20220823IPC to CEO 1-3.pdf

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An IDACOiP Company
LISA D. NORDSTROM
Lead Counsel
[e-mail]
LDN:cd
Attachment
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August 23,2022
VIA ELECTRONIC FILING
Jan Noriyuki, Secretary
ldaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg 8,
Suite 201-A (83714)
PO Box 83720
Boise, ldaho 83720-0074
Re Case No. IPC-E-22-22
!n the Matter of ldaho Power Company's Application to Complete the Study
Review Phase of the Comprehensive Study of Costs and Benefits of On-
Site Customer Generation & For Authority to lmplement Changes to
Schedules 6, 8 and 84 for Non-Legacy Systems
Dear Ms. Noriyuki:
Attached for electronic filing is ldaho Power Company's Response to the First
Production Request of Clean Energy Opportunities in the above-referenced mafter.
lf you have any questions about the documents referenced above, please do not
hesitate to contact me.
Very truly yours,
Lisa D. Nordstrom
LISA D. NORDSTROM (lSB No. 5733)
MEGAN GOICOECHEA ALLEN (lSB No. 7623)
ldaho Power Company
1221 West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
ln o rd strom@ ida hopowe r. com
mqoicoecheaa I len @idahopower.com
Attorneys for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILIT!ES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION TO
COMPLETE THE STUDY REVIEW
PHASE OF THE COMPREHENSIVE
STUDY OF COSTS AND BENEFITS OF
ON-SITE CUSTOMER GENERATION &
FOR AUTHORITY TO IMPLEMENT
CHANGES TO SCHEDULES 6, 8, AND
84 FOR NON-LEGACY SYSTEMS
GASE NO. IPC-E-22-22
IDAHO POWER COMPANY'S
RESPONSE TO CLEAN ENERGY
OPPORTUNITIES FOR IDAHO'S
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY
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COMES NOW ldaho Power Company ("ldaho Powe/' or'Company"), and in
response to the First Production Request of Clean Energy Opportunities for ldaho
('CEO') dated August 2,2022, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO CLEAN ENERGY OPPORTUNITIES FOR IDAHO'S
FIRST PRODUCTION REQUEST TO IDAHO POWER COMPANY - 1
REQUEST FOR PRODUCTION NO. 1: ln section 4.1.1.2 of the VODER study, the
Company explains that:
"for purposes of the study, the value for the ECR uses a historically based
indicative price based on a 3-year average of the ICE Mid-C lndex."
A similar 3-year averaging is used in section 4.1.1.3 with ELAP price data. Please
explain why 3-year averages were utilized for calculating ICE MID-C lndex and ELAP
ECR values in light of Commission direction to use the "most current data possible".
RESPONSE TO REQUEST FOR PRODUCTION NO. 1: The VODER Study
("Study") used the historically based 3-year average indicative price for illustrative
purposes. The 3-year average incorporates 2021 prices, which represents the most
current calendar year data available when the Study was filed. ldaho Power did not
propose implementing a particular method for the avoided energy component of the
export credit rate in the Study. lnstead, the Study evaluates two "fixed" structures to
illustrate the average value based on historical prices: (1) flatsingle price; (2) seasonal
time-variant. The Study also included hourly pricing data by year so that stakeholders
could analyze any of the given years to inform historical avoided energy values for the
most recent calendar years.
As described in more detail in Section 5.1 of the Study, the lntercontinental
Exchange Mid-Columbia ("lCE Mid-C') and the Western Energy lmbalance Market Load
Aggregation Point ('ELAP") energy prices represent actual market prices. Actual market
prices provide the opportunity for the energy value to not remain "fixed" as the historical
indicative pricing represents. lnstead, ldaho Powe/s billing system could apply actual
market prices for the given hour that the customer-generator's export occurs. The energy
price could continually use the actual non-firm adjusted ICE Mid-C or ELAP price to value
IDAHO POWER COMPANY'S RESPONSE TO CLEAN ENERGY OPPORTUNITIES FOR IDAHO'S
FIRST PRODUCTION REQUEST TO IDAHO POWER COMPANY - 2
exports in the billing period. Therefore, this energy input method would not require an
"update" in this example because ldaho Power would compensate customers at actual
market values instead of a historical-based price.
As stated in the Study, ldaho Power, stakeholders, and ultimately the Commission,
must evaluate the benefits and potential impacts of leveraging a forecasted, or historical,
energy price (e.9., flat or seasonal time variant fixed price based on the most recent 12
months or some other duration of historical averages) compared to an actual market
price. The Study evaluates the merits and considerations of using either approach. For
example, forecasted or fixed energy prices offer stability and may be easier for customers
to understand. A forecast or fixed price provides stability but may not maximize value for
the customer-generator when market prices are higher than the forecasted or fixed
energy prices. However, a forecast also mitigates a drop in market prices, which could be
lower than the forecasted price.
