HomeMy WebLinkAbout20230714IPC to Staff 6-14.pdfMEGAN GOICOECHEA ALLEN
Corporate Counsel
mgoicoecheaallen@idahopower.com
July 14, 2023
Jan Noriyuki, Secretary
Idaho Public Utilities Commission
11331 W. Chinden Boulevard
Building 8, Suite 201-A
Boise, Idaho 83714
Re: Case No. IPC-E-23-14
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
Dear Ms. Noriyuki:
Attached for electronic filing is Idaho Power Company’s Response to the Second
Production Request of the Commission Staff to Idaho Power Company in the above-
entitled matter.
If you have any questions about the attached documents, please do not hesitate
to contact me.
Sincerely,
Megan Goicoechea Allen
MGA:sg
Enclosures
RECEIVED
2023 JULY 14, 2023 1:30PM
IDAHO PUBLIC
UTILITIES COMMISSION
IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 1
MEGAN GOICOECHEA ALLEN (ISB No. 7623)
LISA D. NORDSTROM (ISB No. 5733)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: (208) 388-2664
Facsimile: (208) 388-6936
mgoicoecheaallen@idahopower.com
lnordstrom@idahopower.com
Attorneys for Idaho Power Company
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
IDAHO POWER COMPANY’S
RESPONSE TO THE SECOND
PRODUCTION REQUEST OF
THE COMMISSION STAFF TO
IDAHO POWER COMPANY
COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), and in
response to the Second Production Request of the Commission Staff (“Commission” or
“Staff”) dated June 23, 2023, herewith submits the following information:
IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 2
STAFF REQUEST FOR PRODUCTION NO. 6: Under the Company's proposed
real-time measurement interval, please explain how often AMI data is collected by the
Company for determining a customer's energy charges and export financial credits.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 6: The cadence
for collecting Advanced Metering Infrastructure (“AMI”) data occurs irrespective of the
measurement interval proposed. The AMI hourly interval data that would be used for a
real-time net billing measurement interval includes the following:
(1) Delivered – energy sent from the utility to the customer, and
(2) Received – energy sent from the customer to the utility (i.e., exported).
AMI hourly interval data is collected in eight-hour blocks. The hourly interval data
is then sent to the Meter Data Management (“MDM”) system every 24 hours. The data is
then sent from the MDM system to the billing system monthly for the billing period.
The response to this Request is sponsored by Grant T. Anderson, Regulatory
Consultant, Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 3
STAFF REQUEST FOR PRODUCTION NO. 7: Please describe and quantify the
incremental administrative burden and any IT infrastructure needed for the Company for
collecting and processing AMI data and billing at the real-time measurement interval.
Please provide supporting workpapers in excel format with formulas enabled.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 7: The Company
has not identified an incremental administrative burden for collecting and processing AMI
data. The current net energy metering compensation structure requires a manual
exception review process that would no longer be necessary under a net billing
compensation structure because the Company anticipates a reduction in manual
processes from implementing net billing.
No additional IT infrastructure is needed for collecting and processing AMI data
and billing under a real-time or hourly net billing measurement interval. As described in
Response to Staff’s Request for Production No. 6, Idaho Power already collects the AMI
data necessary for net billing. However, implementing the new structure in the Company’s
billing system will incur an incremental cost. Please see the Excel file labeled “Attachment
– Response to Staff’s Request No. 7” for the estimated cost.
The response to this Request is sponsored by Matisse Weigel, ERP Applications
Senior Manager, Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 4
STAFF REQUEST FOR PRODUCTION NO. 8: Under an hourly net billing Export
Credit Rate ("ECR") structure, please describe and quantify the incremental
administrative burden and any IT infrastructure needed to the Company for collecting and
processing AMI data and billing at the hourly measurement interval. Please provide
supporting workpapers in excel format with formulas enabled.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 8: Please see
Response to Staff’s Request for Production No. 7.
The response to this Request is sponsored by Matisse Weigel, ERP Applications
Senior Manager, Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 5
STAFF REQUEST FOR PRODUCTION NO. 9: Please describe in detail the
resolution of information available to customers with interconnected solar systems under
the Company's proposed ECR:
(a) Please provide examples of Schedule 6, Schedule 8, and Schedule 84
customer bills under the Company's proposed ECR;
(b) Please describe what usage and export level data will be available to
customers (i.e., real time, hourly usage, etc.); and
(c) Please explain if the information will be different for a customer accessing their
usage data from the Company's mobile app or online account.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 9: Please see the
below responses regarding information available to customers:
(a) Examples of customer bills are not yet available. Bill presentment will be
developed over the next several months, and the Company will coordinate with
Consumer Affairs Staff to ensure compliance with the Utility Customer
Relations Rules (“UCRRs”), Contents of Bills (Rule 201).
