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Home My WebLink About20230912IPC to Staff 48-50.pdf MEGAN GOICOECHEA ALLEN Corporate Counsel mgoicoecheaallen@idahopower.com September 12, 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 Seventh Production Request of the Commission Staff 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 Tuesday, September 12, 2023 3:51:19 PM IDAHO PUBLIC UTILITIES COMMISSION IDAHO POWER COMPANY’S RESPONSE TO THE SEVENTH 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 SEVENTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), and in response to the Seventh Production Request of the Commission Staff (“Commission” or “Staff”) dated September 6, 2023, herewith submits the following information: IDAHO POWER COMPANY’S RESPONSE TO THE SEVENTH PRODUCTION REQUEST OF THE COMMISSION STAFF - 2 STAFF REQUEST FOR PRODUCTION NO. 48: In its Application, the Company states that "Consistent with the Commission's prior directives, the proposed changes to the on-site generation service offerings would only apply to non-legacy customers taking service under Schedules 6, 8, and 84, as appropriate." Application at 16. In the proposed Schedule 6, 8, and 84 tariffs, the Company makes changes to NET ENERGY METERING - CONDITIONS OF PURCHASE AND SALE section 2d language that effects legacy customers. Please explain the reasoning for these changes and explain why it is appropriate to make these changes as part of this filing. RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 48: The proposed revision to tariff Schedules 6, 8, and 84, under the Conditions of Purchase and Sale, Section 2(d), is intended to remove an administrative complexity regarding credit transfers for customers with legacy and/or non-legacy systems. Two factors drive the complexity and administrative burden of requiring priority to eligible meters on the same rate schedule. First, due to the manual nature of the meter aggregation process, the Company cannot easily identify all eligible meters to evaluate which are on the same rate schedule. Second, the balance of credits changes from when the customer submits the request until the credits are transferred. Therefore, customers submit a request to transfer a percentage of their credit balance rather than a flat amount of credits so that all requested meters that meet the eligibility requirements receive the requested allocation of credits. Conditions of Purchase and Sale, Section 2(v) continues to define which tariff schedules credits can be transferred. The response to this Request is sponsored by Grant T. Anderson, Regulatory Consultant, Idaho Power Company. IDAHO POWER COMPANY’S RESPONSE TO THE SEVENTH PRODUCTION REQUEST OF THE COMMISSION STAFF - 3 STAFF REQUEST FOR PRODUCTION NO. 49: In the proposed Schedule 6, 8, and 84 tariffs, NET ENERGY METERING - CONDITIONS OF PURCHASE AND SALE section 2b, the Company changed "between January 1 and January 31 of each year" to "between December 1 and January 31 of each year." Please clarify the year of the months reference and the amount of time the customer has to submit transfer requests. RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 49: Please see the Response to Staff’s Request for Production No. 29. The response to this Request is sponsored by Grant T. Anderson, Regulatory Consultant, Idaho Power Company. IDAHO POWER COMPANY’S RESPONSE TO THE SEVENTH PRODUCTION REQUEST OF THE COMMISSION STAFF - 4 STAFF REQUEST FOR PRODUCTION NO. 50: Page 20 of Grant Anderson's testimony describes the limitations of legacy on-site generation customers when transferring financial credits. Please answer the following a. Please explain how a legacy customer can have financial credits; b. Please clarify if it is possible for non-legacy customers to transfer financial credits to a legacy system; c. Please clarify if it is possible for legacy systems to transfer kWh credits to nonlegacy systems, given they meet the legacy requirements of credit transfers; and d. Please explain which guidelines govern the transfer when credits are transferred between legacy and non-legacy systems. RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 50: Please see below the responses related to on-site generation customers transferring credits: a. Legacy on-site generation systems will not accumulate financial credits, they will continue to accrue kilowatt-hour (“kWh”) credits. If a customer with a system otherwise eligible for legacy treatment wishes to instead accumulate financial credits and to transfer those financial credits to a service point not eligible under the rules applicable for Net Energy Metering, the customer could elect to forfeit the legacy status of the system and begin accumulating financial credits under the Net Billing service offering. These financial credits could be transferred according to the Net Billing criteria proposed in the respective on-site generation tariff schedule. b. Yes, it would be possible for a customer with a non-legacy system to transfer financial credits to an eligible meter with a legacy system under the Company’s IDAHO POWER COMPANY’S RESPONSE TO THE SEVENTH PRODUCTION REQUEST OF THE COMMISSION STAFF - 5 proposed criteria. Attachment 2 to the Application includes proposed revisions to Schedules 6, 8, and 84, which list the following criteria for aggregation of meters for the annual transfer of unused credits: (i) the account subject to offset is held by the customer, and (ii) the electricity recorded by the meter is for the customer’s requirements. c. Yes, it would be possible for a customer with a legacy system to transfer kilowatt- hour (“kWh”) credits to an eligible meter with a non-legacy system - or to any other eligible meter, irrespective of whether that meter has an on-site generation system. d. Please see Attachment 2 to the Application for the proposed changes to tariff Schedules 6, 8, and 84. Section 2 of the Conditions of Purchase and Sale for Net Metering and Net Billing describes the aggregation of meters for the annual transfer of unused credits. The response to this Request is sponsored by Grant T. Anderson, Regulatory Consultant, Idaho Power Company. IDAHO POWER COMPANY’S RESPONSE TO THE SEVENTH PRODUCTION REQUEST OF THE COMMISSION STAFF - 6 DATED at Boise, Idaho, this 12th day of September 2023. MEGAN GOICOECHEA ALLEN Attorney for Idaho Power Company IDAHO POWER COMPANY’S RESPONSE TO THE SEVENTH PRODUCTION REQUEST OF THE COMMISSION STAFF - 7 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 12th day of September, 2023, I served a true and correct copy of Idaho Power Company’s Response to the Seventh 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 SEVENTH PRODUCTION REQUEST OF THE COMMISSION STAFF - 8 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 SEVENTH PRODUCTION REQUEST OF THE COMMISSION STAFF - 9 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