service to a broader range of
resources.
O. Did
concerns with
for generatlon
A. Yes.
the Companyrs
at the ful-l-
the Commission Staff ("Staff") raise any
proposal to credlt customers
retail- rate?
Staff's Comments indicated that
subsidization would occur but woul-d be limited if
participation in the net metering service was Iimited:1
For the Commission to accept a netmetering tariff where customer generati-on iscredited at full- retail rates, iL must bewilling to accept the fact that Idaho Power maynot recover its ful1 costs of providing service
from net metering customers. Those costs that
are uncol-lected must either come from Idaho
Power through its shareholders or from other
customers collectiveIy.
Despite Staffrs concerns about theIikel-ihood that some of the costs of servingnet metering customers will- be subsidized byother customers, the overall- doll-ar impacts ofnet metering will- be smal1 if participation
Tevel-s are restricted.
o.
regarding
Did the Company share Staff's concerns
the credj-tj-ng of customers at the ful-I retail-
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rate?
1 Case No. IPC-E-01-39, Staff's Comments, p. 3 (emphasis
added) .
CSB REPORT]NG(208) 890-s198
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ASCHENBRENNER, DI 6A
Idaho Power Company
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A. Yes. In response to two separate Staff
production requests in Case No. lPC-E-01-39, the Company
stated, "It is possible that the retail rate may be
higher lthan the va]ue of generationl,"2 and
acknowledged that Idaho Power would not fuIIy recover its
cost of providing service if a net meteri-ng customer
ful1y offsets their monthly usage with their own
generation.3
O. Why did the Company propose to credit net
metering customers at the full retail rate in 2001 if it
understood the potential for cost shifting?
A. The Company's proposal in Case No. IPC-E-01-39
was intended to facilitate the development of small
resources and was specifically designed to provide a
simple, standardized interconnectj-on arrangement
utiliz1ng a single, inexpensive watt-hour meter. The
Company acknowl-edged the proposal woul-d result in a smal-l
subsidy to those customers that chose to develop net
metered projects, but pointed out that if the program was
capped, this subsidy would be 1imited to a reasonabl-e
level and wou1d be partially offset by savj-ngs resulting
from the simplifications of the net metering service.
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CSB REPORTTNG(208) 890-s198
ASCHENBRENNER, DI 7
Idaho Power Company
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2 Case No. IPC-E-01-39, ldaho Power's Response to Staff's
Production Request No. 6.
3 Case No. IPC-E-01-39, Idaho Power's Response to Staff's
Production Request No. '7.
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CSB REPORTING
(208 ) 890-s198
ASCHENBRENNER, DI 7A
fdaho Power Company
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CSB REPORTING
(208 ) 890-5198
ASCHENBRENNER, D] BIdaho Power Company
In the response to Production Request No. 6
referenced above, the Company stated:
The Company believes, dt this time, thatthe benefits gained in reducingadministrative costs offset any potential-difference Iin value]. By employingretail- rates, the Company will- eliminate a
cumbersome, invol-ved process required tocalculate the additional monthly chargecurrently defined under Schedule 85Option B. By providing a simple mechanism
to credit customer generation at retailrates, the Company wil-1 reduceadministrative costs and customers wil-1
have a methodology that wil-l- be easier to
understand and track their account.
0. Was the
full- retail- rate
issue of crediting customers at the
addressed by the Commission in that same
case?
A. Yes. The Commission placed limits on
individual- R&SGS projects of 25 kW as wel-l- as a total-
instal-l-ed capacity limit of 2.9 megawatts ("MW"). In its
Order No. 28957, the Commission stated it:a
4 Case No. IPC-E-01-39, Order No. 28951, p. 1"2.o 25
428
recognizes that in the program we approve
today for Schedul-es 1 and 7 customers, thefull cost of the program may not be borneby participants. Raising the cap, werealize, increases the l-evel- ofsubsidj-zation We al-so expectfurther information regarding costshifting and the Company's ability torecover customer costs from programparticipants.
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CSB REPORTTNG(208) 890-5198
ASCHENBRENNER, DI 9
Idaho Power Company
o.
Company I s
Case No.
A.
Were further modifications made to the
net metering service after the concl-usion of
rPC-E-01-39?
Yes. fn Order No.2895L, the Commission
a net metering proposal fordirected Idaho Power to file
its other customer classes (customers with three phase
service and demand metered customers) within six weeks of
the issuance of the Order.s On March 29, 2002, Idaho
Power filed an application j-n Case No. IPC-E-02-04 in
compliance with the Commission's dj-rective. In that
fj-Iing, the Company reiterated that so long as the 2.9 MW
cap remaj-ned in place, excess costs and subsidies
associated with net metering should not be so substantial
as to justify special ratemaking treatment.6
O. What was the resul-t of Case No. IPC-E-02-04?
A. The Commission issued Order No. 29094 on August
2\, 2002, approving the Company's compliance filj-ng
without modification. In this Order, the Commissj-on
reaffirmed its view that the cumulative nameplate
generation capacity limit of 2.9 MW was appropriate at
that time.7
5 td. at 1.
6 Case No. IPC-E-02-04, Drake DI, p. l'7.
7 Case No. IPC-E-02-04, Order No. 29094, p. 7o25
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CSB REPORTING(208) 890-s198
ASCHENBRENNER, DI 10
Idaho Power Company
the Company's
capacity l-imit
generation?
A. The
O. How did Idaho Power notify the Commission when
net metering
of 2.9 MW of
service was nearj-ng the
cumulative nameplate
Company fil-ed Case No. TPC-E-12-21 with the
Commission on November 30, 2012.
The primary objectives of the Company's request
j-n IPC-E-12-27 were to (1) expand the net metering
service beyond the 2.9 MW cap, (2) establish new customer
cl-asses and j-mplement a modified rate structure for R&SGS
net metering customers, and (3) modify Schedule 12 and
Schedule 84 to al-l-ow expansion of the offering.
0. What was the Company's request regarding the
capacity limit of the net metering service?
A. In its application, the Company sought to
double the capacity l-imit to 5.8 MW. The Company
expressed its belief that maintaining a capacity Iimit
was important to al-l-ow the Company and other stakeholders
the opportunity to evaluate the net metering service as
it expanded. By increasing the capacj-ty limit to 5.8 MW,
the Company woul-d facil-itate the expansion of its net
metering service while maj-ntaining the ability to
appropriately evaluate and request modifications to the
servi-ce as necessary.
o.
Case No.
Did the Commission authortze a
rPC-E-72-27 ?
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CSB REPORTING
(208 ) 890-s198
ASCHENBRENNER, D] 11
Idaho Power Company
A. No. In its Order No. 32846, the Commj-ssion
decl-j-ned to increase the cap at that time and instead
el-iminated it entirely. In conjunction with removal- of
the capacity limit, the Commission ordered the Company to
file an annual status report with the Commission
discussing the net metering service. In that order, the
Commission stated: B
The Report shal-l- discuss, withoutlimitation, the net metering serviceprovisions and pricing and how distributedgeneration may be impacting systemreliability. The Company also shal-l-promptly fil-e an earlier report if at anytime it expects its net metering service
wil-l- materially and negatively impact its
system.
0. Did the Commisslon approve the Company's
request to establish new customer classes and modify the
pricing structure in TPC-E-1,2-27?
A. No. In Order No. 32846, whil-e the Commi-ssion
acknowledged that net metering customers "have some
characteristics that could justify moving them into a
separate class and onto a different schedule from the
general R&SGS rate c1asses, "9 the Commissj-on declined to
authorj-ze pricing changes at that tj-me.
B Case No. IPC-E-L2-21, Order No. 32846, p. 19.
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CSB REPORTING
(208 ) 890-s198
ASCHENBRENNER, DI 12
Idaho Power Company
II. CI'RRENT NET METERING PARTICIPATION
O. What is the current level- of customer
particlpation in the Company's net metering service?
A. The Company had 1,468 active and pendinglo ,r"a
meterlng systems in its Idaho service area as of June 30,
20L7. This represents a 15 percent increase in the
number of systems since the Company's l-ast update to the
Commission in the 2011 Annual- Net Metering Status Report
("20L7 Report") found as Exhibit No. 9 to my testimony --
in just three months, the number of active and pending
systems in Idaho has j-ncreased from L,277 as of March 37,
2011, to L,468 as of June 30, 2017.
The figures in Table 1 refl-ect customers taking
net metering service, ds wel-l- as customers who had
submitted applications for net meterj-ng service as of
June 30, 2017. The figures in Tabl-e 2 refl-ect the
nameplate capacity in MW of those same systems.
Tab1e 1 Ida,ho Net lfietering Customers
C].ass Photovo1taic tlind Hydro/Other Total.
Residential L,258 55 7 t ,320
Commercial &
Industrial-
133 6 4 !43
Irrigation q 1 5
Tota].11 L,4681,395 62
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CSB REPORTING
(208 ) 890-s198
ASCHENBRENNER, DI 72A
Idaho Power Company
10 "Pending" refers to a customer i^rho has applied to
participate in the Company's net metering service, but whose system
has not yet been inspected and energized. In Idaho Power's
experience, once an application for a net metering system is
submitted, that system will generally come online within
approximately five months.o 25
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CSB REPORTING
(208 ) 890-5198
ASCHENBRENNER, Dr L3
Idaho Power Company
feble 2 Idaho Net l[etering t{aneplate Capacity (in Mfft)
CIass Photovoltaic ltind By&orlOttrer Total
Residential 7 .95 0.29 0. 07 8.3L
Commercial &Industrial 2.48 0. 05 0.09 2 .62
Irrlgation 0.14 0. 04 0.18
Tota].10.57 0.38 0.16 11.11
O. How does the nameplate capacity of installed
net metering systems at June 30, 20L7, compare to the
original participation cap of 2.9 MW as authorized by the
Commission i-n 2002?
A. The total capacity of active and pending
systems in the Companyrs Idaho service area was 11.11 MW
as of June 30, 20L7, with growth of almost four times the
original cap. Figure 1 shows year-over-year installed
capacity of Idaho's net metering service since 20t2. The
solid horizontal line represents the initial 2.9 MW cap
authorj-zed by the Commission in 2002.
1 CumuLative te
lFq'
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I Residentlal Icommerclal & lndustrlal
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O. Does the Company believe that customers will
continue to install on-site generation?
CSB REPORTING
(208 ) 890-s198
ASCHENBRENNER, DI 13A
Idaho Power Company
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CSB REPORTING(208) 890-s198
ASCHENBRENNER, D] 74
Idaho Power Company
A. Yes. As noted 1n Mr. Tatum's testimony, as
weII as in prevj-ous reports to the Commissionll, the
Company expects that as the costs of installing a
residential- PV system j.mprove, the installation of these
systems will become more attractive to and financially
attainable by the Company's average residential- customer.
O. Has the Company projected future adoption of
residential custonrers with on-site generation?
A. Yes. As previously reported to the
Commissior-,12 using historical growth trends, the Company
projects that the count of residential customers with
on-site generatj-on could be as high as 1,032 customers or
as Iow as 6,1,71 customers by 2022, with the median growth
rate resulting in 6,816 residential customers wj-th
on-sj-te generatj-on. Fi.gure 2 reflects this forecast.
11 Case No. IPC-E-1,2-2'7, 2016 Annual Net Metering Status
Report, p. 8.
12 Case No. IPC-E-1-2-21, 2017 Annual Net Metering Status
Report, p. 8.o 25
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CSB REPORTING(208) 890-s198
ASCHENBRENNER, Dr L5
Idaho Power Company
2: Eorecastcd GroryEb ia Bidectia]. Oo-Sita
Geaeratioa
III. CUSTODER END EITGAGETGN,|I
O. Did the Company consult with R&SGS net metering
customers and stakeholders prior to the date of this
filing?
A. Yes. The Company consulted with customers and
stakeholders in 2016 and again in 201-7.
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CSB REPORTING
(208 ) 890-sl-e8
ASCHENBRENNER, DI 15A
Idaho Power Company
O. Please describe the Companyrs efforts in 2016.
A. In JuIy of 2076, the Company held a workshop
for customers and stakeholders to share the results of
the 2016 Annual Net Metering Status Report to the
Commission ("2016 Report'r) and solicit feedback on a
potential filing the Company was considering. The
Company sent an invj-tation (via direct mail) to all
current and pending R&SGS net metering customers, an
invj-tation (via email) to all parties who intervened in
Case No. IPC-E-12-27, and an
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invitation (via emaj-l) to a list of instal-lers who were
known to be doing business in the Company's service area.
In totaI, the Company sent out approximately 830
invitations to participate in the workshop.
O. What were the objectives of the workshop?
A. The Companyrs objectives were to (1) share the
results of the cost shifting analysis presented to the
Commission j-n the 20L6 Report, (2) raise awareness among
the Company's R&SGS net metering customers about the
issue of cost shifting and that the Company was
considering making a filing that may seek to modify rate
design, and (3) solicit input, feedback, and concerns
from customers and stakeholders.
0. What was the format of the workshop?
A. As one of the Company's representati-ves, I
presented participants with an overvi-ew of how Idaho
Power quantifies the costs associated with providing
service (revenue requirement), a brief explanatj-on of how
Idaho Power then assigns those costs to the varj-ous
customer classes (c1ass cost-of-service study process),
as well- as an explanation of how existing residential
rates are established to collect those costs (rate
design). I al-so presented the cost shift findings
published in the 2AL6 Report. The presentation used at
the workshop is attached as Exhibit No. 10.
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CSB REPORTING(208) 890-s198
ASCHENBRENNER, DI 16
Idaho Power Company
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I then discussed a potential "straw man" for
net metering residential rate design and the Company's
eval-uation of a filing that woul-d j-nclude: (1)
recognizing how net metering customers use the system
differently by segmenting R&SGS net metering customers
into their own respectlve classes, and (2) addressing the
cost shift caused by the existlng residential- rate design
by establishing a rate that would collect more fixed
costs through a higher fixed service charge from those
classes. I also explained to participants that the
Company was considering different options that coul-d be
proposed to mj-tigate the impact of the potential filing
to existing net meterj-ng customers.
O. How many customers attended the workshop?
A. The Company had L24 customers and stakehol-ders
attend in person and 18 customers and stakehol-ders
participated remotely via WebEx.
O. Did you ask for feedback from participants of
the workshop?
A. Yes. After my presentation, I posed two
questions to participants to promote discussion: (1) how
should Idaho Power best collect grid costs from net
metering customers, and (2) if rates were changed, how
can Idaho Power best mitigate the impact to existing net
meterJ-ng customers?
ASCHENBRENNER, DI 1.7
Idaho Power Company
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CSB REPORTING
(2oB ) B9o-s198
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a. Generally, what did you hear from the workshop
participants?
A. Overall, of the customers and stakeholders who
commented, most felt that the Company's analysis
contained in the 20L6 Report should have quantified
potential- benefits that on-site, customer-owned
generation systems provide to the Company. Several of
those who commented felt that the Company's assessment of
cost assignment overstated a net metering customer's use
of Idaho Power's system.
Some commenting partj-cipants felt that the
straw man rate design was punj-tive for net metering
customers and would discourage future adoption of net
metering. A few participants felt that others (the
Company or other customers) should be compensating
customers with on-site generation for the j-nvestment they
made in their systems.
a. What did the Company do with the feedback it
received from participants of the workshop?
A. After carefully considering the input from
customers and stakeholders, the Company decided not to
make a filing in 2016 and instead contemplated alternate
case strategy while contj-nu.tng to monitor the
participation in the net metering service.
O. Did the Company engage in additional
stakeholder outreach?
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CSB REPORTING
(208 ) 890-s198
ASCHENBRENNER, DT 18
Idaho Power Company
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CSB REPORTTNG
(208 ) 890-5198
ASCHENBRENNER, DI 19
Idaho Power Company
A. Yes. The Company hel-d a stakehol-der meeting on
June L6, 20L7. The Company invi-ted (via email) all
parties who intervened in Case No. IPC-E-12-27.
O. What were the objectives of this meeting?
A. The Company's objectives were to (1) update
participants on activity slnce the customer meeting held
in July 2016, (2) j-nform stakehol-ders of a filing the
Company was considering, and (3) invite additional-
feedback from stakeholders.
O. What was the format of the meeting?
A. The Company held a 9O-minute meeting at j-ts
Corporate Headquarters. There was no formal
presentation, but as a representative of the Company, I
provi-ded a summary of the July 2016 workshop and
discussed the Company's decision to not pursue pricing
changes for R&SGS net metering outside of a future rate
proceeding. I discussed the Company's desire to continue
to work with stakeholders both throughout this proceeding
and in advance of a future rate case to determine areas
of alignment regarding rate design and compensation
methodologies for RcSGS customers who install distributed
energy resources ("DER"). I also discussed the Company's
planned filing and why the Company feel-s that
establishing customer classes j-n advance of a general
rate proceeding is
O. How many
necessary.
stakeholders attended the meeting?o 25
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CSB REPORTING
(208 ) 890-5198
ASCHENBRENNER, DI 20
Idaho Power Company
A. There were t6 stakeholders who attended the
meeting, including several parties from IPC-E-12-27
(Commission Staff, Idaho Conservation League, Idaho Clean
Energy Association, and the Snake River Alliance).
O. Did the Company solj-cit feedback from
participants at the meeting?
A. Yes. At the conclusj-on of my remarks, I asked
all of the stakeholders j-n attendance to provide feedback
on potential- areas of agreement and to express ideas for
how the Company could best facil-itate future meetJ-ngs to
discuss alternate rate design and compensation
methodologies for customers with DER.
a. Generally, what did you hear from participants
at the meeting?
A. Participants at the meeting expressed a desire
to quantify the potential benefi-ts that on-site,
customer-owned generation systems provide to the Company
prior to discussi-ng whether establishing new customer
classes is appropriate. Some parties expressed concern
that because other j-nequlties exist within the
residential customer cl-ass, the Company should not
address rate desj-gn
on-site generation.
what a comprehensive
involve.
associated with customers who have
There was also discussion regarding
value of DER proceeding could
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CSB REPORTING
(208 ) 890-s198
ASCHENBRENNER, DI 2LIdaho Power Company
O. Did the Company solicit feedback from sol-ar
j-nstallers prior to making thrs filing?
A. Yes. The Company held a meeting with solar
install-ers on June 30, 20L1. The Company invited (vla
email) all instal-lers who are known to be doing business
in the Company's service arear ds wel-l- as the Commission
Staff, to partj-cipate in the discussion.
O. What were the objectives of the meeting?
A. The Company's objectives were to (1) update
participants on activity since the Iast customer meeting
hel-d in JuIy 2016, (2 ) inf orm stakeholders of a f iling
the Company was considering, (3) discuss the Company's
desire to pursue a smart inverter requirement, and 4)
j-nvite feedback from installers on what, Lf dDy, changes
to Schedule 72 they percei-ved necessary.
O. What was the format of the meeting?
A. The Company held a 9O-minute meeting at its
Corporate Headquarters. There was no formal-
presentation, but as a representative of the Company, I
provided a sunrmary of the JuIy 20L6 meeting and al-so
discussed the Company's decision to not pursue pricing
changes for R&SGS net metering outsj-de of a future rate
proceeding. I discussed the Company's desj-re to
continue to work with stakeholders both throughout this
proceeding and in advance of a
determj-ne areas of alignment
future rate case to25
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regarding rate design and compensation methodologies for
R&SGS customers who instal-l DER. I al-so discussed the
Company's planned filing and why the Company feel-s that
establ-ishing customer classes j-n advance of a general
rate proceedj-ng is necessary.
Company witness Dave Ange11 then led a
discussion focused on the current interconnection
requirements in Schedu1e 72, including a discussion
specifically regarding inverters and the Company's desire
to require smart inverter functionality at a future time
when the industry establishes a standard for what
constitutes a smart inverter.
O. How many installers attended the meetj-ng?
A. There were 19 install-ers who attended the
meeting.
O. Did the Company sol-icit feedback from
installers at the meeting?
A. Yes. After Mr. Angel1's remarks, he asked the
installers for feedback specifically related to smart
inverters and also invited the install-ers to discuss any
sections of Schedul-e 72 that they find difficult to
comply with.
A. What type of feedback did the Company receive
from installers?
CSB REPORT]NG(208) 890-s198
ASCHENBRENNER, DI 22
Idaho Power Company
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CSB REPORTING
(208 ) 890-s198
ASCHENBRENNER, DT 23
Idaho Power Company
questions
Commission
some expressed
conversations
O. Did the
j-nstallers present
Company specifically
had concerns about
inverters
ask if the
the possibility of
in the future?
A. The install-ers asked several-clarifying
ask thearound the Company's plans to
to establish separate customer classes, and
a desire to participate j-n future
with the Company to determine the benefits
and costs of on-site generation systems. Those present
also asked clarifying questions around the benefits of
smart inverters.
the Company requlring smart
A. Yes. Mr. AngeJ-I asked participants, based on
the discussion in the meeting, if they woul-d have
concerns if the Company were to seek the incl-usion of a
smart inverter requirement at the time when an industry
standard was adopted. The installers present indicated
that professionally installed systems already utilize
inverters that have "smart functionality" and did not
express any concerns around the Company's plan to require
smart inverters at a future date; however, those who
commented suggested the Company shou1d clearly
communicate or offer a list of inverters that meet the
requirements and a process to configure them at the point
when those i-nverters are mandated.
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CSB REPORTING
(208 ) 890-s198
ASCHENBRENNER, DI 24
Idaho Power Company
O. Did the Company incorporate the feedback it
heard durj-ng June from stakeholders and installers into
this filing?
A. Yes. At the tlme of the meet j-ngs I described,
the Company simply planned to request the establishment
of new classes and propose a smart i-nverter requirement.
As described more fuI1y in Mr. Tatumrs testimony, the
Company's decision to ask the Commissj-on to open a
generic docket where parties from across the state could
participate in a discussion about identifying/quantifying
the benefits and costs of on-site generation was the
dj-rect result of what the Company heard from interested
stakeholders and instal-lers during those meetings.
O. Does the Company intend to participate in
future workshops/meetings with stakehol-ders and
interested parties?
A. Yes. As described by Mr. Tatum, following the
conclusj-on of this case, the Company anticipates
participating in a Commission-l-ed generic docket where
parties will- evaluate the benefits and costs of on-site
generation.
IV. ESTABLISHMENT OF SEPARJATE CUSTOMER CI,ASSES
separate
segments ?
V{hy is the
classes for
Company requesting to establ-ish
the R&SGS net metering customer
O
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CSB REPORTING
(208 ) 890-s198
ASCHENBRENNER, DI 25
Idaho Power Company
A. It is a long-standing ratemaking
establish separate customer cl-asses to set
segments
where the
of customers with different costs
from their
described
identified
practice to
rates for
of service or
nature or type of l-oad is distinctly different
current customer classification.
On page 7 of Order No. 26780, the Commission
class differentiating characteristj-cs
in Idaho State Homebuil-ders v. Washington
Water Powerl3 "cost of servi-ce, quantity of electri-city
used, differences in conditions of service, or the time,
nature and pattern of use" as "guidelines the Supreme
Court has set for the Commission to use to evaluate
whether there is a reasonable justification for setting
different rates and charges for different classes of
customers. tt
O. What characteristj-cs differentiate the R&SGS
net metering customers from standard R&SGS customers such
that a reasonable justificatlon exists for setting
different rates and charges?
A. The nature and pattern of
net metering customers is different
R&SGS customers. As described more
testimony, the tj-me, nature,
differs because the standard
segment
energy use by R&SGS
than the standard
fully in Mr. AngelJ-'s
and pattern of energy use
service R&SGS customer
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73 ldaho State HomebuiJ-ders r/. Washington Water Power, 701
Idaho 415, 420, 690 P.2d 350, 355 (1984).
CSB REPORTING
(208 ) 890-s198
ASCHENBRENNER, DI 25A
Idaho Power Company
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CSB REPORTING(208) 890-sr9B
ASCHENBRENNER, DI 26
Idaho Power Company
only consumes energy from the grid, while the R&SGS net
metering customer segment both consumes energy from the
grid and delivers excess net energy to the grid when not
consuming all generation on-site. That is, the standard
service customer has a one-way rel-ationship with the grid
while the net metering customer has a two-way
relationship. This two-way fl-ow of energy is unique and
fundamentally different than a non-net meterj-ng customer.
Further, while the daily demand reguirements of the two
customers may be similar, net metering customer's net
monthly energy as a basis for bj-I1ing does not refl-ect
their utilization of the grid.
O. Do the R&SGS customers with on-sj-te generation
differ from one another such that i-t makes sense to
create a separate
on-sj-te generation
classes not because of the amount
customer cl-as.s for the residential
and
rather than creati-ng a
smal-l- general on-site generation
single new customer cl-ass for
these on-site generation customers ?
A. Yes. R&SGS customers vrho take standard service
from Idaho Power are set apart in separate customer
of energy they use but
is different from onebecause the nature of energy use
another. The nature of energy use by resldential-
customers is for general domestic uses, such as
or living in
commercial
a space. The nature of energy use
occupying
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CSB REPORTING(208) 890-s198
ASCHENBRENNER, DI 27
Idaho Power Company
customer is generally for business, professional, ot
other gainful purposes.
O. If R&SGS customers with on-site generation are
distinctly different from each other, why has the
Company's analysis focused primarily on the residential
net metering customers?
A. The Company's analysis focused on the
residential- net metering customers because most of the
recent growth in the net metering service is in the
residential class; however, because the residential- and
the smal1 general service customer classes both have a
two-part rate design with most of the customer-related
fixed costs and al-l- of the demand-rel-ated fixed costs
being recovered through a vol-umetric charge, both
customer classes have the potential to create a cost
shift.
O. How is the residential net metering customers'
impact on the grid different than that of the residential
standard service customers?
A. The load shapes in Figure 3 illustrate the
demand placed on the grid by the Company's residential-
net meterlng customer segment and the Company's
residential standard service customer class on the 20L6
adjusted peak
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CSB REPORTING(208) 890-s198
ASCHENBRENNER, DI 28
Idaho Power Company
day.re Specifically, note the distinct difference in the
time and pattern of use between the two.
Figure 3: Average Load Shapea for Rscidential Standard
Service Cuctoaerg and Ragidsatial l$et lleter Customers
The first noticeable difference is the distinct
dip in load during midday for the residential net
metering customer segrment caused by increasing production
by on-site generation, which reduces their reliance on
Company-provided energy. The second noticeable
difference is the steep ramp-up of demand for Idaho
Power-owned generation following the midday dip for the
residential net metering customer segment caused by
decreasing production from on-site generation combi-ned
with increasing loads. On the other hand, the
residential standard service load shape
L 2 3 4 5 6 7 I 9 10111213141516171819201t2'22124
Hour Ending
-Residential
Net Metering
-Residential
Standard Service
300
2.DO
1.00
2.ffi'
4.00
3J
000
1.00
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14 The adjusted system peak day represents the hour at which
the system would have peaked had the Company not dispatched its
demand response programs. This methodology is consistent with the
filed cl-ass cost-of-service study from the Company's last general
rate case (IPC-E-11-08) .
CSB REPORTING(208) 890-s198
ASCHENBRENNER, Dr 28a
ldaho Power Company
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maintains a steady demand profile with l-ess variation
from hour to hour.
O. Is a net metering customer's usage simil-ar to a
standard service residential customer who has little
monthly kilowatt-hour ("kV{h") usage?
A. No. Figure 4 shows a comparison of the load
shapes among different residential energy usage leveIs to
the load shapes of the entire residential- customer class
and the residential- net metering segment on the 2076
adjusted peak day. Eigure 4 illustrates that while the
time, nature, and pattern of use of al-I residential
customers are consistent between different energy usage
1evels, they are distinctly different than the time,
nature, and pattern of use of the net metering customer
segment. Another j-mportant difference is that the sum of
the hourly usage over the bill-ing month accurately
reflects the utilization of the grid by the customer with
Iittl-e monthly kWh usage whereas the net monthly energy
as a basis for billing may not reflect the util-ization of
the grid by the net metering customer.
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CSB REPORTING(208) 890-s198
ASCHENBRENNER, DI 29
Idaho Power Company
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CSB REPORTING
(208 ) 890-s1_98
ASCHENBRENNER, DI 3O
Idaho Power Company
Figmre {: Average Load Shalrs for Residsatial ltet !{atering
Custom€rs anrd Standard Service Leve].a
O. fs the service taken by a residential standard
service customerfs vacation home, with no kWh usage in a
month, comparable to a residential net metering customer
whose usage nets to zero?
A. No. While the residential net metering
customer and a residential standard service customer with
a vacant vacation home have the potentiaL for similar net
usage on a monthly basis, the similarity ends there. The
way in which these two types of customers utilize the
electrical system on a daily or hourly basis differs
dramatically. When a vacation home has zero energy
consumptj-on over a month, it is because the customer did
not take any energy during the month, and therefore, did
not utilize the Company's grid duri-ng that month. On the
1me6
75%
5S6
25%
0e6
-25%
..5096
I 2 3 4 5 6 7 8 9 10111213141516171819202t222!7.4
Hour Endlng
0-7m
2.151 +
- - 701-1,25O
-
Resideftttal
1,251 2,1s0
Het Metering
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CSB REPORT]NG(208) 890-s198
ASCHENBRENNER, DI 32
Idaho Power Company
in the hours when the system is generating. When the
system is not generating, the grid is relied upon to
serve the ful] demand.
Lastly, the sum of the hourly usage over
the utilizationbilling month accurately reflects
grid by the customer who installs
whereas the net monthly energy as
not reflect the utilizati-on of the
the
of the
metering customer.
O. Why doesnft the net monthly energy reflect the
utilization of the grld for a customer with on-site
generation?
A. Most R&SGS customers with on-sj-te generation
both consume energy from the grid and deliver excess net
energy to the grid when not consumlng all generati-on
on-site. When a customer with on-site generation
produces either the same
system than they util-ize
the customer's use wil-I
energy efficiency,
a basis for billing may
grid by the net
amount or more energy from their
over the course of the month,
net to zero; this is commonly
customer. However, duri-ng
the net zero customer is a
and durj-ng other
a net consumer of
customer utilizes al-l-
the hours they are
referred to as a "net zero"
certain hours of the month,
net exporter of energy to the grid,
hours of the month, the customer is
energy from the grid. The net zero
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consuming energy
and dlstribution
(incl-uding the generation, transmission,
systems) but
CSB REPORT]NG(208) 890-s1_98
ASCHENBRENNER, DI 32A
Idaho Power Company
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CSB REPORTING
(2OB) 890-s198
ASCHENBRENNER, DI 33
Idaho Power Company
then al-so util-izes the distributi-on
hours they are
system during the
the grid.to
o. why
exporting energy
i-snrt the current rate structure for the
standard service customers
on-site generation?
A. The residential
appropriate for customers with
customers taking service under
Schedul-e L, Residential
design wlth most of the
all the demand rel-ated fixed costs being recovered
through volumetrj-c charges. The revenue requirement for
the residential- customer cl-ass is comprised of
approximately 70 percent fixed costs and 30 percent
variable energy costs; however, only five percent of the
total- revenue is collected through the fixed service
charge and the remaining 95 percent is col-lected through
the vol-umetric energy charge. As explained in Mr.
AngeII's testimony, while the daily demand requirements
of the two customers may be similar, net metering
customers' net monthly energy as a basj-s for billing
fails to col-lect the appropriate amount of costs and does
not reflect their util-ization of the grid.
O. Can you provide an example illustrating how the
current rate design fails to collect the appropriate
amount of costs from a net zero customer?
Service, have a two-part rate
customer-related fixed costs and
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CSB REPORTING
(208 ) 890-s198
ASCHENBRENNER, D] 34
Idaho Power Company
A. Yes. When a net metering customer' exports
meter "spj-nsexcess net energy to
backwards, " or in the
usage electronically.
day or month when the
the grid, their retail
case of a modern meter, subtracts
Later during other hours of the
customer is consumj-ng energy from
the grid, the meter "spj-ns forward, " or adds usage
electronically. Sor orr a month.ly basis, the net meterlng
customer is using the grid, every hour, every day, but
because usage j-s measured for bil-l-ing purposes on a
monthly basis, that net metering customer appears to have
"zero usage" for the month.
Table 3 shows the annual 2016 base rate revenue
received from a net zero customer and the base rate
revenue received from a standard service customer who
lives nearby. As shown in Mr. Angell's testimony, the
net zero customer utilizes ihe grid as much (albeit
bi-directj-onally), as a nearby standard service customer
whose annual energy requirements are
Powerrs average residential usage per
that customer will- not be bi-lled for
cl-ose t'o fdaho
customer; however,
any kwh charges (and
excess of $S perwil-l- avo-id paying for
month) so long as the
generation exported to
of the hours when the
grid. The net zero
neighbor of the net
fixed costs in
sum of the hours with excess
the grid
customer
is greater than the sum
was consuming from the
customer paid $60 in 201,6;
zero customer, who consumed
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CSB REPORTING
(208 ) 890-s198
ASCHENBRENNER, DI 35
Idaho Power Company
all- their energy needs from the grid, paid base rates of
$1,225 .
fable 3: Annual Utility BiJ.J. Comparison (net zero
customer and nearby residential custoner)
Net ZeroResidential Nearby
Residentia].
Service Charge
kWh Charges
$60
U
$60
1, 165
Total $so $L,225
While these two cust.omers may look similar from
a grid utilization standpoint, the current pricing
structure only appropriately collects costs from the
standard service customer who uses the system in one
direction.
O. Is the net zero customer representative of all
the Company's R&SGS net metering customers?
A. No. However, the net zero customer most
clearly illustrates the issue of applying the standard
service rate design to a segment of customers who have
the ability to reduce some or all of their usage, when
measured on a net monthly basis. As the cost to install-
solar PV continues to decline and if a retail rate net
metering policy remains in p1ace, customers wil-l- continue
to receive a price signal that is not refl-ective of
having access to fdaho Power's grid for both the supply
of energy and demand in hours when a customer's on-siteo25
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CSB REPORTTNG(208) 890-s198
ASCHENBRENNER, DI 35A
Idaho Power Company
system is not generating, as
for the export of excess net
on-site. In a recent letter
Exhibit No. 11 to
wel-l- as access to the grid
energy that j-s not consumed
to the editor (attached as
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CSB REPORTING
(208 ) 890-s198
ASCHENBRENNER, DI 36
Idaho Power Company
my testimony), one
instal-ling a sol-ar PV system last summer: "now my monthly
e.l-ectric bill is only $5.27 ."
O. Other intra-class subsidies exist within the
residential class. Why is the Company only proposing to
cl-asses for R&SGS customer with
on-site
separate customer
generat j-on?
As discussed in Mr. Tatumrs testimony, other
i-ntra-class subsidies do exist and continue to exist
absent fu11y unbundled cost-based rates; however, the
distinct differences between the time, nature, and
pattern of use by standard service customers and R&SGS
customers with on-sj-te generatj-on is what is driving the
need for separate customer classes. As explained
previously, the Company groups segments of customers
together into cl-asses based on differentiation by
cost-to-serve and how and when they use the system. The
unique way that R&SGS customers with on-site generation
interact with and use the grid dernonstrates that creatj-ng
R&SGS on-site generation classes of their own is
appropriate and can enabl-e more effective rate design to
accurately reflect the costs incurred to serve those
segments of customers.
Idaho Power customer remarked of
create
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CSB REPORTING(208) 890-s1-98
ASCHENBRENNER, DI 37
Idaho Power Company
V. PROPOSED TARIFF CEAIIGES
O. In the Companyrs proposal, under which tariff
schedule wj-Il the exJ-sting and pending net metering
customers take service?
A. Existlng net metering customers and those
pending customers who have submitted a complete net
metering System Verifj-cation Form el-ectronically or
post-marked on or before December 37, 2011, will continue
to take service under Schedule 84.
0. What constitutes a complete System Verification
Form?
A. Pursuant to the interconnection requJ-rements
contained within Schedule 72, once a customer has
completed the installation of the system, they must
provide the Company
federal, state, and
customer must then
the documentation verifying that all
loca1 requirements have been met; the
Verification Form to take
a net metering System
servi-ce under Schedul-e 84.
O. Who will- take service under the proposed new
Schedules 6 and 8?
A. New R&SGS customers, who request to
interconnect an on-site generation system (evldenced by
the completion
submi-ssion of
of the state electrical- inspection and
the net meterJ-ng
submit
after the effective date of the
system verification form)
proposed new Schedules 6I25
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CSB REPORTING(208) 890-s198
ASCHENBRENNER, DI 38
Idaho Power Company
and 8, January L, 2078, wj-J-J- take service under Schedul-es
6 or 8. Schedule 6 and Schedule 8 are included as
Attachments 2 and 3 to the Application.
O. Why is the Company proposj-ng an effective date
of January 7, 2078?
A. In the Companyrs experience, over 95 percent of
applications received for net metering service submit the
System Verj-fication Form within five months (the proposed
schedu]e of thj-s case) .
experience that
instal-Ied prior
tax credit in a
a. Is the
Eurther, it is the Company's
desire to have their systemcustomers
to year-end to be eligible for the income
given tax year.
Company proposing any changes to the
in Schedul-e 84?rate structure or compensation method
A. No. The Company is not proposi-ng
to the rate structure or compensation method
84.
any
in
changes
Schedul-e
O. WiIl customers who take service under Schedules
6 or 8 have different
method than Schedule
metering schedule?
A. Not at this
rates or a different compensation
84, the Company's current net
time. The rate structures proposed
rates inin Schedules 6 and I will continue to mi-rror the
Schedules l- and 7, respectively, until the Commissi-on
approves changes to the rate design or theo25
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compensation method for these customer segments in a
future rate proceeding.
O. Is the Company proposing any changes to
Schedules 6 and I that differ from Schedule 84?
A. Yes. Because the prices for the Schedu1e 6 and
8 services will be contained within the newl-y proposed
schedules, the Company is proposing to include language
1n those schedules to inform customers that prices
contained in the schedule today a::e subject to change and
they will be subject to any future changes to rate design
and/or compensation methodol-ogies subsequently approved
by the Commission. While all tariff schedul-es are
lnherently subject to change, the addition of this
language is intended to continue the Company's efforts of
increasing customer communication concerning the
potential- for pricing changes that exist under its
tariff.
O. If the Commission approves Schedules 6 and 8,
will the Fixed Cost Adjustment ("FCA") apply to those new
schedules?
A. Yes. Because there are no changes proposed to
rate design as part of this proceeding, j-t is approprj-ate
that the approved FCA rates will continue to apply to
customers in the newly estab-lished R&SGS schedules. The
Company envisions proposing modifications to how and to
CSB REPORTTNG
(208 ) 890-s198
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ASCHENBRENNER, D] 39
Idaho Power Company
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what extent the FCA should apply going forward to
Schedul-es
ASCHENBRENNER, DI 39A
Idaho Power Company
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CSB REPORTING(208) 890-s198
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CSB REPORTING(208) 890-s198
ASCHENBRENNER, DI 40
Idaho Power Company
6 and 8 at the time rate design is addressed for these
customer cl-asses.
O. What changes does the Company propose to
Schedule 84?
A. The Company is proposing to close Schedule 84
to new service for R&SGS customers as of the effective
date of the proposed new Schedules 6 and B. The proposed
Schedule 84 is included as Attachment 1 to the
Application.
O. What changes does the Company propose to
Schedule 72?
A. The Company is revising Schedule 72 to
i-ncorporate the defined terms necessary to sync the
interconnectj-on requirements between Schedule 12 and the
newly proposed Schedules 6 and 8.
The Company is al-so proposing to make one minor
revision to Schedul-e 72 to al1ow the Company additional
time to compJ-ete the on-site inspection of a newly
install-ed on-site generation system when circumstances
beyond the Company's control arise, making the onsite
J-nspectlon impracticable or impossible within the
1O-business day requirement. V[hi]-e this is not a likely
occurrence, there are factors outsj-de of the Company's
control- that would prevent it from meetj-ng this tariffed
requirement, as it currently exists. For example, durlngthe 2016-2017 winter, the Company encountered difficulty25
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CSB REPORT]NG(208) 890-s198
ASCHENBRENNER, D] 47
Idaho Power Company
performing inspections due to heavy snow fa11 that
prevented solar PV systems from powering up for the
inspection.
