20220912IPC to Staff 56-61.pdf

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An loAcoRP @mpany
LISA D. NORDSTROM
Lead Counsel
[e-mail]
LDN:sg
Attachments
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September 12,2022
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
ln 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 Third
Production Request of the Commission Staff in the above-referenced matter.
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]
[e-mail]
[e-mail]
Attorneys for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES 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
CASE NO. |PC-E-22-22
IDAHO POWER COMPANY'S
RESPONSE TO THE THIRD
PRODUCTION REQUEST OF THE
COMMISSION STAFF
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COMES NOW, ldaho Power Company (.ldaho Powe/' or "Company"), and in
response to the Third Production Request of the Commission Staff ("Commission" or
"Staff) dated September 2,2022, herewith submits the following information:
IDAHO POVVER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 1
REQUEST FOR PRODUCTION NO. 56: To evaluate the monetary value of the
accumulated excess kWh credits, the Value of Distributive Energy Resources ("VODER")
Study used each customer class's average energy rate and stated "[t]he average energy
rate was selected because the accumulated k\A/h credits can only be used to offset the
energy components of a customer bill." VODER Study at 105. Please explain why the
Export Credit Rate ("ECR") is not used to evaluate the monetary value of the accumulated
excess k\Mr credits. ln your explanation, please reconcile with the statement in the
VODER Study at 105 "the use of non-time variant export credit rates is appropriate."
RESPONSE TO REQUEST FOR PRODUCTION NO. 56: Under ldaho Power's
current net metering offering, accumulated excess kilowatt-hour ("kWh") credits can either
be transferred to another account held by the customerl or retained by the customer and
used to offset future usage. Under either of these scenarios, the k\lVh credits can only be
used to offset the energy components of a customer bill. ldaho Power's assumption in
this analysis is that the monetary value to the customer holding the k\Ml credits is equal
to their average energy rate. As noted in ldaho Power's VODER Study ("Study") on page
104, Appendix 10.1 provides a methodology that could be used to quantiff a monetary
value associated with the accumulated k\A/h credit balance as of December 31,2021. A
different methodology could be to assume that the monetary value of the accumulated
kWh credits to the system is the export credit rate which could be used to calculate the
value. ldaho Power does not have temporal information that is granular enough to
determine if the excess kWh's were accumulated during on-peak or off-peak times.
Therefore, if the export credit rate was used to value the accumulated k\Mr credits, the
1 l.P.U.C No. 29, Tariff No. 101 Schedule 84 Customer Energy Production Net Metering Service
]DAHO PO\A'ER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 2
use of a non-tame variant export credit rate would be appropriate for this analysis.
The response to this Request is sponsored by Tami\Mtite, Budget and Revenue
Manager, ldaho Power Company.
IDAHO POVT,ER COMPA}.IY,S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF.3
REQUEST FOR PRODUCTION NO. 57: The VODER Study states that "[i]n
recognition that excess accumulated k\Mts benefitted the system at the time thev were
created, the accumulated k\Ms could be compensated at the Export Credit Rate and
recovered through the PCA similar to how the study anticipates the cost of export credits
would be recovered." Voder Study at 105. Please clariff whether the ECR used to
compensate for the excess accumulated kWhs is the ECR at the time when the excess
accumulated k\A/hs were created or
ouf'. Please explain why.
RESPONSE TO REQUEST FOR PRODUCTION NO. 57: ldaho Power did not
have an Export Credit Rate ('ECR") atthe time the excess k\M credits were accumulated
through December 31, 2021. For purposes of the Study, the Company's analysis used
the non-time variant average ELAP ECR as a proxy. The ECR in place at the time a new
compensation structure is implemented (in other words "cashed oufl) could be used.
The response to this Request is sponsored by Tami \Mrite, Budget and Revenue
Manager, ldaho Power Gompany.
IDAHO POVVER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF.4
REQUEST FOR PRODUCTION NO.58: The VODER Study states "[i]f the excess
k\tVh credits were expired and not used to offset customer usage, ldaho Power would
benefit by collecting the average energy rate for the usage not offset." VODER Study at
106. Please explain why the benefit is not measured based on the avoidance of the ECR
payments.
RESPONSE TO REQUEST FOR PRODUCTION NO. 58: Idaho Power assumes
ECR payments would be collected from customers through the Power Cost Adjustment
('PCA') mechanism. The benefit to ldaho Power of excess k\Mt credits expiring would be
realized through the process of billing customers for the energy components of those
kWh's because they would no longer be available to offset future usage.
The response to this Request is sponsored by Tami White, Budget and Revenue
Manager, ldaho Power Company.
IDAHO POVVER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 5
REQUEST FOR PRODUCTION NO. 59: Please respond to the following
regarding the Tab Summary in Appendix 10.1.
a. Please confirm Cell B20 should have been "Residentia!", instead of
"Commercial".
b. To calculate "Transfers as a o/o of KWH Balance", why is "Excess Net
Energy Credit Transfers - Actuals" of one year divided by "Net Excess -
1(\ /H" of the previous year? Forexample, why is "Excess Net Energy Credit
Transfers -Actuals" as of 1213112018 divided by "Net Excess - l(\NH" as
of 1213112017, instead of using the same yea/s data?
c. Please explain why the formula used to calculate "Transfers as a % of t(NH
Balance" for lrrigation customers is different than that for Residential and
Commercial classes?
d. Why does this analysis not include Schedule 6 customers and the industria!
customers of Schedule 84?
