20230626CEO 1-7 to IPC.pdf

Kelsey Jae (ISB No. 7899)
Law for Conscious Leadership
920 N. Clover Dr., Boise, ID 83703
Phone: (208) 391-2961
[e-mail]
Attorney for the Clean Energy Opportunities for Idaho
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO
POWER COMPANY’S
APPLICATION FOR AUTHORITY
TO IMPLEMENT CHANGES TO
THE COMPENSATION
STRUCTURE APPLICABLE TO
CUSTOMER ON-SITE
GENERATION UNDER
SCHEDULES 6, 8, AND 84 AND TO
ESTABLISH AN EXPORT CREDIT
RATE METHODOLOGY
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CASE NO. IPC-E-23-14
CLEAN ENERGY OPPORTUNITIES
FOR IDAHO’S FIRST PRODUCTION
REQUEST TO IDAHO POWER
COMPANY
COMES NOW Clean Energy Opportunities for Idaho (CEO), by and through its attorney
of record, Kelsey Jae of the firm Kelsey Jae LLC, and requests that Idaho Power Company (“the
Company” or “Idaho Power”) provide the following documents within 21 days or sooner if
possible.
This Production Request is continuing, and the Company is requested to provide, by way
of supplementary responses, additional documents that it or any person acting on its behalf may
later obtain that will augment the documents produced. Please provide answers to each question
with supporting workpapers that provide detail or are the source of information used in
calculations. Please provide any Excel files with formulas active. Additionally, please include the
name and phone number of the person preparing the document, and the name, location, and
phone number of the record holder and, if different, the witness who can sponsor the answer at
CLEAN ENERGY OPPORTUNITIES FOR IDAHO - FIRST PRODUCTION REQUEST - 1
RECEIVED
Monday, June 26, 2023 2:30:01 PM
IDAHO PUBLIC
UTILITIES COMMISSION
hearing if need be. As allowed by IDAPA 31.01.01.228.01, CEO agrees to the Company
depositing the response in an electronic depository.
CONTEXT/BACKGROUND
CEO submits the following production requests related to the sale and procurement of
renewable energy attributes so that this docket may explore utilizing the renewable energy
attributes of exports by Idaho customers to serve other customers’ needs for renewable energy.
For example, through its Green Power Program, Idaho Power customers can opt to
purchase renewable energy attributes in an amount associated with some or all of the energy they
purchase from the Company. Customers pay 1 cent per kWh for that benefit, and the Company
incurs costs to serve those and other demands for renewable energy. The following production
requests aim to better understand those and related costs and benefits.
REQUEST NO 1. In 2022, what was the average cost per kWh incurred by the
Company for each 1 cent Green Power premium sold to Idaho Power customers?
REQUEST NO 2. In Order No. 33570 (in IPC-E-16-13), the Commission directed the
Company to submit a biennial Green Power Prudency Report, which includes the following
information (as copied from the 2022 Green Power Program Biennial Report page 1):
CLEAN ENERGY OPPORTUNITIES FOR IDAHO - FIRST PRODUCTION REQUEST - 2
The most recent biennial Prudency report covered a period ending December 31, 2021.
Please provide an update of the above information for the period covering January 2022 through
December 2022, with the exception that neither the marketing summary nor the Solar 4R
Schools expenses are needed. Specifically, please provide the comparable data presented in
Tables 1 through 5 of the 2022 Green Power Prudency Report.
REQUEST NO 3. Among the "Energy Solutions for Your Company" , Idaho Power
offers a Large Renewable Energy Purchase option. With regard to that program, please provide
the following for the year 2022:
● Number of business customers participating, if any
● Total quantity of RECs purchased by those customers
● Average price per REC paid by customers for purchase of such RECs
● Were all of the RECs purchased by customers under the Large Renewable Energy
Purchase option already owned by Idaho Power?
● If not, what was the total cost to Idaho Power for purchase of such RECs?
● What, if any, dollar amount of proceeds from any such REC sales were transferred to the
PCA?
CLEAN ENERGY OPPORTUNITIES FOR IDAHO - FIRST PRODUCTION REQUEST - 3
REQUEST NO 4. The table below, taken from the Prudency reports submitted under
Order No. 33570, show that the number of participants and the quantity of RECs purchased
under the Green Power program has increased dramatically between 2017 and 2021.
