20220510IPC to ICL 1-6.pdf

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LISA D. NORDSTROM
Lead Counsel
[e-mail]
f i :1r.'Ji!,Jl:l
May 10,2022
Jan Noriyuki, Secretary
ldaho Public Utilities Commission
11331 W. Chinden Boulevard
Building 8, Suite 201-A
Boise, ldaho 83714
Case No. !PC-E-214O
Application to Expand Optional Customer Clean Energy Offerings Through
the Clean Energy Your Way Program
Dear Ms. Noriyuki
Attached for electronic filing is ldaho Power Company's Response to the First
Production Request of the ldaho Conservation League in the above-entitled matter.
lf you have any questions about the attached document, please do not hesitate to
contact me.
Sincerely
Re
X* !.7("1.t ",*,Lisa D. Nordstrom
LDN:sg
Enclosure
P.O. Box 70 (t3707)
1221 W. ld.ho St.
Boiic, lD E:t702
LISA D. NORDSTROM (lSB No. 5733)
ldaho Power Company
1221 West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
ln o rd strom@ ida hooower. com
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION TO
EXPAND OPTIONAL CUSTOMER
CLEAN ENERGY OFFERINGS
THROUGH THE CLEAN ENERGY YOUR
WAY PROGRAM.
CASE NO. IPC-E-2140
IDAHO POWER COMPANY'S
RESPONSE TO FIRST
PRODUCTION REQUEST OF THE
IDAHO CONSERVATION LEAGUE
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COMES NOW, Idaho Power Company ("ldaho Powef or "Company"), and in
response to the First Production Request of the ldaho Conservation League ('lCL") dated
April 19,2022, herewith submits the following information:
IDAHO PO\A'ER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE IDAHO
CONSERVATION LEAGUE TO IDAHO POI/VER COMPANY- 1
REQUEST FOR PRODUGTION NO. 1:
Ms. Williams' Direct Testimony, page 39, lines 8-14, states that the Program
Charge for the Subscription option will include "administration and marketing costs to
advertise and maintain the offering" and, separately a "term adjustment charge" applied
to subscriptions for less than 20 years. Then, on page 40, lines 7-9, Ms. Wlliams states
that the term adjustment charge will cover "ongoing advertising and marketing." How is
ldaho Power distinguishing between these two sources of funding for the advertising and
marketing to avoid double collections of these costs?
RESPONSE TO REQUEST FOR PRODUCTION NO. 1:
The overall Administrative Charge (paid by all subscribers, regardless of term
length) is intended to cover the costs of an initial marketing push and general program
administration.
The Term Adjustment Charge recognizes that customers under one-month, 5-
year, or 10-year term lengths will leave the program at unpredictable (month-to-month)
and predictable (5- and 1O-yearterms) times. The Term Adjustment Charge will be scaled
(that is, highest for the shortest term) to account for the levels of unpredictability for
month-to-month subscribers and, to a lesser extent, subscribers with 5- and 1O-year term
lengths. The charge will provide dedicated funding to renew marketing and advertising to
the program at specific times to ensure the Subscription is fully subscribed over the long
term. Idaho Power conceives of this mid-cycle marketing as wholly different from the initial
marketing push and ongoing administration of the Subscription program, meaning there
wil! be no double collection of costs.
IDAHO POVVER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE IDAHO
CONSERVATION LEAGUE TO IDAHO POWER COMPANY- 2
The response to this Request is sponsored by Alison \Mlliams, Regulatory Polioy
and Strategy Advisor, ldaho Power Company.
IDAHO POWER COMPANYS RESPONSE TO FIRST PRODUCTION REQUEST OF THE IDAHO
CONSERVATION LEAGUE TO IDAHO POVVER COMPANY. 3
:
Ms. \Mlliam's Direct Testimony, page 41, line 13 states that any unsubscribed
power from the subscriber option resource will dispatch into the grid and be included in
"broader customer rates." However, Ms. \A/illiams also states on page 40, line 5 of her
Direct Testimony that the "term adjustment charge" wil! cover "any unexpected under-
collection of program costs due to early customer exit from the Subscription." Since ldaho
Power will be charging its rate base for any power that is not subscribed, how will ldaho
Power assure that it does not double recover program costs through both the term
adjustment charge and including unsubscribed power in broader customer rates?