RESPONSE TO REQUEST FOR PRODUCTION NO. 59:
a. Yes. Cell B20 should be labeled "Residential.'
b. Under ldaho Power's current net metering offering2 customers submit
requests to transfer excess accumulated k\ /h credits by January 31 each
year. The assumption used in this analysis is that customers accumulate
excess kWh credits throughout the year and request to transfer some or all
of them in the subsequent year.
2 !.P.U.C No. 29, Tariff No. 101 Schedule 84 Customer Energy Production Net Metering Service
IDAHO PO\A'ER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF.6
c. When customers submit a request to transfer excess kWh credits as
described above, they are asked to specify a percent of credits to transfer
rather than an actua! amount of kWh's. After reviewing the eligibility of each
request, ldaho Power executes approved transfers no later than March 31
each year. Between the time forms are submitted (January) and the
transfers are executed (March), energy generation and consumption will
continue to occur, impacting the available balance of excess energy credits.
Therefore, it is possible for excess net energy credit transfers to exceed the
amount of accumulated excess kWh's, as was the case for lrrigation
customers. Idaho Power adjusted for this by setting the formula to not
exceed 100o/o.
d. This analysis does include Schedule 6 Residential Service On-Site
Generation customers. They are included in the category labeled
"Residential." This analysis does not include large industrial customers of
Schedule 84 because they had no accumulated excess kVUh credits at the
end of 2017,2018,2019,2020 or 2021.
The response to this Request is sponsored by Tami\Mite, Budget and Revenue
Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 7
REQUEST FOR PRODUCTION NO. 60: Please respond to the following
regarding the Tab Average Energy Rate in Appendix 10.1.
a. Please define'APCU - March Forecast".
b. Please explain why ldaho's PCA and Oregon's PCAM and APCU - March
Forecast should be summed together to arrive at the total system value.
RESPONSE TO REQUEST FOR PRODUCTION NO. 60
a. The Annual Power Cost Adjustment ("APCU') is a rate mechanism in
Oregon that was implemented to adjust rates on an annual basis to capture
variability in power supply expenses. lt has two components, an October
Update, and a March Forecast. The October Update establishes the
prospective "base" or'normal' power supply expenses by modeling the test
period (April through March) under multiple historicalwater conditions. The
March Forecast establishes expected power supply expenses by modeling
the same test period with a single forecast water condition.
The results of the October Update are reflected as an update to base rates
and the results of the March Forecast are reflected in the March Forecast
Rate Adjustment listed in Schedule 55.
b. The accumulated excess kWh credits and the excess net energy credit
transfers include both ldaho and Oregon customers. For comparability
purposes ldaho Power calculated a total system average energy rate that
included energy billing component charges and power cost adjustment
charges in both states divided by total system by customer class
IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 8
consurnption. The goal of this piece of the analysis was to calculate an
average rate that would be subject to offset by accumulated exess kWt's.
The response to this Request is sponsored by Tami \Mrite, Budget and Revenue
Manager, ldaho Power Company.
IDAHO POUVER COMPANYS RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 9
REQUEST FOR PRODUCTION NO. 6{: Please explain whether all the scenarios
below are possible.
a. For non-legacy systems, accumulated excess kwh credits could be
exchanged for financial credits, after ECRs are approved.
b. For non-legacy systems, accumulated excess k\ffh credits could still be
used as k\Nh credits, after ECRs are approved.
c. For legacy systems, accumulated excess k\Nh credits could be exchanged
for financial credits, after ECRs are approved.
d. For legacy systems, accumulated excess k\lVh credits could still be used as
kWh credits, after ECRs are approved.
RESPONSE TO REQUEST FOR PRODUCTION NO. 61:
a. Yes.
b. Yes.
c. Yes.
d. Yes.
The response to this Request is sponsored by Tami \A/hite, Budget and Revenue
Manager, ldaho Power Company.
DATED at Boise, ldaho, this 12th day of September 2022
X,^, !-(r,l-t^-*,
LISA D. NORDSTROM
Attorney for ldaho Power Company
IDAHO PO\'\'ER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF.lO
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 12th day of September 2022,1 served a true and
correct copy of ldaho Power Company's Response to the Third Production Request of
the Commission Staff upon the following named parties by the method indicated below,
and addressed to the following:
IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 11
Commission Staff
Riley Newton
Chris Burdin
Deputy 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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Chris. burdin@puc. idaho.qov
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@arkoosh. com
erin.cecil@arkoosh. com
Idaho Conservation League
Marie Kellner
Idaho Conservation League
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, ldaho 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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boisecifu attornev@citvofboise. orq
Wil 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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Industria! 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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[e-mail]
awiensen@h ol land hart.com
Jim Swier
Micron Technology, Inc.
8000 South FederalWay
Boise, ldaho 83707
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aclee@holla nd ha rt. com
IDAHO PO\A'ER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF.12
Clean Energy Opportunities for ldaho
Kelsey Jae
Law for Conscious Leadership
920 N. Clover Dr.
Boise, ldaho 83703
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Michael Heckler
Courtney ffiite
Clean Energy Opportunities for ldaho
3778 Plantation River Dr., Suite 102
Boise, !D 83703
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cou rtney@cleanenerqvopportu n ities.com
mike@clea nenerqvopportu n ities.com
Richard E. Kluckhohn, pro se
Wesley A. Kluckhohn, pro se
2564 W. Parkstone Dr.
Meridian, lD 83646
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ldaho Solar Owners Network
Joshua Hil!
1625 S. Latah
Boise, !D 83705
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ABG Power Gompany, LLC
Ryan Bushland
184 W. Chrisfield Dr.
Meridian, lD 83646
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[e-mail]
tStcc^\&^J-
Stacy Gust, Regulatory Administrative
Assistant
IDAHO PO\A'ER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 13