O. Are any other tariff rules or schedul-es
impacted by the creation of new Schedul-es 6 and 8?
A. Yes. The following rules and schedul-es are
effected by the creation of new Sclredules 6 and 8: Rule
H (H-1, H-11), Rule I (I-1 , I-2) , Schedul-e 54 (54-1,
54-2) ,
(61-1),
(66-3,
Schedul-e 55 (55-1 , 55-2, 55-3), Schedule 6l
Schedule 63 (63-1 , 63-2, 63-4), Schedu1e 66
66-4), Schedule 81 (81,-2), Schedul-e 9!(e1-1),
These rulesSchedule 98 (98-1), and the Schedule Index.
and schedul-es are included in this filing as Attachment 4
format.to the Applicatiou in legislative
VI. COMMT'NICATION REGARDTNG THE FILING
0. What efforts has the Company made to current
and pending net metering customers to inform them of this
f i1j-ng?
A. The Company mailed two separate letters today,
July 21, 2017, to active and pending net metering
customers.
Attached as Exhibit No. L2 i-s the letter that
was maj-1ed to existing R&SGS customers takj-ng service
under Schedule 84 as of the date of this fiJ-ing. The
purpose of that letter was to inform existing net
metering customerst25
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CSB REPORTING(208) 890-s198
ASCHENBRENNER, DI 42
Idaho Power Company
of the filing and how they would be impacted; that is,
the Company proposes to leave the existing net metering
customers on Schedule 84 for the time being. The Company
also provided information as to how those customers coul-d
submit a comment for the Commissionrs consideration.
The Company al-so mailed a letter (attached as
Exhibit No. 13) to those R&SGS customers who have
signaled thej-r intent to install- an on-site system under
Schedule 84 by the submission of a net metering
applicatj-on recej-ved prior to this filing. The purpose
of that letter was to inform pendlng net metering
customers of the filing and how they woul-d be impacted;
that is, the Company's proposal envisions that customers
who submit an electronic or post-marked System
Verificatj-on Form on or before December 31, 201,7, will
take service under Schedul-e 84; those customers who
submit an electronic or post-marked system verification
form on or after January l, 20L8, would take service
under the successor schedule to Schedule 84. The Company
also provj-ded informatj-on as to how those customers cou.l-d
submit a comment for the Commission's consi-deration.
The Company also
R&SGS customers who submit
intends to mai-l this letter to
after the date of the filing,
net metering application
but prior to receipt of a
Commission order.
a
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0. Does the Company envision sending additional
communicatj-on to j-ts pending net metering customers whi1e
this case is processed?
A. Yes. The Company also plans to send reminder
letters, via dj-rect maj-l, to customers who have submitted
an application, but who have yet to submit a System
Verification Form, regarding how they may be impacted by
the Company's proposed filing. The Company expects to
send these letters while the case is bej-ng processed.
O. Does this conclude your testimony?
A. Yes.
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CSB REPORTING
(208 ) 890-s198
ASCHENBRENNER, DI 43
Idaho Power Company
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O. Please state your name.
A. My name is Connie G. Aschenbrenner.
O. Are you the same Connie G. Aschenbrenner that
previously presented direct testimony?
A. Yes.
O. Have you had the opportunity to revj-ew the
pre-filed direct testimony of the City of Boise's witness
Stephan L. Burgos; the Idaho Cl-ean Energy Association,
Inc.'s witnesses Kevin King, Michael Leonard, and Stephen
Ir'Ihite; the Idaho Conservation League's witness Benjamin
J. Otto; Sierra Cl-ubrs witness R. Thomas Beach; the Idaho
Irrigation Pumpers Associatj-on, Inc's witness Anthony J.
Yankel; the Snake Rj-ver All-iance and NW Energy
Coalition's witness Amanda M. Levin; Vote Solar's witness
Briana Kober; Auric So1ar, LLCrs witness Elias Bishop;
and the Idaho Public Utilities Commission ("Commission")
Staff 's ("Staff") witnesses Mj-chael- Morrison and Stacey
Donohue?
A. Yes, I have.
O. What is the purpose of your rebuttal testimony.
A. The purpose of my rebuttal testimony is to
address concerns expressed by j-ntervenj-ng parties and
Staff in their direct testimony. My testimony is
comprised of four sections.
CSB REPORTING(208) 890-s1e8
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Idaho Power Company
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CSB REPORTING(208) 890-s198
In Section I, I provide the Commission with an
update on customer participatj-on in net metering since
the filing of the Application in Ju1y.
In Sectj-on II, I briefl-y discuss consumer
protection and provi-de some clarity about informatj-on
related to the Idaho Power Company's ("Idaho Power" or
"Company") stakeholder engagement in preparation of, and
leading up to, the filing of this docket.
In Sect.ion III, I address the concerns
expressed by parties regarding a class cost-of-service
study ("COSS") and how costs are al-l-ocated among the
Company' s customer cl-asses.
In Sectj-on IV, I explain why the current rate
structure for residential and smal-I service ("R&SGS")
customers with on-site generation is outdated and needs
to be addressed.
r. UPDATE ON NET METERIIIG PARTICIPATION
O. Please provide an update of participation in
the Company's net metering service since reported to the
Commission in the Company's Applicatlon.
A. Participation in the Company's net metering
service has continued to grow since its Application was
filed on July 27, 20L7. Tab1es 1 and 2 represent updated
system counts and nameplate capacity as of December 31,
20!7 .I
474 ASCHENBRENNER, REB 2
Idaho Power Company
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CSB REPORTING(208) 890-s198
ASCHENBRENNER, REB 3
Idaho Power Company
Iab1el-IdahoNet tos
Talr1e2-ldaboNet te ty (in lo[)
O. How does the total nameplate capacity of active
and pending net metering systems at December 31, 20L7,
compare to the ori-gina1 participation cap of 2.9
megawatts ("Mltl") as authorized by the Commissj-on in 2002?
A. The total capacity of active and pending
systems in the Company's Idaho jurisdiction was 15.98 MW
as of December 3!, 201"7, approximately 5.5 times the
original cap. Fj-gure 1 shows year-over-year installed
capacity of Idaho's net metering service since 20L2- The
solid horizontal line represents the initial 2.9 MW cap
authorized by the Commission in 2002.
CLass Photovoltaic 9Iind Eydro/ottrer TotaI
Residential-L,178 42 6 7,826
Commercial &
Industrial 1.46 5 4 155
Irrigation 10 1 11
fofa1 L,934 48 L,99210
C]-ass Photovoltaic YIind Eydro/Ottrer TotaI
!2.t0 12.35Residential0.19 0.06
Commercial &
Industrial 2.14 0.03 0.09 2.86
Irrigation 0.73 0. 04 0.00 0.11
Total 15. s8 0.26 0.15 15.98
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CSB REPORTING(208) 890-5198
ASCHENBRENNER, RBB 4Idaho Power Company
1: Cumulative te
O. What is the significance of the 2.9 MW cap?
A. fn its order authorizing the establishment of
Schedule 84, the Commission acknowledged that "the fuI1
cost of the program may not be borne by participants" and
that " [r] aisj-ng the cap . increases the level of
subsidizat.ion. "1
O. Several parties describe the negative impact
the filing is already having on the industry or w111 have
if the filing is approved.2 Do you agree the filing has
had a chilling effect on installatj-ons in the Company's
service area?
18
16
14
^t23
Ero
H8ELGu6
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1,600
1,200
8m
rro0
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201:2 2013 2014 201s
IResidential ICommercial&lndustrial
2016
Ilrrigation
2017
. Capacity
I 25
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CSB REPORTING(208) 890-s198
ASCHENBRENNER, REB 4A
Idaho Power Company
1 Commissj-on Order No. 28957., p. 12.
l-1.
l-l_.
2 Burgos DI, p. 10, 11. 2-3; King DI,
1-3; Leonard DI, p. 4, 11. 5-9, P. 7, LL
8-9; White DI, p. 9, 11. 8-10.
p.10,11. L5-22, p.11,
L4-16; Bishop Df, p. 2,o 25
417
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CSB REPORTING(208) 890-s198
ASCHENBRENNER, REB 5
Idaho Power Company
A. No. The Company received 885 applications for
net metering service during 2017. FJ-gure 2 compares the
number of applications received by month for 2016 and
20L7. The trend before the filing (increase in
year-over-year applications on a month-by-month basis) is
the same as the trend post-filing. It is clear the
filing has not had a negative i-mpact on the continued
adopti-on of customer on-site generation.
Figrore 2, ttet tbteriag 4lIl].icrtioas bgr Uoatlr (2OL6-2O17) :
L4
120
100
80
60
40
20
0
t;8, t25
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r"s
*1:2 *
C .o"d .,e's
12015 2Ot7
O. Steve Burgos claims the City of Boise has
already heard from lnstallers that "their busj-ness
decreased dramatically almost immedj-ate1y after"3 the
Company submitted its Application. How do you respond to
that claim?
3 Burgos DI, p. 7, 1I. 2-3.o 25
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A. The data simply does not support that. As
shown in Figure 2, the Company received 885 applications
during 2077, up from 368 recei-ved during 20L6. If Mr.
Burgos has heard from any installer that their business
is being negatively impacted, it may be more realistic to
attribute that to ei-ther the infl-ux of installers to the
Idaho market or the growth in market share from a
particularly active instal-1er, not the
As shown in Table 3 below, 1n the l-ast
of instal-l-ers in the Company' s
in 2011.
Company's filing.
five years, the
service area hasnumber
grown
TaIoIe
from LB in 20L3 to 51
3: Nuuber of Instal.J.ers and AppJ.ications by Year
20L3 20L4 2015 20t6 20L7
Installers 18 23 36 38 51
Tota].
AppJ.ications
59 1-01 26L 368 BB5
Additionally, a single lnstaller was listed on
335 applications in 2017, which represented 38 percent of
the applications submitted in 20!7. That same installer
was listed on 100 applications representing 27 percent of
the total applications submitted in 20L6.
O. Mr. Burgos also suggests that the,
"Zero-Net-Energy Maintenance and Administratj-on Building
at the Twenty Mile South Farm and could be negatively
j-mpacted by
CSB REPORTING(208) 890-s198
ASCHENBRENNER, REB 6
Idaho Power Company
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CSB REPORTING(208) 890-s198
ASCHENBRENNER, REB 7
Idaho Power Company
the formation of a new schedule. "4 Does the Company
agree with Mr. Burgosr assessment?
A. No. The Company's filing only impacts R&SGS
customers with on-site generation. The City's Zero-Net
Energy Maintenance and Administration Building is neither
residential nor small general service.
II. CONSI'MER PROTECTION A}ID STAIGHOI,DER ENGAGEMENT
1. Consuroer Protection
O. Commission Staff wj-tness Donohue suggests that
if the Company is
coul-d host a list
solar installers,
concerned about consumer protection, it
of "Participating Contractors" for
simil-ar to what it does for contractors
who install energy efficiency ("EE") measures. Do you
believe that to be a reasonable solution?
A. No. First, the purpose of the Participating
Contractor list that Ms. Donohue references is different.
The sofe reason the Company maintains the l-ist of
Participating Contractors referenced 1s to ensure the
prudent management
("Rider") funds.
of the Energy Efficiency Rider
The Company relies on these contractors
to ensure that measures are instal-l-ed correctty -- this
enables the Company to provide the Commissj-on with
reasonable assurance that customer funds are spent
prudently, and that in exchange for those funds, the
Company and i-ts customers are25
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4 Burgos DI, p. 6, 1I. 1,4-16.
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CSB REPORTING
(208 ) 890-s198
ASCHENBRENNER, REB 7A
fdaho Power Company
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receiving the
the measure (s)
this l-ist for
customers participating in
wj-th a reputable dealer."5
Second, it
does not warrant or
kil-owatt-hour ("kwh") savings attributed to
installed. The Company does not maj-ntain
the purpose of making "sure that its
its EE programs are dealing
j-s important to note the Company
guarantee the work
contractor listed.
or servlces
To suggest that
in the
performed by any
hosting a list of
Company's service
customers are
the services
EE
solar instal-l-ers located
area wou1d provide assurances that
0. Whil-e Idaho Power does not be1ieve
appropriate to provide endorsements of sol-ar
are you aware of any
customers find solar
A. Yes. The Energy and
entitledMineral Resources ( "OEMR" ) provides a website6
"Resources for Sol-ar Project Developmentr" which incl-udes
a listing of sol-ar installers throughout the state and in
the
5 Donohue DI, p. 27, 11. 22-23.6 https z / /oemr. idaho. gov,/wp-content/uploads,/
2015.12.31 ID Solar Dev Res.pdf
provi-ded with transparent
(and associated pricing) is
information about
not reasonable.
it is
installers,
help
of Idaho?
information avail-able to
installers in the state
Idaho Governor's Office of
CSB REPORTING
(208 ) 890-s198
ASCHENBRENNER, REB B
Idaho Power Company
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CSB REPORTING(208) 890-5198
ASCHENBRENNER, REB 9
Idaho Power Company
regaon.
on the
Idaho Power provides a Iink to the OEMR website
Company's website:7 The link is included in both
the Solar Checklist and in the Frequently Asked
Questions.
2. StakehoJ.deq E4gegenEq!
O. Ms. Donohue claims that
Company's plan to study the costs
establishing separate rate classes
customers aligns with feedback from
you suggested that "the
and benefits after
for net metering
stakehol-ders.ilB
Do you agree with Ms. Donohue's characterization of what
you claimed in your direct testimony?
A. No. In my direct testimony,' I stated that "the
Company's decision to ask the Commission to open a
generic docket where parties from across the state could
participate in a discussj-on about identifying/quantifying
the benefits and costs of on-site generation was the
dj-rect result of what the Company heard from interested
stakehol-ders and installers during those meetings. "9 I
di-d not claim that stakeholders and installers were
aligned on studying the costs and benefits after
establishing separate rate classes.
green-choice s,/ solar-power-opt j-ons /8 Donohue DI, p. 19, 11. 14-16.
9 Aschenbrenner DI, p. 24, 11. ?-13.
25
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7 https : ,/ /www. idahopower . com/energy,/renewable-energy/
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CSB REPORTING
(208 ) 890-s198
ASCHENBRENNER, REB 10
Idaho Power Company
In fact, I agree with Ms. Donohue that the
preference of stakeholders at the meeting was to engage
in a process to understand the benefits and costs
assocj-ated with on-sj-te generation prior to seeking
authority from the Commission to create new customer
classes.
Ms. Donohue also mj-scharacterizes the Company's
position in that meeting -- she claims that the "Company
made no indication that it might conduct the study after
determining the need for separate rate classes. "10 That
statement is incorrect. As representatives of the
Company, Mr. Tatum and I represented that the Company was
contemplating a filing to seek authorj-ty for creatj-on of
new classes as a first step toward addressing the cost
shift between net metering customers and standard service
customers.
III. CI,ASS COST-OF-SERVICE A}ID COST AILOCATION
O. How woul-d the Commission's deci-sion
cl-asses
regarding
affect thethe establishment
Company's COSS or
A. Tf the
of separate customer
ratemaking processes?
Commission determines there are
differences that warrant the establishment of new
customer cl-asses, the Company wil-l- assign costs to the
new customer classes in a future COSS and design rates
specific to those cl-asses as part of a future rate25
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proceeding.Shoul-d the
10 Donohue Dr, p. 19, 1l-. 20-21.
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CSB REPORTING
(208 ) 890-s198
ASCHENBRENNER, REB 1OA
Idaho Power Company
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CSB REPORTING(208) 8e0-s198
ASCHENBRENNER, REB 11
Idaho Power Company
Commission decline to authorLze the establ-ishment of the
requested new customer classes, the Company woul-d have no
reason to modify its class COSS or ratemaking processes
specific to net metering customers. The Company would
continue to allocate costs to the residential and smal-I
general servj-ce customer classes that exist today.
Staff wi-tness Dr.O. Do you agree with Commission
Morrison's characterizationll of how costs are al-Iocated
in the Company's COSS?
A. No.
Pl-ease explaj-n.
In his testimony, Dr. Morri-son discusses the
of system-coincident
o
A
Company's use
non-coincident demand ("NCD"), and
demands to al-Iocate costs to customer classes. V0hile Dr.
Morrison accurately descrj-bes how the Company utilizes
NCDs in the allocation of distribution plant, his
discussion of SCD and individual peak demands does not
reflect the actual methodology acknowledged in the
Company's most recent general rate case ("GRC"), Case No.
rPC-E-11-08.
O. Please define the SCD and NCD.
A. As described in Mr. David M. Angellrs Rebuttal
Testimonyr 12 the SCD is the average demand for the
customer
demand ("SCD"),
individual- peak
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11 Morrison DI, pp. 18-19.
12 Angelf REB, p. \4, 11. 4-9.
CSB REPORTTNG
(208 ) 890-s198
ASCHENBRENNER, REB 11A
Idaho Power Company
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CSB REPORTING
(208 ) 890-s198
ASCHENBRENNER, REB L2
Idaho Power Company
class at the time of Idaho Power's system peak.
the customer
The NCD
is the maximum average demand
regardless of when it happens.
are cal-cul-ated for each month.
class,
Both the SCD and the NCD
O. How was Dr. Morrj-sonrs discussion of SCD
inaccurate?
A. Dr. Morrison suggested that, "the Isystem]
coincident peak factor Iis] used to al-locate fixed
generation and transmission costs . . "13 While I
agree with the concept that SCDs are used to allocate
fixed generation and transmission costs, I find fault
with his statement because it suggests that there is just
one SCD used to allocate these costs. This is incorrect.
O. How does Idaho Power use SCD to all-ocate costs?
A. SCDs are used to allocate demand-related
generation and transmission costs among the Company's
different customer classes. Demand-related generation
costs associated with serving base and intermediate load
are a1l-ocated usj-ng 12 monthly SCDs, while demand-related
generation costs associated with serving summer peak load
are al-.]-ocated based on the sum of the three SCDs i-n the
13 Morrison DI, p. 18, 11. 14-1"6.
for
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CSB REPORTING
(208 ) 890-s198
ASCHENBRENNER, REB 13
Idaho Power Company
O. With regard
peak demands, was Dr.
summer months (June, July,
rel-ated costs are allocated
and August) . Transmissj-on-
utilizing 12 monthly SCDs.
use of individual- customer
class COSS with these
class, Dx. Morrison's
to the
Morrison correct when he stated,
"individual peak loads are important determj-nants of
costs that the Company expends on distribution p1ant, and
in particufar, on the costs of secondary transformers and
service drops ?'r14
A. No. Individual peaks are not used to allocate
costs in the Company's COSS.
O. Given that several of Dr. Morrj-son's
assumptions were
characteri zat ion
and transmission
A. Without performJ-ng a fuII
customers separated into a distinct
statement cannot be verified.
O. Please explain.
A. The Company performed an
to serve residential- customers with
incorrect, was his overall-
correct that "sIight1y less generatj-on
plant cost"15 would have been al-focated
to residential customers with on-site generation?
analys j-s
on-site
of the cost
generation
for inclusion in the 201,6 Net Metering Status Report.16
14 Morrison DI, p. 19, l-1 . '7 -1-O .
15 Morrison Dr, p. 18, 1. 18.
16 Aschenbrenner DI, Exhibit 9.25
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CSB REPORTING(208) 890-s198
ASCHENBRENNER, REB 14
Idaho Power Company
It should be noted that this analysis was not a ful-l-
class COSS that the Company typically performs in a GRC
filing, but rather an analysis utilizing currently
approved costs to estlmate the cost to serve customers
with on-site generation.
For this analysis, the Company calculated the
monthly SCD and NCD for the residential- segment of
customers with orr-site generatlon.l? Uslng the same
per-unit costs for residential customers from the 201,7
GRC, and multiplying
residential- customers
them by the SCD and NCD for the
estimate of the revenue requirement
generation, an
for residential-
customers with on-site generation was determined.
The results of that analysis determined that
(1) production plant costs associated with serving base
and intermediate l-oad increaseci because they are
all-ocated using an average of 12 monthly SCDs, (2)
productj-on plant costs associated with serving peak l-oad
decreased because these costs are al-l-ocated usj-ng an
average of the three monthly SCDs occurring in June,
Ju1y, and August, (3) transmj-ssion costs increased
because they are allocated usj-ng an average of 12 monthly
SCDs, and (4) distribution
The method used to calcu1ate the system-coincident and NCDs
was provided in response to a data request provided to Vote So1ar
(Vote Solar Request No. Llb), can be found as Exhibit 15.
with on-si-te
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CSB REPORTING
(208 ) 890-s198
ASCHENBRENNER, REB 15
Idaho Power Company
costs increased because cl-ass NCDs are used to al-locate
distribution costs.
moving in different
of what woul-d have occurred had the Company prepared a
ful-l cl-ass COSS cannot be verified.
O. Did the Company perform an additional analysis
of the SCD and NCD for residential customers with on-site
generation and for residential customers without on-site
generation?
A. Yes. Mr. Angell provides the results of the
Company's analysj-s of the SCD and NCD for both groups in
his rebuttal testimony.ls In summary, the SCDs of
customers with on-site generation are l-ower from April
through September than that of customers without on-site
generatj-on but higher from October through March. The
NCDs of customers with on-site generation is higher than
that of customers without on-sj-te generation for al-l- 12
months of the year.
O. How does cost allocation highlight the need to
separate these customers j-nto a distinct class for cost
of service purposes?
A. As I previously discussed, demand-related costs
are allocated to customer classes utj-1i-zing a
18 Ange11 REB, p. 14, 11. 10-17, p. 15, 11. 7-15.
Wj-th multiple allocation factors
direct j-ons, Dr . Morrison ' s statement
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CSB REPORTING(208) 890-s198
ASCHENBRENNER, REB 1,6
Idaho Power Company
combination of monthly system coincident demands and
NCDs. When analyzing these all-ocation factors for
customers with on-site qeneration, certain factors
increased while others decreased, thus making it
difficult to determine the net impact to the cost
determination for this group of customers. Consequently,
j-n predicting the results of a new COSS, Dr.. Morrison was
limited to using phrases such as " [the new study] would
1ike1y have allocated slightly less generation and
transmission pfant, w1e and "it is difficult to determine
whether i-t would have al-l-ocated more or less distribution
plant cost . .tt2o Separati-ng these customers into
their own classes for cost all-ocation purposes would
al1ow the Company, other interested parties, and
ultimately the Commission to determine the actual- cost to
serve customers with on-site generation.
rV. RATE DESIG:N
O. Why is it necessary to have separate customer
classes and a different rate structure for customers with
on-site generation?
A. As described2l by Mr. Angel1, a customer with
on-site generation is a "partial requirements" customer.
19 Morrison DI, p. 18,
20 Morrison DI, p. 19,
21 Ange11 REB, p. 3, I
11. 17-18.
1l-. 15-16.
18 through p. 4,I 15o25
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CSB REPORTING(208) 890-s198
ASCHENBRENNER, REB I7
Idaho Power Company
O. What is a partial requirements customer?
A. A partial requirements customer generates al-l-
or some of their own annual energy needs, while still
relying on the utility for a variety of services. These
servi-ces are described by Mr. Ange11 in his direct
testimony.22 Partial requj-rements service is availabl-e
to give customers fl-exj-bility in meeting some of their
energy needs while also providing the reassurance that
the utility is available to handle all their el-ectrical
needs should their on-site generation be interrupted,
fail t or is inadequate to meet their demand.
O. Why wouJ-d a partial requirements customer
require a different rate structure?
A. fdaho Power's current consumption-based rates
were designed
requirements
collect costs
for R&SGS customers who require full-
from the utility. The rates are designed to
j-n a bundled fashion that i-ncludes recovery
a
of generation, transmission, distrlbutj-on and
customer-related costs primarily through a vol-umetric
rate.
Current rate designs were not developed for
partial requirements customer, such as a customer who
generates al-l- or some of their own electricity.
22 AngeIL Dr, p. 4, Il-. 6-11.o 25
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CSB REPORTING(208) 890-s198
ASCHENBRENNER, REB 18
Idaho Power Company
O. Does
customers with
opportunity for
customers the costs
the current rate structure for R&SGS
on-site generation provide a reasonable
the utllity to recover from those
of serving them?
A. No. A customer who instal-l-s on-site generation
does so with the intent to offset their own usage and
elj-minate the volume of energy they consume from Idaho
Power. Recovering fixed costs through a volumetric rate
simply does not work for this segment of customers.
O. Some parties23 suggest the flaws you describe
with the residential pricing are inherent for all R&SGS
customers who reduce usage and the Company's filing is
discriminatory in that it singles out R&SGS customers
with on-sj-te generation. How do you respond to that
contention?
usage is not inherent to aII
Applying vol-umetrj-c rates to
A. I disagree.
on-site generation have
the utility
inherent to
The degree to which
the
customers with
off-set their
reduce usage.
generate some
not rely on
is al-so not
opportunity to
customers who
customers who
or all- of their own electricity, and who do
for al-l- of their energy needs,
all customers who reduce
The Company j-s proposing to
customer classes for R&SGS customers
usage.
establish separate
with on-si-te
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23 Kobor DI, p. 38, 1. 22, p. 39, l-1. 6-16; King DI, p. 11, I
9; Donohue DI, p. 13, 11. 12-14.
CSB REPORTTNG
[phone]
ASCHENBRENNER, REB 18A
Idaho Power Company
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CSB REPORTING(208) 890-5198
ASCHENBRENNER, REB L9
Idaho Power Company
generation because the load service requirements and
usage characteri-stics of R&SGS customers who instal-l-
on-site generation are different than that of R&SGS
customers without on-site generation. Mr. Ange11
presents evidence that demonstrates the load servj-ce
reguirements
who install
and usage characteristics of R&SGS customers
on-site generation are in fact different than
that of R&SGS customers without orr-site generatj-on and
therefore requj-re separate customer cl-asses.24 Dr. Ahmid
Earuqui of the Brattle Group in his Rebuttal Testimony
al-so provides empirical evj-dence that customers with
on-site generation differ significantly from that of the
standard service customer.25
V. CONCLUSION
O. Please summarize your rebuttal testimony.
choosing to
grow in ldaho
A. The number of R&SGS customers
install on-sj-te generatj-on coutj-nues to
Power's service area. The Company be1ieves that
issue of separate classes today is in theaddressing the
best interest of customers in the term. In this
the load service
long
thatcase, the Company has
requirements and the
customers who instal-l-
demonstrated
usage characteristics of R&SGS
on-
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24 Angel1 REB, p.
through p. 13, I. 10, p.
4 , l-. 20 through p. 'l , 1. 9, p. 12, 1. 6
74, 11. 10-17, p. 15, 11. 7-15.
25 Faruqui REB, p. '7 , 1. 1,4 . - p. 15, I . 6 .
ASCHENBRENNER, REB 19A
Idaho Power Company
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CSB REPORTING
(208 ) 890-s198
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site generation are different than that of R&SGS
customers without on-site generation. These differences
justify the need to establish separate rate cl-asses to
provide a reasonabl-e opportunity to recover the cost of
service from those customers.
O. What is your recommendation for the Commission?
A. I recommend that the Commissi-on lssue an order
authorizing the closure of Schedule 84, Customer Energy
Production Net Metering Service, to new service for Idaho
R&SGS customers with on-site generation, and the
establ-ishment of two new cl-assifications of customers
applicable to R&SGS customers with on-site generation.
O. Does this concl-ude your testimony?
A. Yes, it does.
CSB REPORTTNG
(208 ) 890-s198
ASCHENBRENNER, REB 20
Idaho Power Company
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O. Pl-ease state your name.
A. My name is Connie G. Aschenbrenner.
0. Are you the same Connie G. Aschenbrenner that
previously presented direct and rebuttal testimony?
A. Yes.
A. What is the purpose of your surrebuttal
testimony?
A. My surrebuttal testimony is intended to provide
the Idaho Publ-ic Utilities Commission ("Commission") with
a final- update on customer participation in the Idaho
Power Company's ("Idaho Power" or "Company") net metering
service and to provide additional information to the
Commj-ssion and parties in response to certain statements
made by parties in rebuttal- testimony. My testimony is
comprised of two sections.
In Section \, I provide the Commission with an
update on customer participation in net meterj-ng service
as of January 31, 201-8.
In Section TT, I respond to statements made by
parties related to rate desJ-gn considerations regarding
customers' ability to access energy consumption data and
the capabilities of the Company's billing system.
In Section III, I cl-arify the scope of the
Company's proposed modifications to Schedul-e 12.
CSB REPORT]NG
(208 ) 890-s198
499 ASCHENBRENNER, SURR REB 1Idaho Power Company
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CSB REPORTING
(2081 890-s198
500 ASCHENBRENNER,-SURR REB 2Idaho Power Company
I I'PDATE OII ITET UETERTNG PARUCIPATIOTI
O. Please provide an update on participation in
the Companyfs net metering service.
A. The Company has continued to experience rapid
growth in its net metering service since I last reported
participation as of December 31, 2017. The Company
received 95 applications during January 2018, maki-ng the
total number of active and pending systems 2,089 in ldaho
through January 31, 20L8.
Tables 1 and 2 represent updated ldaho system
counts and nameplate capacity
fablcl-I&bo![et Ctrstoe=s
lab].o2-I&bollet (ia
CI.aes Photovo],taic IriDd Eydro/otber fotaJ.
Resi.dential 1,87 4 42 5 L,922
L54
Conrrercial &
Industrial 145 5 4
Irrigation L2 L 13
Iotr].2,O31 {8 10 2,O89
C].ags Pbotovoltaic IIind Er&o/othcr fot:].
13.146Residentlalt2.896 0.189 0.051
0.085 2.846
Couunercial &
Industrial 2.13t 0. 030
0.040 Q.000 '0.955Irrigation0. 916
0.1{6 15. 948.Eota].15.543 0.258
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CSB REPORTING(208) 890-5198
501 ASCHENBRENNER, SURR REB 3
Idaho Power Company
The trend in number of submitted appllcations
demonstrates continued interest in net metering. The
number of applications submitted by month from 2016 to
20L8 are shown in Figure 1.
Figrure 1. Net ldetering AlrpJ.ications Suboitted by Month
140
L20
100
80
60
40
20
0
8680
42
29
81
65 'o
53
30 zg 2s 35
(\ .^-\ ^c StrO $" \ii' \r
95
67
36
27
912 lt
"". _*,C +u'"*
"-" r.-"""' "C .""."" ...,".
2016 2017 2018
O. Do you believe the "pendl-ng" applications
should be included in the reported system counts and
capacity?
A. Yes. In Idaho Powerrs experience, once an
application for a net metering system is submitted, that
system wiII generally come online within approximately
five months. Figure 2 shows, by month, the number of net
metering systems that have been energized between 20t.6
and 2018. The trend follows the trend reported in Figure
!; however, it generally lags by a few months.o 25
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CSB REPORTING
(208 ) 890-s198
ASCHENBRENNER; SURR REB 4
Idaho Power Company
Figrre 2. Net Matering Syatens by Monttr of Operation
L20
100
80
60
4A
20
0
111
103 98 93
t5 79
55 62
38 g7 48 45 39 3E ,7
z;1s ,lt zo 26 zz 30 20 2?
od-rd "'eo
."t- {a- r.t'""- -1".".*t "rir'*i.""d
,2016 2077 2018
A. What has been the rate of growth in net
metering system counts and nameplate capacity since the
Company filed its 2017 Net Metering Report?
A. fn the 2Al7 Net Metering Report, the Company
reported that as of March 31, 20L7, there were 1-,277
actj-ve and pending net metering systems in Idaho. As of
January 31, 2018, there are 2,089 active and pending
systems in fdaho. This represents a 64 percent increase
in net metering systems over a ten-month period.
As of March 31, 20L7, the total nameplate
capacity of active and pendlng systems was 9.58 megawatts
('MW") in ldaho. The total nameplate capacity of actj-ve
and pending systems in Idaho was 1-6.95 MW as of ,January
31, 201,8. This represents a 77 percent increase in
nameplate capacity over a ten-month perj-od.e 25
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CSB REPORTING
(208 ) 890-s198
503 ASCHENBRENNER, SURR REB 5
Idaho Power Company
II. INTER\TAI DATA & BILLING SYSTE}4 CAPABILITIES
O. In his rebuttal testimony, witness Beach
suggests, "hourly data are not currently recorded or
provided to customers" and that "the meters are
programmed to record only monthly net usage.'r1 Mr.
Beach goes on to say: "The utility admits that it would
have to re-program its meters and revise its billing
system in order to make such data avaj-1ab1e."2 Are the
assertions made by Mr. Beach accurate?
A. No.
O. Why not?
A. In addition to providing daily register reads,
Idaho Powerrs Automated Metering Infrastructure ("AMI")
meters record hourly kilowatt-hour readings (sometj-mes
referred to as hourly interva1 data) and a 15-minute
maximum demand for the bill month. Because AMI meters
are installed on approximately 99 percent of residential
and smal-l service ("R&SGS") customer accounts, the
Company currently collects hourly j-nterval data for 99
percent of its R&SGS
generation and those
customers those with on-site
without on-site generation.
access to their hourlyO. Do customers have
interval data?
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CSB REPORT]NG
(2oB ) 890-s198
504 ASCHENBRENNER, SURR REB 5a
Idaho Power Company
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CSB REPORTTNG
(208 ) 890-s198
505 ASCHENBRENNER, SURR REB 6
Idaho Power Company
A. Yes. A11 customers with an AMI meter have
access to their hourly interval- data on Idaho Power's
website via My Account, dD online resource. Customers
must sign up for My Account to view and manage their
energy consumption.
O. How much historlcal data is availabl-e to
customers through My Account?
A. Customers currently have access
i-nterval- data for the most recent 60 to 90
to hourly
days.
historical-O. rf a
hourly interval
Company able to
A. Yes.
customer requests access
data beyond the 60 to 90
accommodate
days, is the
that request?
Company already does this
to
fn fact, the
upon customer request.
O. If the Commj-ssj-on
for net
provide
i-nterval
implemented Staff's proposal-
hourly bilIing, would the Company be
all R&SGS customers with historical
able to
hourly
data?
A. Yes. The Company would be abl-e to provide more
data than is currently avaj-1ab1e on its website; however,
this woul-d require some modification to the Company's My
Account application and woul-d require time to make these
modi-fications. Once those modifications have been
completed, this data could be made available to customers
who currently have, or who are considering ano25
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j-nvestment in on-site generation, so long as an AMI meter
is installed at the service location.
0. Would the Company be able to implement net
hourly billing for customers who do not have an AMI
meter?
A. Yes; however, the Company woul-d have to replace
any existing non-AMI meters with meters capable of
providing hourly lnterval data. fn those instances,
historical hourly interval data would not be available
for the approximately 1 percent of customers who do not
currently have AMI meters.
O. Is the Company's billing system capable of
billing net metering customers on a net hourly basis?
A. Not as it is currentl-y configured; however, if
the billing structure for net metering customers required
that net metering customers be bitled on a net hourly
basis, the Company estimates it would need approximately
one year to modify its metering and billing systems in
order to bill net metering customers on a net hourly
basis.
a. Is the Company's billing system capable of
billing net metering customers on time-of-use ("TOU")
rates?
A. Not as it is currently configured; however, if
the billing structure for net metering customers required
CSB REPORTING(208) 890-s198
506 ASCHENBRENNER, SURR REB 7
Idaho Power Company
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that net metering customers be billed on TOU rates, the
Company estimates j-t would need approxi-mately ten months
to
CSB REPORTING
(208 ) 890-s198
507 ASCI{ENBRENNER, SURR REB 'la
Idaho Power Company
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CSB REPORTING
(208 ) 890-s198
5OB ASCHENBRENNER, SURR REB 8
Idaho Power Company
modify its systems in order to bill net metering
customers on TOU rates.
O. What systems would need to be modified to
implement net hourly billing or TOU rates for net
metering customers?
A. As stated above, the existing meters are
recording the information required to implement net
hourly billing or TOU,' however, the meter data
collection, meter data validation, customer billing
system, and the j-ntegration between those systems woul-d
need to be modified to implement either net hourJ-y
billing or TOU rates for net metering customers.
rII. MODIFICATIONS TO SCEEDVI.E 72 ARE MINOR
a. Did any of
testimony agree with
the parties
Commission
who fil-ed rebuttal
Staff's suggestions that
Schedul-e 12 "arethe Company's proposed modificatiorr to
not minor, and constitute a major revision to Schedule
72"3 and "the proposed modification to Schedule 12
incl-udes a large number of revisions that were not
described in the Company's Application or testimony"?4
A. Yes. In Lris rebuttal testimony, Idaho Clean
Energy Assocj-ation witness King notes his appreciation
3 Dr. Morrison DI, p. 2\, 11. 1,6-71.
3 Dr. Morrison DI, p. 23, 11. 6-8.o 25
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for Commission Staff's recognition that "the changes to
Schedule "72 are more sJ-gnj-ficant than represented by
Idaho Power in its application" and are "outside the
scope of this docket. "5
O. Would you please clarify what modifications the
Company has proposed to Schedule 72?
A. The modifj-cations proposed by the Company are
to (1) add reference to the newly proposed Schedul-es 6
and 8, referred to as "Small On-site Generation, " and (2)
add the words "barring conditions beyond the Company's
control" to the inspection process to a11ow the Company
additional time to complete the on-site inspection of a
newly instal-led on-site generation system when
circumstances beyond the Company's control arj-se.
O. How do you respond to Dr. Morrison's suggestion
that there are "a large number of revisions that were not
described in the Company's Application or testimony?"6
A. I disagree with Dr. Morrisonrs
characterization. The changes to Schedule 72 are in fact
very minor. f can see that at a glance, it may appear
that there are additional and substantial revisions;
however, most of the revisions shown in "mark-up" form
are due to
CSB REPORTING(208) 890-s198
509 ASCHENBRENNER, SURR REB 9
Idaho Power Company
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3 King Rebuttal, p. 8, 1l-. 8-10.
3 Dr. Morrison DI, p. 23, 11. 7-8
CSB REPORTING(208) 890-s198
510 ASCHENBRENNER, SURR REB 9AIdaho Power Company
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CSB REPORTING
(208 ) 890-sl-98
511 ASCHENBRENNER, SURR REB 10Idaho Power Company
formatting changes.
the page break occurs
the text to be moved
These fonnatti-ng changes resul-t when
i-n a different location and causes
from one
0. Do
Schedul-e 7 2
you believe
are outside
page to the
the proposed
next.
changes to
docket?
that
the scope of this
A. No. Adding reference to the newly proposed
Schedules 6 and 8 is in fact rrery much necessary and
relevant to this case if the proposed new schedules are
approved. The proposed changes accommodate the addition
of Schedul-es 6 and B where prevj-ousIy only Schedu1e 84
was referenced.
The other revision, to all-ow the Company
additional time to complete the on-site inspection of a
newly installed on-site generation system when
circumstances beyond the Company's control arise, is very
minor. The need for this flexibility became evident
during the 20L6-207'l winter which brought heavy snows and
icy conditions throughout the Company's service area.
O. Did the Company share with installers and
Commissj-on Staff that the Company was considering a
modification to Schedule 72 that would allow the Company
additional time to complete the on-site inspectj-on of a
newly installed on-site generation system when
circumstances beyond the Company's control arj-se?
A. Yes.t 25
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CSB REPORTING(208) 890-5198
572 ASCHENBRENNER, SURR REB 11
Idaho Power Company
O. Did anyone express concern with this
modif i-cation?
A. No.
O. Are any of the proposed changes to Schedul-e 72
related to the Company's request for the Commission to
acknowledge that smart inverters provide functlonality
that is necessary to support the ongoing stabil-ity and
reliability of the distribution system smart inverter
request?
