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Home My WebLink About20230918IPC to Staff 45-47.pdf MEGAN GOICOECHEA ALLEN Corporate Counsel mgoicoecheaallen@idahopower.com September 18, 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 Sixth 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 2023 SEPTEMBER 18, 2023 4:25PM IDAHO PUBLIC UTILITIES COMMISSION IDAHO POWER COMPANY’S RESPONSE TO THE SIXTH 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 SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), and in response to the Sixth Production Request of the Commission Staff (“Commission” or “Staff”) dated August 28, 2023, herewith submits the following information: IDAHO POWER COMPANY’S RESPONSE TO THE SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF - 2 STAFF REQUEST FOR PRODUCTION NO. 45: The Company's response to Staff Production Request No. 15 states that "[a] commercial, industrial or irrigation customer who desires to install an on-site generation system larger than 100 percent of their demand has the option to do so by either selling their renewable energy to Idaho Power as a Qualifying Facility under Schedule 86 or configuring their system to be non- exporting." Please confirm that besides the Schedule 86 option and the non-exporting option, customers can also sign Energy Sales Agreements with the Company as a Qualifying Facility, using avoided cost rates. RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 45: Yes. Schedule 73, Cogeneration and Small Power Production Schedule – Idaho (“Schedule 73), is applicable to Qualifying Facilities (“QF”) that intend to sell their output to the Company by either (i) interconnecting to the Company’s electrical system at an interconnection point within the State of Idaho, or (ii) delivering the output to the Company at a Point of Delivery (“POD”) on the Company’s electrical system within the State of Idaho. A Customer selling the output of any QF will be required to enter into a written Energy Sales Agreement (“ESA”) with the Company in accordance with contracting procedures set forth in Schedule 73. Any such ESA is subject to the approval of the Idaho Public Utilities Commission. The response to this Request is sponsored by Camille Christen, Resource Acquisition, Planning and Coordination Manager, Idaho Power Company. IDAHO POWER COMPANY’S RESPONSE TO THE SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF - 3 STAFF REQUEST FOR PRODUCTION NO. 46: The Company's response to Staff Production Request No. 24 mentions "the differing types of interconnection studies required". Please explain how a PURPA project's interconnection study and an on-site generation customer's interconnection study are different. RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 46: The three types of interconnection studies that may be required as part of the interconnection process are the same regardless of the project type; the studies consist of a Feasibility Study, a System Impact Study, and a Facility Study. Therefore, a PURPA project and a large customer generation project could have similar interconnection study requirements. Due to their higher complexity, and often larger size, PURPA projects will generally go through each of the three study phases but may be able to jump directly to the System Impact Study upon mutual agreement. Typically, on-site generation customer interconnections are less complex and do not require all three study phases; for projects less than 3 MW an initial Feasibility Review is conducted to determine whether the Company’s system is adequately equipped to incorporate the proposed project and to inform the need for additional studies. Due to generally smaller system sizes, most customer generation projects do not require a detailed Facility Study but are interconnected after passing a Feasibility Review. For those customer generation projects that do require additional studies, the simplicity and lower size of customer generation generally brings less risk to the electric system and usually does not require the same study detail, including the determination of protective equipment installed on Idaho Power’s system, resulting in an abbreviated Facility Study compared to a PURPA project’s Facility Study. The exception would be inverter-based customer generation IDAHO POWER COMPANY’S RESPONSE TO THE SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF - 4 projects 3 MW and larger or synchronous generation-based customer generation projects 500 kW and larger, as detailed in Schedule 68. 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 SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF - 5 STAFF REQUEST FOR PRODUCTION NO. 47: Please respond to the following regarding the Company's response to Staff Production Request No. 27. a. Please explain why credits transfer between contiguous meters served by the same primary distribution feeder can mitigate potential under-recovery of fixed costs. b. Please explain how the proposed ECR mitigates the under-recovery issue so that the requirement for contiguous meters served by the same primary distribution feeder is not necessary. RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 47: Please see the following responses: a. In Order No. 32925 in Case No. IPC-E-12-27, the Commission found “that allowing customers to apply credits to offset usage on contiguous meters that are served by the same primary feeder is a reasonable means by which to limit the potential under-recovery of fixed costs.” b. Under the existing monthly Net Energy Metering service offering, a customer receives a one-for-one kilowatt-hour (“kWh”) credit that can offset future energy charges. The kWh credit offset allows the customer-generator to offset fixed costs embedded in the energy charges. Under the real-time net billing proposal, the real- time measurement partially mitigates fixed cost under-recovery with a more accurate measure of energy consumed from and exported to the grid. Additionally, an avoided-cost-based Export Credit Rate (“ECR”) further mitigates fixed cost under-recovery because the credit is decoupled from the retail energy rate, which reflects an embedded portion of fixed costs required to serve a residential IDAHO POWER COMPANY’S RESPONSE TO THE SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF - 6 customer. The response to this Request is sponsored by Grant T. Anderson, Regulatory Consultant, Idaho Power Company. IDAHO POWER COMPANY’S RESPONSE TO THE SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF - 7 DATED at Boise, Idaho, this 18th day of September 2023. MEGAN GOICOECHEA ALLEN Attorney for Idaho Power Company IDAHO POWER COMPANY’S RESPONSE TO THE SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF - 8 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 18th day of September, 2023, I served a true and correct copy of Idaho Power Company’s Response to the Sixth 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 SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF - 9 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 SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF - 10 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