(b) As described in Response to Staff’s Request for Production No. 6, Advanced
AMI hourly interval data is currently collected for the delivered and received
channels. As a result, customers would have access to usage (delivered) and
exports (received) by hour. Under real-time net billing, these would be billed
separately at the retail and export credit rate, whereas, under hourly net billing,
the hourly “net” value would be calculated (e.g., delivered minus received
kilowatt-hours) and charged either the retail or export credit rate. The
information on the customer bill will meet the necessary criteria pursuant to the
IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 6
UCRRs and contain a summary of kilowatt-hours (1) consumed by billing tier
or time-of-use period and (2) exported on- and off-peak for the total billing
period.
For net billing, customers will have visibility to monthly, daily, and hourly usage
(delivered) and export (received) data in the My Account website and mobile
application. These customers will also see an indicator of on-peak times in the
hourly usage graphs. These changes will be reflected in both the My Account
website and the mobile app.
(c) There would not be any differences in how customers view usage data between
the My Account website and the mobile app for net-billing customers.
The response to this Request is sponsored by Grant T. Anderson, Regulatory
Consultant, Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 7
STAFF REQUEST FOR PRODUCTION NO. 10: For 2019, please provide
"Customer Generation Exports ELCC and Maximum Output" similar to those found in
Exhibit 2 workpapers, sheet "Gen_Capacity".
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 10: Idaho Power
cannot provide the 2019 information in the format requested because the hourly data for
2019 does not represent 12 months with consistently validated interval data. Idaho Power
utilized data for 2020, 2021, and 2022 to calculate the capacity contribution of customer-
generator exports for the exported credit rate's avoided generation capacity value and
proposed to use the most recent three years of information in future updates. As proposed
by the Company, the next annual update would calculate the contribution capacity based
on customer-generator exports for 2021, 2022, and 2023.
The response to this Request is sponsored by Jared L. Ellsworth, Transmission,
Distribution & Resource Planning Director, Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 8
STAFF REQUEST FOR PRODUCTION NO. 11: Please provide an updated
customer bill impact analysis for tariff Schedules 6, 8, and 84 using the proposed changes
from this case (Case No. IPC-E-23-14) and the rates proposed in the general rate case
(Case No. IPC-E-23-11).
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 11: Please see
three Excel files labeled:
“Attachment 1 – Response to Staff’s Request No. 11 – Schedule 6”
“Attachment 2 – Response to Staff’s Request No. 11 – Schedule 8”
“Attachment 3 – Response to Staff’s Request No. 11 – Schedule 84”
The response to this Request is sponsored by Grant T. Anderson, Regulatory
Consultant, Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 9
STAFF REQUEST FOR PRODUCTION NO. 12: Please explain if the Company
plans to send customer notifications that show the combined impact of the Company's
proposed ECR and the Company's currently filed general rate case.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 12: The Company
issued notices consistent with requirements outlined in IDAPA 31.01.01, Rules of
Procedure of the Idaho PUC, Rule 125, Notices to Customers of Proposed Changes in
Rates (“RP 125”). Accordingly, bill inserts were sent to all customers, informing them of
the requested relief and notifying them of how to participate in the proceeding.
Additionally, the Company sent more comprehensive notices to all existing and pending
on-site generation customers. The changes and bill impacts described were isolated to
the impacts of those requested in this instant case and were submitted with the application
filed in this matter.
The Company also sent notices in the Company’s general rate case, Case No.
IPC-E-23-11. Consistent with RP 125, the notices in that docket described the bill impacts
resulting from the requests in that case.
The Company believes its approach is consistent with prior Commission direction
regarding noticing, where the Commission indicated it “expects the Company’s Customer
Notice to inform customers that they may comment about the Company’s application in
the proceeding in which the application is being reviewed” (Order No. 32552 issued in
IPC-E-12-17). The Company is not opposed to issuing additional notices; however, there
is the consideration that it could confound the matters relative to each docket from a
customer perspective. Further, because of the added complexity that must be considered
when estimating bill impacts for an on-site generation customer (e.g., size of the system
IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 10
installed relative to usage), providing a generic “average residential impact” is
challenging. That said, the Company has completed a “combined impact” bill analysis for
customers with 12 months of billing data for 2022, which is included in response to Staff’s
Request for Production No. 11.
The response to this Request is sponsored by Connie G. Aschenbrenner, Rate
Design Senior Manager, Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 11
STAFF REQUEST FOR PRODUCTION NO. 13: Please describe how distributed
energy resources will be modeled (i.e., existing, new resource, etc.) in the Company's
proposed annual ELCC updates.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 13: For the annual
Effective Load Carrying Capability (“ELCC”) updates, the Company proposes to rely on
total hourly customer-generator export data from the most recent three consecutive years
to produce a singular average capacity contribution value (the average of the three years
ELCC). All distributed energy resources active for the most recent year will be included
in that year’s ELCC update. The Company has not proposed to separately evaluate
existing versus new resources.