A. No. In this case, the Company requested that
the Commissj-on order the Company to submit a compliance
filing in the form of a tarlff advice within 60 days of
the adoption of the revised Institute of Electrical and
Electronic Engineers standards, or 60 days of the
concl-usion of this case (whichever occurs later) if it
agrees that smart j-nverters provide functj-onality that is
necessary to support the ongoing stabllity and
reliability of the distribution system.
rv. coNcl.usloN
0. Pl-ease summarize your surrebuttal- testimony.
A. The continued pace at which R&SGS customers are
instal-l-ing on-site generation underscores the importance
of addressing the Company's net metering service now.
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Idaho Power's AMf meters currentl-y collect both
hourly interval data and dail-y register reads for 99
percent of its R&SGS customers. Eurther, customers
currently have access to this hourly interval data on
Idaho Power's website via the My Account application.
Whil-e the Company's billing system is not
currently configured to bil-1 R&SGS net metering customers
on a TOU or net hourly basis, TOU or net hourly billing
for R&SGS customers with on-sj-te generation can be
accomplished in approximately one year.
The proposed changes to Schedule 72 are
relevant to this case, and while the modifications may
appear to be substantial, they are in fact very minor.
O. Does this conclude your testimony?
A. Yes, it does.
CSB REPORTING
(208 ) B9o-s198
513 ASCHENBRENNER, SURR REB L2
Tdaho Power Company
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CSB REPORTING(208) 890-sr-98
ASCHENBRENNER (X)
Idaho Power Company
(The fol-l-owing proceedings were had in
open hearj-ng. )
COMMISSIONER RAPER: And cross-examination
begins with Ms. Germaine.
MS. GERMAINE: Thank you, Madam Chair.
CROSS-EXAM]NATION
BY MS. GERMAINE:
O Good afternoon. You stat.ed in your
testimony that during stakehol-der outreach, it was the
preference of stakeholders to conduct an analysis of both
the benefits and the costs associated with on-site
generation prior to placing these customers in a separate
cl-ass; is that correct?
A Yes. Irm just getting to that place, but
yes.
O So just to clarify, thatrs a yes?
A Yes.
O And yet, the Company went ahead and filed
this application prior to conducting a value of solar or
a cost of service study;
A rt is.
O And isnrt
is that correct?
it true that the Company claims
that it must first separate these on-sj-te generation25
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CSB REPORT]NG(208) 890-s1_98
ASCHENBRENNER (X)
fdaho Power Company
customers in order to better help them conduct a cost of
service or value of sol-ar study; is that correct?
A Yeah, I believe Mr. Tatum answered those
questions at length, but y€s, the Company's application
j-n this case is a first step that we ask the Commission
to acknowledge the differences between these customers,
establishing separate customer classes, and then in the
futurer w€ woulzd look to have an additional stakeholder
engagement through the val-ue of a distributed energy
docket where we would establish cost of service and then
rate design.
a But isn't it fair that based on the filed
testimony and also the testimony given by Mr. Tatum today
that the Company 1s able to identify these customers
currently without putting them into a separate class; is
that correct?
A Yes.
o And
to
in fact,
be a net
these customers sel-f-identify
metering customer with Idahowhen they
Power; is
appry
that correct ?
A They do, and they take service
separate schedul-e, Schedul-e 84, yes.
O So is it faj-r to say that the
separate them into a separate class based on
to analyze them better is no longer an issue
under a
reason to
the ability
in this25
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CSB REPORTTNG
[phone]
ASCHENBRENNER (X)
Idaho Power Company
case ?
A]
Company's request
rate design that
with the distinct
think that as Mr. Tatum clarified, the
in this case is acknowledgment that the
is applicable to these customers coupled
usage characteristics of that segment
of customers warrants the establj-shment of separate
classes so that we can assign costs and benefits to those
customers in a future proceeding and establish rates that
most appropriately collects the cost to serve them.
O And that would be in a value of sofar or a
cost of service study; correct?
A Yes.
a The Company has al-so stated that
separating these net metering customers
when the percentage of these customers
now instead of
is higher wil-I
shift that ishelp sort of mitigate
occurring within this
the alleged cost
cl-ass; j-s that correct?
A I think Mr. Tatum addresses
his testimony. I
address the issue
think that the Companyrs
now prior to larger or,
additional customer adoption is rea1ly,
recognition that the rate design that is
doesn't a1low f or the sustainabl-e kind of
the timing in
desire to
you know,
you know,
in place today
scaIabIe, I
guess, expansion of net metering service. The Companyrs
position has been that taking a step today, understandingo25
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CSB REPORTING(208) 890-5198
ASCHENBRENNER (X)
Idaho Power Company
this is the first step and in a process
to do thatsome time, that it is better
do reach larger adoption as we l-ook at
projections of on-slte generation.
O So before this class of
that wil-l- take
today before we
the future
customer becomes
larger and this cost shift coul-d potentially become more;
is that correct?
A Yes.
O But
that cost shift is
A The
with serving
o
that customer
yet, the Company can't identify what
currently; is that correct?
Company has provided estimates to the
the fj-ling of the last two annualCommission through
reports where we have estimated the cost shift associated
these customers "
But you have not evaluated the val-ue that
brings to the schedule ej-ther, though; is
that correct?
A What we have done through the cost studies
that we have submitted, I guess I rvouldnrt agree that we
haven't quantified any value or benefit associated with
that. To the extent that the customers are abl-e to
reduce utilization of the system, that woul-d be
recognized in the SCD and the NCD that Dave tal-ks about
in his testimony. We did uti-lize those factors in those
cost studies, So they would have had lower costs assignedo25
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CSB REPORTING
(208 ) 890-s198
ASCHENBRENNER (X)
Idaho Power Company
to them to the extent that were offsetting usage.
at what the costs are onl-s
they
l-ook
woul-d agree that it was what are
the costs to serve them from the utiJ-ity side. We did
What we did do, though,
the utility side, so I
not separately do
OSo
any value
then would
yet, if this customer is
is not being charged a
they're bringing value
just resul-t in a higher
to serve that separate
of the excess generation.
you that it could be
the case that once you separate
separate schedule and evaluate
cost to serve this customer, it
they actually provide a benefit
whole; is that correct?
agree
these customers into a
the val-ue of sol-ar and the
could be the case that
to the Company as a
A I think there would be benefits associated
with that, yeah.
O And
separate class, but
because potentially
Company, this could
administrati-ve cost
that correct?
A Can
already in a
separate rate
to the
schedule; is
you restate that question?
O Of course; so if this customer i-s
separated, the net metering customer is separated, into a
separate class and the value and cost of service study is
done and it's determined that this customer actually
brings a val-ue or is equal to the other customer, theo25
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CSB REPORT]NG(208) 890-s198
ASCHENBRENNER (X)
Idaho Power Company
non-net metering customer, in that schedul-e
A Can you define what you mean by "value, " I
guess?
O That there's not an increased cost to
serve this customer.
A Okay; so they have the same cost to serve?
O Yes, as the non-net metering customer
within that schedule.
A Okay.
O Would it be faj-r to sdy, then, that that
would result in not a new rate for this customer?
A Not necessarily. I think that what we
have presented in this case is that charging a vol-umetric
or a bundled rate design applied against customers who
are bil1ed on a net monthly basis doesn't provide the
utility with an opportunity to collect those costs. The
example that we've presented, you know, even if the cost
to serve a customer is the same, if you have a customer
who has the ability to reduce their usage, in some cases
to zero would be the extreme example, that customer has
utilized the grid throughout the month; however,
our existing rate design, we would only col-1ect a
service charge from that customer, and so I woul-d
under
that even if the costs to serve them are the same,
volumetric rate design as it exists today for the
$s.00
suggest
the
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CSB REPORTING
(208 ) 890-s198
ASCHENBRENNER (X)
Idaho Power Company
residential class is not appropriate for that segment of
customers.
O So to clarify that, if the cost to serve
that customer was the same,
customer be the same in that
would the rate for that
separate schedule?
expect it to be.
the Company's concern about
the potential cost shift to non-generating residential-
customers, you
not establish a
-i-n fact stated that if the Commission does
class, the Company would
cost of servj-ce study or
to these net metering
A No, I wouldn't
Anci related to
new customer
O
have no reason to modify its
ratemaking processes specific
customers; is that correct?
A Yes.
0 So the Company does not plan on studying
the benefits or the value of solar from these customers
if they remain in the same schedul-e; is that correct?
A What I stated in my testimony was that if
the Commission determines there are differences that
warrant the establishment of new customer classes, the
Company woul-d assign costs to that new customer cl-ass in
the future,
specific to
decline to
cost of service
those customers.
study and design rates
Should the Commission
new classes, the Company wou1d have no
authorize che establ-ishment of the requested
reason to modifyo25
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CSB REPORTTNG(208) 890-5198
ASCHENBRENNER (X)
Idaho Power Company
its class cost of servj-ce study or ratemaking processes
specific to net metering customers. The Company would
continue to allocate costs to that customer cfass as it
does today to the
0so
entire class.
if the Company does not
or the cost of servicevalue
plan on
to thesestudying the
customers if
to say that
they remain in the same schedul-e, is it fair
the Company reaIly isn't concerned about a
cost shift within that schedule?
A I don't agree with that.
MS. GERMAINE: Thank you. I have no
further questions.
COMMISSIONER RAPER: Thank you. Mr.
Carter.
CROSS-EXAMINATION
BY MR. CARTER:
O Good afternoon.
A Afternoon.
A Just a preliminary question, do you have
copies of your testimony that you filed?
A f do.
O All- right, I'm going to start I'm a
little nervous because f don't know, understand aboutt25
52].
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2
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4
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6
7
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load shapes and all that, but you were involved in the
analysis of l-oad shapes of net metering versus non-net
metering customers; correct?
A To a degree.
0 Okay.
A Yes.
O WelI, I'l-1 ask the question and if you're
going to direct me to Mr. Ange11, then, that's fine.
A Yes.
O So did Idaho Power look at all the
possible segments that woul-d have different load shapes
as compared to the average R&SGS customer and decide that
net metering customers I l-oad shapes are the most
different or did they look at, say we're going to l-ook
at, net metering customers' l-oad shapes, oh, Iook,
they're different and that difference is different enough
to justify a new rate c.l-ass?
A No, we did not analyze other segments
within the c1ass. The reason that the Company has
performed analysis on the net metering segment of
customers is that the Commission has asked us to provide
them with annual updates through a reporting requirement
established after Case No. TPC-E-12-27. The Commission
directed the Company to provide updates on the net
metering service without limitaticn and to provide
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CSB REPORTING
(208 ) B9o-s198
ASCHENBRENNER (X)
Idaho Power Company
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CSB REPORTING(208) 890-s198
ASCHENBRENNER (X)
Idaho Power Company
updates on the cost of servj-ng those customers or t you
know, cost shift and system reliability. That was the
context of doing the load shape analysis that we
presented in our testimony.
O Sure; so itrs not the Company's testimony
that net metering customers' Ioad shapes are more
different than other potential segments in the R&SGS
class. It's just, in the Company's opinion, those l-oad
shapes are different enough to justify a different
customer classi is that correct?
A Yeah.
O Can you turn to page 25 of your direct
testimony?
A
o
A
Yes.
Okay, can you
Sure. "It is
read l-ines 1 to 5?
practice"amlin
O Yeah,
a long-standing ratemaking
right place?
sorry. I don't know why John was
Iaughing.
Okay, "It
establish
segments
A No, that was
MR. HAMMOND:
THE V'IITNESS:
is a long-standing
separate customer
of customers with
funny.
I apologize.
I know, ratemaking is fun.
ratemaking practice to
cl-asses to set rates for
different costs of service oro25
523
o 1
2
3
4
5
6
7
B
9
where the nature or type of load is distinctly different
from their current customer classification. "
O BY MR. CARTER: Great, and you put the
emphasJ-s right where my emphasis is.
A All right.
a I'd like to try to unpack the two
components of that sentencer So it's your testimony that
it's the Commission's long-standing rate practice,
ratemaking practi-ce, to set rates for segments of
customers with different costs of service; correct?
A Yeah, where therers different
segmentations identified, yes. The first step would be
establ-ishment of that separate class. The second step
would be cost of service, and then the third step would
be rate design.
O So is it your testimony, I guess, that
it's the Commission's long-standing ratemaking practice
to establish a separate customer class based soIely on
the nature and type of load of that proposed class?
A WeI1, I don't think I stated it was the
Commj-ssion's practJ-ce. I did state that it is a
long-standing ratemaking practice to establ-ish and I know
you and Mr. Tatum had a lot of discussion around this
topic.
a Sure, and so just to clarify, you're
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CSB REPORTING
(208 ) 890-s198
ASCHENBRENNER (X)
Idaho Power Company
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CSB REPORTING
(208 ) 890-s198
ASCHENBRENNER (X)
Idaho Power Company
saying in general, this is how ratemaking works, not this
i-s how the Idaho Public Utilities Commission has made
rates in the past?
A Right. Generally, you first segment
customers and then with those segmentations, you woul-d
assign costs to those customer cl-asses and then establish
rates to collect those costs.
O Okay; so can you provide an example of
when the Idaho Public Utilities Commission or strike
that. Can you provide an example when the fdaho Publ-ic
Utilities Commission created a separate customer class
without considering the cost of service, rate design, and
the rate for the new cl-ass?
A My answer is no different than Mr.
Tatum's. I donrt recall- something, no.
O I couldn't find anything either. That's
why I'm asking these, and I guess'the answers to my other
questions are obvious, but f'm going to ask them anyway.
Do you have an example of when the ldaho Pub1ic Utilities
Commission created a separate rate cl-ass first and then
considered the rate and rate design years later?
A I donrt.
ODo you have any example
Commission created a
when the Idaho
Public Util-ities separate rate cl-ass
where the proposed new class is already -tdentified ando25
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CSB REPORT]NG
(208 ) 890-s198
ASCHENBRENNER (X)
Idaho Power Company
the Company already has the ability to study that
proposed class?
A f don't.
a Okay, in your rebuttal
present information on the number of
applications that have been submitted
correct?
A Yes.
King in this case?
I have, yeah.
And do you reca11
testimony, you
net metering
tn 201,6 and 2017;
surge of
Kevin King in his direct
applications created by
specifj-caIIy recal-l-. I don't have
would accept that, yeah.
like to see it or can I just
A
O And thatrs on page 4 and 5?
Okay.
Have you reviewed the testimony of Kevin0
A
o
testimony describing a
the Company's filing?
A I don't
it in front of me, but I
o
quote from it?
A
Would you
You can quote
thisOkay; so
experience is that customers got
f rom Idaho Power' s communi-cati-on
o
page 8, "My
impression
from it.
is Kj-ng's direct testimony,
the
that
would be grandfathered provided they had sj-gned
they
up byt25
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CSB REPORTING
(208 ) 890-s198
ASCHENBRENNER (X)
Idaho Power Company
December
inqui-ries
completed
31. Sol-ar instal-l-ers
from people anxious
before December
began receiving a surge of
to have instal-Iations
2071."
data in your rebuttal
this application was
31,
this
testimony, it
filed on July
A
o
Looking
shows
27, 2011;
It was,
And this
at
well-, f irst,
correct?
yeah.
data shows a jump in applications
in August; correct?
A I wouldn't
testimony states is that
looking at the increase
month-by-month basis is
agree with that. What my
the trend before the fiJ-ing when
in net metering applications on a
the same as the trend
fn
received the same month
post-filing, so pri-or to us filing the application in
Ju1y, we had seen increases of approximately double.
June, it looks like about three times the amount of
of applications
A Yes, in that one month, but I'd I1ke to
clarify, though, fry chart was looking, reaI1y, at a
year-over-year by month comparison, so in
applications
o Okay, but from July to
increased from 53 to
54. The year prior, in 20L7, I-t was 98.
June, June in 2016, was 25, and June of
month before the Company made the filing.
the year prior.
August, the number
98; correct?
August, 1t was
If you look at
20L1 was 81, the
a 25
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CSB REPORTING(208) 890-s198
ASCHENBRENNER (X)
Idaho Power Company
O Correct, but just lookj-ng at the 201,7
numbers here
A
o
Right.
so July was 53, August was 98;
correct?
A
o
A
o
A
0
Yeah.
September was L23; correct?
Uh-hrih.
October was 725?
Yes.
And then November was 80 and December
83
A
o
Yes.
which is a decrease from prior months,
levels; is that correct?but still wel-l- above 2016
A Yes.
MR. CARTER: I don't have any more
questions.
THE WITNESS: Okay, thanks.
COMMISSIONER RAPER: Mr. Hammond
o 25
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CSB REPORTING
(208 ) 890-5198
ASCHENBRENNER (X)
Idaho Power Company
CROSS-EXAMINATION
BY MR. HAMMOND:
0 Good afternoon.
A Afternoon.
O Thank you
appreciate your time and
come here in front of the
for being here. We much
the efforts
Commission
of the Company to
and present the
resolution at somej-ssue and hopefully, we'II get
point of some of these things.
testimony on page 25
A Okay.
toa
Getting back to your
0 your direct testimony, it's my
understanding that the Company is basJ-ng, and if I'm
getting this wrong, is basing its decision to separate
these customers in a separate rate class because of the
time, nature, and pattern of use is sort of the generi-c
phrase. V[e get more granular as we talk about the ]-oad
curve and the l-oad shape. Is that fair to say that sort
of the overarching is we think we should move these
customers because of the time, nature, and pattern of
use?
A I think,
O And yet,
starting at line 6, you
your testimony on page 25,
menti-on, and correct me if I'm
yes.
l-n
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CSB REPORTING
(208 ) 890-s198
ASCHENBRENNER (X)
Idaho Power Company
wrong, that in an Order, a past Commission Order , 26780,
the Commission described class differentiating
characteristics identified in Idaho State Homebuilders,
I'm paraphrasing
A Uh-huh.
O and so those class differentiating
characteristics j-nclude a laundry list of things; is that
fair to say?
A
o
Right.
But the Company is saying
nature
the only one
and pattern of
use; is that
that matters in this case is the
use or the time, nature, and pattern of
correct?
A Those are the differences that we've
identified and Mr. Ange11 and Dr. Faruqui have presented,
yeah.
O So is it a long-standing ratemaking
practice in your experience to have two separate rate
classes with identical rates? Let me try to unpack this
a Iittle bit better.
A Okay.
O Currently,
wants to separate new net
with on-site generation,
Company has used, into a
as I understand it, the Company
metering customers or customers
whatever the definition the
new schedul-e; 6 for residentia];o 25
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CSB REPORTING(208) 890-s1_98
ASCHENBRENNER (X)
Idaho Power Company
t 25
531
8 for sma1l commercial. Existing net metering customers,
at least for the time being, will remaj-n on 1 and 1 . A11
will be related to Schedul-e 84, of course; is that
correct?
A Wel-l-. the existing customers who signed up
for service under Schedul-e 84 woul-d continue to be
associated with that schedu]e. New customers would be
placed on the newly-established Schedules 6 and 8.
0 AnC woul-d the rates for those that are
placed on the new schedules be the same as the rates that
the people have on the old schedules?
A Yes.
O And the issue, o:: at least one central-
issue in this case that Idaho Power has presented, is
this cost shift that could occur due to underrecovery
based on consumption and volumetric rates, but if we're
putting these two we're establishing rate classes with
the same rates, it's really not addressj-ng the problem
that Idaho Power has presented; is that correct?
A tr{hat werre asking for, and as Mr. Tatum
testified, you know, we're asking for, I think, a
decision at this point in time that would establj-sh that
first step, and that first step woul-d really provide that
answer to whether or not we would continue on with the
steps two and three to establish rates specific to
o 1
2
3
4
5
6
1
8
9
customers with on-site generation. If the Commission
declines to authorize separate classes, w€ would continue
to allocate costs to the residential cl-ass and collect
costs from them.
O I could be wrong here, but I feel like
that the Company feels very strongly about this in the
cost shift and there's probably other reasons. If the
Commission were to deny the separate rate class, why
wouldn't the Company contj-nue on to demonstrate that they
needed to change the rate if you believe you're
underrecovering and there's a cost shift?
A Can you restate the question?
O Sorry.
A No, thatrs okay.
O So I guess what Irm saying is if the
Commlssion decj-des today or, excuse me, at the end of
this process to not grant separate rate classifj-cations,
but Idaho Power, it seems like it feels very strongly
l-ittle about this, why woul-dn't the Company continue
forward trying to identify ways to address this cost
shift? It seems l-ike to me the Company is sayj-ng we
don't get the separate rate cl-asses, wef re just going to
walk away.
A And I don't know that that would be our
positionr so I guess maybe thank you for rephrasing the
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(208 ) 890-s198
ASCHENBRENNER (X)
Idaho Power Company
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CSB REPORTING(208) 890-s198
ASCHENBRENNER (X)
Idaho Power Company
question. You know, the
mismatch between the rate
characteristics of these
identified a
the usage
We bel-ieve that
the creation of
Company has
design and
customers.
their usage characteristics support
separate customer classes to be abl-e to
to
apply whatever
those usagerates, you know, would be applicable
characteristics to be able to collect
requirement.
residential class that you're
and we woul-d have those usage
that revenue
assigning costs
characteristics
You know, I suppose if the Commission in
their determination said that they didn't see differences
that warranted a separate establj-shment, what we wou1d
have is we'd have the usage characteristics of the entire
i-t's
to based on
to design
difficultrates from and, you
to establish rates
that cl-ass when we
to understand what
know, establishing
for a subsegment of
don't have the usage
the best rate design
customers within
characteristics
would be for
those customers.
O But I believe the testimony of other
wj-tnesses in here is that you do have those usage
characteristics or at least that's the opinion of the
Company.
A We do, but they're not segmented out for
cost all-ocation purposes. They're not separated out foro25
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CSB REPORTING
(208 ) 890-s198
ASCHENBRENNER (X)
Idaho Power Company
rate design purposes.
O But you're not prevented by doing that if
grant separate rate cl-assesthe Commission were to not
today or in this case?
A I guess I havenrt thought of it in that
manner.
O So if the Commission were to deny the
request for separate rate classification, that wouldnrt
prevent Idaho Power from comi-ng back 1n a separate
proceeding and ask for an adjustment of , l-et's sdy,
Schedule 84, what compensation do you pay or credit the
net metering customer for their export of energy?
A Thatfs correct.
O Okay; so right now we have two rate
cl-asses that the Company j-s proposing to go forward with
and would you say they're separate but equal?
A f donrt know what I don't know that I
would agree with that.
MR. HAMMOND: That ' s al-I I have .
THE WITNESS: Okay.
COMMISSIONER RAPER: Nice way to end, Mr.
Hammond. Mr. Nykiel.
o 25
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CSB REPORTING(208) 890-s198
ASCHENBRENNER (X)
Idaho Power Company
CROSS_EXAM]NATION
BY MR. NYKIEL:
O Good afternoon.
A Vfhere am I looking?
O Ms. Aschenbrenner, you testified about
your participation in a case, IPC-E-12-21, and do you
recalI that stakeholders in that case cal-Ied for a
cost-benefit study?
A I'm sorry, I missed the first part of your
question.
A Yeah,
that you were aware
and that case number
A Yes,
actively partlcipate
O Okay,
that the stakeholders
cost-benefit study of
residential and small
customers?
in your testimony, you testified
or parti-cipated in a previous case
there was IPC-B-72-21?
I'm fami]iar with the case. I didn't
in it, but, yes.
and do you recall or are you aware
in that case call-ed for a
the energy use and generation from
general service net metering
A I do not recaIl.
a Okay, in your testj-mony, you also
reference several stakeholder meeti-ngs that were held
following that case.25
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CSB REPORTING
(208 ) 890-s198
ASCHENBRENNER (X)
Idaho Power Company
A
o
Yes.
And you recalled in your
the customers and stakeholders
testimony that
there 1n thoseovera11,
meetings
potential
felt that Idaho Power should quantify the
benefits that on-site customer-owned generation
systems provide the Company?
A Yes.
questions. Thanks.
BY MR. COSTELLO:
of service
MR. NYKIEL: No further questions.
THE WITNESS: Okay.
COMMISSIONER RAPER: Mr. Preston.
MR. PRESTON: No questions.
COMMISSIONER RAPER: Ms. Nunez.
MS. NUNEZ: No questions.
COMMISSIONER RAPER: Mr. Costello.
MR. COSTELLO: I have a couple of
CROSS-EXAMINATTON
A
a
O Good afternoon.
Afternoon.
So just a couple of questions about cost
A Okay.I 25
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CSB REPORTING(208) 890-s198
ASCHENBRENNER (X)
Idaho Power Company
O first of all, and just sort of to
piggyback on Mr. Nykiel. The workshop was j-n 2016,
right, the
asked you
one he was referencing where the stakeholders
to conduct a cost-benefit study?
A There were two where I heard that at.
in 201,6, July of 20L6, and then one in JuneThere was one
of 2017.
o
any analysis
Company?
A
o
A
Thank you; so after those meetings, did
of benefits ever take place by the
No.
What about any cost-based analysis?
The ones that f referenced ear]ier that
were presented to the Commission in the status report.
o
A
o
that?
A
a
to separate
evidence of
Right, and
Right.
But no cost
just the annual updates?
of service or anythlng like
No,
So
we have not.
this
do you
group of
think it's fair and reasonable
customers wi-th no cost-based
what they might be charged in the future
whenever that rate kicks in?
A Yeah, you know, as Mr. Tatum has testified
earlier, we don't believe that having a cost of serviceo25
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CSB REPORTING(208) 890-s198
ASCHENBRENNER (X)
Idaho Power Company
study is necessary for the Commission to make a
determination in this case. You know, I would add that
at those stakeholder meetings, some of the analysis that
the Company had done and f know Staff witness Donohue
attached, ds an exhibit to her testimony attached, part
of our presentation that we gave at thatr we did talk
about the cost of service based on our estimated analysis
to serve a potential net metering customer as we looked
at the future potential for cost shift, so I guess I
wouldn't agree that there is no evidence on the record or
no analysis that's been presented to the Commission about
what the potential costs to serve those customers were.
O In this case was anything presented?
A No, not in this case I didn't.
O Thank you.let's move on to the
metering customer andnext question. At the
stakeholder workshop
same
Okay,
net
I'm sorry,
slide show
for one of the
workshops, you
included that
created a right, and you
Exhibit 10?
A
o
with your testimony as
I did, yes.
And do you have a copy of that that we can
discus s ?
A I do.
O Okay; so
used that slide show to
generally speaking, the
discuss the dri-vers for
Company
the needo25
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CSB REPORTING(208) 890-s198
ASCHENBRENNER (X)
Idaho Power Company
to al-ter the Companyrs net metering program; is that
correct?
A We talked about the mismatch between the
rate design and the costs of collection, yes.
O Okay, within that slide show, that sort of
synthesis of why this program should change, was time,
nature, and pattern of use characteristics, were they
discussed at all?
here.
AI
f'11 give,
didn't I donrt have notes inc]uded in
if I may, a l-ittl-e context around this,
slides were presented, but I didnrt
you donrt remember if time, nature, and
because I know the
OSo
pattern of use were included in the slide show?
A WeII, I described in the class cost of
I said,service, sl-ide No. 5 is when f discussed, l-ike
verbally at the meeting that customers are segmented into
customer classifications and then the Company then
al-locates costs to those segments of customers.
O But you didn't discuss 1oad?
A Not that I recall.
O Okay; so reaIIy, I mean, the application,
rea11y, was based on this cost shift and stakeholder
meetings were based on the cost shift and that was realIy
the focus, is that correct, before rebuttal testimony in
this case?o 25
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CSB REPORTING
(208 ) 890-s198
ASCHENBRENNER (X)
Idaho Power Company
A Ifm sorry, those are two different
questions. Was the focus of the are you asking what
the focus of the stakeholder meeting was?
O Focus of the stakeholder engagement.
A Okay, Ln 2076, the focus of the
stakeholder engagement was to present the resul-ts of the
analysis the Company had prepared in the 2016 net
metering report, which did dernonstrate a cost shift that
was occurring. We also expressed concern about the
potential- for the future of that cost shift to grow and
had a conversation with stakeholders and with customers
about the mismatch in the rate design that's currently
applied to net consumption for the residential net
metering customer segment.
of
O Okay, thank you, but the time,
use characteristics weren't rea11y
nature, and
addressedpattern
prior to this case; is that correct?
A No.
O And they weren't rea11y addressed in the
application to this case either; is that correct?
A f don't have the applicati-on in f ront of
me. I think we had a load curve in the application.
O Okay, weII, I just want to make sure, just
one last question. Do you tlrink it's fair and reasonable
to the Commission, to S'taff, to all the intervenors, ando25
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CSB REPORTING(208) 890-5198
ASCHENBRENNER (X)
Idaho Power Company
the general public to sort of have that shift in focus in
a case like this? Does that make sense?
A I guess I don't agree that we had a shift
in focus. Vilhat we asked for in our application was that
these customer classes be estab]ished on the basis of
differences in the nature, time, and pattern of use.
Upon party criticism that the Company did not provide
enough data to support thatr w€ in our rebuttal testimony
presented evidence as asked for by --
O So you disagree that there was a shift
from the cost subsidy or the cost shift in the
application to the time, nature, and pattern of use in
rebuttal?
A I do.
MR. COSTELLO: Thank you. That's all- I
have.
THE WITNESS: Okay.
COMMISSIONER RAPER: Mr. Bender.
I,lR. BENDER: Thank you.
CROSS-EXAMINATION
BY MR. BENDER:
O Good afternoon, David Bender for Vote
So1ar. Do you have Staff's exhibits with you up on the25
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stand?
A I donrt.
a Do you have them here that we can get you
a copy?
A I don't, if somebody else has them.
MR. BENDER: Madam Chair, this will be an
exhibit that will come in with Staff.
THE WITNESS: Do I have i-t in mine? Is it
the sl-ide from the
MR. BENDER: No.
THE WITNESS: Okay, sorry. I was trying
to save you time.
MR. BENDER: May I approach?
COMMISSIONER RAPER: AbsoluteIy.
(Mr. Bender approached the witness. )
THE WITNESS: Is it the 2016 report?
O BY MR. BENDER: It is the 20LG report.
A Right, I've got that, all set.
O A11 right; so this is, for the record,
al-so Staff's Exhibit 110 with witness Donohue. This is
something you just referred to several times in your l-j-ve
test j-mony today, but I don't think you had it as one of
your exhibits; correct?
A I didn't, no.
0 Okay, I just wanted to ask you some
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CSB REPORTTNG(208) 890-s198
ASCHENBRENNER (X)
Idaho Power Company
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CSB REPORTTNG(208) B9o-s1_98
ASCHENBRENNER (X)
Idaho Power Company
questj-ons about it since we've talked about it a couple
of times now.
A Okay, sure.
O So this is the 2016 annual net metering
status report; is that right?
A Yes.
A Okay, and this j-s the report in which
you and you did this report; is that right?
A I was one of the Company -- yeah, I
O Okay, you're famil-iar with the report?
A Ifm familiar with the report, yes.
O And this is the one where the Company
tried to approxj-mate a cost shift?
A Yes.
O So Irm looking at page 7 --
A Okay.
*- which is also Exhibit
That is in the 1ower right-hand corner
page 8 of 19.
just so we're on
the same page.
A Okay, I'm on page 7 of the report.
O Tabl-e 3 at the top?
A Yes.
a My understanding is this table summarizes
the approximated cost shift, is that right?
A Yes.
n
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CSB REPORTING(208) 890-s198
ASCHENBRENNER (X)
Tdaho Power Company
O My understanding j-s what the Company did
was use the 20LL cost of service study and make some
adjustments to it, unitize it and then try to apply it to
the loads of net metering customers?
A Yes.
O Okay, and so you then derived a cost to
serve approximated from a five-year-old cost of service
study?
A From an approved revenue
currently in rates, y€s.
O Which was a 2017 cost of
requirement
servl_ce study?
rates.
the total
A Adjusted for
Fair enough,
other additions to
and you then derive
revenue requirement for the net metering customers of
$464,532; rlght?
A Yes.
a Okay, and that j-s for 366 net metering
customers?
A That sounds right, yeS.
a Okay, does the average residential-
customer collect his or her costs in the cost of service
study?
A Can you restate that?
O Sure. Is there an intraclass subsidy
within the resi-dential class?
O
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CSB REPORTING
(208 ) 890-s198
ASCHENBRENNER (X)
Idaho Power Company
A I think what's described
referring to whatrs described on page 10 of
are you
the report?
I think so.
Okay.
f 'm describing what I interpret this l-ine
Yes.
So letrs look at that, so Tab1e 4 --
Okay.
this is a separate analysis. This is
cost shift based on assumptions.
A hypothetical, yeah.
So one hypothetical customer.
Yeah.
o
A
o
to be.
A
o
A
o
projecting a
A
o
A
O But in this, on the second to last line,
it says, "Difference between revenue requirement and
utility bill-." Do you see that?
A Right.
O If I look under standard service
residential customer, that column is the non-net metering
customer; is that right?
A Yes, the first column?
O Right, standard service, and I see $96.00
is the difference.
A Yes.a 25
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CSB REPORTING(208) 890-s198
ASCHENBRENNER (X)
Idaho Power Company
O So I interpret that to mean that this
standard customer, which I understand to be an average
customer in the cIass, undercoll.ects by $96.00.
A WeII, this goes back to the timing that I
think you brought up that it's been several years since
the Company's last-filed rate case and cost of service
study. We've had a decline in usage
resi-dential class since 2All. That $96.00 represents
rates that were set based on 201-L usage where we had
approximately 10.50 per month per customer and currently
that has gone down cver subsequent years, so yes, there
was an adjustment made j-n here to account for that
dlfference.
a And that difference is unrelated to net
metering?
A Yes.
O Was that adjustment al-so made in Table
3?
A I'm flipping
3 was l-ooked at the current
per customer for the
around. What we did in Table
revenue requj-rement and
revenue collection tocompared that
determine if
to the current
there was a difference in that.
0 So was there an adjustment made to the
$464,532 to account for the fact that non-net metered
customers have a $96.00 deficit?I 25
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CSB REPORTING
(208 ) 890-s198
ASCHENBRENNER (X)
Idaho Power Company
A No.
O No?
A No, but the no.
O Okay; so if we were to compare if we
were to create a similar Table 3 for the non-net metering
customer, it would also show a it woul-d show the
actual revenue requirement based on 201-5 with no
adjustment for the fact that by 2015, sales had gone down
and so customers were undercollectl-ng what the cost of
service study was based on?
A It may, yeah. I would accept that. I'd
have to work through it.
O Okay; so Iet's 1ook, then, at the same
page, Chart 4. ft shows the 600 or the $464,532 revenue
requirement in one bar of the graph. Do you see that?
A Uh-huh
O Then the revenue collection, 408,820. Do
you see that?
A Yes.
O Okay; so that difference is what you
ca]culate to be the cost shift?
A What we said was the estimated cost shift,
yeah.
A But, again, that does not account for the
fact that if you graphed standard servi-ce, non-neto25
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CSB REPORT]NG(208) B9o-s198
ASCHENBRENNER (X)
Idaho Power Company
metered customers, you would also see a lower revenue
collection than revenue requirement because of that
di-f f erence
O So some of
fact and not because of net metering?
A Without
don't know that I can
not an adjustment made
quantification.
j-n usage
A Ona
liability. We owe the
kilowatt-hour back that
how net metering works.
since the cost of service study?
base rate basis, yes.
that difference is due to that
going through the anal-ysis, I
draw that conclusion, but there was
for $96.00 in that
O Okay, and when you look at revenue
collection, you're looking at bil-l-s sent out and paid,'
right?
A Yes.
O And so net metered customers also send
kj-l-owatt-hours to the Company. The Company then reseIls,
right, and so at the end of a month, there are whatever
the customer has paid for his or her biII, plus some
kil-owatt-hours that he or she has transacted; right?
A I would say that what we do with those
kilowatt-hours is we record them as
customer who
essentially a
generated that
ki.lowatt-hour in a later month is
O So the revenue is reduced by the creditingo25
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CSB REPORTING(208) 890-s198
ASCHENBRENNER (X)
Idaho Power Company
system; right?
A Right, 'Ehat's what we bill on is a net
amount thatrs been established.
O If the inflows to the customer over the
month were 11000 and the customer's exports were 500,
then the customer gets a bil-I for 500 kilowatt-hours?
A Yes.
0 Thatrs the difference; right?
A Yes.
a So if he or she pays that, that shows up
as revenue; right?
A Yes.
O And the customer, though, has also sent
you 500 kilowatt-hours during that month.
A Right, because we're obligated to provide
that back to them later for no compensation.
O But that shows up here as reducing the
revenue?
A It does reduce the revenue. If a customer
consumes 1r 000
and Iater sends exported, we're only
over the month, so we
billing them on
only col-l-ect 500
kil-owatt-hours over the course of a month
s00
500 kil-owatt-hours
kil-owatt-hours '
o
kilowatt-hours
worth.
Right. Yourve also received, though, 500
that were used to serve some othero25
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CSB REPORTING(208) 890-s198
ASCHENBRENNER (X)
Idaho Power Company
customer's load?
energy, but
been talking
$.10 credit
A We've received 500 kilowatt-hours in
under our net billing practice and what we've
about today is we owe the customer about a
for each of those kil-owatt-hours that they
offset
there's a
and resold
reduction
send to us that they will use in a later month
consumption in a different period.
O Right, but the vaIue, you said
value of those kilowatt-hours that you receive
to other customers, that doesn't show up in a
of revenue calculation?
A Can you restate that?
to
O Sure, the 500 kilowatt-hours in this
hypothetical- reduced revenue by 500 kilowatt-hours times
the retai-l rate.
A Riqht.
O So that shows up as a reduced revenue
col-lection; right? Thatrs what we're talking about, the
shift
A Yes.
0 thatrs what that calcul-ation i-s based
oD, but you have also received from that customer those
500 kilowatt-hours.
A Yes.
O That doesn't show up. To the extent thato25
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thatrs a value, that exchange, the Company got those
kilowatt-hours, 9ot that energy that 1t did not have to
generate and transmit and resold it to other customers?
A Yes.
0 To the extent there's a val-ue to those
that offsets some costs of the Company, that doesn't show
up in this Chart 4, revenue requirement compared to
revenue collection?
A No, bul it would have shown up in the
revenue requirement calculation. To the extent that we
don't have to generate excess energy because customers
are generating energy on-site, our system would respond
in kind by reducing generation, which would reduce
overall costs for al,l- customers, which would be a benefj-t
to al-1 customer classes. What happens under the
residential and small- general service, the retail- rate
net metering, the cost associated with that gets shifted
to other customers within the residential class for the
fixed cost col-lection that we're not able to pick up from
that customer.
O So Table 3, the cost of servj-ce revenue
requirement is reduced by productj-on used behind the
meter because the billing determinants are lower, the
energy billing determinants; right?
A Uh-huh.
CSB REPORTING(208) 890-s198
ASCHENBRENNER (X)
Idaho Power Company
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CSB REPORT]NG(208) 890-sl-98
ASCHENBRENNER (X)
Idaho Power Company
reducing the
exports?
A
j-s assigning utility costsr so
costs to customers. We looked
were utiliz:nq.
assigned to them
O But you're not accounting you're not
revenue requirement by the val-ue of
In this analysis, Do. What we were doing
they weren't
them.
0
A
o
we didn't assign negative
at whether or not they
If they were utilizing, they got a cost
If they were exporting,we would say
costs touti1izing and we didn't assign
You assj-gned zero?
Yes.
Okay, but if theyrre exportj-ng, there's a
this
value to what they
does not show up in
Table 3?
are exporting to you and that value
the revenue requirement column in
A Right.
O Right, and it doesn't show up in the
revenue collection coluron in Chart 4?
A Right, the revenue coll-ection was
informatj-on straight out of our billing system. We
received $408,000 from those 366 customers during 2075.
to understandO f get it. I'm just trying
there's another val-ue stream involved in
relationship, in this net metering relationship, ando25
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that's not accounted for in this particular comparj-son.
A I think the value that those customers
receive for their excess generation was the retail rate
credit and we accumulate that credit and we carry that on
that customer's bill to offset future use.