RESPONSE TO REQUEST FOR PRODUGTION NO. 2:
ldaho Power would certainly prefer that the Subscription is fully subscribed upon
launch of the program. However, the Company would like to move fonnrard with the
program even if it only reaches an initial subscription level of 80 percent. ln this 80 percent
example, which is purely hypothetical, the unsubscribed 20 percent of the resource
generation would be dispatched in the manner described in Ms. \Mlliams'testimony. In
such a scenario, 80 percent of the generation from the Subscription resource would be
made up of participants with varying term lengths. The Term Adjustment Charge would
be specifically applied to these participants to maintain-and ideally grow-the 80 percent
subscriber level. Were the Subscription levels to grow to 90 or 100 percent, less
generation would be dispatched to the system, with less paid by non'participating
customers within rates. Meanwhile, the collection of the Term Adjustment Charge would
grow to ensure ongoing marketing expense and unexpected programmatic costs were
IDAHO PO\A'ER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE IDAHO
CONSERVATION LEAGUE TO IDAHO POWER COMPANY-4
available. This inverse relationship between Subscription amounts and dispatch amounts
witlensure there is no double collection of costs.
The response to this Request is sponsored by Alison \Mlliams, Regulatory Policy
and Strategy Advisor, ldaho Power Company.
IDAHO POVI'ER COMPANYS RESPONSE TO FIRST PRODUCTION REQUEST OF THE IDAHO
CONSERVATION LEAGUE TO IDAHO POWER COMPANY- 5
REQUEST FOR PRODUCTION NO. 3:
Please refer to \Mlliams direct testimony at 39, lines 15-18 describing the
Subscription option Program Credit.
a. Please clariff how ldaho Power intends to determine the energy and capacity
value of the program resource for the CEYW Subscription option.
b. Willthe Company use the Value of Solar study currently underway?
RESPONSE TO REQUEST FOR PRODUCTION NO. 3:
a. ldaho Power will not develop a proposed Subscription program credit until the
Company submits the second filing associated with the Subscription program.
ln that filing, the public and interested stakeholders will have the opportunity to
weigh in on the proposed program pricing and credit values, as explained on
page 36 of Ms. \Mlliams'testimony.
b. While the Company has not yet determined the basis for the Subscription
program credit, the forthcoming Value of Distributed Energy Resources study
may offer a useful reference point or methodology for determining credit values
in the SubscriPtion.
The response to this Request is sponsored by Alison \Mlliams, Regulatory Policy
and Strategy Advisor, ldaho Power Company.
IDAHO POVVER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE IDAHO
CONSERVATION LEAGUE TO IDAHO POVVER COMPANY- 6
REQUEST FOR PRODUCTION NO.4:
ln response to Request No. 28(a) from Commission Staff, ldaho Power states that
the Program Credit for the Subscription option cannot exceed the Program Cost. Explain
why there is no scenario in which the energy and capacity components of the subscription
credit could exceed the program costs.
RESPONSE TO REQUEST FOR PRODUCTION NO.4:
lf the energy and capacity credit for the Subscription were to exceed the Program
Charge, ldaho Powerwould need to paycustomers to participate in the Subscription. The
Subscription will be offered as a voluntary program to customers, consistent with the
voluntary nature of the current Green Power Program. As such, participation in the
Subscription will have a cost. Further, there is no scenario in which the cost of a dedicated
Subscription resource will be less than the value that the resource brings to ldaho Powe/s
system.
The response to this Request is sponsored by Alison \Mlliams, Regulatory Policy
and Strategy Advisor, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE IDAHO
CONSERVATION LEAGUE TO IDAHO PO\A'ER COMPANY- 7
REQUEST FOR PRODUCTION NO. 5:
ln response to Request No. 47 lrom Commission Staff, ldaho Power provides an
estimated timeline for the Subscription option. Although the resource procurement is
estimated to be finalized by April of 2023, the Subscription option is not expected to
commence until November 2024. Why does ldaho Power anticipate such a lengthy
timeline for the start of this option?
:
Once the ldaho Public Utilities Commission ('Commission") approves the
proposed renewable resource for the Clean Energy Your Way ('CEYW') - Subscription
offering, ldaho Power would then need to allow time to construct the resource before
customers could actively participate in the program. An estimated 18-month construction
timeframe was built into the CEYW - Subscription offering schedule that was submitted
in response to Commission Staffs Production Request No. 47. However, current supply
chain constraints for renewable energy equipment and components, combined with
extended tarifh and the current federal investigation related to non-domestic solar panel
components, could impact construction timelines and the commercia! operation date for
new renewable projects.
The response to this Request is sponsored by Alison \Mlliams, Regulatory Policy
and Strategy Advisor, ldaho Power Company.
]DAHO PO\A'ER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE IDAHO
CONSERVATION LEAGUE TO IDAHO POWER COMPANY. S
:
ln Response to Request No. 1 from Commission Staff, ldaho Power states that
one advantage of the current proposed Subscription option over the previous Community
Solar pilot is that the larger resource provides greater "economies of scale." Please
provide all analysis showing that the proposed 50 MW resource is the optimal size to
achieve these economies of scale.
a. Did Idaho Power compare the benefits of one 50 MW resource with the
benefits of multiple smaller (for example,25 MW) resources?
b. Did ldaho Power compare the benefits of one 50 MW resource with the
benefits of a larger resource in the current economic environment?