The response to this Request is sponsored by Jared L. Ellsworth, Transmission,
Distribution & Resource Planning Director, Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 12
STAFF REQUEST FOR PRODUCTION NO. 14: Please list any other existing
Company resources that receive annual ELCC updates.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 14: Idaho Power
implemented the ELCC methodology in the 2021 Integrated Resource Plan (“IRP”), where
capacity contribution values were provided for existing and future resources (see table
provided on page 99 of the 2021 IRP Appendix C: Technical Report). ELCC updates for
other existing Company resources will be completed bi-annually to coincide with future
IRP cycles.
The response to this Request is sponsored by Jared L. Ellsworth, Transmission,
Distribution & Resource Planning Director, Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 13
DATED at Boise, Idaho, this 14th day of July 2023.
MEGAN GOICOECHEA ALLEN
Attorney for Idaho Power Company
IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 14
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 14th day of July, 2023, I served a true and correct
copy of Idaho Power Company’s Response to the Second Production Request of the
Commission Staff upon the following named parties by the method indicated below, and
addressed to the following:
Commission Staff
Chris Burdin
Deputy Attorney General
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg No. 8
Suite 201-A (83714)
PO Box 83720
Boise, ID 83720-0074
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X Email Chris.burdin@puc.idaho.gov
IdaHydro
C. Tom Arkoosh
ARKOOSH LAW OFFICES
913 W. River Street, Suite 450
P.O. Box 2900
Boise, Idaho 83701
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X Email tom.arkoosh@arkoosh.com
erin.cecil@arkoosh.com
Idaho Conservation League
Marie Callaway Kellner
Idaho Conservation League
710 North 6th Street
Boise, Idaho 83702
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X Email mkellner@idahoconservation.org
Brad Heusinkveld
Idaho Conservation League
710 North 6th Street
Boise, Idaho 83702
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X Email bheusinkveld@idahoconservation.org
Idaho Irrigation Pumpers Association,
Inc.
Eric L. Olsen
ECHO HAWK & OLSEN, PLLC
505 Pershing Avenue, Suite 100
P.O. Box 6119
Pocatello, Idaho 83205
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X Email elo@echohawk.com
IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 15
Lance Kaufman, Ph.D.
2623 NW Bluebell Place
Corvallis, OR 97330
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X Email lance@aegisinsight.com
Clean Energy Opportunities for Idaho
Kelsey Jae
Law for Conscious Leadership
920 N. Clover Dr.
Boise, Idaho 83703
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Michael Heckler
Courtney White
Clean Energy Opportunities for Idaho
3778 Plantation River Dr., Suite 102
Boise, ID 83703
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mike@cleanenergyopportunities.com
courtney@cleanenergyopportunities.com
Micron Technology, Inc.
Austin Rueschhoff
Thorvald A. Nelson
Austin W. Jensen
Holland & Hart, LLP
555 Seventeenth Street, Suite 3200
Denver, Colorado 80202
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tnelson@hollandhart.com
awjensen@hollandhart.com
aclee@hollandhart.com
clmoser@hollandhart.com
Jim Swier
Micron Technology, Inc.
8000 South Federal Way
Boise, Idaho 83707
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IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 16
City of Boise
Darrell G. Early
Deputy City Attorney
Boise City Attorney’s Office
150 N. Capitol Blvd.
PO Box 500
Boise, Idaho 83701-0500
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boisecityattorney@cityofboise.org
Wil Gehl
Energy Program Manager
Boise City Dept. of Public Works
150 N. Capitol Blvd.
Boise, Idaho 83701-0500
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Vote Solar
Abigail R. Germaine
Elam & Burke, PA
251 E. Front Street, Suite 300
PO Box 1539
Boise, ID 83701
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Kate Bowman
Regulatory Director
Vote Solar
299 S. Main Street, Suite 1300
PMB 93601
Salt Lake City, UT 84111
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Stacy Gust, Regulatory Administrative
Assistant
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-23-14
IDAHO POWER COMPANY
REQUEST NO. 7
ATTACHMENT NO. 1
SEE ATTACHED SPREADSHEET
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-23-14
IDAHO POWER COMPANY
REQUEST NO. 11
ATTACHMENT NO. 1
SEE ATTACHED SPREADSHEET
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-23-14
IDAHO POWER COMPANY
REQUEST NO. 11
ATTACHMENT NO. 2
SEE ATTACHED SPREADSHEET
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-23-14
IDAHO POWER COMPANY
REQUEST NO. 11
ATTACHMENT NO. 3
SEE ATTACHED SPREADSHEET