O That's what they got in exchange?
A Yes.
O But the Company received something,
something of value, for that creditr so if I'm exporting
a kilowatt-hour, I get the credit that has a value to me,
because I can offset, right, but that energy has a value
to the Compdny, right, and that value to the Company of
that export doesn't show up in the way this particular
calculatlon was done?
A I think I would accept that, y€s.
O Letrs talk briefly about Table 4, then.
This is not actual cost shift approximatj-on. This is a
proj ection?
A Yes.
O And this makes certain assumptions?
A And this is what?
O Makes certain assumptions.
A Yes.
O This assumes that the person, customer,
who decides to put on solar has a class average usage.
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ASCHENBRENNER (X)
Idaho Power Company
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A Yes.
O And that he or she puts on a 6 ki1owatt
system.
A Yes, that was the most commonly installed
system size in 201-5, so yes.
O But the average usage was not common of
the average that net metered customer pre-so1d?
A Right, if you'11 give me a second here,
the context that's provided in the report discusses that
the existing customers or the kind of the 366, I
guessr we don't believe is representative of what the
future net metering customer cl-ass wil-l- look l-ike. We
have early adopters in that class. They have much
greater than average usage. What we were attempting to
do in here, and we characterized it at such, it's a
potential, and as you said, I mean, it's a hypothetical.
We said, we11, what if an average sj-ze residential-
customer installs a 6 kW system, what would the cost of
service Iook like for that customer and what woul-d the
rate design provide for an opportunity for revenue
collection, and what we saw in that, and I mentioned it
earlier, j-s that in that hypothetical-, what we believe j-s
that there may be a 26 percent reduction in the cost to
serve a standard sized customer, because to the extent
that they're able to reduce usage on facilities on peak
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(208 ) 890-s198
ASCHENBRENNER (X)
Idaho Power Company
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ASCHENBRENNER (X)
Tdaho Power Company
ocr you know,
there would be
group coincident, non-coincident demand,
a commensurate reduction in cost. What we
saw was that whi1e they had a 26 percent reduction in
cost to serve, there was a 71 percent, or would be under
the hypothetical a 1! percent, reduction in the revenue
collected from that customer.
O And like the prior tab1e, that compares
bill-s paid --revenue requirement to
A Yes.
O revenue received. It does not account
for that additional value stream that the Company is
receiving of the exported electricity?
A The avoided cost of energy or some va1ue
of energy?
o Yes.
A No.
0 Thatrs still missing from this
calculation?
A That was not incl-uded in this.
MR. BENDER: Okay. Nothing further.
Thank you.
COMMISSIONER RAPER: Thank you. Do the
Commissioners have any questions?
Any redirect, Ms. Nordstrom?
MS. NORDSTROM: Yes, thank you.o 25
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CSB REPORTING(208) 890-s198
ASCHENBRENNER (ReDi)
Idaho Power Company
REDIRECT EXAMINATION
BY MS. NORDSTROM:
a Ms. Aschenbrenner, we
bit about the 2077 workshop that the
month prior to fiting this case.
that workshop with stakehol-ders?
A The purpose of that
reconvene the group of intervenors
in 20L6 and to descrj-be, rea1Iy, I
had been done between June of 20L6
and June of 20L7. At the time of
discussed a little
Company held one
What was the purpose of
workshop was to
that we had met with
guess, the work that
and -- or JuIy of 2016
the workshop in 2016,
the Company was considering making a filing that would
have included modification to rates at that time. We
were considering making a filing to establish separate
classes and asking for a movement of some of the fixed
cost recovery into a higher servj-ce charge for net
metering customers, so keeping the same rate design, but
shifting some of the fixed cost collection.
We got together with stakeholders in 201,7
to describe that after hearing the overwhelming, how I
would classify it, feedback from stakehol-ders in 20L6
that changes to prj-cing was not something that any of the
stakeholders, that f heard from anyways, were aligned
with, customers certainly had concerns with that, that weo25
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CSB REPORTING(208) 890-s198
ASCHENBRENNER (ReDi)
fdaho Power Company
had rea11y
would do at
taken a step back and reevaluated what we
this time. We di-d discuss that the Company
thecontinues to have concerns with cost shift with
retaj-l rate applied to the net consumption. That coupled
with the growth in the net metering service provides
concerns for the Company.
What we discussed was wanting to move
forward with looking at what the right compensation
structure and rate design woul-d be. At that meeting,
really, stakeholders and the Company weren't able to come
to an agreement that there was a problem that needed to
be solved, f guess, is how I would characterize that, so
at that meeting and as I described in my testimony, I
think most stakeholders wanted to engage in a val-ue of
soIar, val-ue of distributed energy docket, but there
wasn't consensus that there was a problem. You know, a
Iot of discussion was around the adoption is still very
small- and it's too early to make a change.
You know, what the Company did at that
time was came back with that feedback and determined that
we do believe that now i-s the time for the Commission to
make a policy determination on customer classes, but we
wanted to incorporate the feedback that we heard and that
was where our request to ask the Commission to order us
into a value of distributed generation docket came fromo25
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CSB REPORTING
(208 ) 890-5198
ASCHENBRENNER (ReDi)
Idaho Power Company
so that we could work with
the Commi-ssion feels that
be solved, you know, that
determinati-on and move in
something thatrs workable
earlier about whether
and hopefully, come to
from all perspectj-ves, you
and stakeholders if
problem that needs to
take that
some questions
of instances in the
parties
there I s a
we would
know, going forward.
O So at this workshop did you discuss with
stakehol-ders that were present that Idaho Power was
thinking about requesting a determination of these new
customer cl-asses?
A Yes.
O Thank you. There were
past, and f guess my
that there have been
to you is, are you aware
in the past where the
classes and then l-ater
you were
question
instances
aware
Commission has created customer
set rates or later closed them if they determined that
they didn't want to set different rates?
A Yes. As I understand generally, there
have been other service schedules, I guess one that comes
to mind is I can't remember the schedul-e, but there
used to be different rate schedules for maybe
all-electric customers versus other heat source customers
and that those customer cl-asses were later rol-Ied back
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CSB REPORTING
(208 ) 890-s198
ASCHENBRENNER (ReDi)
Idaho Power Company
generally, I'm famil-iar where there's been carve-outs and
then put back in.
O Mr. Hammond asked you about Schedule 84
A Yes.
0 and what would happen if adjustments
were made to Schedule 84. If we were to adjust Schedule
84, would that address the concerns that the Company has
rai-sed in its case?
A No.
MS. NORDSTROM: Thank you. No further
questi-ons.
COMMISSIONER RAPER: You may step down.
THE WITNESS: AIl right.
(The witness left the stand. )
COMMISSIONER RAPER: Would you like to
ca.l-1 another witness?
MS. NORDSTROM: Idaho Power cal-ls Dave
Ange11.
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CSB REPORTING
(208 ) 890-s198
ANGELL (Di)
Idaho Power Company
produced as a witness
Company, having been
DAVID M. ANGELL,
at the instance of the fdaho Power
first duly sworn to tell the truth,
as follows:was examined and testified
DIRECT EXAMINATION
BY MS. NORDSTROM:
o
A
o
Good afternoon, Mr. Ange11.
Good afternoon.
Please state your name and spe1l your l-ast
name for the record.
A
o
David Angell, A-n-g-e-l-l-.
And by whom are you employed and in what
capacity?
A I'm employed by Idaho Power Company. I am
the senior manager of transmissj-on and distribution
planning.
O Are you the same
direct testimony on ,Ju1y 211h,
74?
Dave Ange11 that fil-ed
201"7, and prepared Exhibit
A
o
26t}], 20L8,
A
Yes, I am.
Did you file rebuttal testimony
and prepared no exhibits?
Yes, I did.
on January
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CSB REPORTING(208) 890-s198
ANGELL (Di)
Idaho Power Company
O
surrebuttal
additional
Are you
testimony
exhibits?
the same Dave Angell that filed
on February 23rd, 2078, with no
Yes, I am.
Do you have any corrections or changes to
or exhibits?
There is one correction which was
35.
Are you referring to the prefiled
That is correct.
A
o
your testimony
A
provided, page
o
correction
A
o
February 23rd,
A
o
20]-8?
That is correct.
If I were to
of rebuttalr page 35, that you fj-l-ed on
in your prefiled testimony,
ask you the questions set out
would your answers be the
same today?
A Yes, they would.
MS. NORDSTROM: I would move that the
prefiled direct, rebuttal, and surrebuttal testimony of
Dave Ange11 be spread upon the record as if read and
Exhibit L4 be marked for identification.
COMMISSIONER RAPER: Ir'lithout objection,
Mr. Ange11's testimony will be spread across the record
as if read and we wil-I admit Exhibit 14.o 25
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(Idaho Power Company Exhibit No. L4 was
admitted into evidence. )
(The following prefiled direct, rebuttal,
and surrebuttal testimonies of Mr. David Ange11 are
spread upon the record. )
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CSB REPORTING(208) 890-s198
ANGELL (Di)
Idaho Power Company
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O. Please state your name and business address.
A. My name is Dave Angell. My business address is
7227 West Idaho Street, Boise, Idaho.
O. By whom are you employed and in what capacity?
A. f am employed by Idaho Power Company ("Idaho
Power" or "Company" ) as the Transmission and Distribution
Planning Manager.
O. Pl-ease describe your educational- background.
A. I graduated in 1984 and 1986 from the
University of Idaho, Moscow, Idaho, receiving a Bachelor
of Science Degree and Master of Engineering Degree in
Electrical- EngJ-neering, respectively. I have provided
electrical engineering instruction for both the
University of Idaho and Boise State University. Most
recently I instructed power system analysis at Boise
State University during the 2009 sprlng semester. f am a
licensed professional engineer in the State of Idaho and
a senior member of the Institute of Electrical- and
Electronic Engineers.
O. Pl-ease describe your work experience with ldaho
Power.
A. From 1986 to 7996, T was employed by ldaho
Power as an engineer in both communications and
protection systems. In 7996, I became the Engineering
Leader of System Protection and Communications. I heldthis position
CSB REPORTING(208) 890-s198
ANGELL, DI 1
Idaho Power Company
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CSB REPORTING
[phone]
ANGELL, DI 2
Idaho Power Company
until- 2004, when f transferred to Transmission and
Distribution Planning. During the fal-l of 2006, T
accepted the positions of System Planni-ng Leader and
Manager of Delivery Plannj-ng. I have been managing Idaho
Power' s interconnected-transmisslon system,
sub-transmission, and distribution pJ-anning since 2006.
A. What is the purpose of your testj-mony in this
proceeding?
A. I wil-I provide an explanatj-on of the electrj-cal
grid and how the Company's resj-dential and small- general
service ("R&SGS") customers with on-site generation
utilize the distribution system. I will then address the
questJ-on of whether increasing levels of distributed
energy resources ("DER") will contribute to the deferral
of future investment i-n distribution infrastructure.
Fina11y, I wiII describe how smart inverters provide
functionality that is necessary to support the ongoing
stability and reliability of the distribution system and
explain the Company's request relative to a smart
inverter requj-rement j-n Schedule 72 for customers who
interconnect privately-owned DER to Idaho Power's system.
I. THE GRID
O. What is meant by the term "the grid"?
this context, is t.he electric
power
A. The grj-d, in
system including the conversion, transformation,t 25
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transmission, distribution, and delivery of energy in the
form of electricity to customers.
The conversion of energy contained in
reservoirs, fossil fuels, wind, geothermal wells r or
solar rays to electricity power occurs at generation
stations. Many of the generation stations are located
remote from the customers' point of use. Therefore, the
el-ectricity is transformed to extremely high voltages in
order to reduce the el-ectrical losses when transmitting
the electricity on transmission l-ines for long distances.
Transformers are used throughout the grid to change the
electric voltage level to match utilizatj-on and reduce
electric losses. Once the electricity is delivered to
communities, it is transformed to a l-ower voltage at
substations for local distribution. The electricity is
distributed through the l-ocal communj-ty on distribution
l-ines where transformers are used to tap the line and
deliver customers electrj-city at a reduced voltage to
match their intended use.
a. What kinds of services does the grid offer
Idaho Power customers?
A. The grid offers reliabl-e electricity delivery,
in the context of dependability and bal-ance of supply,
across large reglons in the amount and at the instant of
customers' demand. The grid also provides flexibility byallowing the utility access to a diverse portfoli-o of
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CSB REPORTING
(208 ) 890-5198
ANGELL, DI 3
Idaho Power Company
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resources for power generation, even if those resources
are located far from where the power is needed.
O. What functions does Idaho Power perform in
order to maintaj-n a safe and reliable distribution system
and grid?
A. In order to provide safe and rel-iable energy on
demand, Idaho Power must perform the following functions:
voltage control, system protection, scheduling,
dispatching, and l-oad balancing. These functions are
commonly referred to and coll-ectively known as ancillary
services.
O. How does Idaho Power control voltage to
maj-ntain a safe and reliable distribution system and
grid?
A. Voltage control is achieved by managing the
voltage throughout the grid at the generator,
transmission, and distribution systems. Automatic
voltage regulati-ng devices control the voJ-tage output of
the generators to match the grid operators set vol-tage.
At the substations, grid operators also remotely switch
substation capacitors and inductors to raise and lower
the transmission voltage, respectively. Automatic
voltage management occurs at the distribution substation
transformers with voltage controf based on Ioad, known as
load tap changers. Additional automatic control signals
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CSB REPORTING
(208 ) 890-sr_98
ANGELL, DI 4Idaho Power Company
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are sent to swj-tched distributj-on circuit capacitors
based on substation transformer loading.
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CSB REPORTING
(208 ) 890-s198
ANGELL
Idaho Powe
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ompany
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CSB REPORTING
(208 ) 890-s198
Finally, voltage control- occurs at substations that
service large commer:cj-al and industrial customers.
0. What is system protection?
A. System protection is the detection and
j-solation of both short circults and system operation
that may damage generation, transmission, substation, and
distribution facilities. Idaho Power coordinates the
protection equipment to isolate onJ-y the failed component
and allow the remaining grid to continue to supply
energy.
O. How do scheduling, dispatching, and load
balancing help Idaho Power maintaj-n a safe and reliable
distribution system and grid?
A. The Idaho Power-owned generation stations are
controll-ed by grid operations personnel. These personnel
schedule a generatorrs electrical output ahead of time
based on the load forecast and its optimal use in
consideration of energy market economics. Durj-ng each
hour of the
generation
production
generation
duy, the operators efficiently dispatch the
fl-eet to maintain the balance between
and forecasted use. They operate the
stations
and
within a set of operational,
economic constraints to maximizeenvironmental,
customer value.Some of these generation stations are
also configured with the nearly instantaneous ability to25
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Idaho Power Company
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automatically adjust the electric output to balance the
generated electricity with the actual
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CSB REPORTING(208) 890-s198
ANGELL,
Idaho Power
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CSB REPORTING
(208 ) 890-s198
ANGELL, Dr 6
Idaho Power Company
use, known as automatic generation control. Additional-
generation capability is hel-d j-n reserve and is avail-able
for dispatch if the actual load exceeds the forecast or
if some of the dispatched generation is forced out of
service unexpectedly.
O. How do wind and sol-ar resources impact this
scheduling, dispatchJ-ng, and load balancing?
A. Independently-owned wind and sol-ar generation
resources differ from Idaho Power-owned and operated
generation stations because their production is difficul-t
to forecast and they cannot be dispatched by Idaho
Power's grid operators. Because the actual output from
these independently-owned resources typically varies from
the forecast, they place increased demands on the
dispatch and utilization of the automatic generation
contro1 and reserve generation.
O. Does DER located on the customer side of the
meter increase the complexity of forecasting?
A. Yes. While on an individual basis a smal-l-
independently-owned on-site generation system (capacity
of < 25 kilowatts ("kV'I")) may not be noticeable to the
automatic generation control, the aggregate amount of DER
instal-led across Idaho Power's system is noticeable and
does increase the complexity of forecasting. As of June
30, 2011, Idaho Power's net metering service had ao25
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cumulative nameplate capacity of 11 megawatts including
customers who had submitted applications for net metering
service. Because the net metered systems are install-ed
on the customer side of the meter, Idaho Power is not
abl-e to detect the amount of DER at any given moment,
which j-ncreases complexity of both forecasting and load
following.
O. You have described the overall services that
the grid provi-des to Idaho Power's customers and the
functions that Idaho Power performs to maintain a
rel-iable grid. Does the grid provide other services that
are specific to a person with privately-owned generation?
A. Yes. The grid provj-des the following services
that customers with privately-owned generation require:
inverter operation, motor starting, energy balancing, and
standby servj-ce.
O. What is an inverter?
A. Inverters convert direct current ("DC")
electricity into alternating current (r'ACr') electricity.
Inverters are used in both off-grid and on-grid
applicati-ons. An inverter is required for customers who
j-nstall- a photovoltaic ("PV") generation system because
solar panels produce DC el-ectricity and the home
appliances require AC power supplied by the j-nverter.
CSB REPORT]NG(208) 890-s198
ANGELL, DI 1
Idaho Power Company
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application and an "on-grj-d" applj-cation?
A. An off-grid generation system is one that is
not interconnected to the electric grid; the off-grid
system provides al-l electrj-c needs of the owner they
are independent of the utility. In the case of an
off-grid solar PV system, the DC electricity generated by
the PV system is used to charge a battery bank connected
to the customer's equipment through an off-grid inverter,
which does not require the grid to operate.
On the other hand, an on-grid generation system
is one that is interconnected to the el-ectric grid. Eor
on-grid systems, the DC electricity generated by the PV
system is sent directly to an on-grid inverter which
converts the electricity to AC for use by the DER
customer or other customers through the grid.
O. How does the grid provide servj-ces for on-grj-d
system inverter operation?
A. hllthout the grid, the customer's generation
system would not operate because these line commutati-ng
inverters would not be able to devel-op voltage or deliver
energy. In other words, the grid must be present for
customers with on-grid inverters to operate their
generation system.
CSB REPORTING(208) 890-s198
ANGELL, Dr I
Idaho Power Company
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CSB REPORTING(208) 890-s198
ANGELL, DI 9
Idaho Power Company
For the remainder of my testlmony, all
discussions in regard to inverters will be specific to
on-grid inverters.
O. How does the grid enable a customer with
self-generation to start a motor?
A. El-ectro-mechanj-cal- devices such as generators
and motors transfer energy via the interaction of
magnetic f iel-ds.current
in addition to the
These magneti-c fiel-ds require
current associated with the
transfer. This additional current is known as
energy
reactive
current. The induction motor, the most widely used
motor, is constructed with an electro-magnet which re11es
on a power source to develop a magnetic fiel-d. When
energized, the motor has no magnetic fiel-d to impede the
current flow from the power source. Therefore, during
motor starting, a current draw of about six times the
full- load value occurs. Most inverters currently
interconnected with the Idaho Power system are not able
to supply these high starting and continuous reactive
currents. The grid, via its generators and capacitors,
supplies the motor starting and continuous reactive
current. In other words, a customer with on-site
generation would not be able to turn on certain equipment
Iike air conditioners, pumps, and household motors
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CSB REPORTING(208) 890-s1e8
ANGELL, DI 10
Idaho Power Company
O. How j-s standby service provided by the grid
beneficial- to a customer with self-generation?
A. When a customer's self-generation system is not
able to meet their demand, that customer must rely on
power from the grid. AIso, when a customerrs system is
not generatlng because of weather conditions, time of day
or operational malfunction, the customer rel-ies on power
from the grid to meet their electrj-city demands.
0. Is it a requirement for someone with
privat.ely-owned generation to be connected to the grid?
A. No. A person with privately-owned generation
is not requj-red to be connected to the grid. However,
most customers voluntarily choose to connect to the grid
in order to receive the services that the grid provides
as described above.
IT. USE OF TEE GRID BT STAT{DARD SERVICE CUSTOMERS AIiID
CUSTOMERS WITH ON-SITE GENERATION
customers with on-slte generationO. How do R&SGS
use the grid compared
customers?
to R&SGS standard service
A. The prj-mary difference is that the R&SGS
customer with on-site generation uses the grid in a
bi-dj-rectional manner by both consuming energy from the
grld and delivering excess net energy to the grid when
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the grid.
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ANGELL, Df 10a
Idaho Power Company
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CSB REPORTING(208) 890-sr_98
ANGELL, DI 11
Idaho Power Company
Furthermore, whil-e the daily demand requirements of the
two customers may be similar, the net monthly energy may
not reflect the util-ization of the grid by the on-site
generation customer.
O. What is meant by the term "net zero" customer?
A. A net zero customer is one that, over the
course of a year, generates as much or more energy
consume. That is,(kil-owatt-hours
during certain
("kwh") ) than they
hours of the year, the customer is a net
exporter
the year,
the grid.
o.
of energy to the grid, and during other hours of
the customer is a net consumer of energy from
Does the net zera customer utilize the
distribution system l-ess than the standard service
residential customer?
A. No. A net zero customer util-izes all- aspects
of Idaho Power's grid during the hours they are consuming
energy (incl-uding the generation, transmission, and
distribution systems) and utilizes the distribution
system during the hours they are exporting energy to the
grid.
To illustrate this, the Company selected a
single residential net metering customer who netted their
usage to zero during 2016. Figure 1 demonstrates the
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customer on the Companyrs 201-6 adjusted system peak day
(June 29) and
CSB REPORTING
(208 ) 890-s198
ANGELL, Dr 11a
Idaho Power Company
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CSB REPORTTNG(208) 890-s198
ANGELL, DI L2
Idaho Power Company
compares
service
metering
customerts usage
customer.
that customer's hourly usage to a standard
whose home is nearby the net
Figrrre 1. Resid€atial ttet lbtsring Customer vs. Standatd
Service Recid€atial Cugtmer (ilunc 29, 2016)
O. Would you characterize these customers' usage
as similar?
A. No. While the daily absolute dernand
requirements of the two customers are similar, the net
monthly energy consumed by the net metering customer j-s
not representative of their usage of the grid.
O. tr{hy is the net monthly energy not
representative of the customer's use of the grid?
A. [ihen a net metering customer exports excess net
energy to the grid, their retail meter "spins backwards, "
or in the case of a modern meter, subtracts usage
electronically. Later, during other hours of the day or
month when the customer is consuming energy from the
L 2 3 4 s 6 7 I 9 1011L2t3t4 151617L8 192021222324
Hour Ending
r "Net Zero" Net Metering Customer * Standard Service Residential Customer
=J
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CSB REPORTING
(208 ) 8eo-s198
ANGELL, DI 13
Idaho Power Company
grid, the meter "spins forwardr " and adds usage
electronically. On a monthly basis, the net metering
customer is using the grid, every hour, every day, but
because usage is measured for billing purposes on a
monthly basis, that net metering customer appears to have
"zero usage" for the month.
To understand the extent to which the net
metering customer uses the grid, you can use the absolute
value of the energy being transacted to and from the net
meteri-ng customer. Figure 2 represents the same day as
Eigure L, but shows all of the energy as positive, that
is, the total amount of energy that is being transacted
between the net metering customer and the Companyrs grid
regardless of which direction the energy is flowingi.
Figrure 2. Utilization of ttre Digtribution Systen by
Residential. l[et lfietering Custon€r vs. Standard Service
Residential Customer June 29 2016)
8
7
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2
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9 10 11 L2 13 L4 t5 L6 L7 18 19 20 21 22 23 24
Hour Endlng
r Net Metering BExported Net Excess r Standard Service
3I
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CSB REPORTING(208) 890-s198
ANGELLIdaho Powe
r74
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,DrC
The sum of the hourly consumed energy for the standard
service residential- customer on June 29, 2016, was 71 .7
kwh, and the sum of the absolute value of the net hourly
enerqy for the residential
kwh. Yet, when looking at
dayr it wou1d appear the
customer transacted 17.1
residentj-al- net metering
that customer transacted
When Iooking
individual- hours within
two customers, the sum
customer was 55.4
reads from that
net metering
their meter
of the hourly consumed
the standard servi-ce residential- customer was
and the sum of the absol-ute value of the
standard service residential-
kWh of energy, while the
customerrs meter would register
17.28 kwh.
at the sum of al-I of the
the month of June for those same
energy for
L,480 kwh,
the resldential net metering
net hourly
customer wasenergy for
1,323 kwh.
the month,
residential
register
kwh, to
Yet, when looking
it wou1d appear the
at their meter reads for
standard service
customer transacted L,4B0 kWh of
while the residential- net metering customer's
energy,
meter would
that customer exported excess net energy of 440
be carried forward to offset consumption in a
that customer woul-d be billed for zerofuture month, and
kwh
This demonstrates how the net monthly energy as
a net meteri-nga basj-s for billing does not refl-ect
customerrs utilization of the grid.o 25
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CSB REPORTING(208) 890-s198
ANGELL
Idaho Powe
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III. LOCAI DISTRIBIITION III\IESTL{ENT
O. Has Idaho Power studied the relationship
between distributed, rooftop solar PV and its
dj-stribution system operations?
A. Yes. In 2015, the Company performed a study
comparing solar j-ntensity variations and distribution
circuit demand. This study is attached as Exhibit No.
1,4. A portion of the study sought to determine if there
was a relationship between sol-ar intensity and
distribution circuit loading. The Company's system peak
load is largely driven by the Treasure Valley residential-
and commercial 1oads. Therefore, weather stations with
irradiance sensors were installed on a Treasure Va1ley
distribution circuit that supplied primari-ly residential
and some commerci-al- customers. Three irradiance sensor
orientations at three locations were used. The
orientations were southerly facing at a 35" tilt,
horizontal and westerly facing at a 53o tilt. The study
demonstrated that there was a significant time delay
between peak solar intensity and peak distribution
circuit demand.
O. What
A. The
sensor peaked
distribution
did the study conclude?
study demonstrated that a southerly facing
approximately four hours prior to the
cj-rcuit peak load and a westerly facingo25
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sensor peaked approximately two hours prior to the
distribution
CSB REPORT]NG(208) 890-s198
ANGELL, Dr 15a
Idaho Power Company
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CSB REPORTING
(208 ) 890-5198
ANGELL,
Idaho Power
DI 16
Company
circuit peak
systems will
circuit peak
demonstrate
a steep decl-ine
will- result in a
load. In both cases, sj-milarly ori-ented PV
not significantly reduce a distribution
load. Additionally, the measurements
that the western facing PV system will create
in production at the end of the day that
rapid change j-n circuit voltage and
voltage regulatlng abilities to respondrequire
to this
enhanced
rapid decline.
As the study concluded, even a
load hours
system oriented
of the summerwest will not peak during peak
peak on a specific distribution circuit or substation.
The distribution circuit peak l-oad occurred from 17:00
through 19:00 hours. At 19:00 hours, the contribution
from a PV array wil-l- be about 20 percent if faced
southerly and about 55 percent if faced westerly. PV
generation would only shift the peak l-oad to 20200 hours
and decrease it by 10 percent. To ill-ustrate this,
Figure 3 presents a typical nomi-naIized1 load shape with
the irradiance shape for the southerly-configured sensor
and the resulting load shape less the solar irradj-ance.
1 fo find relationships between sol-ar intensity and 1oad, the
data was nominal-ized so that each variabl-e ranged between 1 and 0.
That allowed the two correlated time-series to be more easily
re.l-atable when graphed.I 25
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Figrure 3. Southerly Solrr lrradi-''ce Sbape vs. Load Shape
1.0
0.8
oE 0.6)
!,o'.EE
EEE 0.4
U'
0.2
I
0:00 2:00 4:00 6:00 8:00 10:00 t2:00 14:00 16:00'18:00 20:00 22:OA 24:00
Hour
Similarly, Figure 4 presents a tlpical nominalized load
shape with the irradj-ance shape for the
westerly-configured sensor and the resulting load shape
less the solar irradiance.
CSB REPORTING
(208 ) 890-s1_98
ANGELL, DT I7
fdaho Power Company
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Figiure 4. westerry solar rrradiance shape vs. Load shape
0
0:00 ::00 6:00 8:00 10:00 11:00 14:0rl t 6:00 1B:0rl 10:00 2l:00 14:00
Hour
LDad (Stdi W lrradiance (Std)
-
Loa,J-lnadiance
O. Why is the plannJ-ng horizon five years?
A. ldaho Power is able to forecast distribution
circuit and substation capacity requirements with some
certainty five years into the future. This planning
horizon period all-ows the Company to lnvestigate options
to avoid facllity overloads, select more cost-effective
options, and design and construct improvements to meet
the identified overloads.
O. Can Idaho Power forecast on-site generation
installations by distribution circuit and substation?
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CSB REPORTING
(208 ) 890-s198
ANGELL, D] 18
Idaho Power Company
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CSB REPORTING(208) 890-5r-98
ANGELL, DI 19
Idaho Power Company
A. No. A customer's interest and abil-ity to
invest in an on-sj-te generation system is based on many
factors such as their ability to finance a system, risk
tolerance, the loca1 economy, and electricity prices.
The l-ast two factors are incorporated into the forecasts
used in the Integrated Resource Pl-an analysis for on-site
generation additions for the service area. However, it
is extremely difficult to buil-d a reasonabl-e forecast
with those same assumptj-ons for specific circuits and
substations.
O. Can increased leve1s of rooftop PV reduce 1ocal
distribution infrastructure investment?
in Iimited circumstances. Idaho Power has
in place to serve all customers during
peak l-oad hours. Idaho Power must
A. OnIy
infrastructure
distrj-bution system investments in
plan
order
reliable service. In order to reduce the
investment, sufficient PV additions must
distribution circuit during Idaho Powerrs
planning horizon.
and undertake
to provide this
infrastructure
occur on the
five-year
O.
might be
A.
investment
Can you provi-de an example where infrastructure
reduced?
An example of a circumstance where an
could be deferred is a remote section of a
distribution circuit where the load peak occurs duringo25
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CSB REPORTING(208) 890-s198
ANGELL, DI 20
Idaho Power Company
dayJ-ight hours,
and the voltage
customers are
is declining.
increasing at a sl-ow rate,
A traditional solution,
Power
e.9., install-ation of a capacitor, might
to 50 ktal of PV generation.
O. Has this occurred on the Idaho
be reduced by 20
A. Yes. Idaho Power engineers revj-ewed
system?
the
distribution system and found one location that met the
criteria above. A pilot PV project was instal-Ied in 2016
and the engineers are presently moni-toring the
performance for evaluation this faIl.
O. Is the distributj-on system capable of handling
increasing level-s of DER without any modification?
A. No. High DER penetration amounts create
distribution circuit operation challenges, such as
voltage management, short circuit detection, and
j-slandj-ng. Isl-anding occurs when a customerrs generation
is capable of supporti-ng the load of other customers
physically located near the customer's generator when
that section of the electrical circuit is isol-ated from
the Idaho Power system.
O. Why does the presence of DER impact the
distribution cj-rcuit voltage?
it changes
When DER is contributing power to the circuJ-t,
the power requj-rement from the distribution
transformer as shown previously. This changesubstationin
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CSB REPORTING(208) 890-s198
ANGELL, DI 2L
Idaho Power Company
power flow causes the typical circuit voltage drop to
change.
O. What is meant by typical circuit voltage drop?
A. Voltage drop (l-oss) occurs any time power flows
through a conductor. For a typical circuit, the voltage
is highest at the substation (the power source) and drops
to the lowest point at the end of the circuit. The rate
of drop is based on the amount of current flow and
conductor resistance.
O. How is the distribution circuj-t voltage
managed?
A. The distribution circuit voltage is typically
automatically controlled by three components: (1) the
substation distribution transformer load tap changer
("LTC"), (2) regulators l-ocated along the circuit, and
(3) shunt connected capacitors. The LTC automatically
adjusts the substation bus voltage based on the power
flow through the transformer. The LTC and regulators are
mechanical devj-ces that slowly wear with each change of
tap.
with
Therefore,
sufficient
the controls on these devices are set
bandwidth and time delay to avoid
excessive wear and maintain the voltage withj-n a range
to function properly. Thefor the customer's
capacJ-tor controls
equipment
are set to manage the reactive power
flow while keeping the
descri-bed above.
circuit voltage within the rangeo25
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O. May the controls be set to accommodate DER
penetration in excess of 15 percent of peak load?
A. No. The traditional LTC and regulator controls
were designed assuming the circuit power would only flow
from the substation to the loads on the circuit. During
conditions of DER power output that exceed the local
Ioad, these controls wil-l sense the power flow and adjust
the voltage to increase the vo1tage when it is not
desired. Idaho Power would need to replace the
controllers with the latest models that are able to
detect a reverse power condj-tion and adjust accordinqly.
This l-evel of PV penetration can require
additional voltage adjustment (tap change) cycles in
addition to the daily l-oad cycle adjustments.
Adjustments down are needed as the voltage rises with PV
output peaking with the sol-ar peak and adjustments up
when the voltage decreases during the load peak while the
sofar output wanes.
Fina11y, the PV output wil-1 change rapidly when
broken cl-ouds pass over the PV systems. Rapid changes to
output result in rapid voltage fluctuations that cannot
be regulated by the time-delayed regulating devices.
O. Are there operational practices or equipment
available to reduce these operational challenges?
A. Yes. Idaho Power first replaces thecontrollers and optimizes their settings for reduction of
CSB REPORTING(208) 890-s198
ANGELL, DI 22
Idaho Power Company
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CSB REPORTING(208) 890-5198
ANGELL
Idaho Powe
723
ompany
,DrC
voltage deviation without substantially increasing the
devj-ce wear. Beyond this, there are two options. The
first option is to reduce the remaining voltage deviation
by decreasing the circuit impedance through full-
conductor replacement on a given feeder. This option is
not practical- given that a fu1l conductor replacement
would not be cost-effectj-ve. The second option is to
require voltage regulation from the DER.
IV. TN\/ERTER FEJATURES AT{D EUNCTION
a. How can on-site generation provj-de regulatJ-on?
A. An on-sj-te generation system interconnected to
the grid through a
its voltage control
O. What is a
smart inverter can regulate voltage if
function is enabled.
smart inverter?
A. A smart inverter provides configurable
functions beyond the conversion of DC to AC. A few of
the features are: voltage/reactive power control,
anti-isl-anding, monitoring, and remote communication.
0. Have these regulation functions been
demonstrated?
A. Yes, multiple studies and experience from
Germany, California, and Hawaii have shown that the
deployment of smart inverters can reduce the voltage
impact of on-sj-te generation. The industry adoption of
smart j-nverter requirements will help to mitigate circuit
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CSB REPORTING(208) 890-s198
ANGELL,
Idaho Power
Dr 24
Company
deviation. States l-ike California and Hawaii have
already started requiring
j-nstallatj-ons. Germany,
required smart inverters
smart inverters in residenti-al
the global leader in PV, has
for the last
0. Is there a cost differential
few years.
between a smart
inverter and a standard inverter?
Yes, however,
and with the
smart inverter costs are
decreasing adoption of smart inverter
requirements in Californj-a and Hawaii, these costs will-
decrease even more rapidly due to scal-es of production.
A standard j-nverter costs approximately $0.23 per watt
whereas a premj-um inverter with the smart inverter
functionality built j-n costs around $0.35 per watt. For
example, if a customer were to install a 61 000 watt
system, the price difference between a smart inverter and
a standard inverter for this system would be roughly
$120.
Most inverter manufacturers already provide
smart inverter function capabilities in their devices, it
is just a matter of upgrading the software to enable the
smart inverter functionality. The manufacturers that do
not currentfy provj-de smart inverter capabilities j-n
their products are generally lower cost but they will
have to offer smart j-nverter capabilities in the future
to remain competitive in the market. The Company
recognizes that
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CSB REPORTING(208) 8 90-sr_98
ANGELL, DI 25
Idaho Power Company
there
legacy
O
customers
is a potential cost difference between lower cost
inverters and smart inverters.
Does the Company currently
who instal-l- privately-owned
requJ-re that
interconnect to the grid using a smart
generation,
inverter (s) ?
A. No. The current Schedule 72, Interconnection
to Non-Utitity Generation, requires that grid
interconnected inverters have either a certification with
Standard for Invertets, Converters, Controll-ers and
Interconnection System Equipment for Use with Distributed
Energy Resources UL L7 41, Institute of El-ectrical- and
Electronj-c Engineers Interconnecting Distributed
Resources with El-ectric Power Systems Standard L541
("IEEE L547") or be subject to third-party testing
performed at the customer's expense. None of the
standards that are in effect today include a mandate for
the use of a smart inverter.
O. Does the Company believe that it would be
beneficial to requl-re Idaho Power customers with
pri-vately-owned generation to interconnect to the grid
through a smart inverter?
A. Yes. As described previously, the Company
have been demonstratedbelieves that many benefits
associated with the use of smart inverters. In fact, the
Instj-tute of El-ectrj-cal- and Electronj-c Engineers are in
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CSB REPORTING(208) 890-s198
ANGELL, DI 26
Idaho Power Company
process of revising the
around what constitutes
O. When are the
IEEE 1541 to adopt the standards
revlsions to IEEE L547 and 1547.1,
anticipated to be approved?
A. The IEEE L547 and \541.1, standards are
presently being bal-l-oted. It is anticipated that IEEE
1,547 could be approved as early as the end of 20L'7 and
IEEE 1547 .7 coul-d be approved by mid-2018.
O. What is the Company recommending in this filing
regarding smart inverters?
A. Idaho Power requests that the Idaho Public
Utilities Commission acknowledge that smart inverters
provide functionality that is necessary to support the
ongoing stability and rel-iabil-ity of the distribution
system by ordering the Company to submit a compliance
filing in the form of a tarj-ff advice within 60 days of
the adoption of the revised IEEE standards, or 60 days of
the conclusion of this case, whichever occurs later.
This tariff advice will seek to modify Section 2 of
Schedule 72 to requJ-re that customers with on-site
generation install a smart j-nverter that meets the
requirements defined in the revj-sed IEEE standards.
O. Why would reduction of the voltage deviation, a
power quality issue, be the responsibility of the DER?
a smart lnverter.
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CSB REPORTING(208) 890-s198
ANGELL
Idaho Powe
T27
ompany
,DrC
A. It
deviation
mitj-gate the
is the DER that creates the voltage
it is al-so the DER that can cost-effectively
deviation through the installation of a
smart inverter. Establishing this as a requirement in
Schedule 72 is similar to the requirement for customers
to comply with Practices and Requirements for Ha.rmonic
Control in El-ectric Power Systems as set forth in the
current IEEE Standard 519 in Rul-e K.
O. Does this conclude your testimony?
A. Yes.
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O. Please state your name.
A. My name is David M. Ange11.
O. Are you the same David M. AngeII that
prevj-ously presented direct testimony?
A. Yes.
O. Have you had the opportunity to review the
pre-filed direct testimony of the City of Boise's witness
Stephan L. Burgos; the Idaho Clean Energy Association,
Inc.'s ("ICEA") witnesses Kevin King, Michael Leonard,
and Stephen White; the Idaho Conservation League's
(" ICL" ) witness Benj amj-n J. Otto; Sierra Cl-ub' s witness
R. Thomas Beach,' the Idaho Irrigation Pumpers
Association, fnc's witness Anthony J. Yankel; the Snake
River A1liance and NW Energy Coalj-tj-on's ("SRA/NW
Energy") witness Amanda M. Levin; Vote Solar's witness
Briana Kober; Auric Solar, LLC's witness El-ias Bishop;
and the Idaho PubIic Utilities Commission ("Commj-ssion")
Staff's ("Staff") witnesses Michael Morrison and Stacey
Donohue?
A. Yes, I have.
O. What is the scope of your rebuttal testimony?
A. The purpose of my rebuttal testimony is to
present evidence that the load service requirements and
usage characterj-stics of residential and small- general
service ("R&SGS") customers who instal-I on-site
ANGELL, REB 1
Idaho Power Company
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(208 ) 890-s198
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generation are different than that of R&SGS customers
without on-si-te
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ANGELL, REB 1A
Idaho Power Company
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generation, and to respond to various arguments rai-sed by
intervening parties and Staff in their direct
testimonies. My testimony is comprised of three
sections.