RESPONSE TO REQUEST FOR PRODUCTION NO.6:
ldaho Power Company has not yet identified a specific resourc,e(s) or resource
size(s) for the Subscription program. Rather, the Company has estimated an amount of
renewable resource generation that could reasonably be subscribed, based on expressed
customer interest. ldaho Power will continue to analyze and seek input on an ideal
resource(s) and location(s) for the Clean Energy Your Way - Subscription program.
Ultimately, the Company will weigh important elements such as project size(s),
location(s), resource cost, available commercia! operation date, price sensitivity of
customers, among other factors, in determining the selected resource.
As a baseline assessment, the Company has carefully considered the responses
it has received to both the 2021 and 2022 All-Source Request for Proposals ("RFP") for
system capacity resources. These recent RFPs have not only furthered the Company's
understanding of the current renewables market in general but have also enabled the
IDAHO PO\A/ER COMPANY'S RESPONSE TO FIRST PRODUCT]ON REQUEST OF THE IDAHO
CONSERVATION LEAGUE TO IDAHO POWER COMPANY- 9
Company to evaluate specific renewables projects that bid into these RFPs. While the
details of these renewable projects are confidential, it is fair to summarize that the
Company would generally achieve more favorable pricing with one larger-scale project
as opposed to multiple smaller projects. That said, the Company recognizes that the
Subscription may work under a range of resource options. ldaho Power will seek to
identiff the most economical resource that will allow the most customers to subscribe at
the least cost.
The response to this Request is sponsored by Alison \Mlliams, Regulatory Policy
and Strategy Advisor, ldaho Power Company.
IDAHO POVVER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE IDAHO
CONSERVATION LEAGUE TO IDAHO POWER COMPANY- 1O
DATED at Boise, ldaho, this 1Oth day of March 2022.
&L!.ff"*t***,
LISA D. NORDSTROM
Attomey for ldaho Power Company
IDAHO POWER COMPANYS RESPONSE TO FIRST PRODUCTION REQUEST OF THE IDAHO
CONSERVATION LEAGUE TO IDAHO PO\A'ER COMPANY. 1 1
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 10th day of May 2022,1 served a true and correct
copy of ldaho Power Company's Response to First Production Request of the ldaho
Conservation League to ldaho Power Company upon the following named parties by the
method indicated below, and addressed to the following:
Commission Staff
Dayn Hardie
Deputy Attorney Genera!
ldaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg No. 8,
Suite 201-A(83714)
PO Box 83720
Boise, lO 83720-0074
Industrial Customers of ldaho Power
Peter J. Richardson
Richardson Adams, PLLC
515 N.2lh Street
P.O. Box 7218
Boise, lD 83702
Dr. Don Reading
6070 Hil! Road
Boise, ldaho 83703
ldaho Conservation League
Benjamin J. Ofto
Emma E. Sperry
ldaho Conservation League
710 N.6th Street
Boise, lD 83702
Walmart, Inc.
Norman M. Semanko
Parsons Behle & Latimer
800 W. Main Street, Suite 1300
Boise, lD 83702
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IDAHO PO\A'ER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE IDAHO
CONSERVATION LEAGUE TO IDAHO POWER COMPANY.l2
Walmart, lnc.
Vicki M. Baldwin
Parsons Behle & Latimer
201 South Main Street, Suite 1800
Salt Lake City, UT 84111
Steve W. Chriss
Director, Energy Services
Walmart, lnc.
City of Boise
Ed Jewell
Deputy City Attorney's Office
150 N. Capitol Blvd.
P.O. Box 500
Boise, !D 83701-0500
Wil Gehl
Energy Program Manager
Boise City Department of Public Works
150 N. Capitol Blvd.
P.O. Box 500
Boise, lD 83701-0500
Clean Energy Opportunities for ldaho
Kelsey Jae
Law for Conscious Leadership
920 N. Clover Dr.
Boise, ID 83703
Courtney White
Mike Heckler
Clean Energy Opportunities for ldaho
3778 Plantation River Drive, Suite 102
Boise, !D 83703
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mike@cleanenerovopportu nities.com
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE IDAHO
CONSERVATION LEAGUE TO IDAHO POWER COMPANY- 13
eu"J.
Staey Gust, Regulatory AdministratiVe
Assistant
IDAHO POVUER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE IDAHO
CONSERVANON LEAGUE TO IDAHO POWER COMPAi.IY- 14