The response to this Request is sponsored by Jared L. Ellsworth, Transmission,
Distribution & Resource Planning Director, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO CLEAN ENERGY OPPORTUNITIES FOR IDAHO'S
FIRST PRODUCTION REQUESTTO IDAHO POWER COMPANY - 3
REQUEST FOR PRODUCTION NO. 2: Please provide in Exce! format, similar to
that used in the Appendices referenced below, the most current 2022hourly data possible
(with no averaging of prior years) for:
a. 2022lRP hourly prices as per that provided in Appendix 4.1
b. 2022lCE MID-C hourly prices as per Appendix 4.2
c. 2022 Energy lmbalance Market Load Aggregation Point (ELAP) hourly
prices as per Appendix 4.3
d. 2022 Nel hourly exports as per Appendix 4.4
RESPONSE TO REQUEST FOR PRODUCTION NO. 2: !n preparing this
response, it came to the Company's attention that the hourly prices provided in Appendix
4.2 and 4.3 were in Pacific Time. All pricing data published by the California lndependent
System Operator C'CAISO') are in Pacific Time. ln contrast, the exports in Appendix 4.4
and 4.5 are in Mountain Time. To correctly align the hourly pricing and export data, the
Company has provided the following revised appendices with this production request:
Appendix 4.2; Appendix 4.3; Appendix 4.6; Appendix 4.7.
Additionally, please see Excel attachments with available data for 2022. All data
provided is in Mountain Time. The following comments provide additional context for each
attachment:
. Attachment2a - 2022 forecast price from the 2021 lntegrated Resource Plan for
ldaho Power zonal prices consistent with Study Appendix 4.1
. Attachment 2b - January 1,2022, through July 31 ,2022,|CE Mid-C hourly prices
consistent with revised Appendix 4.2
. Attachment 2c - January 1, 2022, through July 31 , 2022, ELAP hourly prices
consistent with revised Appendix 4.3
IDAHO POWER COMPANY'S RESPONSE TO CLEAN ENERGY OPPORTUNITIES FOR IDAHO'S
FIRST PRODUCTION REQUEST TO IDAHO POWER COMPANY - 4
. Afrachment 2d - January 1, 2022, through July 31 , 2022, net hourly exports
consistent with Appen dix 4.4
The response to this Request is sponsored by Jarcd L. Ellsworth, Transmission,
Distribution & Resource Planning Director, ldaho Power Company.
IDAHO POVI/ER COMPANY'S RESPONSE TO CLEAN ENERGY OPPORTUNITIES FOR IDAHO'S
FIRST PRODUCTION REQUESTTO IDAHO POWER COMPANY - 5
REQUEST FOR PRODUCTION NO. 3: Figure 10.3 at page 109 in the VODER
study presents "ldaho Power webpage of examples of a typical home's payback under a
Net Energy Metering and Hourly Net Billing compensation structure." Please provide in
Excelformat allformulas and data used to compute the eight break-even points in Figure
10.3, specifically:
a. Current compensation - Net monthly: pay cash up-front, simple payback
b. Current compensation - Net monthly: pay cash up-front, discounted payback
c. Modified compensation - Net hourly: pay cash up-front, simple payback
d. Modified compensation - Net hourly: pay cash up-front, discounted payback
e. Current compensation - Net monthly: 2O-year loan financing, simple payback
f. Current compensation - Net monthly: 20-year loan financing, discounted
payback
g. Modified compensation - Net hourly: 2O-year loan financing, simple payback
h. Modified compensation - Net hourly: 20-year loan financing, discounted
payback
RESPONSE TO REQUEST FOR PRODUCTION NO. 3: Please see Exce|
attachment for the financial analysis that informed the payback periods for the average
residential customer example on ldaho Powefs website. There are four tabs that include
the simple and discounted paybackforeach scenario. The fourtabs are titled: NEM_cash,
NEM_finance, HNB_cash, and HNB_finance.
The payback range considers many assumptions within a range of sensitivities and
benchmarked several assumptions against the National Renewable Energy Laboratory
("NREL") guidance. Examples of benchmarks and assumptions used in the analysis
include:
IDAHO POWER COMPANY'S RESPONSE TO CLEAN ENERGY OPPORTUNITIES FOR IDAHO'S
FIRST PRODUCTION REQUESTTO IDAHO POWER COMPANY.6
a
a
Operating Costs
o NREL range: $5 - $18/kW
o Modeled: $O/kW
Annua! Degradation Rate
o NREL range: 0.50% - 1.00%
o Modeled: 0.50%
System Cost
o NREL range: $1.50 - $5.00/watt
o Google Sunroof: $3.00/watt
o Modeled: $3.00/watt
a
ldaho Power's website also notes that future compensation structures, including
measurement interval and excess energy credit value, have not been determined. The
examples in this analysis are intended to demonstrate the potentia! impacts of future
changes on customer investment payback periods.