In Section Tt I explain in detail, the
additional analyses performed by the Company and how the
Company has demonstrated that the load service
requirements and pattern of use are distinctly different
for residential customers with on-site generation as
compared to residential customers without on-site
generati-on.
In Section II, I explain how the utilization of
the grid by customers with on-site generation is distinct
and discuss the impacts to the grid.
In Section III, I expJ-ain why the proposed
changes to Schedul-e 72 are very minor and can easily be
addressed as part of this case. I wil-l also explain that
the Commission and Staff will have the opportunity to
review the Institute of El-ectrical- and El-ectroni-c
Engj-neers ("IEEE") requirements before it is adopted.
I. A}IAIYSIS SUPPORTING ESTABLISHMENT OF SEPARATE CI,ASSES
O. Did other parties agree with Idaho Power
Company ("Idaho Power"
with on-sj-te generatj-on
customers and therefore
class ?
or "Company") that R&SGS customers
are different than standard R&SGS
require a separate customer
CSB REPORTING(208) 890-s198
ANGELL, REB 2
Idaho Power Company
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CSB REPORTING
(208 ) B9o-s198
ANGELL, REB 3Idaho Power Company
A. No. Several partiesl suggested that the
Company did not provide sufficient evidence to justify
that R&SGS customers with on-site generati-on are
different than R&SGS customers wlthout on-site
generation.
O. What factors does the Company believe
distinguish customers with on-site generation from those
without on-site generation?
A. The Company continues to belj-eve that the load
service requirement and the pattern of use should be used
to eva1uate whether a segment of customers is different
from their current customer cl-assification.
1. Load Service Requirenent
O. How does the load service requirement of a
customer with on-site generation differ from that of a
standard service residential- customer?
A. The load service requirements of a customer
fundamentally different than
on-site generation. Customers
"partial- requirements"
with on-site generation is
with on-site generati-on are
customers. A partial
that of a customer without
::equirements customer is one who
of their own el-ectricity. Thegenerates al-l- or
utility provides
needs. Partial
variety of
some
only part of
requirements
the customer's
customers stil-]
energy
require aI25
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1 Levin DI, p. '7, 11. 9-10; Kobor DI, p. 32, 1. 18 through p.
5; Donohue DI, p. 5, 1. 5.33, 1
CSB REPORTING(208) 890-s198
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Idaho Power Company
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CSB REPORTING(208) 890-s198
ANGELL, REB 4
Idaho Power Company
services from the utility even though they provide some
or al-1 thej-r own energy. So long as these customers
remain connected to the utj-lity, they continue to take
other services from the utility. As described 1n my
direct testimony, the ancillary services they require
typically include: capacity to meet the in-rush current
requj-rements for starting motor l-oads such as air
conditioning compressors, supplemental services when
solar is not avail-abl-e at night, and frequency services
to maintain power quality. Idaho Power can economically
provide partial requirements service that allows
customers with on-site generation flexibllity in meeting
their energy needs with the reassurance that the utility
is avail-abl-e to handl-e al-l- their electrical needs shoul-d
their on-site generation be interrupted or fail.
O. What analyses did the Company perform to
evaluate the load service requirement?
A. The Company studied the l-oad factor for both
groups of customers.
Load Factor
O. Why is the load factor an important measure to
determine that residential- customers with on-site
generation are different than resj-dential customers
without on-site generation?
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CSB REPORTTNG
(208) 890-s198
ANGELL, REB 5
Idaho Power Company
A. The load factor is the average load divided by
the peak load in a specified time period. It is a
measure of variability of consumption; a low l-oad factor
indicates that load j-s hiqhly variab1e, compared to
consumers with steady consumption. The more consistent
the consumption, the higher the load factor. A low load
factor identifies a customer with infrequent high demand
and the capacity required to serve that peak demand sits
idle for long periods. Thus, customers with a lower load
factor use the Idaho Power system capacity l-ess
efficientJ-y and, when considering the exj-sting rate
design which coll-ects most fixed costs for system
capacity, through the volumetric kil-owatt-hour ("kWh")
charge, are subsidj-zed by customers with higher load
factors.
O. Pl-ease describe the load factor analysis that
was performed by the Company.
A. The Company calcul-ated the monthly load factors
for residential customers wj-th on-sj-te generation and
residentj-aI customers without on-site generation who were
biIled for energy in the 2016 calendar year. The
analysis included all Idaho residential customers and all
Idaho residential- customers with on-site generation. To
calcul-ate the monthly average kwh, the billed energy was
divided by the number of days
was then divided by 24 hours.
in the billing period which
For each customer, theo25
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CSB REPORTING
(208 ) 890-s198
ANGELL, REB 6
Idaho Power Company
average kWh was then divided by the segments largest k!{h
for each billing period.
0. Vlhat did the Company's load factor analysis
conclude?
A. The Companyrs load factor analysis demonstrated
that residential customers with on-site generation have
notably lower load factors than residential customers
without on-site generation. The monthly load factors for
both groups are provided in Figure 1.
Figure 1. Average Monthly Load Factor
Average Load Factor
30Yo
25o/o
20%
L5%
L0%
s%
0%lrl,l'l
Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec
I Residential s Net metered
O. Please summarize your conclusions of the load
factor analysis.
A. Residential customers with on-site generation
consistently have notably lower load factors than
resj-dential customers without on-site generation. In
fact, for months May through August, the load factor for
the customers with on-site generation is less than halft25
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CSB REPORTING(208) 890-s198
ANGELL, REB 7
Idaho Power Company
of the residential- customers without on-site generation.
The Company also compared the annual- l-oad factor of both
groups of customers. V'Ihile the annual- load f actor was
generally better for both groups, 27 percent for
residential- customers with on-site generation and 45
percent for residential customers without on-site
generation, the annual l-oad factor for resldential
customers with on-site generation was still l-ess than
half of the residentlal customers without on-site
generation.
2. Pattern of Usage
O. Did the Company perform additional analyses on
the use patterns of residential customers with on-site
generation and residential customers without on-site
generation?
A. Yes.
O. What analyses dld the Company perform to
evaluate the pattern of use of both groups?
A. The Company studied the load profile,
system-coincident demands ("SCD"), and non-coincident
demands ("NCD"), for both groups of customers.
Load ProfiTe
O. Regarding the load profile for both
the Company initially perform any analyses of
profile of either group?
groups, did
the loadI
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A. Yes. In her direct testimony, Connie A.
Aschenbrenner presented a graph comparing the average
hourly consumption of a customer with on-site generation
to that of a residential customer without on-si-te
generation on June 29, 20L6.2 f have reproduced Ms.
Aschenbrenner's graph as Figure 2.
Figiure 2. Average L,oad Shapes for Residential Standard
Service Customers and Reeidential Net Meter Customers.
O. Does Staff agree with the Company that
eustomers with on-site generation are different than
standard servi-ce customers?
A. No. Dr. Morrison states that "there are no
meaningful differences between net metering and non-net
metering customers in the quantities of electricity used,
differences in conditions of servi.ce, time, nature, and
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CSB REPORTING
(208 ) 890-s198
ANGELL, REB 8
Idaho Power Company
L 2 3 4 5 6 7 8 9 1011L2t3t4 15151718192021222324
Hour Ending
-Residential
Net Metering
-Residential
Standard Service
-1.00
-2.00
4.00
3.00
2.00
1.003.-
0.00
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2 Aschenbrenner DI, p. 28, Figure 3.
CSB REPORTING(208) 890-s198
ANGELL, REB 8A
Idaho Power Company
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CSB REPORTING(208) 890-s198
ANGELL, REB 9
Idaho Power Company
pattern of use."3 Dr. Morrison goes on to say "the
distribution of individual
groups
of both
is nearly i-dentical"
consumptj-on patterns from both
and " Ic] onsumption patterns
. . rr4groups are slmil-ar
O. Do you agree with this assessment that the
consumption patterns of both groups are similar?
A. No. I believe that the two load profi-Ies shown
in Figure 2 above are distinctly different. They are
different for many reasons. The first and most obvious
difference is that an average customer with on-site
generation has negative consumption, meaning that energy
flows to the utility. The second difference is that the
average customer with on-site generation has a higher
demand for energy during the evening and nighttime hours.
The third difference is that the rate of change in usage
by customers with on-site generation during the day is
significantly larger than for customers without on-site
generation.
O. Did Commission Staff study the load patterns of
both groups of customers?
A. Yes. Dr. Morrison of Commission Staff
presented a graph comparJ-ng the consumption patterns of
3 Morrj-son DI, p. 4, 1. 25 - p. 5, 1. 4
4 Morrison DI, p. l-7, 1l-. 2-6o25
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CSB REPORTING
(208 ) B9o-s198
ANGELL, REB 10
Idaho Power Company
average residential customers with on-site generation to
that of a residential customer without on-site
generation. 5
O. Was the graph that Dr. Morrj-son provided
consistent with the graph that
to il-l-ustratein her testimony the hourly consumption of
an average customer with on-site generation compared to
an average customer without on-sj-te generation?
A. Yes. In fact, the values that each plotted
appear to be the same. The only difference between the
two graphs is that Ms. Aschenbrenner created a line chart
and Dr. Morrison created a bar chart. Other than that,
the charts are virtually the same.
O. Did the Company perform additional anal.yses to
study the load profile of both groups of customers?
A. Yes. Because the Company's initial- analysis
focused on a single day, the Company's summer peak day,
the Company performed additional analyses to study the
Ioad profile of both groups over the course of a month.
The Company analyzed all 12 months of 2016 and has shared
the results for a winter month, a sprj-ng month (aIso
representative of faII), and a suflrmer month in Figures 3,
4, and 5 respectively. For the three graphs, each hour
data point is the average for that hour throughout the
month.
Ms. Aschenbrenner included
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Idaho Power Company
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CSB REPORTING
(208 ) 890-s198
ANGELL, REB 11
Idaho Power Company
FigUre 3. ilanuarl 20LG Average HourJ.y Use - I{inter Peak
January Load Profiles
c
Elz
3.50
3,00
2.50
2.00
1.50
1.00
0.50
0.00
t'2 3 4 5 6 7 8 9 1011L2L314 1516171819202t272324
-Residential ffiNetMetering
Figure 4. ApriJ. 2OL5 Averagre HourJ.y Use - Shoulder Monttr
April Load Profiles
2.00
1.50
1.00
0.50
-c
= 0.00
J
-0.s0
-1.00
-1.50
-2.00
723 4 5 6 7 8 910 L9 20 21 22 23 24
-fts5idsjli3l
mNetMetering
Figrure 5. ,fune ?OLG Avera,ge Hourly Use - Sumer Month
June Load Profiles
3.00
2.00
1.00
3J 0.00
L23456789 r.8 19 20 2t 22 23 24
-1.00
-2.00
-fts5i(sn1i6l -
Net Metering
Lt2t3t4L5L6t7
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CSB REPORTING(208) 890-s198
ANGELL, REB L2
Idaho Power Company
O. Do
in Figures 3,
similar?
A. No.Once again, for the reasons I noted
regarding Eigure 2, the load profiles continue to be
different.
O. Please summarize your conclusions of the load
profile analysis.
A. For al-l three months, customers wj-th on-site
generation had a higher demand for energy during the
evening and nighttime hours than customers without
on-site generation and their rate of change in usage
during the day is larger than for customers without
on-site generat j-on.
0. What other dlfferences were discovered in the
analysj-s of the l-oad profiles?
A. The obvi-ous difference is that customers with
on-site generation have negative consumption that is
energy flows to the utility. This represents the amount
of excess energy produced by the customers' on-site
generation. The Company did notice that the amount of
excess generation varies from month to month.
During January, as a cIass, the customers with
on-site generation do not generate excess energy. Of
partj-cuIar interest, the resul-ts for the month of April
you believe the load profiles of each group
4, or 5 are nearly identical or even
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demonstrate that, not only do the customers with on-site
generation generate excess energy, they generate more
CSB REPORTING
(208 ) 890-s198
ANGELL, REB L2A
Idaho Power Company
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excess energy on a per-customer basis than in June. This
Iarge spring excess occurs when the electrical- market is
flooded with excess energy and energy prices are
si-gnificantly depressed. The rate of change j-n usage
during the days in April is greater than during June. It
also comes as no surprise that durj-ng June, customers
with on-site generation do generate excess energy. The
Company noted that, when looking at the entire sufirmer
month, the magnitude of excess energy was larger than
when lookj-ng at the peak day only (as was done in Figure
2).
O. Why is the rate of change significant?
A. As described in my direct testimony, the
Company schedul-es and dispatches generation al-ong with
automatic generation control to bal-ance generation to
l-oad at every instant in time. Maintaining this ba1ance
during high rate of change periods requJ-res more
generation dispatches compared to other s1ower changing
periods. Additionally, the highly economic hydroel-ectrj-c
system is constrained in its ability to balance such
rapid changes due to river flow ramping lj-mits. This
constraj-nt causes the Company to dispatch l-ess economic
resources resulting in higher energy costs for retail
customers.
System-Coincident and Non-Coincident Demands
CSB REPORTING(208) 890-s198
ANGELL, REB 13
Idaho Power Company
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O. You mentioned that an analysis was performed on
the system-coincident and NCDs of residential- customers
CSB REPORTING(208) 890-s198
ANGELL, REB 13a
Idaho Power Company
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with on-site generation and residential customers wj-thout
on-sj-te generation. What analysis did the Company
perform?
A. The Company calculated the 201.6 system-
coincident and NCDs for both groups of customers. The
SCD is the average demand for the customer class at the
tj-me of Idaho Powerrs system peak. The NCD is the
maximum average demand for the customer class regardless
of when it happens. System-coincident and NCDs were
calculated for each month.
O. trilhat did you observe from your analysis of the
SCDs for both groups of customers?
A. The monthly SCD of customers with on-site
generation j-s lower than customers without on-site
generation from April through September; however, it is
higher than customers without on-site generation from
October through March. The monthly SCDs for both groups
of customers are shown in Figure 6.
Figure 5. 20LG Syeta-Coincident Dornds by llonth
System-Coincident Demand
s.00
4.00
3.00
E 2.oo
1.00
(1.00)
May Jun Jul Aug 5ep Oct Nov
m NEM System-Coincident Demandt Residential System-Coincident Demand
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CSB REPORTING
(208 ) 890-51-98
ANGELL, REB L4
Idaho Power Company
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CSB REPORTING
(208 ) 890-sl-98
ANGELL, REB 15
Idaho Power Company
O. Why is the SCD an i-mportant measure when
evaluating whether a segment of customers is different
from their current customer classification?
A. SCDs are used to allocate costs amongst the
Companyrs different customer classes. Ms. Aschenbrenner
explai-ns how costs are allocated using the SCDs.6
O. hlhat observations are drawn from the analysis
of the NCDs for both groups of customers?
A. The NCD of customers with on-sj-te generation is
higher than customers without on-sj-te generation for a1f
12 months of the year. During the winter months, the
non-coincident of customers with on-site generation is
more than 60 percent higher than the NCD of customers
without on-site generation. The NCDs for both groups of
customers are shown in Figure 1.
Fignrre 7. 2016 Non-Coincidsnt Doands by Monttr
Non-Coincident Demand
3L
5,00
4.00
3.00
2.00
1.00 ltl
Sep Oct Nov
ltl
Mar Apr May.la n Feb Jun Jul Aug
I Residential Non-Coincident Demand r NEM Non-Coincident Demand
Dec
6 Aschenbrenner REB, p. L2, I. i-4 through p. 13, I. 2.I 25
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CSB REPORTING(208) 890-s198
ANGELL, REB L6
Idaho Power Company
0.
evaluating
from their
A.
Why is the NCD an important measure when
whether a segment of customers is different
current customer classification?
The non-coincident group peak demand is used to
allocate costs among the Company's different customer
classes. Ms. Aschenbrenner explains costs are allocated
using the non-coincident group peak demand.
O. Did any other parties conduct an analysis of
system-coincident and NCDs for both groups?
A. Yes. Dr. Morrison of Commission Staff
calcul-ated the system-coincident and NCDs for both
groups. T
O. Were the results of Dr. Morrison's study
study?
to his
January 11,
computation,
the results
Dr.
his study
' s study.
Company
analyses.
consistent with the
A. Yes. Dr.
direct testimony on
Morrison's revised
are consistent with
results of the Company's
Morrison fil-ed a revision
0. Pl-ease summarize the
201,8, and with
the results of
of the Company
concl-usions the
has made after having performed these various
A. The resul-ts of additional analyses performed by
the Company demonstrate that the l-oad factor, the load
profile, the SCDs and the NCDs for R&SGS customers wj-th
on-site generation are distinctly different than R&SGS
customers without on-site generation. The Company haso25
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7 Morrison DI, p. 18, 1. 13; p. 19, l-1. 2-4.
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ANGELL, REB 16A
Idaho Power Company
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ANGELL, REB L7
Idaho Power Company
clearly demonstrated that the load service requirement
and the pattern of use are distinctJ-y different for
residential customers with on-site generation as compared
to residential customers wj-thout on-site generation.
]I. UTILIZATION OF THE GRID
1. Impact on the Grid
O. Ms. Donohue claims that "net metering has
minimal grid impacts . . "8 Does the Company agree
with Ms. Donohuers statement?
A. No. Each net metering instal-latj-on has a smal-l-
impact on the voltage management of a distribution
circuit. Low net metering penetration on a circuit is
accommodated without changes to the vol-tage management.
However, large penetration has significant grid impacts
that require mitigation measures and j-s discussed in my
Direct Testimony.
0. Several- witnesses9 assert that the excess
energy generated by customers with on-site generation is
consumed by neighboring loads. Do you agree with this
assertion?
A. In a broad, general sense this is true. The
assertj-on that the exc'ess energy is consumed by
neighboring
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9 Kobor DI, p. 63,11_. 1-8; Otto DI. p. 5,1. 18; Beach DI, p
20, 1t_. 18-19.
CSB REPORTING(208) 890-s198
ANGELL, REB l'l a
Idaho Power Company
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CSB REPORTING
(208 ) 890-s198
Ioads assumes that neighbors are consuming in unison with
the customer's on-site generation excess production.
Figure 4 demonstrates the difference in on-site
generation excess production and consumption of customers
without on-site generation. The 2:00 p.m. hour refl-ects
the customer without on-site generation load at 1 kWh and
the excess on-site generator production at l-.8 kwh.
Therefore, on average, two customers without on-site
generation are required to consume the excess generation
of one customer with on-site generation. When the excess
energy exceeds the neighbors' consumption, which is
1ike1y to occur in the spring and faII months, the excess
flows through the distribution system, and at times, to
the transmj-ssion system.
O. Mr. Leonard c]aims that: "There are also
extremel-y good grid benefits
the distributed energy side
qualitY. "ro Do You agree
A. I agree that some
lowering line losses on
j-ncreasing power
his claim?
losses may be reduced
by
and
with
line
with distributed generation ('rDGrr) as described in the
Company's community sofar
testimony identified that
and
case.11 In that case, my
the transmission, substation,
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Idaho Power Company
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10 Leonard Df, p. 5, ff. 2-3.
lL In the Matter of ldaho Power Company's AppTication to
Approve New Tariff ScheduLe 63, A Community SoTar PiTot Program, Case
No. IPC-E-16-14 .
CSB REPORTING(208) 890-s198
ANGELL, REB 18a
Idaho Power Company
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CSB REPORTING(208) 8e0-s198
ANGELL, REB 19
Idaho Power Company
distribution primary losses would be offset but the
secondary losses will- continue to be present. This
outcome was determined by comparing the load profile of
the customers located near the proposed community solar
project to the projected solar production profile. The
Company determined that local- customer load would consume
the projected solar generation at all times. The
existing DG energy production, forecasted DG production,
DG locations, forecasted DG locations, and annual feeder
l-oad profiles would need to be analyzed to determine the
proper 1j-ne loss a1l-ocation.
I do not agree with the assertion of increased
power quality. Distribution circuit voltage variability
increases with DG, resulting in reduced power quality.
In fact, the Company performs voltage flicker analysis (a
power quality issue) during the small and large generator
interconnection study process when distribution system
interconnection is requested. This condition is
described in Section IV of my direct testimonyr 12 related
to the request for requiring smart j-nverter functionality
in the future and described in the next section of this
testimony.
O. Does on-site generation have a similar impact
when a customer i nstall-s an energyASto the grid
efficiency ("EE'r ) measure?25
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12 Angef 1 Dr, pp. 23-2'7.
CSB REPORTING
(208 ) 890-s198
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ANGELL, REB l_9a
Idaho Power Company
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A. No. The grld impact is different because, when
a customer with on-site generatlon is generating excess
energy, their system can stop generating at any moment.
When this occurs, the Company must instantaneously supply
not only their load that was supplled by their own
generation, but also the excess generation they were
contributing to the system. This change in the direction
of supply wiII also negatively impact the distribution
system voltage.
0. How does an instantaneous loss of supply by the
customer with on-site generation impact the grid?
A. The Company and its grid must always maintain
the balance of generation and 1oad. Vrlhen a loss of
supply from on-site generation occurs, the grid must
supply the customer load and any excess generation that
was being produced. As shown in Figure 4, during the
2:00 p.m. peak export hour, the grid may have to
instantaneously supply the customer energy and excess
generation of greater than 2.8L kwh (assuming 1 kWh or
greater energy consumption by the customer with on-site
generation) .
Additionally, a change in the direction of
supply will- change the cj-rcuit voltage. This resul-ts
from voltage drop the decrease j-n the voltage along a
conductor due to the flow of current through the
CSB REPORTING(208) 890-s198
ANGELL, REB 20
Idaho Power Company
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conductor. The voltage at the current source location
will be higher than other
ANGELL, REB 20a
Idaho Power ComPanY
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CSB REPORTING
(208 ) 890-s198
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locations along the distribution circuit. When a
customer with on-site generation is sourcing current
(exporting energy) to the distributj-on circuit, i-ts
voltage, including its neighbors' voltage, will be higher
than other l-ocations on the circuit due to voltage drop.
Once the customer stops sourci-ng (e.9., when a cloud
passes over the solar panels), the loca1 higher voltage
j-mmediately drops to a lower voltage based on voltage
drop from the substation to the customer location. These
quick changes resul-t in reduced power quality.
O. Several parties compare on-site generation to
8E.13 Some even suggest that on-site generation "wi11
reduce a customer's long-term consumption from the grid,
just as an energy efficiency measure . . "14 Do you
agree that on-site generation reduces a customerrs
long-term consumption from the grid simil-ar to that of an
EE measure?
A. No. On-site generation j-s significantly
different than EE. On-site generation will produce
energy based on the profile of the generating resource.
Solar production varies daily and throughout the year
based on the angle of incidence of the sun to the sol-ar
panels and weather conditions. This sofar production is
not rel-ated
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CSB REPORTING
(208 ) 890-s1 98
ANGELL, REB 27
Idaho Power Company
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DI,
13 Beach DI, p. 11, lf. 7-8; Donohue DI, p. 18, 1I. 2-4; Kobor
p. 50, 1. 20 through p. 51, 1. 1.
14 Beach Df , p. 5 , l-1 . 3-4 .
CSB REPORTING
(208 ) 890-5198
ANGELL, REB 2ta
Idaho Power Company
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CSB REPORTING(208) 890-s198
ANGELL, REB 22Idaho Power Company
to the energy consumed by the customer. EE measures
dlrectly reduce the consumption of the electrical
equj-pment all the time it is operati-ng throughout the
year. When the equipment is running, one can count on EE
occurring. The efficiency does not ramp in and out of
operati-on like a solar generation system.
O. How does the load shape of a customer who
participates in EE compare to that of a customer who
instal-l-s on-site generate on?
A. As discussed by Dr. Ahmad Faruquils of the
Brattle Group in his rebuttal testimony, the load shape
of customers wj-th on-site generation differs
significantly from those of customers who participate in
EE programs. f previously dj-scussed the significance of
the rate of change and how that impacts grid operatj-ons.
The greater the rate of change, the more volatile the
load shape. EE measures may reduce energy use through
the day or just reduce the peak use periods. Either
outcome is not 1ike1y to j-ncrease the load volatility.
This is in contrast to a customer who instal-ls
on-site generation
of the customer's
which would j-ncrease the volatility
load profile. This can be explained by
Iooking
system
at both the level of demand (kW) placed on the
and the amount of energy (kwh) consumed over time.t 25
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CSB REPORTING(208) 890-s198
ANGELL, REB 22a
Idaho Power Company
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CSB REPORTING
(208 ) 890-s198
ANGELL, REB 23
Idaho Power Company
V0hen a customer installs an EE measure to reduce their
energy consumption,
instantaneous demand
they may reduce both the
(kilowatts ("kW") ) that they place
consumed overon the grid
time. This
and reduce the amount of energy
is not the case with a customer who reduces
their energy consumption using on-si-te generation. When
an on-sj-te generation system is not generating, and the
utility is called upon to provide the energy, the
customerrs load requirement is the same as it was before
the on-site generation system was installed. In other
words, there is generally no reduction of the
instantaneous qglrrenq (kW) placed on the utility's system.
The customer with on-site generation does, however,
reduce the amount of energy (kwh) they consume from the
Company but not achieve any reduction in total energy
use.
0. Other than having different impacts on the
grid, what other differences exist between customers who
reduce their energy usage by installing EE measures and
by installing on-site generation?
A. A customer with on-sj-te generation has the
opportunity to net their billed energy all the way to
zero while still utilizing the grid; whereas, a customer
who reduces their energy consumption by installing EE
measures is not
energy from the
abl-e to do that unl-ess they consume no
utility forLhe entire month.o 25
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CSB REPORTING(208) 890-s198
ANGELL, REB 24
Idaho Power Company
O. Did any parties disagree with you in your
assertion that customers wi-th on-site generation who net
their usage to zero are not the same as a vacation home
wj-th no kWh usage in a month?
A. Yes. Commissi-on Staff witness Donohue
disagrees.15 She suggests that, because both groups of
customers are subsidized by other customers, customers
with on-site generation who net their usage to zero are
not different than a vacation home with no kWh usage in a
month.
O. In what ways does the Company assert that a
vacatj-on home with no kWh usage is different than a net
zero customer, a customer who generated either the same
amount or more energy from their system than they
consumed over the course of the month?
A. f n addit j-on to the dif ferences listed by Ms.
Aschenbrenner in her direct testimony, lT
substantial differences in the services that the Company
provides the vacant home and net zero customer over the
course of the month. The Company provides no services to
the vacant home that consumes no energy. However, in
addition to providing energy to the customer with on-site
generation when their system is not generating or is not
there are
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CSB REPORTING(208) 890-s198
ANGELL, REB 24a
Idaho Power Company
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16 Donohue DI, p. 16, 1I. 18-25.
17 Aschenbrenner DI, p. 30, 1. 8. - p. 31. 1. 13.
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CSB REPORTING(208) 890-s198
ANGELL, REB 25Idaho Power Company
generating enough energy to meet their demand, the
Company also provides regulated voltage for i-nverter
operatlon, motor starting current, and energy balancing
when the customer j-s generating electricity.
2. Excess Generation
O. Ms. Donohue suggests that "most of the energy
produced [by net metering customers] is consumed on-site
rather than pushed back onto the gtrid. "te Does the
Company agree that most of the energy produced by
customers with on-sj-te generatj-on is consumed on-site
rather than flowing back onto the grid?
A. Yes. However, the Company performed an
analysis to quantify how much energy generated from
residential- on-site generation flowed onto the grid.
Figure 9 provides the monthly net consumptj-on and the
excess generation produced by the 565 net metering
customers who had 12 months of billing data during 20L6.
The graph also includes the monthly percentage of excess
generation as compare to the net consumption. As you can
see, there are months when the residential customers with
on-site generation generated in excess of 60 percent of
their net consumption.
18 Donohue DI, p. 7, l-1. 8-9.I 25
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CSB REPORTING(208) 890-sL98
ANGELL, REB 26
Idaho Power Company
Figure 9. ?OLG Net Consurption and Excess Generation
20L5 Residential Net Consumption and Excess Generation
1,400
L,20O
1,000
800
500
400
200
.tr
3E
II
Jan Feb
.l
+r
BJ
&,1f.t
ru
IH ililililJilJ
Apr May Jun Jul Aug Sept OctMar Nov Dec
I Excess Generation n Consumption Percentage Net Consumption
O. How much excess generation does the average
residentiaL customer with on-site generation exchange
with the grid each month?
A. The Companyrs analysj-s shows that, in January
and December, the average resldential customer with
on-site generation consumes most of their generation and
has very little excess generation; however, for the
remaining months, particularly April through September,
customers have anywhere from 678 to 11 005 kWh of excess
generation per month. Table 2 lists the average excess
generation produced by a residential customer with
on-sj-te generation, by month.o 25
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CSB REPORTING
(208 ) 890-s198
ANGELL, REB 27
Idaho Power Company
Tab1e 2. Average Monthly Excess Generation per Customer
Month Average ExcessGeneration (kllh)
January
Eebruary
MarchApril
May
June
July
August
September
October
November
December
0
336
480
1, 005
936
773
678
693
759
321
161
0
3. Net Zero Customers
0. Ms. Donohue references Dr. Morrison's analysis
showing that only about 11.5 percent of customers with
on-site generation are net zero.l9 Do you agree with the
results of his analysis?
A. I agree that on an annuaf basis, there are
approximately 11.5 percent of customers with on-site
generation who are net zero; however, that number does
not represent the number of customers with on-site
generation who are nearly net zero or who are net zero on
a monthl-y basis.
O. Has the Company performed an analysi-s of the
number of customers with on-site generation who are net
zero on a monthly basis?
19 Donohue DI, p. 79, -l-1. 4-7.25
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CSB REPORTING
(208 ) 890-5198
ANGELL, REB 28
Idaho Power Company
A. Yes. Using the same 20L6 dataset for the 565
residential net metering customers who had L2 months of
billing data during 20L6, the Company calculated that,
for three of the L2 months, more than 40 percent of
customers with on-site generation netted their usage to
zero and for an additional four months, more than 30
percent of customers with on-sj-te generation netted their
usage to zexo. Figure 10 shows the percentages of net
zero customers for each month.
Figure 10. Percent of, Net Zero CuetoBers b1'Month in 2016
Percent of Net Zero NEM Customers
(by month)
IO0o/o
90%
80%
70%
60%
50%llll
May Jun Jul Aug 5ep
F].or is Distinct to Custonsrs ritlr On-Site
O. Do any parties disagree with your assertion
that customers with on-site generation have a two-way
rel-ationship with the grid?
40%
30%
20%
L0%
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I
Feb Mar Apr
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A. Yes. Ms. Levin of SRA/NW Energy suggests that:
"With advanced metering infrastructure ("AMI"), any
customer can have a two-way relationship with the grid.
ANGELL, REB 28a
Idaho Power Company
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CSB REPORTTNG(208) 890-s198
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CSB REPORTING
(208 ) 890-s198
ANGELL, REB 29
Idaho Power Company
AMI al-l-ows all customers,and any of their "smart"
fol-low and track customer(grid-enabled) devices, to
usage, system conditions, and energy prices and respond
to this information . ."20
O. Do you agree with Ms. Levj-n that this "two-way"
flow of j-nformatlon is the same as the "two-way" fl-ow of
energy?
A. No. AMI allows the utility two-way
communicatj-on with customer meters and, depending on the
technol-ogy deployed, may provide the customer with
informatj-on as Ms. Levj-n described. The customer may
even act based on the information provided. However, the
customer is not in a two-way relationship with the grid.
The customer is simply making informed energy use choj-ces
that may decrease or increase their demand. This is not
at al-l- similar to the production of energy by R&SGS
customers with on-sj-te generation whose production is
driven by daily solar irradiance, not information that
might be provided by an electric utility.
O. Do any other parties disagree with you that
customers with on-site generation use the grid in a
bi-directional- manner?
A. Yes. Sierra Club witness Mr. Beach suggests
that the Company's
lWl hen a
thinking is flawed. He claims that:
solar customer exports power to theI25
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utility, it i-s the solar customer
20 Levin DI, p. 4, 11. 13-16 (emphasis in original)
CSB REPORTING
(208 ) 890-s198
ANGELL, REB 29aIdaho Power Company
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CSB REPORTING(208) 890-s198
ANGELL, REB 30
fdaho Power Company
that is providing a service - generation tothe utility. Once the exported power passesthe DG customer's meter, the util-ity takestitle to the exported power.It j-s the utilitythat delivers the exported DG power to the DGcustomer's neighbors. It is the utility thatis compensated by the neighbors for the servicethat the utility provides in delj-vering the DGexports to them. Thus, it is the utility andthe neighboring customer that use thedistribution system to del-iver the DG exports.
The DG customer is in no way responsibl-e forthe del-ivery of their exported power, has nocontrol over who receives their exports, andrecej-ves no compensation for the delivery ofthe exports.2l
0. Do you agree with Mr. Beach that it is the
utility that is utilizing the grj-d when a solar customer
exports power to the utility?
A. Mr. Beach is correct in the DG customer has no
responsj-bility for the grid or the delivery of energy
through the grid. However, the DG customer relies on the
grid voltage for the inverter to produce alternating
current for the export of energy and the grid's ability
to receive and distribute this energy to other loads
while maintaining a balance between energy and l-oad.
grid in aFurther, my statement of "uses the
bi_directional manner,,22 pertains
to receive power from the grid and
grid at any time, collectively
simply to the ability
supply power to the
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omitted) .
20, 11. I5-24 (emphasis in original) (footnote
22 Ange1l Dl, p. 10, 11. 22-23.
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CSB REPORTING(208) 890-s198
ANGELL, REB 30a
Idaho Power Company
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referred to as "exchange. " The R&SGS customers with
on-sj-te generation exchange more energy with the grld
than a R&SGS standard service customer.
O. Did the Company perform analysis to assess when
R&SGS customers with on-site generation exchange more
energy with the grid?
A. Yes. The Company analyzed the hourly exchange
for al-1 565 net meteri-ng customers who had 12 months of
billing data during 2016 and compared that to the
exchange of the residential customers without on-site
generati-on. The Company analyzed all 12 months of 2076
and has shared the resul-ts for a winter month, a spring
month (also representative of falI), and a summer month
in Figures lL, 12, and 13 respectively. For the three
graphs, each hour data point is the average of the
abso1ute value for that hour throughout the month. The
absolute value of each hour captures the amount of the
energy exchange, regardless of which direction the energy
is flowing.
A comparison of Figures 11, 12, and 13 with
Eigures 3, 4, and 5, respectively, reveal the export of
energy during the daylight hours when net metering
customers are exporting to the grj-d. The net metering
customers on average are consistently exchanging more
energy with the grid every hour of each month. This
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ANGELL, REB 31
Idaho Power Company
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energy exchange, when combined with their lower l-oad
factor, results in less efficient use of grid capacity.
CSB REPORTING(208) 890-5198
ANGELL, REB 3la
Idaho Power Company
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CSB REPORTING(208) 890-s198
ANGELL, REB 32
Idaho Power Company
Figrure 11. ilanuary 20LG Average Hourly Energy Exchange
January Average Energy Exchange
3-:z
3.s0
3.00
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0.00
6 10
ilililililt
1 2 3 4 5 7 8 9 tt t2 L3 14 15 16 17 18 19 20 2L 22 23 24
I Residential s Net Metered
Figure 12. ApriJ. 2OLG Average HourJ.y Energy Exchange
April Average Energy Exchange
3.00
2.50
2,00
ilmilil
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ilJl
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! r.so
ilililililil
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r Residential tr Net Metered
Figure 13. ,June 2OtG Avera,ge Hour1y Energy Exchange
June Average Energy Exchange
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2.00
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ilil
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1.00
0.50
0.00 ilililil
3455L2 7 10 11 12 13 14 15 1,6 L7 18 t9 20 2t 22 23 24
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CSB REPORTING(208) 890-s198
ANGELL, REB 33
Idaho Power Company
O. Did Mr. Beach conduct any analyses to support
his argument that it is not the customer with on-site
generation that is utj-lizing the grid when generating
excess energy?
A. No. However, Mr. Beach describes a study to
determj-ne the distribution benefits provided by DG. The
study calcul-ated a peak capacity allocation factor for 12
substations' 20L6 loads and combined this factor with two
Boj-se solar profiles. The study concludes that 0.22 kW
and 0.31- kW of marginal distribution capacity costs can
be avoided by one kW of south-facing and west-faci-ng
sol-ar DG, respectivel-y. 23
O. Do you agree with Mr. Beach's conclusions from
this analysis?
A. No. Mr. Beach' s concl-usion of margJ-na1
distribution capacity costs avoidance from DG sol-ar is
j-nconsistent with the Company provided substatj-on
capacity and 201-6 l-oad data. I believe this is due to
the generalized summatj-on approach used within the study
which discounts the capacity and l-oading of a single
substation. Eor example, the L2 substations' 20!6
non-coincident peak Ioad hours are only 70 percent of the
total instal-led
23 Beach DI, p. 30, 1. 14 - p. 31, I. 2O25
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capacity. Based on this, one could conclude that no
capacity additions are required.
Analysis of the load data of each substation
reveals specifics that are lost in the generalized
approach of the study. Six of the 72 substations serve
predominately irrigation customers who have a consistent
2A-hour l-oad profile during the irrigation season. Two
of the substations supply winter peaking loads. Based on
the Company's and the electric utility J-ndustry's
experience with solar and battery DG technology, eight of
the t2 substation capacity upgrades would not be avoided
by solar DG or sol-ar with battery DG. First solar DG
cannot provide power to suppJ-y irrigation load through
the night nor supply the winter morning peak loads of the
winter peaking substations. Additionally, solar combined
with batteries is not an economically viable option to
supply l-oads lasting more than four hours based on
present and near-term battery technology.
Mr. Beachrs generalized approach 1ikeIy
overstates the realizable capacity avoidance. It shoul-d
also be noted that the discussion regarding the value of
DG is beyond the scope of this docket. fn Order No.
33946, the Commission denied ICEA's alternate
recommendation to decide the val-ue of DG prior to
addressing reclassification of R&SGS
CSB REPORTING(208) 890-s198
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ANGELL, REB 34
Idaho Power Company
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CSB REPORTING(208) 890-s198
ANGELL, REB 35
Idaho Power Company
customers with
requested that
the conc]usion
utilities can
on-site generation.
the Commission open
of this case where
Idaho Power has
a generic docket at
stakeholders and other
col-l-aborate to assess the benefits and
costs
Beach
that DG brings
. Were there
that you would
. Yes. Mr.
u
A
to the electric system.
any other suggestions made by Mr.
Iike to address?
Beach mi-scharacterized a statement
from my direct testimony. Mr. Beach cl-aimed that I
asserted:
resuJ-ting
limited to five-year period
is outside the
any distribution benefits wil-l- be limited tothe five-year period in which Idaho Power plans
distribution upgrades and expansions. "24
To clarify, the statement f made was
"fdaho Power is able to forecast distributioncircuit and substation capacity requj-rementswith some certainty five years into the
future. This planning horizon period allows
the Company to investigate options to avoid
facility overloads, sel-ect more cost-effectiveoptions, and design and construct improvementsto meet the identified overloads.2s
I did not suggest that distribution benefits
from customers with on-site generatj-on will- be
as such benefit
scope of this docket.
a
determination
24 Beach Dr, p. 27, 1I. 24-25.
25 Angelf Dr, p. 18, 11. 4-10.o 25
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CSB REPORT]NG(208) 890-s198
ANGELL, REB 36Idaho Power Company
O. Please summarize the impact that customer
on-site generatj-on has on the grid.
A. Customer on-site generation is not like EE.
The grid must be able to absorb excess generation when
supplied, supply the customerrs load, and replace the
excess generation when ca1Ied upon, all whil-e minj-mizLng
distribution circuit voltage variabil-ity to maintain
customer power quality.
III. MODIFICATIONS TO SCEEDVT.E 72
1. Smart Invegler Requirement
O. Do parties support the Company's proposal to
require all new net metering customers to use smart
inverters within 60 days followj-ng the adoption of an
industry standard definition of smart i-nverters as
defined by the IEEE?