Year Participants # of RECs
(MWhs)
Total revenues
2017 1935 16621 $166,209
2018 2265 18151 $181,471
2019 2627 19884 $198,880
2020 3126 25063 $250,802
2021 3793 29682 $296,817
During that same period, annual payments to Green-e and auditors have increased by
almost two-thirds (from $16,400 to $25,550). That increase in the amount paid for Green-e and
auditor was roughly proportional to the increases in the number of participants and total RECs
provided during the 2017 through 2021 period. With regard to those payments:
● Were the amounts owed to Green-e and/or the auditors for their services in each of those
five years determined in whole or in part by the number of participants or number of
RECs retired?
● If yes, would the Company expect to have to make larger dollar payments to Green-e
and/or the auditors for their services if there are future increases in the number of
participants or number of RECs retired?
● Were any of those payments made to either Green-e or the auditors related to services
provided for certifying or auditing RECs sold to business customers under the Large
CLEAN ENERGY OPPORTUNITIES FOR IDAHO - FIRST PRODUCTION REQUEST - 4
Renewable Energy Purchase program?
● If not, were there any analogous payments for certification or auditing made under the
Large Renewable Energy Purchase program?
● If such payments were made under the Large Renewable Energy Purchase program, how
many dollars were spent on those matters in 2022?
REQUEST NO 5. Within the reports WREGIS produces, Idaho Power is listed as the
Qualified Reporting Entity (QRE) for, among others, the following Renewable Generation Units:
➢ Neal Hot Springs Unit #1
➢ OSPV2010
➢ OSPV 2011
➢ OSPV2013
➢ OSPV 2014
➢ Elkhorn Valley Wind Farm
● Did Idaho Power gain ownership to any of the RECs produced by any of these renewable
generation units during 2022?
● If yes, how many RECs were transferred to Idaho Power?
REQUEST NO 6. Did Idaho Power gain ownership of any RECs under any PURPA
contracts during 2022? If yes, how many RECs were transferred to Idaho Power?
REQUEST NO 7. In his direct testimony (see Exhibit 6, page 1), Grant Anderson shows
CLEAN ENERGY OPPORTUNITIES FOR IDAHO - FIRST PRODUCTION REQUEST - 5
that pretty much regardless of their level of monthly consumption, Schedule 6 customers are
expected to export roughly .5MWh/month under a net billing export credit structure (see image
below):
In her direct testimony (see Table 2, page 34) Connie Aschenbrenner shows 9,379 non-Legacy
Residential and Small General service customers in Schedules 6 and 8.
As these customers are limited to arrays of no more than 25kW, please divide them into
the following five groupings when replying to the two data requests below:
< 5kW
> 5kW but <10kW
> 10kW but < 15kW
>15kW but < 20kW
>20kW
Please provide data regarding:
● The number of such non-Legacy R&SGS customers in each of the five nameplate
grouping, and
● The average array size (in nameplate kWs) for each grouping
CLEAN ENERGY OPPORTUNITIES FOR IDAHO - FIRST PRODUCTION REQUEST - 6
DATED this 26th day of June, 2023.
Respectfully submitted,
______________________________
Kelsey Jae
Attorney for CEO
CLEAN ENERGY OPPORTUNITIES FOR IDAHO - FIRST PRODUCTION REQUEST - 7
CERTIFICATE OF SERVICE
I hereby certify that on this 26th day of June, 2023. I delivered true and correct copies of
the foregoing FIRST PRODUCTION REQUEST to the following persons via the method of
service noted:
Electronic Mail Delivery
Idaho Public Utilities Commission
Jan Noriyuki, Commission Secretary
[e-mail]
Idaho PUC Staff
Chris Burdin
Deputy Attorney General
Idaho Public Utilities Commission
[e-mail]
Idaho Power Company
Megan Goicoechea Allen
Lisa D. Nordstrom
[e-mail]
[e-mail]
[e-mail]
City of Boise
Darrell Early, Deputy City Attorney
[e-mail]
[e-mail]
Wil Gehl, Energy Program Manager
[e-mail]
Idaho Conservation League
Marie Callaway Kellner
[e-mail]
IdaHydro
Tom Arkoosh
[e-mail]
[e-mail]
Idaho Irrigation Pumpers Association, Inc.
Eric L. Olsen
Lance Kaufman
[e-mail]
[e-mail]
Micron Technology, Inc.
Jim Swier
[e-mail]
Austin Rueschhoff
Thorvald A. Nelson
Austin W. Jensen
Holland & Hart, LLP
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
Vote Solar
Abigail R. Germaine
Elam & Burke, P.A.
[e-mail]
Kate Bowman
[e-mail]
_____________________________
Kelsey Jae
Attorney for CEO
CLEAN ENERGY OPPORTUNITIES FOR IDAHO - FIRST PRODUCTION REQUEST - 8