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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 ) ) ) ) ) ) ) ) ) ) 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 Hand Delivered U.S. Mail Overnight Mail FAX FTP Site 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 Hand Delivered U.S. Mail Overnight Mail FAX FTP Site 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 Hand Delivered U.S. Mail Overnight Mail FAX FTP Site X Email mkellner@idahoconservation.org Brad Heusinkveld Idaho Conservation League 710 North 6th Street Boise, Idaho 83702 Hand Delivered U.S. Mail Overnight Mail FAX FTP Site 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 Hand Delivered U.S. Mail Overnight Mail FAX FTP Site 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 Hand Delivered U.S. Mail Overnight Mail FAX FTP Site X Email lance@aegisinsight.com Clean Energy Opportunities for Idaho Kelsey Jae Law for Conscious Leadership 920 N. Clover Dr. Boise, Idaho 83703 Hand Delivered U.S. Mail Overnight Mail FAX FTP Site X Email kelsey@kelseyjae.com Michael Heckler Courtney White Clean Energy Opportunities for Idaho 3778 Plantation River Dr., Suite 102 Boise, ID 83703 Hand Delivered U.S. Mail Overnight Mail FAX FTP Site X Email 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 Hand Delivered U.S. Mail Overnight Mail FAX _ FTP Site X Email darueschhoff@hollandhart.com tnelson@hollandhart.com awjensen@hollandhart.com aclee@hollandhart.com clmoser@hollandhart.com Jim Swier Micron Technology, Inc. 8000 South Federal Way Boise, Idaho 83707 Hand Delivered U.S. Mail Overnight Mail FAX FTP Site X Email jswier@micron.com 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 Hand Delivered U.S. Mail Overnight Mail FAX FTP Site X Email dearly@cityofboise.org boisecityattorney@cityofboise.org Wil Gehl Energy Program Manager Boise City Dept. of Public Works 150 N. Capitol Blvd. Boise, Idaho 83701-0500 Hand Delivered U.S. Mail Overnight Mail FAX FTP Site X Email wgehl@cityofboise.org Vote Solar Abigail R. Germaine Elam & Burke, PA 251 E. Front Street, Suite 300 PO Box 1539 Boise, ID 83701 Hand Delivered U.S. Mail Overnight Mail FAX FTP Site X Email arg@elamburke.com Kate Bowman Regulatory Director Vote Solar 299 S. Main Street, Suite 1300 PMB 93601 Salt Lake City, UT 84111 Hand Delivered U.S. Mail Overnight Mail FAX FTP Site X Email kbowman@votesolar.org 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