A. In general, yes. Mr. Otto of ICL recommends
the Commission approve Idaho Power's request to require
smart inverters according to industry standard
definitions.26
O. Do any parties oppose the Company's proposal to
require aII new net metering customers to use smart
inverters within 60 days following the adoptlon of an
26 otto Dr, p. 10, 11. 14-15.e 25
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industry standard definition of smart inverters as
defined by the IEEE?
A. Yes. Staff witness Dr. Morrison opposes the
Company's proposed smart inverter requirement.
O. Why does Dr. Morrison oppose the smart inverter
requi-rement for all- new net metering customers?
A. Dr. Morrison states that, "the Company is
requesting that Commission adopt IEEE 1547 and IEEE
l.547.1 before these standards have been rel-eased"2? and
the Company "didnrt provide any hard information about
ei-ther of the proposed smart meter Iinverter]
standards. "28
O. Will the Commission and Staff have the
opportunity to review the IEEE 1,547 and IEEE 1,547 .L
standards before approving them?
A. Yes. The Company's request regarding the
inverter requirement was that the Commission order the
Company to subm'it a compliance filing in the form of a
tariff advice within 60 days of the adoption of the
revi-sed IEEE standards, or 60 days of the concl-usion of
this case, whi-chever occurs later. This tariff advice
wil-1 seek to modify its interconnection tariff to require
that customers with on-site generation install a smart
inverter that meets the requirements defined j-n the
revised IEEE standards.
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ANGELL, REB 37
Idaho Power Company
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27 Morrison DI, p. 20, 11. 16-18.
28 Morrison DI, p. 21, 11. 1,-2.
ANGELL, REB 37A
Idaho Power Company
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CSB REPORT]NG(208) 890-s198
ANGELL, REB 38
Idaho Power Company
The Commission and Staff would have the opportunity to
review the standard in the tariff advice filing.
O. Should the current l-ack of a defined standard
by IEEE prevent the Commission from adopting the
Company's inverter proposal?
A. No. The current l-ack of a defined standard by
IEEE should not prevent the Commission from acknowl-edging
that smart inverters provide functionality that is
necessary to support the ongolng stabil-ity and
reliability of the distribution system and that the
industry adoption of a smart inverter requirement wil-l-
help mltigate circuit voltage deviation.
2. Other Minor Revisions to Schedu].e 72
O. The Company has requested to modify Schedule 72
as part of this case. Do any parties object to the
proposed changes to Schedule 72?
A. Yes. Staff witness Dr. Morrison states that
the Company's proposed modifications to Schedule 72 are
not minor and would constitute a major revision to the
tariff. He goes on to suggest that "the Company's
proposed modifj-cations to Schedule 72 go far beyond the
scope of its application . .w29
0. Do you agree with Dr. Morrison's suggestion
that the proposed revisions are major?
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29 Morrison DI, p. 2.7, 11 . 20-22 .
ANGELL, REB 38a
Idaho Power Company
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CSB REPORTING
(208 ) 890-5198
ANGELL, REB 39
Idaho Power Company
A. No. The proposed revj-sions to Schedul-e 12 are
Most of the revisi-ons to Schedul-e 72in fact very minor.
are to incorporate
the i-nterconnection
the defined terms necessary to
requlrements between Schedule
the newl-y proposed
minor revision to a1low the Company additional time to
complete the on-site inspection of a newly installed
on-site generation system when circumstances beyond the
Company's control arise (e.9., large snowfall). If the
addition of proposed Schedules 6 and 8 were removed,
there is only one revision under Section 2, step 5. A11
other revisions are due to the addition of proposed
schedules 6 and B. None of the proposed revj-sions affect
any other energy providers who are subject to Schedule
72.
rv. coNcLusroN
O. Please summarize your rebuttal testj-mony.
A. In response to the direct testj-mony of other
witnesses, I have explained in detail the additional-
analyses performed by the Company. The Company provided
additional analyses in the foll-owing areas:
' Customers with on-site generation are partial
requi-rements customers and therefore thej-r l-oad
service requirements are different than ful-l
requirements customers.
Schedul-es 6 and B and to make
sync
72 and
one
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' The l-oad profile of customers with on-site
generation is distinct from the load profile of
customers without on-site generation.
' The rate of change j-n usage by customers wlth
on-site generatio, auri.rg the day is
significantly larger than customers without
on-site generation.
' Customers with on-sj-te generation have notably
Iower load factors than customers without
on-site generatlon.
' The system-coincident and NCDs for customers
with on-sj-te generation are different than
customers without on-site generation.
In summary, the results of additional analyses
performed by the Company demonstrate that the l-oad
factor, the load profJ-1e, the SCDs and the NCDs for R&SGS
customers with on-site generation are distinctly
different than R&SGS customers without on-site
generation. The Company has clearly demonstrated that the
load service requirements, and the pattern of use, are
distinctly different for resldential customers with
on-site generation as compared to residential customers
without on-site generation. I have explained that the
two-way flow of energy ls dlstinct to customers with
CSB REPORTING(208) 890-s198
ANGELL, REB 40
Idaho Power Company
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on-site generation and have also explained the limited
revisions to and the processscope of
CSB REPORTING(208) 890-5198
ANGELL, REB 40a
Idaho Power Company
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CSB REPORTING(208) 890-s198
ANGELL, REB 47
Idaho Power Company
of approving the proposed revisions to Schedu1e 72 and
smart inverter requirement.
O. What is your recommendation for the Commission?
A. I recommend that the Commission issue an order
to establ-ish two new classifi-cations of customers
applicable to R&SGS customers with on-site generation, to
approve the proposed revisions to Schedule 72, and to
acknowledge that smart inverters provj-de functj-onality
that is necessary to support the ongoing reliability of
the distribution system by ordering the Company to amend
its applicable tariff schedules to require the
installation and operation of smart inverters for all new
customer-owned generator i-nterconnections within 60 days
adoption of an industry standard definition
inverters as defined by the IEEE.
your testimony?
A. Yes, it does.
following
of smart
the
o.Does this conclude
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CSB REPORTING
(208 ) 890-s198
ANGELL, SURR REB 1
Idaho Power Company
O. Pl-ease state your name.
A. My name is David M. Ange11.
O. Are you the same David M. Angell that
previously presented direct and rebuttal- testimony?
A. Yes.
O. What is the purpose of your surrebuttal
testimony?
A. The purpose of my surrebuttal- testimony is to
respond to Idaho Clean Energy Association's witness Kevin
Kingrs recommendation to wait to make changes to the net
metering service until the total nameplate capacity of
residential solar net metering reaches 50 megawatts
("MW" ) .
O. Pl-ease summarize the recommendation made by
Mr. King related to the 60 MW namepJ-ate capacity of
resj-dential sofar net metering.
A. In his rebuttal testimony, Mr. King recommends,
"That any changes to net meteri-ng rate policy should not
go into effect until after the total nameplate capacity
of net metering residential solar reaches a benchmark
level of 60MW. "1
Wheno.
Company
nameplate
metering?
would you
Powertt or( " Idaho
capacity of 60
estimate that Idaho Power
"Company") would reach a total
MW for residenti-al- solar net
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CSB REPORTING(208) 890-s198
ANGELL, SURR REB 1A
Idaho Power Company
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CSB REPORTING
(208 ) 890-s198
ANGELL, SURR REB 2Idaho Power Company
A. I believe that Idaho Power will reach a total
nameplate capacity of 60 MW for resj-dential solar net
meterlng in 2020. When considering the likely year or
more it would take for multiple utilities and
stakeholders to coalesce on the costs and benefits of
distributed generation ("DG") in a general docket, I
believe that by the time this case and a general docket
are concluded and j-mplemented, the Company will be
nearing a cumul-ative 60 MW of residential solar net
metering installations and applications.
O. How were you able to conclude that the total
nameplate capacity for residential- solar net metering
will- reach 60 MW in 2020?
A. To estimate when the instal-l-ed capacity for
residential solar net meterlng might reach 60 MW, the
Company applied a fourth order polynomial curve fit to
the cumulatj-ve installed capacity of active and pending
residential solar install-ations from 20L2 to January 31,
2018. As shown in Eigure 7,
after January 2020 but before
the trend line reached 50 MW
July 2020.
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CSB REPORTING(208) 890-s198
ANGELL, SURR REB 3
Idaho Power Company
Figure 1. Trend Line for Idalro Residcntial. SoJ,ar Capacity
80,000
70,000
50,000
s0,000
! +o,ooo
30,000
20,000
10,000
0
"p-t*tpt""tp*tp{"*1"r","*t"rt,t"r"."*{Date
O. Do you agree with Mr. King's recommendation to
waj-t to make changes to the net metering rate policy,
including the requirement for smart inverters, until the
total nameplate capacity of net meterlng residential
solar reaches 60 MW?
A. No. There is no need to set an arbj-trary
capaci-ty threshold. f believe that by the time this case
and a general docket would be concluded and implemented,
the Company will be nearing a cumulative 60 MW of
residential solar net metering installations and
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CSB REPORTING(208) 890-s198
ANGELL, SURR REB 4
Idaho Power Company
O. What
waiting to make
inverters until
would the operational consequences be of
changes to the requirement for smart
metering residential solar
nameplate capacity of net
reaches 60 MW?
A. The Company has determined that, without the
impacts may result on
distribution circuit
smart inverter requj-rement, voltage
certain distribution circults due to
DG penetration prior to reaching 60 MW of net metering
residential solar. Voltage impacts would be identified
during the study of additional DG installation and would
requj-re customer-funded mitigation before the DG coul-d be
i-nstal-Ied and operated.
O. How did the Company determine that there would
be voltage impacts on certain circuits without the smart
inverter requirement?
A. A hosting capacity calcul-ation program
developed by E1ectric Power Research Institute ("EPRI")
and named Distribution Resource Integration and Value
Estimation Tool- ("DRfVE") was used for this analysis.
Six high DG penetration distribution circuits were
model-ed in DRIVE. These models incl-uded customer load,
customer generati-on, and Idaho Power voltage management
devices. The voltage threshol-ds were set at Amerj-can
National- Standard Institute (ANSI) C84.L, ELectric Power
Systems and Equipment-VoLtage Ranges, Range A tol-erances
of plus or
the total
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minus 5 percent. The program identified the DG capacJ-ty
which caused a voltage threshold to be exceeded due to
addition of DG on the circuit. Simul-ations were run with
standard inverters and with smart inverters, conforming
to the proposed TEEE-1547 standard, to determine the
remaj-ning hosting capacity under each scenario.
O. What were the resu1ts from the analysis of the
two cases?
A. Two-thirds of the distributi-on circuits
analyzed would be able to host more DG if smart j-nverters
are installed with reactj-ve support capabiJ-ity enabled.
Without the ald of smart inverters and assumlng the high
DG penetration circuits continue to maintain their high
ratio of installations relative to other circuj-ts, four
of the six circuj-ts would be limited before the proposed
60 MW system threshold is reached.
O. What was the condition that limited the hosting
capacity on these distribution circuits?
A. The condition was that the localized high
voltage conditions exceeded 1-05 percent of nominal
voltage. This condition occurs when one or more
inverters are sourcing power into the distribution
circuit during periods of l-ow customer energy usage.
O. How wiII the requirement of smart inverters
mi-tigate these impacts to the grid?
CSB REPORTING(208) 890-s198
ANGELL, SURR REB 5
Idaho Power Company
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CSB REPORTING
(208 ) 890-s198
ANGELL, SURR REB 6Idaho Power Company
A. The smart inverters with voltage control
localized hiqh voltageenabled woul-d mitigate
conditions as described on page 23 of my direct
testimony.
O. fn your
cost differential
direct testimony, you stated that the
between a smart inverter and a standard
inverter for a 61 000 watt system was $720.2 Is that
stiII true today?
A. Research performed by the Company suggests that
it is no longer accurate. The Company's research shows
that smart inverters are becoming prevalent and most
solar inverter manufacturers only offer smart inverter
functionality. Of net metering applications received by
the Company during the last year, 98 percent of the
applications identified inverter manufacturers which
offer smart inverter functionality as a standard feature
of their product. This would suggest that there is not
necessarily an "additional" cost for a smart j-nverter,
but rather the smart inverter is commonly incl-uded as a
standard feature.
0. Why is it necessary to have a tariff
requirement for smart inverter functionality if most
manufacturers only offer smart inverters functionality?
A. When a smart inverter is installed, the smart
inverter functionality can be disabled. A tariff
these
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ANGELL, SURR REB 6A
Idaho Power Company
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requirement would ensure that smart inverter
functionality is enabled for all instal-lations.
O. Please summarize your surrebuttal testimony.
A. The Company has demonstrated that delaying
changes to the net metering rate policy, including the
implementation of the requirement for smart inverters,
based on an arbitrary capacity threshold will- negatively
impact customers' ability to instal-l- DG on the
distribution circuits where their neighbors have already
installed DG.
O. Does this conclude your testimony?
A. Yes, it does.
CSB REPORTING
(208 ) 890-s198
ANGELL, SURR REB 7
Idaho Power Company
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CSB REPORTING(208) 890-s198
ANGELL
Idaho Power Company
(The fol-Iowing proceedings were had in
open hearing. )
MS. NORDSTROM: I present this witness for
cross-examination.
COMMISSIONER RAPER: We will- start with
Ms. Germaine.
MS. GERMAINE: No questions at this time.
Thank you.
COMMISSIONER RAPER: Mr. Carter.
MR. CARTER: I don't have any questions
either.
COMMISSIONER RAPER: Mr. Hammond.
MR. HAMMOND: No questions. Thank you for
being here, though. I appreciate it.
COMMISSIONER RAPER: Mr. Nykiel.
MR. NYKIEL: No questions. Thanks.
COMMTSSIONER RAPER: Ms. Nunez.
MS. NUNEZ: No questions.
COMMISS]ONER RAPER: ATe
Thank you.
you going to
break a streak?
MR. COSTELLO: I'm going to break a
streak. I have a few questions.
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CSB REPORTING(208) 890-s198
ANGELL (X)
Idaho Power Company
CROSS-EXAMINATION
BY MR. COSTELLO:
O First, I just wanted to talk a bit about
the IEEE standards, L547 and 7547.\.
A That would be just fine.
O Are you famil-iar?
A Yes.
O So the Company i-s asking the Commission to
acknowledge certain sort of benefits and technological
aspects of smart inverter technology, is that correct,
just in a general sense?
A Yes.
O But the standards or specifications that
are developed from are comj-ng from
been, actually hasn't been,
correct ?
these recommendations
a standard that hasn't
refeased yet; is that
A Released would be a correct word. The
standard has been approved.
O Irm sorry?
A The standard has been approved.
be avail-abl-e for
It was
approved in February.
publication, right now
April.
it's forecasted to be out in
It will
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CSB REPORTING
(208 ) 890-s198
ANGELL (X)
Idaho Power Company
standard 1541 and 1541.1?
A No, thatrs 1547. 1547.L is stil-l in
process.
O We11, regardl-ess, w€ don ' t have those
standards j-n front of us today, do we, and the Commj-ssion
doesn't elther?
A You do not and the Commission does not;
however, through discovery, the details of those
standards were provided j-n a PowerPoint presentation and
they are essentially the same.
O But wouldn't you
ask the Commi-ssion
say it's slightly
and Staff and thepremature to
intervenors to sort of grapp1e with standards that they
can't actually
the Company --
A
recognition by
servi-ce advice
and
physically analyze and what woul-d prevent
go ahead and answer that.
Wel-l, again, what we're askj-ng for is for
the Commission that we would provide a
when that second standard is approved and
at that point in time, the Commissionpublished,
Staff will have an opportunity to review that and these
are standards that are developed nationally and are
prudent utility practices is the way I l-ook at them.
O Thank you.
A So presently Schedule 72 sets forth the
requirements for interconnection and j-n thoset25
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CSB REPORTING
(208 ) 890-s198
ANGELL (X)
Idaho Power Company
requirements for interconnectj-on today, Schedule 72
references IEEE L547 and all- we're saying is that we want
to make sure that the Commission understands that once
this second -- once this new standard is approved, that
is the standard that is being referenced from in t541
O f appreciate that.
A in the existing schedule.
O But the one that is referenced in the
schedule does not include the smart inverter technology
specifications, the new smart inverter specifications; is
that correct?
A Do you have a copy of Schedule 72 in front
of you?
O WeIl, J-et me just ask you one last
question. When the standards are released, what would
prevent the Company from submitting the actual
specifications for analysis by intervenors and Staff?
A Oh, yeah, the publication itself is
copyrighted, so I would expect what we could do is notify
Staff and al-I intervenors of the ability to go out and
purchase that standard. I rm not sure that the Company
would go and purchase the standards for everyone, but I
suppose
be the
we coul-d if the Commission so thought that would
right
0
thing to do.
Thank you; so next I'd like to tal-k just ao25
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bit about grid utilization. We talked a little bit
before, I think with Mr. Tatum, about that connecti-on
between the on-site generator and the grid, so the basis
for that connection is the definition of paral1e1; is
that correct?
A Paral-lel operation
a Yes.
A of an on-site generation with Idaho
Power's system, yes.
O Okay; so para1Ie1 connection means
generating electricity from an on-site generation system
that is connected to and receives voltage from Idaho
Power's system; is that correct?
A Essentially, yes.
O Okay, thank you, and so j-n parallel
doesn't rea11y have to incl-ude pushing power back on to
the grid; is that correct?
A No, that is correct. It does not have
to.
O Okay; so we spoke a l-ittle bit about
battery storage and the Commissioners had some questions
about this as wellr so if a customer had, let's sdy, a
grid-tie inverter, I know there was some discovery about
this, a grid-tie limiter, I'm sorry, thank you, and so
there was no actua-I functional capability of pushing
CSB REPORTING
(208 ) 890-s198
ANGELL (X)
Idaho Power Company
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energy back on to the grid, you would still- recommend
that that customer be in Schedul-e 6 or B; is that
correct?
A That is correct. I would recommend that a
grid -- a paralIel-operated on-site generation with a
grid-tie limiter woul-d stil1 be within the schedule.
A why?
A Very good, I'm glad you asked that
question. The reason is that as our case has stated and
in my testimony, these customers are essentially partial
requirements customers, so they are dependent upon the
Idaho Power system for essentially backup supply and such
that when that inverter is off-line for any reason, as
far as any kind of production, local- production, that
Idaho Power's system is balancing for that every minute
of the day.
O So they have no capability of pushing
energy back on to the grid, but you're saying because
when they need it, they can pul1 from the grid?
A They can puII from the grid at any point
in time and they do, yes.
A And they should be classified with all
other bi-directional customers?
A Yes.
O Thank you. Just a couple more questions.
CSB REPORTING
(208 ) 890-s198
ANGELL (X)
Idaho Power Company
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CSB REPORTING(208) 890-s198
ANGELL (X)
Idaho Power Company
So as far as load factor, generally
does not use l-oad factor in its cost
speakj-ng, the Company
of service
methodology for
correct?
A
cost assignment purposes; is that
Cost assignment sort of discussions would
have been better addressed by Ms. Aschenbrenner.
O Okay; so are you generally aware of
whether Ioad factor, and you conducted an anal-ysis on
load factor, whether that is then used by Ms.
Aschenbrenner for cost assignment?
A We1I, f can tel1 you that load factor is
used by the Company to identify and explain the impact of
rate designs based on a customer and their usage.
O Have you ever seen, in your experj-ence
have you ever seen, a rate cl-ass, not a pilot program or
anything like that, established using purely
non-cost-based rationale?
A Again, I would recommend that you ask any
of questions to Ms. Aschenbrennerof those type
o
A
o
don't.
one last question; so
coincident peak, you
in your
stated that
You don't have an answer for that?
No, I
Just
totestimony related
system coincident
by the Company to
peak and non-coincident peak are used
allocate cost to serve.25
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CSB REPORTING(208) 890-s198
ANGELL (X)
Idaho Power Company
A That is correct, and if you read further
on, it states that Ms. Aschenbrenner would provide more
details on that in her testJ-mony.
O Well, it's in your testimony; so just one
last question, but in this docket, the Company didn't
actually use system coj-ncident peak or non-coincident
peak to allocate costs to net meterers; is that correct?
A There has not been a cost allocation
determination. That would be the next phase, one of the
next phases, in thj-s proceedj-ng.
MR. COSTELLO: Thank you. That's all I
have.
COMMISSIONER RAPER: Mr. Bender, here's
your opportunity.
CROSS-EXAMTNATION
BY MR. BENDER:
O Good afte::noon. I have a f ew questions
efse. Yourfor you that I previously tried with somebody
testimony, Iooking at your rebutta], you point
service and pattern of use as the criterj-a to
this case to determine whether customers with generation
are different from their current classification; is that
right?
to load
evaluate in
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CSB REPORT]NG
(208 ) 890-s198
ANGELL (X)
Idaho Power Company
rebuttal, you
customers with
Fair enough.
Okay, and in your direct
do various comparisons of
generation and customers
l_n
and your
loads between
or the class as a
A
o
whol-e; is that right?
A Yeah, w€ have the direct, j-t was
then in our rebuttal,andlookj-ng
we took
yes.
at a single customer,
and looked at multiple customers in months,
O Letrs do it in that order. Can you turn
to page 12 in your direct?
A I'm ready.
O Okay, Flgure 1, as I understand it, this
fj-gure is representing what you call using or util-izLng
the grid by various or two different example
customersi is that right?
A Sure, that woufd be usage of the grj-d,
yes.
O And this j-s f or two residential- customers.
It characterizes one with net metering and l-ike a
neighbor who does not
A
O
That is
have net metering; is that right?
correct.
and so in the chart, the blue line
net metering, the red bars are the
metering; rlght?
Okay,
withis the neighbor
neighbor without nett25
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CSB REPORTING(208) 890-s198
ANGELL (X)
Idaho Power Company
A That is correct.
O And so on this you show the customer with
a net metering system havi-ng a lower use of
Company-supplied, grid-supplied, electricity during each
of the 24 hours, except for hour 20 where it was slightly
higher?
A That is correct.
O Then you also show in the hours, I think,
9 through 15 exports for those hours?
A That is correct.
O And in the Company's analysis, exports
count as l-oads for customer utilization of the grid; is
that fai-r?
A I would not say
a
A
O
A
Okay, how do you
How do I define
Yeah.
an export is a load.
define a load?
load?
Yeah, l-oad woul-d be any device that
consumes energy.
O So itrs consumption behind the meter,
thatrs the load?
A Yes.
a And load served by the Company is devices
behind the meter consuming electricity l-ess any provided
by the rooftop solar system also behind the meter?o 25
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CSB REPORTING(208) 890-s198
ANGELL (X)
Idaho Power Company
A Yes.
O So Company-served l-oad is the net delivery
to the net metered customer?
A Yes, under the net load.
using our bil-ling data from -- weIl, in
using billing data. In some cases we're
Advanced Metering Infrastructure, hourly
time and that's a 24-hour
to this graph, any of the
nature, I woul-d call that
the red line there, that
having only load.
Again, we I re
some cases wetre
uslng our AMI,
data.
d"y, and so if I was to speak
bars that are positive in
customer load and, obviously,
is the traditional customers
o
okay? Looking
A
the blue
graph.
vertical
negative
I'm just getting
back at Eigure 1
Yes.
your definition first,
A so you're not counting the outflows,
lines that drop below zeror ds load?
A WeIl, again, so let me just explain the
It might be most easy if we do that, so on the
axis is kilowatts and there's positive and
kilowatts, and then on the horizontal- axis is
any of
and if
Now,
the positj-ve
if I was to
blue bars, I
look at the bl-ue
woul-d say that
Ioad, so
bars,
is net
thatit's positive, that would be net
would be the customer's l-oad less the generat j-on suppliedo25
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CSB REPORTING(208) 890-s198
ANGELL (X)
Idaho Power Company
by the customer. Any of the negative blue bars, I would
classify that as excess generation that would be received
by the Idaho Power Company.
O Do you know where Idaho Power Company
receives that? Where does that exported
A Idaho Power owns the meter, up to the
meter. The customer owns everything on the other side of
the meter, al-l- the facilities on the other side of the
meter.
O So when this
exporting excess generation
Company takes title to that
A You could essentj-aI1y say
the meter.
Figure 1 is
the Company, the
at the meter?
that we take
then turn to Figure 2 on the next
this, this is the same data
except you use the absolute
customer in
received by
electri-city
title of that energy at
O So fet's
page. As I understand
represented in Eigure 1
val-ue; right?
Yes,
So in
the absol-ut.e value.
negative numbers into
layman's terms, you turned the
positive?
A That is correct.
0 And you call this utilj-zation of
distribution system by residential net metering customer
versus standard servj-ce; right?
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CSB REPORTING(208) 890-s198
ANGELL (X)
Idaho Power Company
A Yes, and the reason it's labe1ed that way
is as you can see where the lighter bl-ue bars are now
positive and previously they were negative,
because the net meterj-ng customer is tied to
Power's system receivj-ng voltage from Tdaho
system and has the ability for the inverter
such that it's able to export into
that's where
Idaho
Power' s
to operate
Idahoenergy out
I used thePower's
Figure
that if
and available
system, and the
2 for util.ization
that
terminology in
of the distribution system is
distrj-bution system wasn't there
to that meterJ-ng customer, that
and present
net
energy to
reason
metering customer woul-d not be able to supply
Idaho Power's system.
O So a grid-tied net metering system
requires voltage and a connection in order to export?
A We1l, to operate period.
O To operate?
A To even serve its own load.
O It has to synchronize to the frequency and
voltage?
A Voltage of the Idaho Power system, that is
correct. It doesn't have the capability of generating a
sinusoj-dal- wave, AC electricity without Idaho Power's
grid.
O That's true of any generator, large orI25
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CSB REPORTING(208) 890-s198
ANGELL (X)
Idaho Power Company
small. It needs to have that voltage and it needs to
synchron ize?
A WeII, there are inverters that -- weII,
the answer to that is no. There are generators that
don't have to be synchronized to the grid. DC generators
don't have to be synchronized to the grid.
O Ifm talking about generators that feed
supply that Idaho Power uses to supply its customers.
A Yes. We11, I can just take the example of
our hydro units, right? Our hydro units before they
supply electricity to Idaho Powerrs system, before
they're synchronized to the system, they come up and we
have water that spins them around, spi-ns the turbine
whj-ch spins the generator, and we excite a fie1d, a
magnetic field, electromagnet, and then itrs producing
its owns sine wave all by itself, and then we essentially
through control- systems synchronize it
before we cl-ose, but, yeah, it has the
produce a 60
our system.
o
Hertz sine wave completely
Right; so before you close the bus,
up with the system
ful-l- ability to
independent of
meaning before
A
o
the system is
connect it to
j-s correct,
your system?
right.
you
That
So before you connect it to
there with voltage and at 60
the system,
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A Yeah, and they're operating completely
independent and if we don't have them properly
synchronized, it wil-l destroy the machine
instantaneous 1y.
O And you won't cl-ose the bus?
A Oh, no. Yeah, we won't close that
breaker.
O You need to close the bus and it's
supplying your system, your grid?
A Viell, when we cl-ose the bus, essentially
because the amount of water being put through it is just
enough to consume al-1 the losses that it's spinningr so
once you immediately connect to it, it doesn't export
power immediately. Then we have to open up the gates,
pour more water into it, and allow -- which causes it to
push more energy out into the system, but anyway, yeah.
O The loads here or the utilization levels
that you show are the amount of export in Figure 2?
A No, the utilization is both the -- we11,
again, it's net, it's net exports, rightr so everythj-ng
across there, aII those blue bars, are net utilization of
the grid, and, you know, as Tim -- excuse me, Mr. Tatum
spoke to earlier, because itrs al-1 netted even on an
hourJ-y basis, the utitization of the system is likety
higher than what is displayed right here.
CSB REPORTING(208) 890-s198
ANGELL (X)
Idaho Power Company
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CSB REPORTING
(208 ) 890-s198
ANGELL (X)
Idaho Power Company
O Let's look at hour ending 13, so between
noon and 1:00 o'clock; right?
A Yes.
A A customer with a net metering system is
net exporting five kilowatts -- no.
A I think a little l-ess than five, maybe
four-and-a-haIf kil-owatts .
0 Four-and-a-half. A neighbor customer is
importing something slightly l-ess than that, sdy
A Yeah, 4.2, sure.
O The exported power from a net metering
system is going to flow to the nearest l-oad; is that
fair?
A It wil-1 fl-ow to where it can be consumed,
if that
time or it
yesr and that coul-d be a nearby customer
customer's load is operating at the same
may -- you know, i-n many cases we have export into our
transmission system.
O I'm talking about this instance in the
figure right now.
A WelI, again, this customer is nearby, so
these customers really arenrt rel-ated and the energy may
be consumed by a completely different customer. These
are not next-door customers.
O A customer recej-vi-ng a kj-lowatt-hour cano25
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CSB REPORTING
(208 ) 890-5198
ANGELL (X)
Idaho Power Company
come from the customer exporting the kil-owatt-hour?
A The customer receiving the kilowatt-hour
is consumj-ng any kilowatt-hour that's being produced at
that same time
generator. It
Canyon complex.
o
produced by a
kilowatt-hour
on our system. It could be from this
could be from generators at our Hells
It could be our Jim Bridger plant.
So when one of those kilowatt-hours is
net metering customer, that's
that would have come from one
displacing a
of your other
generating
balancing
generates
generators
period of
energy.
sources ?
A Yes, and so
all- the time. If
a kilowatt-hour -- we1I,
are backed off, and if
we would not things we're
a net metering customer
a kilowatt, other
it's over an hour
o
A
our frequency
o
time, they would not have been producing that
So it's a balance?
Yeah, we bal-ance the systems,' otherwise,
changes.
Company receives is
generation is backed
A That
net metering excess generation the
put on to the system, other
off the system?
is correct.
So as
O So there's no additional- flow across the
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the system? You're replacing one kilowatt from the net
metering system and backing off one kilowatt from other
generation?
A Yeah, I woul-dnrt use the term "additional
usage." I'd sti11 say the label- on the figure is
correct. It is usage of the system.
O That usage, the export, is the same as the
Company is going to have to use the system to serve that
nearby customer's load.
A We1l, Iet me put it to you this way: This
figure from my opinion reflects the fact that a net
metering customer has an inverter that is required to be
connected to the grid to even operate, and at a point in
time when that net metering customer's Load is less than
the generati-on provided by whatever system J-s there,
whether it be wind or solar, then it needs the grid,
Idaho Power's distribution system, if it's going to be
just consumed locally to be abLe to export, and at that
point in time you're utilizing the grid. If the grid is
not connected, we're not having this discussion.
O The same electrons fl-owing out of that net
metering customer's system on to the grid are not serving
some other customer's load?
A Yes.
O And that customer is going to need those
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CSB REPORTING(208) 890-s198
ANGELL (X)
Idaho Power Company
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CSB REPORTING(208) 890-s198
ANGELL (X)
Idaho Power Company
electrons to serve his 1oad, whether it came from the net
metering customer's exports or from the Company's other
generation?
A Oh, yes.
O Let's talk about your l-oad factor analysis
in your rebuttal test j-mony on pages 5 and 6.
A Yes.
O Okay; so I'm looking at Figure L, page 6.
Are you there?
A Yes, I am.
O Okay, this shows average load factor by
month for two groups of customers; correct?
A Yes.
O It is residential class as a whol-e based
on the l-oad sample data; right?
A Wel-l-, if you're talking about load factor,
I believe this is from billing data.
O Okay, but j-t's the cl-ass as a whol-e?
We11, this is the billing data for the
class, yes.
And then the orange j-s the net metered
subgroup
That is correct.
within residential-?
Yes.
A
resi-dential-
0
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CSB REPORTING(208) 890-s198
ANGELL (X)
Idaho Power Company
0 And the way you figured the load factor
was you took off all flows and netted them for the
month?
A Yeah; so what the chart reflects is the
billing that occurs for both a resj-denti-al- customer
without on-site generation and the billing for a net
meterj-ng customer, and if you look at the billing for
those customer classes as werve separated them here,
you'11 see these differences in load factor.
O This is the difference in net billing;
correct?
A YeS, I
it's the difference 1n
think that would be fair to sdy,
a
consumption is
A
o
net bi11ing.
as we've defined it as the
And in the orange bars
load by exportsactually reduced the
So load
A Right.
O to get
A Yeah, and
l-oad factor is something
standard customers that
introducing
muddl-es load
generation
factor, and so
the imports; right?
Correct.
the net
if you
that's
only
into
in this chart, you
flow?
thj-nk about load factor,
applicable to, you know,
have load. Once you start
kind ofthe equation,
this chart is really being
ir
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presented with respect to Iooking at the sor again,
the calculation of load factor, rightr so itrs energy
over peak, right, and so therers you know, how often
are you operating near peak, which, agaj-n, so peak
l-oad --
O I hate to interrupt, but my question was
just what you did and I didnrt ask for the explanation.
A Oh.
O This will go faster if you just answer my
question.
A Sure.
A Irm sure counsel can ask you explanations
and I may ask you explanations, but if you can limit it
to the questi-on --
A Okay.
a I appreciate it; so what you did was
there were months with exports from net metering
customers in the group as a whole, you used those exports
to reduce the loads that went into cal-culating these l-oad
factors?
A Yes; so i-n a given month, it would be what
was bi-l1ed, either whether it's resident j-al or a net
metered customer.
O So if we just l-ooked at hours where the
customer was a net consumer, where a customer had net
CSB REPORTING
(208 ) 890-s198
ANGELL (X)
Idaho Power Company
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CSB REPORTTNG
(208 ) 890-s198
ANGELL (X)
Idaho Power Company
l-oad as we've def ined it today
Yes.A
O use
different values in this chart?
A Yeah, you'd show much greater util-ization
of the system,
it demonstrates
today reaIly doesnrt
it would show a different
the bil-l-ing arrangement
account for the use of
but the point of this whol-e chart is that
how that we have
the
and essential-Iy, werre not recovering for that
system.
system
use of the
O So my question --
A Yes.
O is if we define load as energy received
from the Company and used by the customer, that's how we
define load, and we cal-culate load factor, we'd have a
different value for net metered customers than show up in
Figure L?
A Yes, you could display it that way.
O And they would be higher?
A They would be hi-gher, but the billing
would be as reflected.
O Letrs tal-k about your Eigures 3 through 5
your rebuttal.on page 6 Do, on page 11 of
Yes.
So here you grouped residential- customers
A
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CSB REPORTING
(208 ) 890-s198
ANGELL (X)
Idaho Power Company
as a whole and plotted their loads across three dj-fferent
months.
A Yeah, this is
data in hourl-y samples.
O Okay, and then
customers' net hourly billing
the orange l-ine?
A Wel1, you said
residential- customer sample
you also took net metered
data and plotted that as
"net hourly billing data, "
that hourly data
correct.
this these comparisons
we only bill
a
A
o
on monthly, so
Hourly data?
That woul-d be
Okay, and so
so the orange,
A
a
A Yes.
O Okay; so in
metering customers who are
importing, those woul-d net
the net metering l-oad shape
Yes.
includes the net of their exports?
an hour if there was some net
exporting and some who. are
each other out and you'd get
the net number for the va1ue you plotted?
A Yeah, these are all averages.
O Right, and thatrs the way the math woul-d
work; right? So if you have some exports, some imports,
they woul-d negate each other and average out to whatever
the average of the negative and positive numbers j-s?t 25
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CSB REPORTING(208) 890-s198
ANGELL (X)
Idaho Power Company
A
o
as just load
consumption,
load shapes,
different?
A
experj-ence on
o
averages?
A
o
customers who
Yes, it's averages.
And so if we were to define
as we've earlier defined it as
right, and we excluded exports
a load shape
customer
from these
the orange load shape would look
Right, it wouldn't be the profile that we
our system.
And as you just mentioned, these are also
Yes, they are.
So you have large groups, 500 some, 11 000
have very dj-fferent loads who are al-l
averaged together to create one solid line?
A Which line are you referring to?
O Either.
A Okay; so there's 565 customers maklng up
the net metering, the sample data that produces these
samples is, oh, I can't remember the exact number over
500 customers.
O Right; so we're taking and each of
those 500 some is going to have a different l-oad in every
hour?
That is correct.
And so we're averaging it together to
A
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CSB REPORT]NG(208) 890-s198
ANGELL (Com)
Idaho Power Company
create one value?
A That's correct.
O Right, but that doesn't show us the range
and it doesn't show us the groupings within that range,
that diversity, does it?
A
figure on page
o
Well-, let me refer you to Dr. Faruqui's
L4, Eigure 4 --
I'11 ask him. I'11 ask the Doctor about
it. I'm asking you that your
reflect diversity? It groups
averages?
averages on page Ll- do not
them to create those
A
o
It reflects averages.
And there is diversity within those
groups?
A Oh, yes.
MR. BENDER:I don't have anything
further.
COMMISSIONER RAPER: Thank you.
Commissioners ?
EXAMINAT]ON
BY COMMTSSIONER RAPER:
We11, I have
bel-ieve Mr.
O a few questions for you, not
Tatum's testimony, butbecause I don'to25
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CSB REPORTING
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ANGELL (Com)
Idaho Power Company
because he essentially directed me to ask you.
A He deferred to me.
O He deferred; so same scenario that you
heard before, right, and this is in rel-ation to my
limited understanding of how a net metering customer's
house is built and what is on the homeowner's side of the
meter and what is on the Company's side of the meter, so
what I heard from some of the questions that were asked
of you now was, and what I heard Mr. Tatum say was, even
if a solar customer, someone with solar panels on his
roof, doesn't ever want to export excess generation back
into the grid, it makes the meter move question mark?
A Question mark?
A I can go further with that to describe it
if you want.
question and
Yes, f understand the nature of the
Ir11 make sure she can stil-I hear me,' so on
an j-nstantaneous basis, loads j-n a house can changer so
running theyour air conditioner may come on. You may be
dryer. You may --
onr al-1 rightr so
your refrigerator compressor may kick
any time those devices kick on,
especially, and, again, going back to my testimony, the
direct testimony, therers a section in there talking a
litt1e bit about motors and how motors essentially draw
reactive current and thatrs going to come from the grid.
A
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CSB REPORTING(208) 890-s198
ANGELL (Com)
Idaho Power Company
Now, reactive current itself
a reliance of the households
is not measured, but that I s
on the grid, and so f want
on a moment-by-moment basj-s,butto just make that point,
so a solar, sdyr a sol-ar array and it has a maximum
amount of power that it can put out, any devi-ce that
comes on and operates beyond that maximum amount of
power, and it may only be on for five mj-nutes at a time,
wil-l draw more current than what can be delivered or more
power or energy than can be del-ivered by the sol-ar array,
and then if you look at it over the course of an hour, it
may net to zero, but if we had a meter that recorded
every watt of power that went through that meter, you
would end up seeing load delivered that was much greater
than what we are recording today.
O Understood; so somebody couldn't have a
solar array put
of the way that
versus the meter
one another?
on their roof and you not know it because
their electrical within their house
on your side of the meter interact with
A No, that's not true. Anyone could put
generation on their house. The only way we would be able
to detect that would be a reductj-on in the metered energy
over time.
O So does Idaho Power care about those
customers? I know T'm asking you for an opinj-on that may25
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CSB REPORTING(208) 890-s198
ANGELL (Com)
Idaho Power Company
be somewhere else in the witnesses, but I
if the Idaho Poweropinj-on
having
on it. I mean,system
to absorb the energy, find another place for it,
the customer is paying their customer charge, but just
their energy is reduced, right, the energy that they're
pulling from your grid is reduced, how is that different
than a vacation home, than a person who has energy, is
utilizi-rrg energy efficiency measures, on what spectrum --
where does Idaho Power put that on a spectrum?
