20230828IPC to Staff 37-40.pdf

MEGAN GOICOECHEA ALLEN
Corporate Counsel
[e-mail]

August 28, 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 Fourth
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
Monday, August 28, 2023 4:28:45 PM
IDAHO PUBLIC
UTILITIES COMMISSION

IDAHO POWER COMPANY’S RESPONSE TO THE FOURTH 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: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]

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 FOURTH
PRODUCTION REQUEST OF
THE COMMISSION STAFF TO
IDAHO POWER COMPANY

COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), and in
response to the Fourth Production Request of the Commission Staff (“Commission” or
“Staff”) dated August 7, 2023, herewith submits the following information:

IDAHO POWER COMPANY’S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 2
STAFF REQUEST FOR PRODUCTION NO. 37: Please provide the count, total
nameplate capacity, average kW size, total battery capacity, and average battery capacity
of active and pending solar+battery type export systems by class.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 37: Please see
Table 1 for details on active and pending export systems with battery storage.
Energy storage devices either share an inverter with the generation facility (“DC
coupled”) or have a stand-alone inverter (“AC coupled”). Because Idaho Power only
collects the nameplate capacity of the inverters, only the battery size for AC-coupled
energy storage devices is known. In comparison, DC coupled energy storage device
capacity is shared with the generation facility and cannot be separately reported in the
table. Therefore, the total and average capacity in the “storage only” section of Table 1 is
only available for AC coupled energy storage devices.
Table 1
Active and pending exporting systems with battery storage, as of June 30, 2023.

Solar + Storage Storage Only
Customer Type Count
Total Capacity
MW
Average Size
kW
Total Capacity
MW
Average Size
kW
AC Coupled Export Systems
Residential 286 3.97 13.87 1.59 5.54
Small General - - - - -
Commercial & Industrial - - - - -
Irrigation - - - - -
Total AC Coupled 286 3.97 13.87 1.59 5.54
DC Coupled Export Systems
Residential 614 6.69 10.90
Small General - - -
Commercial & Industrial 10 0.10 9.80
Irrigation 1 0.06 64.00
Total DC Coupled 625 6.85 10.96 n/a n/a
Total 911 10.82 11.88 n/a n/a
Note: Numbers may not add due to rounding.

IDAHO POWER COMPANY’S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 3
The response to this Request is sponsored by Grant T. Anderson, Regulatory
Consultant, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 4
STAFF REQUEST FOR PRODUCTION NO. 38: Please explain why it is
appropriate to model exports from customer-generator solar+battery systems in the same
manner as exports from a standalone solar system when the Company's battery
resources are modeled separately in the LOLE algorithm.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 38: Idaho Power
has proposed to utilize real-time exports from all customers with generation behind the
meter, independent of the generating resource. For these combined systems, Idaho
Power cannot distinguish if exported energy comes from the solar or the battery because
Idaho Power does not control the storage in a customer-generator combined system.
In comparison, for utility-scale generation paired with storage, where Idaho Power
has control over the storage component and can dispatch according to system needs,
separate modeling is feasible and provides more accurate results.
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 FOURTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 5
STAFF REQUEST FOR PRODUCTION NO. 39: Please explain if gaming
opportunities exist for customer generators with solar+battery systems under the
Company's proposed ECR. If, so how does the Company plan to prevent or mitigate
gaming exports during on-peak times.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 39: The Company
has not identified gaming opportunities under the Company’s proposal for customers with
solar and battery energy storage devices. The proposed credit structure incentivizes
customers to optimize systems to maximize exports during the Company’s hours of
highest risk. Additionally, deriving the Export Credit Rate from avoided costs mitigates
concerns about potential gaming opportunities - it allows the customer with an energy
storage device paired with their exporting system to choose between exporting during on-
peak hours or offsetting their energy needs later in the evening. As a result, other
customers should be indifferent and will be held harmless to the operating decisions of
customer-generators with storage paired with their exporting system.
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 FOURTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 6
STAFF REQUEST FOR PRODUCTION NO. 40: Please describe what factors are
driving the delay between the annual update time frame of 12 months ending Dec. 31st
and the proposed filing date in April. In the response, please explain when and what data
is available, and how long it takes to process it following the end of the annual time period.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 40: The primary
factor driving the annual update timing is the dispute resolution process for the Energy
Imbalance Market (“EIM”), which is defined by California Independent System Operator
(“CAISO”). The Initial Statement T+9B is received nine (9) business days after the
relevant trading day and has a dispute deadline of thirty-one (31) business days from the
relevant trading day. The Recalculation Statement T+70B is received seventy (70)
business days after the relevant trading day. The Company proposes to use the
Recalculation Statement T+70B to inform the EIM Load Aggregation Point (“ELAP”)
hourly market prices in its annual update of the Export Credit Rate (“ECR”). The
Recalculation Statement T+70B for the trading day December 31 would be available near
April 15 after excluding weekends and holidays.
Additionally, several other inputs to the ECR components are summarized within
Table 1 of the Direct Testimony of Grant T. Anderson (“Anderson Testimony”) and listed
as “annual” or “routine” updates. In addition to ELAP hourly market prices, the other
annual updates include the following:
(1) Real-time exports for the 12 months ending December 31.
(2) Peak annual exports.
(3) Contribution capacity three-year rolling average.
Each of these inputs requires consolidated hourly meter reads for all on-site generation

IDAHO POWER COMPANY’S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 7
customers who have been on-line for the duration of proceeding calendar year. While
these inputs are not a primary factor in the proposed updating timing, the time to conduct
the consolidation and subsequent analyses is expected to occur over the months of
January and February.
The remaining inputs listed in Table 1 of Anderson Testimony are listed as “routine”
updates. These inputs would rely on the most recently filed Integrated Resource Plan or
the most recently completed Variable Energy Resource Integration Study. Therefore,
these inputs are not a factor in the timing from the end of the calendar year and the timing
of when the Company proposes to file its annual update.
Regulatory lag of this nature is not uncommon, and any impact is minimized under
the Company’s proposal because updates occur before the next summer season. This
timing ensures that customers see the most accurate and timely updates for on-peak
prices for the ECR each year.
The response to this Request is sponsored by Grant T. Anderson, Regulatory
Consultant, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 8
DATED at Boise, Idaho, this 28th day of August 2023.

MEGAN GOICOECHEA ALLEN
Attorney for Idaho Power Company

IDAHO POWER COMPANY’S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 9
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the 28th day of August, 2023, I served a true and
correct copy of Idaho Power Company’s Response to the Fourth 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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IdaHydro
C. Tom Arkoosh
ARKOOSH LAW OFFICES
913 W. River Street, Suite 450
P.O. Box 2900
Boise, Idaho 83701

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Idaho Conservation League
Marie Callaway Kellner
Idaho Conservation League
710 North 6th Street
Boise, Idaho 83702

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Brad Heusinkveld
Idaho Conservation League
710 North 6th Street
Boise, Idaho 83702

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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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IDAHO POWER COMPANY’S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 10
Lance Kaufman, Ph.D.
2623 NW Bluebell Place
Corvallis, OR 97330
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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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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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Jim Swier
Micron Technology, Inc.
8000 South Federal Way
Boise, Idaho 83707
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IDAHO POWER COMPANY’S RESPONSE TO THE FOURTH PRODUCTION REQUEST OF THE
COMMISSION STAFF - 11
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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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