The response to this Request is sponsored by Grant T. Anderson, Regulatory
Consultant, ldaho Power Company.
DATED at Boise, ldaho, this 23rd day of August 2022.
X;!.fl'.,*t"-*,
LISA D. NORDSTROM
Attorney for ldaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO CLEAN ENERGY OPPORTUNITIES FOR IDAHO'S
FIRST PRODUCTION REQUEST TO IDAHO POWER COMPANY - 7
CERTIFICATE OF SERVICE
! HEREBY CERTIFY that on the 23rd day of August 2022, I served a true and
correct copy of ldaho Power Company's Response to Clean Energy Opportunities for
ldaho's First Production Request to Idaho Power Company upon the following named
parties by the method indicated below, and addressed to the following:
IDAHO POWER COMPANY'S RESPONSE TO CLEAN ENERGY OPPORTUN]TIES FOR IDAHO'S
FIRST PRODUCTION REQUEST TO IDAHO POWER COMPANY - 8
Commission Staff
Riley Newton
Depu$ Attorney General
ldaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg No.8
Suite 201-A (83714)
PO Box 83720
Boise, lD 83720-0074
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XEm ail [e-mail]
Ch ris. Bu rd in@puc. ida ho.oov
ldaHydro
C. Tom Arkoosh
Amber Dresslar
ARKOOSH LAW OFFICES
913 W. River Street, Suite 450
P.O. Box 2900
Boise, ldaho 83701
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Amber.d resslar@a rkoosh.com
erin.cecil@arkoosh. com
ldaho Conservation League
Marie Kellner
710 North 6th Street
Boise, ldaho 83702
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ldaho lrrigation Pumpers Association, lnc.
Eric L. Olsen
ECHO HAWK & OLSEN, PLLC
505 Pershing Avenue, Suite 100
P.O. Box 6119
Pocatello, Idaho 83205
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Lance Kaufman, Ph.D
4801 W. Yale Ave.
Denver, CO 80219
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City of Boise
Mary Grant
Deputy City Attorney
Boise City Attorney's Office
150 North Capitol Boulevard
P.O. Box 500
Boise, ldaho 83701 -0500
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bo isecitvatto rn ev@citvofbo ise. o ro
Wi! Gehl
Energy Program Manager
Boise City Dept. of Public Works
150 N. Capitol Blvd.
PO Box 500
Boise, ldaho 83701 -0500
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lndustrial Customers of ldaho Power
Peter J. Richardson
RICHARDSON ADAMS, PLLC
515 North 27th Street (83702)
P.O. Box 7218
Boise, ldaho 83707
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Dr. Don Reading
6070 Hill Road
Boise, ldaho 83703
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Micron Technology, lnc.
Austin Rueschhoff
Thorvald A. Nelson
Austin W. Jensen
Holland & Hart, LLP
555 Seventeenth Street, Suite 3200
Denver, Colorado 80202
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tnelson @holla nd hart. com
awiensen@ holla ndha rt.com
aclee@holland ha rt.com
Jim Swier
Micron Technology, lnc.
8000 South FederalWay
Boise, ldaho 83707
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IDAHO POWER COMPANY'S RESPONSE TO CLEAN ENERGY OPPORTUNITIES FOR IDAHO'S
FIRST PRODUCTION REQUEST TO IDAHO POWER COMPANY - 9
Clean Energy Opportunities for ldaho
Kelsey Jae
Law for Conscious Leadership
920 N. Clover Dr.
Boise, ldaho 83703
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Michae! Heckler
Courtney White
Clean Energy Opportunities for ldaho
3778 Plantation River Dr., Suite 102
Boise, lD 83703
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co u rtnev@clea nene rovop po rtu n ities. com
mike@clea nenerqvopportun ities.com
Richard E. Kluckhohn, pro se
Wesley A. Kluckhohn, pro se
2564 W. Parkstone Dr.
Meridian, lD 83646
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ABG Power Co. LLC
Ryan Bushland
184 W. Chrisfield Dr.
Meridian, !D 83646
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ldaho Solar Ownerc Network
Joshua Hill
1625 W. Latah St.
Boise lD 83705
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[e-mail]
Christy Davenport, Regulatory
Ad min istrative Assistant
IDAHO POWER COMPANY'S RESPONSE TO CLEAN ENERGY OPPORTUNITIES FOR IDAHO'S
FIRST PRODUCTION REQUEST TO IDAHO POWER COMPANY - 1O