A Yes, right, okay; so let's start with
energy efficiency and then as written in testimony, an
energy efficiency device will be reducing the amount of
energy requlred by that device all the time while it's
orrr right, and essentially, that energy efficiency gain,
a reduction in energy, wil-I be avail-able any time it's on
until that device fail-s and then itrs all gone and
replaced; whereas, with regard to self-generation, that
self-generation wil-l- fol1ow its own schedu1e, Iike the
schedule of the sun, regardless of what energy use is
being taken into that home for washing, drying, air
conditioning, heating, so I see those as very different
abil-ities to change, and even if the load is being served
by a soIar, Iet's say a solar system and when a cloud
comes over, the sol-ar panel output reduces by 80, 90
percent, then Idaho Power has to instantaneously pick
do want your
i-sn I t
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CSB REPORTING(208) 890-s198
ANGELL (Com)
Idaho Power Company
that load up, so taking the account of a
so I've got a friend up in Sun Val-l-ey who
further up in the Wood River Va11ey, when
the winter, he's got the water shut off.
He's got everything shut
to read zero energy consumed each month
back and turns things back on. In that
he doesn't care if the lights are out
goes out. He's not going to be calling
center. A11 there's
vacation home,
has got a
he leaves
place
for
going to be, therers going to be
the transformer because
off. Werre going
until he goes
particular case,
I mean the power
into our cal-l-
that, therers
j ust
and not being
some load consumed by
transf ormers have some l-osses.
no draw on our system, no I
essentially l-ike them opening
connected to us at that point.
Other than
mean, it's
up a switch
a Right, but I guess the poi-nt of the
vacation home versus somebody who has solar that you
don't see, right, because they don't export any of it to
you, when the guy in the vacation home goes and turns his
lights or, you stil-l- are requj-red to instantaneously
provide energy the same way that the person that may have
solar that is invisible to you, the cloud goes over the
sun and you have to instantaneously provide that energy.
I mean, you may sort of know that sunrmer homes are going
to require more in Sun Valley at certaj-n times of theo25
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CSB REPORTING(208) 890-5198
ANGELL (ReDi)
Idaho Power Company
year when
A Right, you could predict that.
O You can predict the increase in l-oad and
requirements for you to have to generate
A Yes.
O -- but you donrt know the moment he's
going to turn it on any more than you know the moment
when someone with a solar set on their roof needs to draw
from the system. You just have to be prepared for either
contingency?
A Yes, that is correct.
COMMISSIONER RAPER: Okay. Thank you very
much.
THE WITNESS: You're welcome.
COMMISSIONER RAPER: Is there any redirect
by Ms. Nordstrom?
MS. NORDSTROM: Yes, one moment.
(Pause in proceedings. )
RED]RECT EXAMINAT]ON
BY MS. NORDSTROM:
O Mr.
Commissioner Raper
concerned when we
Ange11, one of the questions
was, is the
that
asked you about Company
have rooftop solar arrays connect too25
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CSB REPORT]NG(208) 890-s198
ANGELL (ReDi)
Idaho Power Company
our system and perhaps we don't know about it.
A Yes.
O Is the Company concerned?
A Yes.
O why?
A Well, you know, there's the obvious safety
aspects of having generation connected in parallel with
our system, which, you know, our utility linemen coul-d be
presented with risk that isn't presented by just load,
load-served customers. The second item that is important
to us is having though the energy consumed by the home
is masked by the net metering information that we have,
understanding what load is present and can
instantaneously detected by Idaho Power's
need to serve is a bit problemati-c, so to
Commissioner Raper's question with regard
whether or not we need to know that, one
be
system and the
go to
to, you know,
thing f think in
terms of is that our SCADA systems for operating our
system are measuring energy at the substation level, and
so you have this whole distribution circuit and so the
l-oad measured at the substation level and l-et's assume
that the generatj-on from the solar
comi-ng back out
that we're going
neighboring
transmi- s s ion
to end up having to
goes off-l-ine for whatever reason,
j-s serving
into thecustomers, it's not
system, so the load
serve when the solaro25
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CSB REPORTING
(208 ) 890-s198
ANGELL (ReDi)
Idaho Power Company
and if it's all systems on that circuit or just a few
systems, w€ actually see typically a doubling of the
change in load that appears instantaneously, so unlike a
home when someone finally goes out and takes a vacation
home and turns on the lights and things, you're going to
see a small increase in load, but as you have distrj-buted
generation out in that system, you're going to see large
changes, and in my testimony, I discussed about large
changes in generation going off-line results in voltage
changes out in the distribution circuit, which can
produce more wear on our regulating devices that are
mechanical devices, so there's many reasons that we're
concerned about thatr so voltage regulation, al-ong with
the bal-ance of energy supplied.
MS. NORDSTROM: Thank you. I have no
further questions.
COMMISSIONER RAPER: Unless it's Bruce
WiIlis's pJ-ace
instantaneous,
in Sun Va11ey, and then it's
straight up,
THE WITNESS:
to turn on aIl
no incremental
Well-, yeah, in
thej-r heatj-ng
change; right?
the winter
for thewhen they have
driveways and al-I that sort of thing.
COMMISSIONER RAPER: The boilers?
THE WfTNESS: Yes, and the hot tubs and
all those things, yeah.25
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CSB REPORTING
(208 ) 890-s198
ANGELL (ReDi)
Idaho Power Company
COMMISSIONER RAPER: Thank you for your
testimony, Mr. Ange11.
THE WITNESS: You're welcome.
(The witness left the stand. )
COMMISSIONER RAPER: We're going to take
a break. We'1l give 10 minutes. Let's try and get
back here and at least get through, I think, Idaho
Power's witnesses for the day. I think that would put
us in a good starting position for the morning, so 10
minutes.
(Recess. )
COMMISSIONER RAPER:So being back on the
to caII your nextrecord, Ms. Nordstrom, would you like
witnes s ?
MS. NORDSTROM: Yes, Idaho Power ca11s Dr.
Ahmad Faruqui.
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CSB REPORTING(208) 890-s198
FARUQUI (Di)
Idaho Power Company
DR
produced as a witness
Company, having been
AHMAD FARUQU],
at the instance of the Idaho Power
first duly sworn to teII the truth,
as follows:was examined and testified
DIRECT EXAMINATION
BY MS. NORDSTROM:
O Good afternoon.
A Good afternoon.
O Please state your name and spell your last
name for the record.
A My
Itrs
By
name is Ahmad Earuqui. Irll spe1l the
entire name.A-h-m-a-d F-a-r-u-q-u-i.
a whom are you employed and in what
capacity?
A My employer
principal of the firm.
O Are you the
is the Brattle Group and I'm a
same Ahmad Faruqui that filed
January 26Lh, 2018?direct or f1l-ed rebuttal testimor)y on
A
o
Yes, I am.
And did lreu al-so prepare Exhibits 16 and
77?
A Yes, I did.
O Do you have to any corrections or changeso25
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CSB REPORTING(208) 890-s198
FARUQUI (Di)
Idaho Power Company
to your testimony or exhibits?
A I do have two corrections. The first one
is on page 10 on
It reads, "Load
Customers. " It
Customers Before
line 6. It j-s the heading of Tab1e 1
Characteristics of DG and Non-DG
should read, "Load Characteristics of DG
and After the Instal-l-ation of DG."
The second and l-ast correction is on page
24 on line 12. I would strike out the word
"unanimously. "
o
A
Directors. "
o
And that is on l-ine L2?
On line 1,2 right after "Board of
Thank you.If I were to ask you the
corrected prefiled testimony,
same today?
questions set out in your
would your answers be the
A Yes, they wou1d.
MS. NORDSTROM: I move that
rebuttal testimony of
the record as if read
Dr. Ahmad Faruqui- be
the prefiled
spread upon
and 11 beand his Exhibits 76
marked for identification.
COMMISSIONER RAPER:Without objection,
rebuttal- testimony willDr. Faruqui's direct testimony
be spread upon the
!7 will be admitted
MS.
record as if read and Exhibits 1,6 and
into the record.
NORDSTROM: Thank you.o 25
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(Idaho Power Company Exhibit Nos. L6 and
L'7 were admitted into evidence. )
(The fol-l-owing prefiled rebuttal testimony
of Dr. Ahmad Faruqui j-s spread upon the record. )
CSB REPORTING(208) 890-s198
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FARUQUI (Di)
Tdaho Power Company
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CSB REPORTING
(2oB ) B9o-s198
FARUQUI
Idaho Powe
EB1
ompany
,RrC
I. INTRODUCTION
and address?O. What is
A. My name
with the Brattl-e
your name
is Ahmad Earuqui.
economics
I am a Principal
consulting firm. My
2800, San Francisco,
Group, do
address is 201 Mission Street, Suite
Cal-ifornia 94105.
o.
A.
Company
o.
A.
several
direct
Ange11,
On whose behalf are you submj-tting testimony?
I am testlfying on behalf of Idaho Power
("Idaho Power").
What is the purpose of your testimony?
The purpose of my testimony is to address
issues raised by various parties in response to
testimony filed by Idaho Power witnesses David M.
Connie G. Aschenbrenner, and Timothy E. Tatum.
O. How is your testimony organized?
A. My testimony is organi-zed into several
sections. Section II presents my qualifications.
Section III is a sulnmary of my testimony. Section IV
presents an empirical assessment of the differences
between dj-stributed generatj-on ("DG") customer load
shapes and those of non-DG customers. Section V is a
discussion of the cost shift between DG and non-DG
customers, and its implications. Section VI addresses
other issues raised by intervenors. Section VII presents
a summary of decisions to address theo25
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cost shift issue in other jurisdictions. Section VIII
concl-udes my testimony.
rr. QuArrFrcaTroNs
O. What are your qualifications as they pertain to
this testimony?
A. I am an energy economist. My consulting
practice is focused on customer-rel-ated issues. My areas
of expertise j-ncl-ude rate design, demand response, energy
efficiency ("EE"), distributed energy resources, advanced
metering infrastructure, plug-in electric vehicles,
energy storage, inter-fuel substitution, combj-ned heat
and power, microgrlds, and demand forecasting.
I have worked for nearly 150 clients on five
continents. These include electric and gas utilities,
state and federal- commissj-ons, independent system
operators, government agencies, trade assocj-ations,
research institutes, and manufact.uring companies. I have
testified or appeared before commissions in Alberta
(Canada), Arizona, Arkansas, California, Colorado,
Connectj-cut, Delaware, the Distrlct of Columbia, FERC,
Illinois, Indiana, Kansas, Maryland, Minnesota, Nevada,
Ohio, Oklahoma, Ontarj-o (Canada), Pennsylvania, ECRA
(Saudi Arabia), and Texas. Also, I have presented to
governments in Australia, Canada, Egypt, Ireland, the
Philippines,
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CSB REPORT]NG(208) 890-s198
EARUQUT, REB 2
Idaho Power Company
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9
Thailand, and the United Kingdom and given seminars on
al-l six continents.
My research has been cited 1n Business Week,
The Economj-st, Eorbes, National Geographic, The New York
Tj-mes, San Francisco Chronicle, San Jose Mercury News,
Wal1 Street Journal-, and USA Today. I have appeared on
Fox Business News, National Public Radio, and Volce of
America and I have authored, co-authored, or co-editor
four books and more than 150 articles, papers, and
reports on energy matters. I have published in
peer-reviewed journals such as Energy Economics, Energy
Journal, Energy Efficiency, Energy Policy, Journal- of
Regulatory Economics and Util-ities Policy, and trade
journals such as The Electricity Journal and the Public
Utitities Eortnightly.
I hol-d B.A. and M.A. degrees from the
University of Karachi, Pakj-stan, an M.A. in agricu1tural
economics, and a Ph.D. in economics from the University
of California at Davis.
More details regarding my professional
background and experience are set forth in my Statement
of Qualifications, included in Exhibit No. 16.
III. ST'M!,TARY
O. Pl-ease summarize your testimony.
A. fntervenors have opposed various aspects of
CSB REPORTING(208) 890-s198
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FARUQUT, REB 3
Idaho Power Company
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Idaho Power's proposal to create a separate rate cl-ass
for
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CSB REPORT]NG(208) 890-s198
EARUQUI, REB 3A
Idaho Power Company
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CSB REPORT]NG
(208 ) 890-s198
EARUQUI, REB 4
fdaho Power Company
residential DG customers. However, having reviewed Idaho
Power's proposal-, I find that the proposal is reasonable
and justified.
DG customers rely heavily on the power grid.
When the sun is not shining or the wind 1s not blowing,
they are drawing power from the grid, l-ike other
consumers. And when the sun is shining or the wind is
blowing, and their power generation exceeds their power
consumption, they will be exporting power to the grid,
unlike non-DG customers. In other words, they have a
bi-dlrectional- relationship with the grid.
However, the rate that Idaho Power currently
offers to DG customers is identical to the rate for
non-DG residential customers. It over-compensates DG
customers for the power they seI1 to the grid. The
over-compensation occurs because the residential rate at
which they are compensated inc1udes not only the variabl-e
costs of electricity, which the DG customers are se11J-ng
to Idaho Power, but also costs
transmission and distribution
costs and fixed costs
associated with the
grid, as weII as generation
of customer service, nonecapacity
of which DG customers are selling to Idaho Power.
not reflect additional costs that DGFurthermore, it does
customers may impose on the
two-way interaction with the
system because of their
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CSB REPORTING(208) 890-s198
FARUQUI, REB 5
Idaho Power Company
This over-compensation to DG customers has to
be recovered from non-DG customers to ensure that the
utility recovers its revenue requirement. Thus, non-DG
customers end up paying a higher rate than they would
otherwise be paying. This results in an unintended
cross-subsidy from non-DG customers (including a
disproportionately large share of lower income customers)
to DG customers. That cross-subsidy largely remains
invisible to the non-DG customers.
This cost shift can be
creation of a separate class of
customers woul-d be offered rates
amel-iorated through the
DG customers. These
based on their cost of
that DG customers wil-1so would ensureservr-ce.Doing
fairpay their share of electrici-ty costs while stil-l-
being compensated an appropriate amount for the
electricity they generate from their solar panels. Since
residential- DG customers have very different l-oad
characteristics than non-DG customers, it is appropriate
to consider them a separate cl-ass of customers with their
own unique rate.
The problem with Idaho Power's current rate
offering, and a description of how this problem can be
addressed through the j-ntroduction of a separate,
cost-based rate for DG customers, is provided in
Figure 1-.o 25
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CSB REPORTING
(208 ) 890-s198
EARUQUI, REB 6
Idaho Power Company
Problem with Current Rate
Figiure 1: Hor a Separate DG Rate Conects the problen inIdaho Power's Exis Rate
o,*dff'r@tr6llM0G(@drEbninqftfl*ii2-frr&{-
Bill < Cost
-55S
o
O rn. rn",",o"c
tubtdv t on n6OG(uttomn3ro06(utto6d3-ranM
0G @rtotEprvro( ta
uta ol6cp63fld
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ud ac(o46qad
lrntY ld PV @tpur<-.--..+
Bill = Cost
r\@,rc.or**,
o lhlHotEa \
acffiad<6
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frlrilar@&
Bill > Cost
+SSS Bill - Cost
@naestamomcuttol'E(s!n€EraiGt
$atErla(eotlcdralrc{ddrls(cYdcBdrdlr&la, unliE Gd \rgbridrftomndOc \(urffirbm \offi,
In this testimony, I elaborate on a number of
points about Idaho Powerrs proposal to create a separate
rate cl-ass for residential DG customers. These incLude:
o There is empirical evidence that DG customer
Ioad shapes differ significantly from that of the typical
residential customer in Idaho. DG load shapes also
differ significantly from those of customers who
participate in EE programs.
o These differences in load shape lead to a
significant and disproportionat.e shift in the recovery of
power system infrastructure costs from DG customers to
non-DG customers.
Correction with Separate DG Rate
ldaho
PoTJer OC
customers
ldaho
Pov;er
Non-DG
Customers
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Non DC
Custotl,i'r:
DG
Customels
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CSB REPORTING(208) 890-s198
FARUQUI, REB 6AIdaho Power Company
o Low-income customers are disproportionately and
shift.negatively impacted by the
o Vfhile DG adoption
cost
Ievels in Idaho are modest,
they are growing fast, ds they are in the rest of the
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CSB REPORTING
(208 ) 890-s198
EARUQUI
Idaho Powe
EB7
ompany
,RrC
country. Thus, it is important to create a new rate
class for DG customers now.
o A "vaIue of soIar" ("VOS") study is not a
necessary prerequisite for DG rate reform. VOS studies
can play a valuable rol-e in cost-effectiveness analyses
and in resource planning decisions. But ratemaking
decisions should be based on cost of service and the
generally accepted principles of rate design.
o There is precedent for creating a separate rate
class for DG customers. This has been implemented in
both Arizona and Kansas. Many states continue to grapple
with the challenges presented by net metering with
volumetri-c rates.
IV DG CUSTOMER LOAD SEAPES ARE SIG'NIFICA}ITLY DIFFERENT
TTIA}I THOSE OF NON-DG CUSTOMERS
O. Does the hourly load
differ significantly from that
A. Yes. While Witness
shape of DG customers
of non-DG customers?
suggests that the differences
immaterial, I have conducted
finds
in l-oad
empirical
that the
Morri-son (IPUC Staff) I
shape are
analysis with
differences areIdaho Power data which
quite significant.
O. What data did
shapes of DG and non-DG
you use to analyze the load
customers?
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CSB REPORTING(208) 890-s198
FARUQUI, REB '7 A
Idaho Power Company
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1 Morrison DI, pp. 3, 1,1 .
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A. Idaho Power provided me with hourly load data
for its residential DG and non-DG customers. The data
begins in January 2074 and runs through October 201,7.
The non-DG customer dataset is ldaho Powerrs load
research sample, which consists of 527 customers who have
not installed rooftop photovol-taic ("PV"). The DG
customer dataset includes 7,545 net metering customers
who installed rooftop PV at some point since 2002. The
data includes the date of installation of rooftop PV and
reflects the net l-oad of the DG customers, including
exports to the grid.
a. What was your methodol-ogical approach to
analyzing the DG customer load shapes?
A. I cal-culated the hourly average consumptj-on of
DG customers before and after the i-nstallation of DG.
This gives a sense of how the DG customer l-oad profiles
differ before and after the j-nstal-lation of rooftop PV.
I al-so compared these average DG l-oad profiles
to those of non-DG customers in Idaho Powerrs l-oad
research sample. This provides perspective on how DG
customer Ioad profJ-les differ from the typical
residential customer.
O. What did you find in your analysis of DG
customer load shapes?
A. The net load shape of residential customers
CSB REPORTING
(208 ) 890-s198
FARUQU], REB B
Idaho Power Company
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Idaho Power Company
changes
rooftop
average
significantly when those customers instal-l-
solar PV. Eigure 2 summarizes the comparison of
I 25
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load profiles for non-DG customers relative to DG
customers both before and after the installation of
rooftop PV. The load shapes of DG customers resembled
those of non-DG customers prior to the installation of
solar PV, though the hourly loads for DG customers were
somewhat higher than those for non-DG customers in both
summer and non-summer months (we define the summer period
to include June through September, and the non-summer
period to lnclude October through May; hereafter we refer
to t,he non-summer period as "winter"). This is no iong.t
the case following installation, when load shapes are
dramatically different in both summer and winter.
L4
Eigure 2: Average Eourly DG and Non-DG Qustomer Load
Profiles
15 Summer Winter
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21"
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(' ro
Ei1alt3E
i ,o
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a 0t
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c lo
3 rs
5'"o
il 05,
I6 0.1
z ro
,t
ion-DG Pero6 lortnllaron
I I I a t 6' a ! tolllllt talt lal? llltmllrlll2a
tlw Endha
id.OG
Quantitatively,
of DG customers
installati-on
CSB REPORTING
(208 ) 890-s198
the average annual net energy consumption
was 36 percent lower following
Hour Indin3
EARUQUI,Idaho Power
REB 9
Company
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CSB REPORTING(208) 890-5198
FARUQUI, REB 10
Idaho Power Company
of DG average.2 In contrast, those customerst average
monthly maxirdum demand was modestly higher by 4 percent.
In other words, while the DG customers reduce their total
energy needs, their heavy reliance on gri-d infrastructure
persists. Table 1 summarizes results of the analysis.
fab].e 1: Lord Charactsrigtics of DG aad llon-DG Cust@ersBefore and tfter the lagtel].atioa of DG
Avg lvbnthly Net- Avg ttlonthly
Energ'y Consumption lMax Demand Load(kwh) (kW) Factor
Pre-PV Summer tvbnths
Post-PV Summer lMonths
% Change
Pre-PV Winter lMonths
Post-PV Winter Nbnths
% Change
Pre-PV All tvlonths
Post-PV All lvlonths
% Change
523
t,207
-57%
1,188
-%%
7.0
6.8
-3%
24%
L7%
-55%
L,179
918
-?2%
6.9
7.5
96
7.0
7.2
4%
23%
t7%
-29"
z3%
L4%
-38%
76
Source: Brattle analysis of lPC load data.
O. Are the load characteristics of DG customers
similar to those of EE customers?
A. No, there are significant differences between
DG customers and other resj-dential customers who pursue
various EE measures. Witness Donohue (IPUC Staff)3 has
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EARUQUI, REB lOA
Idaho Power Company
2 I additionally used a fixed-effects regressj-on model- to
analyze the change in energy consumption attributable to the
instaflation of DG. A regression-based approach al-l-owed me to
control for external factors that may drj-ve differences in pre- and
post-Dc energy consumption (e.9., differences in weather). Under
this alternative approach, I found that the decrease in energy
consumption was even larger, amounting to a 67 percent reduction in
pre-DG energy consumption.
3 Donohue DI, pp. 2, 18.o 25
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(208 ) 890-s198
FARUQU], REB 11
Idaho Power Company
claimed that
identical, "
separate DG
To
conducted a
but have compared the l-oad shapes of
Power's EE programs to those of other
The purpose of the analysj-s is to see
these two customer types are "al-most
and has used this assertion in arguing that a
rate class is not warranted.
address this issue empiricalJ-y, I have
simil-ar analysis to the one described above,
customers in fdaho
non-DG customers.
if the
differences between DG and non-DG customers
significant
are also
non-DGobserved when comparing EE customers to the
cudtomers.
O. What data did you use in your comparison of
non-DG customer and EE customer l-oad profiles?
A. For non-DG customers, I used the same load
research data described above. For EE customers, Idaho
Power provided me with hourly load data for a sample of
5'16 customers. The sample of EE customers was created by
randomly selecting 20 percent of all customers who
participated in an Idaho Power-sponsored EE program
between 20L5 and 2016. The EE programs included in the
sample are the Energy House CaIIs program, the Heating
and Cooling Efficiency program, the Home Improvement
program, and income qualified weatherization programs.
The dataset indicated the program in which the customer
was enrolled and
the program.
the date the customer participated in25
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O. What did you find in your comparison of non-DG
customer load shapes to those of EE program participants?
A. EE customers have load shapes that are similar
to those of customers who have not enrolled in EE
programs, though
somewhat higher
in winter months. It is reasonable
the hourly loads of EE customers were
in summer months and significantly higher
that the EE customers
10
have significantly higher hourly loads in the winter
because electric heating is a requirement to qualify for
Idaho Power's EE programs. Across alL EE customers i-n
the sample, energy consumption decreased by one percent
and maximum demand decreased by three percent following
participation in the EE program. Eigure 3 illustrates
the difference between non-DG customers who have
participated in EE and those who have not.
Figrrre 3: Average Eourly customer Load profiles with andwithout Energy Efficiency
Summer Winter
2.S
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3.5
3.0
2.0
2.5
8,,t.
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1.0
>lei
i r.o
2
Polt tt hirr$ntion ilon.tE
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00
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xour Eadhtt
EE customers are different than
CSB REPORTING
(208 ) I90-51-98
liosr Endlna
DG customers. UnIike DG
FARUQUI, REB L2Idaho Power Company
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grid. Further, whil-e EE investments commonJ-y result in a
reductj-on in both max demand and energy consumption, the
install-ation of PV largely only provides the l-atter.
O. Did you al-so analyze the diversity of load
profiles among DG and non-DG customers?
A. Yes, I did. Wj-tness Kobor (Vote Solar)
suggests that the load profiles of DG customers are not
sufficiently different than those of non-DG customers
when accounting for diversity in l-oad shapes across the
entire residential- customer segment.4 My analysis
shows that in fact the DG load shape is significantly
different even when accounting for this diversity.
O. How did you analyze the diversity of
residential- load shapes?
A. Using the same hourly residential l-oad data
described earlier in thls section of my testj-mony, f
establ-ished the 1Oth and 9Oth percentiles of non-DG
residential- l-oad across each hour of the day in the
summer and winter. The wide spread between the 10th and
90th percentile in each hour indicates that there is
indeed signifj-cant diversity across non-DG customer load
shapes. But the average DG load shape still falls
outside of this range during several hours of the day.
This is speclfically the case when DG customers are
exporting power
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CSB REPORT]NG(208) 890-s198
FARUQUI, REB 13
Idaho Power Company
t 25
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4 Kobor DI, pp. 42-47.
FARUQUI, REB 13a
Idaho Power Company
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to the grid -- a characteristic
other residential customer. The
are summarized in Figure 4.
Figure 4: Divereity in Residential
Summer
that is not shared by any
results of my analysis
Load Profiles
Wlnter
I
!
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c
z
!
E
a
Itlon.OG (9O*l
tloDOG (90tal
f{6'OG (rffi)
t{oDOG
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10
Poit PV C!.bnr.rl
r a I . I a, a t lorl r:D ta rt 16t, t, lrplttrl!lr
tlq. Eiditrt
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tad, Erilnf
o
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0. What do you conclude from your analysis of DG
customer load shapes?
A. The DG customer load profiLe is significantly
different than that of the t.ypical residential customer.
There is a common misperception that, by virtue of
generating their own electricity, DG customers rely on
the power grid signiflcantly less than non-DG customers.
In fact, while a customer reduces his/her total energy
needs by installing a rooftop PV system, the customer
sti1l requires nearly the same amount of power grid
infrastructure
DG customers stlll consume a significant amount
of electricity during hours when the sun is not shining.
And when the sun is shining, DG customers may beo
CSB REPORTING
(208 ) 890-s198
FARUQUI, REB L4
Idaho Power Company
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exporting power to the grj-d. As a result, DG customers
still have
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CSB REPORTING(208) 890-s198
EARUQUI, REB 15
Idaho Power Company
significant demand during those system peak hours that
drive the need for investments in i-nfrastructure that are
necessary to maintain a sufficient 1evel of reliability.
DG customers also introduce new cha1lenges to operators
of the power gri-d, as described extensively in Mr.
Ange1l's Direct Testimony. s
V. TEE DG COST SHIFT IS REJAL AI{D SHOI'I,D BE ADDRESSED
O. Is there a cost shift between DG and non-DG
customers?
A. Yes. Witnesses Burgos (City of Boise)6 and
Otto (Idaho Conservation League)7 have suggested that
the cost shift is unimportant or otherwise has not been
correctly quantified by Idaho Power, and therefore should
not warrant the creation of a separate rate cl-ass for DG
customers. Howeverr ds I discussed previously, the
unique load characteristics of DG customers combined with
net metering under a flat volumetric rate
disproportionately shifts the recovery of Idaho Power's
costs from DG customers to non-DG customers.
The magnitude of this unintended cross-subsidy
will- depend on a number of factors, such as the number of
5 Ange11 nr.
6 Burgos DI, pp.
7 otto Dr, pp. 4
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CSB REPORTING(208) 890-s198
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Idaho Power Company
customers adopting PV, the average size of PV
installati-on, and the rate structure and Ieve1. A survey
of studies in other jurisdictions designed to quantify
the magnitude of this cost shift found that it could
amount to between approximately $400 and $1,800 per DG
customer per year.8 This is summarized in Figure 4,
with supporting details in Exhibit No. 1,7. While rdaho
Power's estimate fal1s at the lower end of this range,
there is litt1e doubt that such a subsJ-dy exists unde.r
the current rate structure.
Figrure 5: Rooftop PV Coet Shift Egtimates ($ Per PV
cust@er per year)
S2,ooo
s1,8oO
s1,600
s1,4oo
S1,2oo
s1,ooo
ssoo
s600
s4oo
s200
So
Poxre.
t{vPuc Nv€ncriy E3-NV WPUC NVEnGfSy E3-CA tuirofl. H.w.iian PG&E- SDG&E PG&E'
(sPPq FPPC) E$r.te (itPC) (NPC) Es(tnrtc ft,blic Ehctsic Lower UpPCr
s.r6c! R.rye Rrn8c
Notes: Year indicates date of cost shift estimate, which j-s
sometimes a forecast. In some cases, reported estimates were
converted to annual dollars per net metering customer for
comparison purposes. The PG&E ranges are calculated using
$L,7sz
(20201
s1,600
(2016)
6o
oo6
r!
Ea
$r,osr(2020)
$86s
(2015)
$gse
(2020)
$to(201s)
s520(201s)
s661
(2020)
$444
(201s)
l47t
(2o1sl
$511
(201s)
ss33
(2015)
ldrho
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8 For further discussion of the cost shift studies, see Barbara
Afexander, Ashley Brown, and Ahmad Faruqui, "Rethinking Rationale for
Net Meteri.g, " Public Utilities Eortnightly, October 2016.
CSB REPORTING(208) 890-s198
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that l-ow income customers are not hurt
assumptions from the California Public Utilities Commission's
Public Modeling Too1. PPC and NPC refer to Sierra Pacific
Power Company and Nevada Power Company service territories
respectively.
O. Do low income customers bear a dj-sproportionate
share of the cost-shift burden?
A. Yes. Witness Donohue (IPUC Staff) o suggests
by the DG cost
observati-on thatshift. However, research supports the
low income customers bear a disproportionate share of the
cost-shift burden. Publicty availabl-e studies by Elro
(for the California Public Utilities Commission), Dr.
Severin Borensteinll (a professor at UC Berkefey), and
So1ar PuIse12 (a solar market research firm which pairs
customers with rooftop PV installers) have al-l- shown
empirically that lower i-ncome customers have been less
1ike1y to instal-l rooftop PV than higher income
customers. Table 1 summarizes the conclusions of each
study.
10 E3, "Introducti-on to the Cal-ifornia Net Energy Metering
Ratepayer Impacts Eval-uation, I' Report prepared for the Cal-ifornia
Publi-c Utilities Commisslon, October 2073.
11 Severin Borenstein, "Private Net Benefits of Residential
Solar PV: The Rol-e of Efectricity Tariffs, Tax Incentives and
Rebates," Haas Energy Institute Working Paper, July 2015.
1,2 Sol-ar Pul-se Staff, "Is Going Solar Just for Wealthy
People?" July 2016, accessed onl-1ne October 2016.o 25
126
9 Donohue DI, p. 22.
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fabLe 2: The Relatioa hip Bebeea EoueeboJ.d Incoe and
Rooftop P\I Adoptioa
Uaing daa for 115,000 DG customers ia California, the study
found that the mdien inccnc of DG c:8 ffi" wes 34h
(t23tlyec) Hgho thm rtrt of .Il ffiy custotD€ts. The snrdy
relied oo. U.S. Ceostrs ircooe data at the C,easus tract levd aad
utility customer data.
E3lCPUG
(x,13)
Usiry Ceosus tract-le\.el income &ta ard utility data to estinate
irdividual household iacomes, the study e:ianines the iacome
distribution of solar adopters alrd how that has changed over tirne.
The study fiads that "6e stew to wea&fty hourehotds .dopdlg
sdar ir 31il riglificrnf b'ut has less€aed sioce 2011."
Bqcoein 1 UC Be*elry
(2o1s)
Usiag household-level data for 11,000 householils, the snrdy found
that'expeusive homes and wedthy homeowners are much msre
lilely to have solar parels." While ttre study suggerts that the
iacooe gap is it fiads that tte aectrge hmrehold
iore of e DG cn t<rrpr wr* Sff7.-4, coryGed b .o z@te
adirreof lSTtfos the averege hqrseholdir the sample.
Sokhrke
eoro
Study I'ey Findings
721
O. Should the cost shift be ignored due to the
modest number of residential customers who currently have
DG in ldaho?
A. Witness Levin (Snake River Alliance and NW
Energy Coalition) r3 has suggested that cument 1ow levels
of rooftop solar adoption in Idaho Power's servj-ce
territory are reason to delay the creation of a separate
DG rate class. fn fact, the opposite is true.
There are signifi-cant benefits to correcting
the DG rate design before rooftop PV is adopted in larger
numbers. At limited levels of adoptj-on it is easier to
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address j-ssues such as grandfathering of existing DG
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13 Levi-n DI, p. 23 .
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the current DG rates policy. The impacts of
grandfathering on
the issue grow
same also applies
educate customers
to customer education.
rooftop PV. The
It is easi-er to
customers and the contenti-ousness of
as more customers adopt
majority is in a simil-ar
have become bifurcated.
their rate options when the vast
situatlon rather than when they
The current leve1 of PV adoption should not
infl-uence the IPUCTs decision in reforming DG rates.
While the market penetration of rooftop solar may
currently be modest j-n Idaho Power's service territory,
the rooftop solar industry is a newly emerging industry.
In fact, SolarCity (a well-known, establ-ished national
rooftop sol-ar developer) was acquired in 20L6 by Tesla at
a price tag of $2.6 billion.1a Rooftop PV costs have
come down significantly over the l-ast several years, and
the solar industry has grown at the same time. The
number of DG installations i-n Idaho Powerrs service area
has increased by more than 400 percent over the past five
years.
VI. OTHER ISST'ES
a. Is a "Value of Solar" study a necessary
prerequisite for proceeding with the establ-j-shment of a
separate DG rate class?
about
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14 Robert Farris, "Tesl-a and SolarCity merger gets approval
from shareholders," CNBC (November 2076), accessed January 10, 2018
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A. No. Vflitnesses Beach (Sj-erra Club) ,1s Kobor
(Vote Solar),1e and Levin (Snake River Alliance and NW
Energy Coalition) 17 have suggested that a study of the
costs and benefits of rooftop solar PV be conducted
before creating a separate DG rate cl-ass. While research
can be helpful in understanding the costs and benefits of
sol-ar generation in ldaho, and helpful in integrated
resource pJ-anning studies, a VOS study shoul-d not be
viewed as being a prerequisite to establishing separate
customer classes.
VOS studies produce an extremely wj-de range of
results, even within a single jurisdiction. Earlier in
this testimony, for instance, I cited 1,2 studies which
found that the DG subsidy embedded in current rate
designs around the U.S. ranges from $444 to $\,752 per DG
customer per year. A study by The Rocky Mountain
Instltute, which surveyed 15 VOS studies, found that the
beneflts of rooftop sofar range from significantly below
to significantly above the average retail- rate. lB
This range of results from VOS studies can
J-argely be explained by the fact that the studies are,
for
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15 Beach Dr, p. 6
16 Kobor Dr, p. 14.
17 Levi-n DI, pp. 2l-22
18 Lena Hansen, Virginia Lacy, Devi Glick, "A Review of Solar
PV Benefit & Cost Studies, " prepared by Rocky Mountain Institute,
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practical reasons, heavily dependent on many assumptions.
Potenti-al- benefits such as avoided distribution costs due
to possible peak demand reductions from solar PV, for
j-nstance, are often based on anecdotal- information rather
than on detailed engineering studies, which woul-d be
expensive and time-consuming. Other assumptions in the
VOS studies are subject to simil-ar uncertaj-nty.
Further, the "va.l-ue" of solar is not relevant
when determining if one segment of customers is
distinctly different from another. That difference is
better addressed through an assessment of customer load
shapes and the associated system costs.
O. WiII the creation of a separate rate class
increase or reduce the uncertainty faced by customers who
are considering investing in DG?
A. Contrary to the comments of Witnesses Burgos
(City of Boise),1e King (ICEA;,zo Leonard (ICeal,zr and
White (ICEA),22 correcting the DG rate design now will
provide more certainty to customers who may be
considering investing in rooftop PV.
19 Burgos Dr, p. '7.
2o King DI, p. 12.
21 Leonard DI, p. 4-5.
22 white Dr, p. 4-6.t 25
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For the various reasons discussed earlier in
this testimony, net metering with flat volumetric rates
is not sustainabl-e and will require a change to the DG
compensatj-on mechanism. This inevitable change is
occurrJ-ng in other jurisdictions throughout the U.S.,
where net metering policies are being ended (e.9.,
Arizona, Hawaii) and/or the underlying DG rate structure
j-s being modified (e.9., Nevada) . Reforming the DG rate
now will take some of the uncertainty out of the
decision-maklng process for customers who are considering
whether or not to j-nvest in rooftop solar.
O. Should state and l-ocal- economic and policy
goals prevent a separate rate for DG customers from being
establ-ished?
A. No. Witnesses Bishop (Auric Solar),2s Burgos
(City of Boise),24 and King (ICea)zs have suggested that
the establ-ishment of a separate DG rate class wil-l- impede
economic development in the state, lead to a l-oss of
jobs, and j-nterfere with the state's environmental- policy
goals. Even if that were the case, rates shoul-d not be
tool-s for promoting economic and environmental policies,
but should rather be based on the cost of service.
Policy objectives
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23 Bishop Dr, pp. 2-3.
24 Burgos DI, pp. 2, 5.
25 King Dr, pp. 3-4, 74.
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are best promoted through other means outside of the
ratemaking process such as tax credits and income
subsidies.
Distributed PV is a clean source of electricity
that provides a societa1 benefit in the form of reduced
greenhouse gas emissions. From a policy standpoint, it
may be desirable to recognize these environmental-
benefits of PV and promote its adoption. However, it
does not make sense to selectively promote PV adoption
through hidden subsidies that are embedded in electric
rates.
If a price has been assigned to a certain
externality, essentially internalizing the externality,
and that price is part of the utility's cost structure,
then it is economically efficient to refl-ect the pri-ce of
that externality in rates for all- customers. However, it
would violate the core principles of ratemaking if only
certain customers or technologies were charged or
compensated for their impact on those externalj-ties.
Eor instance, investments i-n rooftop solar PV
that are arti.ficially subsidized through the current rate
structure could potentially instead be made in lower cost
utility-scale solar or EE, while achieving many of the
same benefits. A11 technol-ogies and customers should be
on a level
design.
playing field when developing resj-dential- rate25
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VII. EXPERIENCE IN OTHER iII'RISDICTIONS
O. Have utilities and regulatory commissions in
other jurisdictions established a separate rate class for
DG customers in order to address the various cost shift
issues described in your testimony?
A. Yes. I am aware of two notab]e cases: Sal-t
River Project ("SRP") in Arizona, and the Kansas
Corporation Commission ("KCC") .
O. Please describe the activity by SRP.
A. In 2014, SRP developed a proposal to create a
separate rate class for DG customers.26 SRP's governing
Board of Dj-rectors approved the proposal j-n 201,5.21 In
doing sor a three-part rate with a demand charge became
the standard rate for al-l- of SRP' s future residential DG
customers. Exj-sting DG customers were grandfathered
under the pre-existing rate structure.
O. Pl-ease describe how the DG cost shift issues
were addressed in Kansas.
26 Satt River Project AgricuJ-tura1 Improvement and Power
District, "Proposed Adjustments to SRPrs Standard El-ectric Price
Pl-ans Effective with the April 2015 Billing Cycle, " December 72,
201,4, accessed on January 10, 2078,http: / /www. srpnet . com/prices/
priceprocsss /pdf x/BlueBook. pdf .
27 trSRP Board Approves Reduced Price rncrease, " SRP (Sa1t River
Project) press release, February 26, 2015, accessed on January 10,
2018,http: / /www.srpnet. com/newsroom/releases / 022615. aspx.
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A.
explore
for DG
Energy
Order
Tn 20!6, the KCC opened a regulatory docket to
the possibility of creating a separate rate class
customers.28 After reviewing filings by Westar
and various intervenor groups, the KCC issued an
in 2011 confirmj-ng that DG customers should be
treated as a separate rate class with its own revenue
requirement.2e The KCC cited the significantly different
load and cost characteristics between DG and non-DG
customers as reasons for its decision.
O. Have other jurisdictions made simil-ar decisions
to address cost shift issues through specific rate
treatment for DG customers?
A. Yes. In California, the California Publ-ic
Utilities Commission elected to make time-of-use rates
the mandatory rate offering for resj-dential DG
customers.30 Unlike other residential customers, DG
customers will not have the option to enrol-l in a flat
rate.
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28 Kansas Corporation Commission, Staff Motion to Open Docket,
Docket No. 16-GIME-403-GIE, March 11, 201-6,
ht!p: //estar. kcc. ks . .p!E?I!=94
c1 8 f 0c- 1 4 2 4 - 4df2- 9d6e-8 l6t1 I 6'7b3 4'7 .
29 Kansas Corporation Commission, Final Order, Docket No.
16-GIME-403-GIE, March 11, 20L6, p. 8,
http://e@ewEi].e.aspx/S20160311132834.pdf?Id:e4
c1 8 f 0c-14 24 - 4dt 2- 9d6e-8 76f7 I 67b3 47 .
30 Cafifornia Pub1ic Util-ities Commission, Decision Adopting
Successor to Net Energy Metering Tariff, Rulemakinq 74-07-002,
January 28, 20L6,
http://docs.cpuc dDocs/Published/GOOO/M158/K181/158181
678.pdf.
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In Arizona, Arizona Pub1ic Servlce and
intervenors reached a settlement
established that residential- DG
agreement which
customers could choose
(2) a two-part rate with
and a "grid access
rate oreither (1) a three-part
a time-of-use volumetric
chargerr.31
rate option
customers.
charge
DG customers do not have access to the flat
that is offered to other residential-
O. Are there other notable cases of regulatory
commissions addressj-ng the DG cost shift challenges?
A. Yes. In Hawaii, the Hawaii Public Util-ities
Commission has ended the staters net energy metering
policy and replaced it with two other options.32 The
first is the "sel-f-supply option" in which DG customers
can net thelr DG output against their electricity
consumption, but are not compensated for net exports to
the grid. The second is the "grid-suppfy" option, in
which aII output from the PV system is compensated at a
l-evel below the retail- electricity price.
31 The grid access charge is a monthly charge based on the
capacity of the rooftop PV system; Ari-zona Corporate Commission,
Staff's Notice of Filing Settl-ement Agreement, Docket No.
E-01345A-16-0036 and Docket No. E-01345A-I 6-0t23, March 21, 201-'7,
http : / / images. edocket . azcc./docketpdf/00001784 13 . pdf.
32 Hawaii Publi-c Utillties Commission, Decisi-on and Order
Resolving Phase 1, Docket No. 2014-01,92i Order No. 33258, October 12,
20L5, http: /,/puc. hawaii. gov,/wp-content/upIoads,/2015/10,/
2Ol4-0192-Order-Resolving- Phase- 1 - I s sues - final . pdf .
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EARUQUI, REB 21Idaho Power Company
changes
customer
o.
experlence
A.Util-ities
Additionally, many utilities have pursued rate
for all customers, such as increasing the monthly
charge.33
What do you conclude from your review of the
in other j urisdictions ?
and regulatory commissions
increasingly understand the importance
chalJ-enges associated with the DG cost
of approaches have been
separate rate cl-ass for
with precedent in other
Idaho Power's proposal
elsewhere.
taken, and the
DG customers is one
jurj-sdictj-ons. In
is consistent with
of addressing the
shift. A variety
creation of a
such approach
this regard,
experience
o.
a separate
A.
customers
distinctly
VIII. CONCLUSION
Do you support Idaho Powerrs proposal to create
rate class for DG customers?
Yes, I support Idaho Powerrs proposal-. DG
have unique
different
load characteri-stics that make them
from the rest of the residential-
characteristics l-ead to a significant
customers are billed under the current
with net metering. That cost shift
left unaddressed. Given the trajectory
class. These load
cost shift when DG
resldential rates
will only grow if
of PV
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33 See, for instance, Mi-nnesota Public Utility Commission, In
the l"latter of the AppTication of Northern States Power Company for
Authority to Increase Rates for Electric Service in lulinnesota, Docket
No. E002lGR-15-826.
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Idaho Power Company
adoption in
the DG rate
Iate.
Idaho, it makes sense to proactively reform
offering, rather than waiting until it is too
O. Does this conclude your testimony?
A. Yes, it does.
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(The foll-owing proceedings were had in
open hearing. )
MS. NORDSTROM: This wj-tness is ready for
cross-examination.
COMMISSIONER RAPER: Ms. Germaine.
MS. GERMAINE: I have no questions. Thank
you.
COMMISSIONER RAPER: Mr. Carter.
MR. CARTER: I just have a few.
CROSS-EXAMINATION
BY MR. CARTER:
0
A
o
A
o
Welcome to Idaho, Dr. Earuqui.
Thank you very much.
Have you been here before?
Eive times.
Very good. Now,
in this case,'
is correct.
you submitted only
rebutta1 testimony
A That
O And
is that correct?
do you have a copy up there with you
today?
A Yes, I do.
O Okay, can you turn to page 4 and read
lines t2 to 15?a 25
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A "However, the rate that Idaho Power
currently offers to DG customers is identical- to the rate
for non-DG customers. It over-compensates DG customers
for the power they seII to the grid. "
O So is it correct to say the problem you've
identified here is with the value of exports provided by
DG customers?
A Correct.
O Okay, page 21, l- j-ne 8 through 12, can you
read those, please?
A "Eurther, the 'va1ue' of solar is not
relevant when determining if one segment of customers is
distinctly different from another. That difference is
better addressed through an assessment of customer load
shapes and the assoclated system costs. "
O Has ldaho Power provided an analysis of
any system costs associated with different customer load
shapes in this case?
A Thatrs not the subject of my testimony.
They may have, but I donrt know.
O On page 22, line I through 11?
A Would you like me to read them?
O Yes, please starting with "Reforming."
A "Reforming the DG rate now will take some
of the uncertainty out of the decision making process for
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CSB REPORTTNG
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EARUQUI (X)
Idaho Power Company
customers who are considering whether or not to invest in
rooftop sol-ar. "
O In this case, has Idaho Power proposed a
new DG rate?
A Not in this case.
O So Idaho Power
the DG rate now, is it?
A Thatrs right.
the witnesses that preceded me
correct.
is not proposing to reform
Based on the testimony of
on the stand, that j-s
O Okay, and I hate to ask this question, but
of compensatj-on forI always have to,
your testi-mony in
A I'm
what's your rate
this case?
always asked that question, and this
time I know the answer.
o
A
o
compensated
A
know, but I
Perfect.
550 an
Okay,
in total-
hour.
and do you know how much you've been
this case?
I don't
$100, ooo.
for your invol-vement in
incurring costs, So
total budget is about
I 'm stil-l
believe the
MR. CARTER: Thank you. No further
questions.
COMMISSIONER RAPER: Mr. Hammond.
MR. HAMMOND: Hopefully, I just have a fewo25
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questions and it will be brief.
CROSS_EXAMINATION
BY MR. HAMMOND:
O Thank you again for being here, Dr.
Idaho before?Faruqui. Have you testified in
No, I have not.
Okay; so we're knocklng that one off.
Il-linois, Indiana, Idaho. Are we going to
Are we going to get there and knock off all
A
0
You've got
Iowa next?
the trI t srr?
A
o
that the Company is proposing to
class for net metering customers
discussed, customers with on-site
A That's correct.
I am excited.
So in this case, is it your
establ-ish
understanding
a new rate
or, I guess what we've
generatJ-on?
O And that through that process, eventually
we're going to or the Company wants to propose to get
different rates and perhaps maybe a different rate design
for on-site customer generatj-on at some point in the
future?
A Possibly. I thj-nk we heard from witness
Tatum earlier today about the process, that this is thet25
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(208 ) I90-sr_98
FARUQUI (X)
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beginning of the process, but at l-east Irm not privy to
what that rate might be.
O So in essence, in your opinj-on, 1s the
Company taking a step in the ratemaking process?
A Yes, I be1ieve they are.
MR. HAMMOND: Okay, f have an exhibit I'd
like to hand out if that's okay, and I'11 start with the
Company and work my way back.
COMMISS]ONER RAPER: Is it three inches
thick?
MR. HAMMOND: ft can be. It depends on
what you want. Be careful.
COMMISSIONER RAPER: I already have one of
those.
MR. HAMMOND: May f approach the witness?
COMMISSIONER RAPER: Yes.
MR. HAMMOND: Okay, thank you.
(Mr. Hammond approached the witness. )
(Snake River Al-l-iance &NW Energy
forCoalition Exhibit No. 1005 was marked
identification. )
O BY MR. HAMMOND: f've
we've marked as Snake Ri-ver Alliance
Coalition Exhibit 1005. Do you recognize this document
that I've handed to you?
handed you what
and NW Energy
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A
O
Yes, I do.
And was this a presentation that you gave
at some point in the past?
A
a
presentation?
A
o
are a
t itle
Yes.
Was this regarding ratemaking, this
Yes.
So on the second page, we have some bubb1e
points or bubbles that
me what at the top the
A "Basic Steps
thereO And is
ratemaking process?
A Determination of revenue requirements and
overall cost of service.
O So what we're doing here today is part of
a ratemaking process and in your presentation what you've
stated is the overall cost of service, in the past fair
to Sdy, is sort of the first step in that ratemaking
process; is that correct?
A That ' s right, and sometimes it I s cal-led
Phase 1.
MR. HAMMOND: I have no further questions.
COMMISSIONER RAPER: Thank you. Mr.
Nykiel.
nice diagram. Can you tel-l
of this page says?
in Rate Making Process. "
a first step in that
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Idaho Power Company
NYKIEL: Thank you.
HAMMOND: Oh, excuse me, I
to ask for the admissi-on of Exhibit
MR
MR apologi ze,
1005 intoI'm going
the record and submit it for the Commission's
consi-deration.
COMMISSIONER RAPER: Thank you. Without
objecti-on, Exhibit 1005 will be admitted and we always do
a catch-a1I at the end to get anything that wasn't
objected to, but I appreciate your catch.
(Snake River All-iance & NW Energy
Coalition Exhibit No. 1005 was admitted i-nto evidence.)
COMMISSIONER RAPER: Now, Mr. Nykiel.
MR. NYKIEL: No questions. Thank you.
COMMISSfONER RAPER: Thank you.
Ms. Nunez.
MS. NUNEZ: We do have a few questions.
Thank you.
CROSS-EXAM]NATION
BY MS. NUNEZ:
Hello, Dr. Faruqui.
Hello.
Would you please refer
rebuttal- testimony?
to Figure 5 on page
1"6 of your
o
A
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A So is it possibly page 6? Irm sorry, I
Iost you there.
O Figure 5.
A Figure 5.
O Yeah.
A Yes, I'm there on page L6.
a Great, thank you. Is it correct that this
figure contains estimates of cost shifts from net
metering that was presented in other states often in
contested regulatory proceedings?
A It comes from a variety of sources. It is
data that we surveyed, the publicly-available studies, dt
the time that the article was written in October of'L6,
and we compiled the data and we did not develop the data.
We just compiled it from existing publicly-available
sources.
O Okay, were some or al-l- of those estimates
prepared by or on behal-f of the utility companies in
those proceedings?
A That I am not 100 percent sure about.
O Okay, when preparing this figure, did you
al-so review estimates that were -- wel-I, you kind of
already answered this. You were comparing estimates from
various sources, from utilities, perhaps. Do you know if
some of those estimates were prepared by parties
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Idaho Power Company
representing the solar industry, such as the various
studies that were referenced i-n Dr. Thomas Beach's direct
testimony?
A f donrt know.
o
testimony at
when you get
A
a
sentence that
A
which surveyed
rooftop solar
significantly
o
that there are
j urisdictions,
cost s ?
A
Can you
on lines
Okay.
page 20
there.
now please refer to your
15 through 18? Will you
Yes, Irm there.
Okay, thank you. WilI you please read the
begins with "A study"?
"A study by The Rocky Mountain Institute,
15 VOS studies, found that the benefits of
range from sj-gnificantly bel-ow to
above the average retail- rate."
So in this sentence are you acknowledging
studies available that show that in some
benefits of net meterj-ng exceed the
There are studies and studies that show
anything you want.
O Eair enough. Okay, thank you. Now refer
to page 4, please, and the lines L2 to 15 of your
testimony, which Mr. Carter already referenced, so i-n
that section, you're assertj-ng that net metering
overcompensates Idaho Power's DG customers. In arri-vingo25
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FARUQUI (X)
Idaho Power Company
at this conclusion, did you review or conduct any
comprehensive study of costs and the benefj-ts of net
metering in Idaho Power's territory specifically?
A No.
MS. NUNEZ: Thank you. Those are all my
questions.
COMMISSIONER RAPER: Thank you, Ms. Nunez,
and I real-ized that I skipped
PRESTON:
over Mr. Preston.
MR No quest j-ons.
RAPER: ThankCOMMISSIONER you. I didn't
talk you out of it, did I?
MR. PRESTON: No.
COMMISSIONER RAPER: That was not my
intent, I apologi ze . Mr . Costell-o .
MR. COSTELLO: I have a couple of
questions as wel-1.
CROSS-EXAMINATION
BY MR. COSTELLO:
O So just to make sure that I understand
you -- understood you correctly earlj-er, you said that
you didn't know whether the Company presented any
evidence of how load shapes drj-ves assocj-ated system
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A Thatrs correct.
O You have no idea?
A I was focusing on the load shapes and how
they differ between PV customers and non-PV customers.
O Did the Company submlt a cost of service
study?
A Not to me.
0 Okay; so when you say that determj-ning
distinct di-fferences between customers is better
addressed through an assessment of customer l-oad shapes
and associated system costs, you're here speaking about
one-half of that equation?
A Would you mind? I've sort of lost track
of which page you're on.
O That's page 27, Iines 10 through L2.
A So what I'm saying there is the value of
solar is not relevant when determining if one segment of
customers is distinctly different from another. That
difference is better addressed through an assessment of
customer load shapes and associated system costs, that's
correct, yesr so I have looked at the load shapes, I have
not at the system costs.
O Thank you. I just want to tal-k a little
bit about your testifying in other jurisdictj-ons
throughout the country. In your rebuttal testimony at
EARUQUI (X)
Idaho Power Company
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page J, lines 9 through 13
A Irm there.
O there you state that two other states
have implemented a separate net metering or DG rate
class; is that correct?
A Yes.
O Okay, and you testified in Kansas before
the Kansas Commission?
A Yes.
O Okay, great, but within that docket,
within the docket in Kansas, there was discussion of
appropriate rate structure as well as a class cost of
service study before the Commission -- before the
decisi-on was made to separate out the DG rate class; 1s
that correct?
A That's correct.
O Okay, and then you al-so testified in
Nevada rel-ated to net metering; is that correct?
A Yes.
O And in that case, your testimony in that
docket, and correct me if I'm wrong, it was more focused
on a three-part rate design?
A Yes.
O But you're generally familiar with the
docket 1n front of the Nevada Commission?
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Idaho Power Company
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Idaho Power Company
A
o
al-so present
A
o
overturned the
I bel-ieve there was.
Okay. Of course, the
Commission's decision
Nevada legislature
and then there I s a
Yes. Itr s been awhj-l-e, though.
Okay. WelI, a cost of service study was
on the record in that case; correct?
statute now that basically makes a separation of net
metering customers from the residential cl-ass i11ega1; is
that correct?
A
just reading it
NV Energy, but
forth.
o
That part I cannot be certain of. I'm
through the media. frm not in touch with
yeah, there has been a lot of back and
Okay, thank you; so just one final
question, so correct me if Irm wrong, but the fact that
Nevada no longer has a separate cl-ass, based on your
experience testifying around the country and your survey
of state actions rel-ated to net metering, tf this
Commission were to
woul-d be
approve a
the onlydocket, it
the country
evidence on
to do so without
separate rate class in this
utility regulatory body in
some sort of cost-based
the record; is that correct?
So my work has focused on looking at load
not been looking at the cost of service
A
shapes. I
studies.
have
I donrt know j-f there are any that have beena25
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CSB REPORTING(208) 890-s198
TARUQUI (X)
Idaho Power Company
carri-ed out or not.
MR. COSTELLO: Okay. Thank you. Thatrs
al-1 I have.
COMMISSIONER RAPER: Thank you. Mr.
Bender.
CROSS_EXAMINATION
BY MR. BENDER:
O Good afternoon, Doctor.
A Good afternoon.
O I just want to before we talk about some
of the details of your testimony, I just want to clarify
something. Throughout your testimony, you refer'to DG
customers. I understand it's distributed generation
customers; correct?
A Correct.
O But the data you l-ooked at were al-l net
metered customers specifically; correct?
A So those net metered customers are a
subset of the DG customers broadly speaking, so Ifm
using, in this context, I'm just focusing on customers
who have photovoltaic rooftop sofar panels on the roof.
Those are the DG customers that I'm focusing on. There
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CSB REPORTING
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FARUQUI (X)
Idaho Power Company
technologies. I'm not looking at those.
O Right; so you 1ooked just at solar PV
you l-ooked at just customers who net meter wj-th their
distributed generation?
A Thatrs correct. I don't know if there
customers who are DG customers, but not net metered.
don't know if there are any such customers. The ones
looked at were net metering customers.
And so the
and
are
I
I
o
you're doing in
customers?
A
o
storage?
A
comparj-son of l-oad shapes that
is specific to net meteredthis case
Correct.
And that's net metered customers without
Net metered customers with sol-ar.
O So you don't know if any of those have
storage in addition to sol-ar?
A So could you repeat that?
O Do you know whether the load data that you
looked at includes any customers with storage, battery
storage, 1n additj-on to solar?
A I don't know. I have no way of
differentiating.
O Letrs look at page L6, again, of your
testimony. We talked about this figure.o 25
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CSB REPORTING(208) 890-s198
FARUQU] (X)
Idaho Power Company
A Did you say 1-6?
O Page 16, Figure
A Oh, yes.
O As I understand
analysis.
A Correct.
it, you did a survey of a
you did not conduct any cost shift
that right?
not.
5
O Okay,
analyses yourself; is
A Idid
0 Okay, and
cost shift analyses that
cost shift
A
by BrattJ-e or
o
basj-calIy did
right?
you did not
show up in
That's correct. None
conduct
Figure 5;
of these
any of the
correct?
were done
by me.
As I understand yolrr survey method, you
Internet research to find these; is that
A The Internet broadly interpreted, right,
so basically I didn't just Google. I kind of knew where
activity was occurrj-ng and I downl-oaded those reports,
and then I extracted the numbers and we put them in this
bar chart
O Okay, is it fair to say this is not a
complete list of aII analyses done of potential cost
shifts for net metering?
A That is correct.t 25
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CSB REPORTING(208) 890-s198
FARUQUI (X)
Idaho Power Company
A Okay,
one bar and then we
and of these, we have Idaho Power as
have four for Nevada NV Energy,
correct?
A Right.
O In that case, you were a hired witness for
NV Energy; correct?
A I was an expert witness.
O And they paid you?
A Yes.
O Yes; so you were a hired witness for NV
Energy. AIso, you were a hired witness for Arizona
Public Service; is that right?
A Subsequently.
O Okay, but of these, dt l-east half are
instances where you were hired by the company who
produced the study; correct?
A So I did not produce these estimates for
the company. They didn't hire me to do these estimates.
These studies were done j-ndependently of their
relationship with me, but y€s, those were my clients at
various stages. I mean, actua11y, if you want to go down
that path, PG&E also hired me in other cases. San Diego
has hired me. Arizona Public Service has hired me.
Idaho Power has hired me, so I mean, I don't know what
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O These are utilities that you were already
familiar with?
A I'm familiar with most utilities.
O And these are the utilities' calculations
that you present here?
A These are calculati-ons that either the
utilities did themselves or other consultants estimated,
like E3 is a consulting firm that I believe is widely
known and they were doing that study for Nevada. I donrt
remember if their client was NV Energy or the PUC or
both.
O Did you read other parties' tesLimonies 1n
the APS case, Arizona Pub1ic Service case?
A Which case?
O The Arizona Public Service rate case in
which you were a witness.
A The one that settled?
a Yes, the one that sett]ed last summer.
A I read those testimonies that pertained to
my testimony.
O Did you read Vote Solar's testimony?
A Off the top of my mind, I cannot say yes
or no. Maybe I did.
O Okay, do you reca11 that Vote Solar redid
Arizona Public Service's cost shift calculation and
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Idaho Power Company
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Idaho Power Company
determined that there were some cost allocators
misapplied?
A I donrt know
O But you had that testimony, because you
in that case.
They only shared with me the testimonies
were relevant for me to look at. I donrt
were a witness
A
that they fel-t
specifically
recal-culating
o
remember the Vote So1ar testimony
these numbers.
Okay, do
in which
you recall in the NV Energy value
of sofar docket you were a
of the cost
witness that Vote
Solar did a calculation
A SoIwas
docket. I was just in
O Okay, do
shi ft ?
not part
their rate
of the value of solar
you recal1
design case.
in the rate design
the alleged costcase testimony
shi ft ?
A
from Vote Sofar on
There were some solar companies
participating
specifically
know Task was
in the rate design case,
remember if Vote Sol-ar was
but I canrt
one of them.
couple of
there or
I
one of them and there were a
others. I don't remember if Vote Solar was
not.
0 Okay, but if Vote Sol-ar was in the case
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CSB REPORTING(208) 890-s198
FARUQUI (X)
Idaho Power Company
their analysis of the cost shift as wel-I; correct?
A The focus of my work differs in each case
and in that case, ily focus was to make the case for
three-part rates and that's what they asked me to focus
on. I was not specifically looking at the cost shift or
value of solar studies. They were dealing with that
through other experts.
O So fair to say those did not factor into
your survey or make it into your chart?
A The survey was done not just by me alone,
but as you can see in the Footnote No. B, Bob Alexander,
who is a consumer advocate, and Ashley Brown, who is at
the Harvard Electricity Policy Group, all- three of us
looked at the sources that are out there at the time we
were writing the artj-cle and we compiled it. I'm not
f'm not saying that I meansayi-ng this is comprehensive.
I'm defending each and e.very one of these numbers. I'm
just trying to make a point
assortment of studies, the
that if you look at a wide
subsidies amount to hundreds
of doll-ars a year per customer.
Right, and the wide assortment are studies
utilities or their consultant, that's what we
O
thedone by
have in this ?
A Some of them, I believe, were done for
commissions as well.I 25
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CSB REPORTING(208) 890-s198
EARUQUI (X)
Idaho Power Company
O You said the E3, but the rest are the
utilities' esti-mates?
A You know, this is an arcane field. I
donrt remember the sources, but I believe most of them,
they are definitely studies that went through a public
process where commissions, utillties, j-ntervenors all
were providing input. This i-s the upshot that came out
of it. I didn't dig deeper into the studies.
a The upshot meaning this is what the
commission found?
A Irm sorry, say that again.
O You said this is the upshot of that
process, do you mean -- are you representing the
commission agreed with these and found these to be the
cost shifts?
A That I don't know, but what I was
when I said upshot, what I meant was it had been
a process and then the studies came out and then
were released.
saying
through
they
o
advocacy in
A
process was.
0
correct?
The utility subm-ttted this as their
those proceedings?
I don't know the details of what the
Let's l-ook at Idaho Power. You have $444;
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CSB REPORT]NG(208) 890-sr_98
FARUQUI (X)
Idaho Power Company
A
O
A
o
Right.
And you have in parentheses 20t.5.
Yes.
And the note says, "Year indicates date of
is sometimes a forecast",'cost shift estj-mate, which
correct?
A
O
annual report
prevj-ous1y?
A
Yes.
Is that referring to the 2015 net metering
that Ms. Aschenbrenner talked about
I believe that's correct.
O Okay, and
when we ta]ked about how
you were here for her testimony
as of 20L5, the analysis showed
366 customers,'a 55,000 cost shift among
Yeah, I did not follow that, but I heard
somethi-ng like
correct?
A
it, yeah.
O Okay, in the $444
single hypothetical customer. Do
A I don't.
O So to the best of
still- represents what the Company
the cost shift was per customer?
A It represents the
1ooked at the study.
was a projection from a
you reca11 that?
your knowledge, this 444
calcul-ated as of 20].5
number that I saw when I
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Idaho Power Company
Looking at
at page 9
hourly
right?
A Ten?
A Nine.
A Nine,
a Okay.
DG and non-DG
Correct.
So this is across two different zones,
summer and winter; correct?
Correct.
And these are when you calculated Ioad,
calculated net hourly flow; is that right?
So as you heard from the earl-j-er
O Letrs talk about l-oad shapes, okay?
your rebuttal testimony, page 6 --
A Page 6?
O Actually, Iet's skip that one. Letrs l-ook
okay.
Eigure 2, you are comparing average
customer load profiles; is that
A
o
A
o
you actually
A
wJ-tnesses, for the
they stil1 have a
measuring the net
DG customers, once they install DG,
single meterr so that single meter is
flow of power as opposed to the gross
customer or the gross exports ofconsumption of
power. It is
the
unable to do that. You woul-d need two
separate meters to do that, so the data that we were
provided by Idaho Power in the post-DG time frame shownt25
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Idaho Power Company
with that red curve,
the customer and the
O Right;
defined it, it's the
A That's correct.
O So if we were to
which would mean any hour where
so an export, if we zeroed that
those hours, w€ could redo this
A That would not be
it is the net fl-ow of power between
grid.
so it's not the l-oad as Mr. Ange1l
net flow?
data that I have seen has customers at zero
restrict this to 1oad,
there's l-ess than zero,
out as zero load for
load analysis?
the load of the
no average
Ioad in the
customer. A customer cannot have zero 1oad.
O A customer cannot have zero l-oad?
A What you're saying is that the average
customer will have zero load and I'm saying
middl-e of the day.
O So the
customers in
negative flow
net metered,
the summer that have
or you call them DG,
negative load or
1t between 10:00 and,as we just redefined
eyeballing thisr sdyr 4:00 p.m.?
A Yes, so thatrs the net load. We could
call- it net inflow/outflow or we could call it net load,
but it's certainly not the gross l-oad and it is also not
their export. It is the net of those two.
O Righti so within the group, some areo25
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FARUQUI (X)
Idaho Power Company
importing and have load,some are exporting?
customers, there would be aA For the DG
strong probability that when the sun is shining in the
afternoon, they wil-l- be exporting. It depends, of
course, on the size of the array. Tf the array is
correctly sized, they wil-l probably be exporting in those
hours, but some may not be. I'm not saying everyone is
going to be, but this is the average shape collectj-vely
of that group of DG customers.
0 So when they are exporting, pushing power
out
A Right.
A thej-r generation exceeds whatever
they're using in the house; right?
A Yes.
O So theyrll have zero utility-supplied load
in those hours. The electricity is flowing out during
those hours.
A So they're consuming electricity as well
as producing electri-city. Theyrre wearj-ng two hats.
O Theyrre consuming their own generation and
they're pushing the rest of it out to the grid?
A Subject to some technical discussj-on
that's beyond my skill- set, I'm not an electrical-
engineer, but I have been tol-d by people that they are inI25
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FARUQU] (X)
Idaho Power Company
two separate
or not, but I
are consuming
surplus out.
channels. I don't know if that
could go with your presumption
their own power first and then
1s correct
that they
sending the
O Okay; so those hours they have zero load
on the utility's grld?
A They're not importing power from the grid,
yes -
O They're not consuming grid-supplied
power?
certainly
house.
A I'I1 go along with that, but they're
consuming power. That's not the load of the
O We1l, your shapes are not the load of the
house either, are they?
A That's correct. I'm unable to show the
Ioad of the house.
O These are also averages; correct?
A Correct. We have also done it separately
for individual customers in other studies and generally
speaking, the averagesr we did that other comparison in
Kansas, show that this general shape of negatj-ve net load
during the sol-ar generation hours is to be found in most
DG customers.
O Letrs exclude hours where therers export.t 25
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CSB REPORTING(208) 890-s198
FARUQUI (X)
Idaho Power Company
Letrs talk about hours where these customers are net
consumers of grid-supplied electrj-cj-ty.
A Okay.
O Okay, in those hours, there's going to be
a range of usage of load from net metered customers;
correct?
A Correct.
O Is it also fair to say that there's
non-net metered customersto be a range of load of
those same hours?
A Correct.
o
you t re
range
A By and 1arge,
that the
you would expect that to be
the case,assum]-ng
is similarcustomer
customer and assuming that they have simil-ar
demographics, appliance ownership characteristics,
similar income profiler so in other words, they have
simil-ar lifestyles, if that is j-ndeed the case, then
yes.
O Okay; so if we exclude exports and we look
at grid-supplied el-ectricity consumed by customers, in
those hours, net metering customers, there would be a
going
in
right,
in the
And if you plotted all of those out,
going to see the net metered customers fall-
of the non-net metered customers; correct?
average size of the sol-ar
to the average size of the non-solar
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FARUQUI (X)
Idaho Power Company
wide distribution of them, non-net metering customers,
wj-de distrj-bution of them and those plots are going to
fall- in the same peak?
A Right; so we're looking
when they're not generating power that
consumption. It may not be exactly the
see in the hours that we're lookj-ng at
you l-ook at those hours, let's say, in
until 10:00 a.m. and then the red line,
at those customers
exceeds their
same as you will
in Figure 2. rf
the early morning
which is the DG
customers, is higher than the l-ine of the non-DG
customers.
0 That ' s the average, ri-ght , and I 'm saying
the dlstribution.
A Yeah, I woul-d expect there to be some good
overlap.
O Then your Tab1e 1 on page 10, you
corrected this to be the customers before and after DG,
and thj-s is their average monthly net consumption and
their net load factor?
A Correct.
O And as werve already discussed, it's
actually the net flow over the month divided by their
peak; correct?
A For the load factor?
O Yes.o 25
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EARUQUI (X)
Idaho Power Company
A Yes.
O Right; so you don't deflne load factor as
load, as imports, divided by peak, you do net fl-ows over
the whole month dlvided by peak?
A I'm looking at their average monthly
demand which if you
7kw
l-ook at the pre-PV summer months,
that number
the implied
look at the
load factor
l_s and their consumption is 1,,207 r so
there is 24 percent, and then I
post-PV summer months and thelr
fel-I dramatically by 51 percent where their
only fell- by 3 percent and, therefore, their
consumption
peak demand
l-oad factor
fell from 24 percent to 11 percent.
O So when you say energy consumption, we're
actually talking about billed energy?
A Correct, because they are net metered
customers.
O Right; so what we're looking at that goes
to 11- percent is their billing divided by their peak
load, not their corrsumption divj-ded by peak?
A We don't know what their consumption is.
O Right, and it's not even the grid-supplied
electricity kil-owatt-hours divided by their peak?
A It's exactly the consumption that you're
billing them on. We think that j-s the appropriate metric
because that i-s how the grid interacts with them.25
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A So anything that theyrve exported you
reduce from their consumption?
A Correct. Itrs their net consumption,
because that's what they're billed on, theyrre net
metering.
O lt's not what they consumed and j_t's not
their imports over the month, it's their net flows?
A Correct, because that's what they're
billed on.
O And thatrs the same thing for Figure 4 on
page !4?
A Yes. Werre not showing any load factors
here, but the concept that you're referring to j-s indeed
the same, which is werre looking at their net load
profile and we are comparing it to the non-DG customers,
which is the solid bl-ack line, and then to look at the
diversity question whj-ch is being addressed herer w€ have
the 10th percentile and the 90th percentile of the non-DG
customers to show that spread, the diversity, thatfs
naturally occurring in the non-DG population, and we are
saying that the red curve is distinctly different in
shape and its negativity from the spread that is between
the 10th and the 90th percentile of the non-DG
customers.
O Right, and what you did here is it's net
CSB REPORTING(208) 890-s198
FARUQU] (X)
Idaho Power Company
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FARUQU] (X)
Idaho Power Company
flow again, rightr so the red l-ine drops below zero?
A Correct, right.
a And yourve reduced hourly loads by
exports?
A You reduce
have so much consumption,
Each hour is a different
hour and then the result
1ine.
your yeah, basicall-y you
you have
sorry. We
is plotted
so much production.
subtract them in each
out in the red
O So if we wanted to l-ook just at their grid
imports, those hours where they have grid imports, right,
and we exclude exports from a load comparison analysj-s,
okay, if that's the analysis we're going to do, the red
l-ine is not going to drop below zero; correct?
A Yeah, if I understand correctly, what
you're saying is yourre not now looking at those
customers as the grid looks at them, but you're doing a
different scenario in which you're assuming that they
are that whenever they export power and, therefore,
they have negative net load, you're going to just zero
that out.
O Right.
A So mathematically what you're saying is
correct.
O So it worked out bel-ow zero and the curveo25
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FARUQUI (X)
Idaho Power Company
will be flatter, because in some of those
some net exports are
the group, right, and
A Yeah,
the grid and we
net metering is
O
you answer my question?
A Would you
O Sure. If
A But that's not
grid, so I'm not sure why we
want to assess what is their
offsetting some net
so it will flatten
how they
wou]d do
shoulder hours,
imports within
out ?
interact with the
grid
by
it will- l-ose that biq dip that it
has.
O And it wil-l- al-so fall- within the 90th and
1Oth percentile bookends; rj-ght?
A Probably, yeah.
O So what we're sayj-ng is if we're just
looklng at grid-supplied electricity serving load and
we're not calling exports a 1oad, then the net metered
customer loads are falling within the natural
distribution, the 10 and 90 percent distributj-on of the
cl-ass ?
that. I mean, we
interaction they have with
can't ignore the main
because they want to
reason they're on
export.
I understand that's your argument. Can
mj-nd asking it again?
we want to look at load and
we're defining load by what's being supplied by the
to the customer, right, and wefre not discounting ito25
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FARUQUI (X)
Idaho Power Company
exportsr w€ just want to l-ook at what they're consumi-ng
from the grid, we want to plot that load, what we're
saying is the red l-ine is not going to drop below zero
and it's actually going to faII within the 10th and 90th
percentile range of the class as a whole?
A In prlnciple, I agree. I haven't done the
cal-cufations, so I don't know how much the red line is
going to move, but it might wel-I fall- within the 10th and
9Oth percentiles.
O And actua11y, j-f we broke out
you're doing here j-s 90th percentile is one
so what
group and
broke thethen the average of the other; right? If
net metered customers out and plotted them
we
right,
all of
they're
them are
going
going
well;
So if
individuals as
A
individually,
to fal-l- within that range, almost
to fal-l- within that range, dS
correct?
we do that with their negative parts
chopped off, again, I've not done that calculation and
there will certainl-y be some vari-ation, there wiII be
some diversity in the DG customers, but the way we are
now talking about them, they are no longer DG customers.
They are some other customers that donrt exist.
MR. BENDER: Nothing further. Thank
you.
COMMISSIONER RAPER: Thank you. Are thereo25
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FARUQUI (Com)
Idaho Power Company
any questions from the Commissioners?
BY COMMISSIONER RAPER:
O I just have one for clarificatj-on based on
readi-ng within your rebuttal testimony that Mr. Carter
asked you to make. On page 22, Iine 8 through !I, when
you read the sentence beginning, "Reforming the DG rate
now, " is that to say that creating a new rate now will
take some of the uncertaj-nty out or beginning the process
now?
A Beginning the process of looking at the DG
customers as a separate class is the first step of a
process. It might perhaps evolve into thej-r being
separate rates. There would be a recognition that these
DG customers interact with the grid in a very different
way even if
opportunity
shoul-d their
o
way that the
Carter pointed it out
contrary to what the
I -- "Reforming the
the rate is not changed and then the
is there to dive deeper into it and to see
rates change, also.
Right, and I understand that.
sentence is read, which may be
to begin with, al-most
Company's position is,
Just the
why Mr.
sounds
which is why
DG rate now will take some of theo25
177
EXAMINAT]ON
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uncertainty out of the decision making process for
customersr" so you're not saying I'm trying to square
that with what I understand the Company's posl-tion is.
Do you mean if they were to actually change the rate now
that it would take some of the uncertainty out, because
thatrs how I read that?
A Thatrs whatrs written.
O It is, so do you stand by that testimony?
A That's my personal positi-on.
O That if the company were to change the
rate at this time, not open up a docket, not look at
things and have discussions, but changing the rate at
this tlme would take some of the uncertainty out?
A I think if I may be al-l-owed to just
elaborate, what I'm looking at is what's happening around
the country and how all of these conversations are
progressing. We have l-ooked at the NARUC Manual-, the
three-inch document you mentioned. We have a l-ot of
sessions occurring at NARUC and EUCI and other forums. I
was just at a session in New York earlier on Tuesday, so
this is happening and what I'm saying is that there's an
opportunity to recognize that this is an issue, and f'm
making a general statement, not necessarily for Idaho
Power in this particular proceeding, but just a general
statement that the longer we waj-t the more difficul-t it
CSB REPORTING
(208 ) 890-s198
FARUQUI (Com)
Idaho Power Company
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PARUQUI (ReDi)
Idaho Power Company
wil-l become to change the rate.
COMMISSIONER RAPER: Okay, thank you.
That's al-l- I have.
Is there any redirect from the Company?
MS. NORDSTROM: Yes, thank you.
REDIRECT EXAMINAT]ON
BY MS. NORDSTROM:
O Dr. Faruqui, Mr. Bender and you discussed
exports in the context of load profiles. In your
professional- opj-nion, why is it important to l-ook at
exports when you're looking at load profiles in
interaction with a utility's system?
A So in my opinion, the DG customers have
instal-led DG for one very simple reason, they want to be,
as much as possible, grid independent. They want green
power. They want it on their roof, and so when they
instal1 that DG, it is not a conservation-only
technology, because if they wanted to do onJ-y
conservation, which is reduce their 1oad, they would have
bought a more efficient aj-r conditioner or more efficient
furnace or j-nsulated their house or put a smart
thermostat or put more insulation and that would be a
pure energy efficiency case, but that is totallyt25
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CSB REPORTING(208) 890-s198
EARUQUI (ReDi )Idaho Power Company
different from what a DG customer's life is about.
They want to have their own power
generation. They're prosumers. They're no longer
consumers. They are prosumers. They are both consumJ-ng
and producing, and so ultlmately in most cases what ends
up happening is that they wiII export power durlng
certain hours and they wiII import power during other
hours. When the sun goes down, those PV panels just sit
on the roof and do nothing. The moonlight is not
suffj-cient to generate power, at l-east with the current
technology, so what you have is they are going to be
exporting and importing; otherwise, their bill is not
going to go down, and the only way their bil-l is going to
go down is if they export at certain hours to compensate
for importi-ng j-n other hoursr so if you take out that
sort of be11y of the curve and we say that they have zero
load, then we are basically assuming away the fact that
they have installed the photovoltaic cel-l-s to produce
power during those hours, and this is called the duck
curve.
It's universally understood and known that
the penetration of solar is going to create this
challenge and the more sol-ar you have the bigger that
challenge is going to be. A customer could conceivably
have zero consumption because they put the sol-ar arraya25
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CSB REPORTING(208) 890-5198
with just
zeto bill
the right size and,
except for the $5.00
therefore, they'I1 have a
fi-xed charge. That is not
appropriate in terms of the other customers who don't
have solar. Itrs a huge cross-subsidy.
MS. NORDSTROM: Thank you. No further
questions.
COMMISSIONER RAPER: Mr. Faruqui, I
bel-ieve that we are done.
THE WITNESS: Thank you very much.
COMMISSIONER RAPER: Thank you, Dr.
Faruquir ffiy apologies.
(The witness left the
COMMISSIONER RAPER:
stand. )
That's going to do
It's 10 after 5:00.everyone
We will-
in for the d.y, I bel-ieve.
reconvene tomorrow, March 9th. I have a
colleague who would like 9:00 and a colJ-eague who woul-d
like 9:30, so being quite litera11y in the middle of
them, I'm picking 9:15. We will- reconvene at 9:15 a.m.
tomorrow. Thank you.
(The Hearing recessed at 5:13 p.m. )
25
781 COLLOQUY