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Home My WebLink About20230920IPC to Staff 54-56.pdf MEGAN GOICOECHEA ALLEN Corporate Counsel mgoicoecheaallen@idahopower.com September 20, 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 Ninth 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 Wednesday, September 20, 2023 3:27:22 PM IDAHO PUBLIC UTILITIES COMMISSION IDAHO POWER COMPANY’S RESPONSE TO THE NINTH 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 NINTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), and in response to the Ninth Production Request of the Commission Staff (“Commission” or “Staff”) dated September 13, 2023, herewith submits the following information: IDAHO POWER COMPANY’S RESPONSE TO THE NINTH PRODUCTION REQUEST OF THE COMMISSION STAFF - 2 STAFF REQUEST FOR PRODUCTION NO. 54: The proposed Tariff language for Schedules 6, 8, & 84 states that financial credits are non-transferable in the event that a customer relocates within the Company' s service territory. Please explain why it is appropriate to require expiration of accumulated financial credits at the time of the final bill rather than transferring them to the new point of service. RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 54: Under the current on-site generation service offering, any accumulated kilowatt-hour credits are non-transferable in the event the customer relocates and/or discontinues taking service at the point of delivery associated with the exporting system. Any unused credits expire at the time the final bill is prepared. Accumulated financial credits should be treated in a similar manner. Any unused financial credits from discontinued service would be absorbed to the benefit of customers through a reduction (i.e., credit) to the Power Cost Adjustment. The response to this Request is sponsored by Grant T. Anderson, Regulatory Consultant, Idaho Power Company. IDAHO POWER COMPANY’S RESPONSE TO THE NINTH PRODUCTION REQUEST OF THE COMMISSION STAFF - 3 STAFF REQUEST FOR PRODUCTION NO. 55: Please explain whether the Company plans to charge customer generators for the cost of a power needs analysis, if needed, for the following cases: a. To ensure they do not go over the eligibility cap if a customer is new, doesn’t have historical billing data available, or they are a new customer with demand that exceeds prior customer needs; and b. To determine if the sum of the customer' s generation nameplate capacity plus the capacity of a battery exceeds the eligibility cap or requires an upgrade. RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 55: As a point of clarification, the Company has not proposed to offer a “power needs analysis” to administer the proposed change to the project eligibility cap for customers that elect to take service under Schedule 84. However, the Company has proposed to administer project eligibility as follows: a. For a new customer, the Company would evaluate and rely on available historical billing data at the service location. In the absence of that information, or in the case where a new customer believes their demand will exceed that of a past customer, the Company has proposed that the customer provide an analysis from a professional engineer to support their demand requirements if the proposed project exceeds 100 kW. b. The Company will determine if the sum of the nameplate capacity for the generation facility and an energy storage device exceeds the project eligibility cap. IDAHO POWER COMPANY’S RESPONSE TO THE NINTH PRODUCTION REQUEST OF THE COMMISSION STAFF - 4 The evaluation under both scenarios described herein would occur during the Feasibility Review of the customer-generator interconnection process pursuant to Schedule 68. The response to this Request is sponsored by Grant T. Anderson, Regulatory Consultant, Idaho Power Company. IDAHO POWER COMPANY’S RESPONSE TO THE NINTH PRODUCTION REQUEST OF THE COMMISSION STAFF - 5 STAFF REQUEST FOR PRODUCTION NO. 56: In its response to Production Request No. 4, the Company explained its process for calculating the Effective Load Carrying Capability ("ELCC") for customer-generators. Please describe how the Company will account for Energy Limited Resources ("ELRs") in these calculations. RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 56: If a customer- generator has battery storage, and only utilizes that storage to serve demand on their premises, the battery storage will not impact exports, and therefore would not impact the ELCC of customer generation. To the extent customer-generators utilize their on-site battery storage to export onto the Idaho Power system, the Company will include those resources in the total hourly customer-generator export data, as described in Request for Production No. 13. 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 NINTH PRODUCTION REQUEST OF THE COMMISSION STAFF - 6 DATED at Boise, Idaho, this 20th day of September 2023. MEGAN GOICOECHEA ALLEN Attorney for Idaho Power Company IDAHO POWER COMPANY’S RESPONSE TO THE NINTH PRODUCTION REQUEST OF THE COMMISSION STAFF - 7 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 20th day of September, 2023, I served a true and correct copy of Idaho Power Company’s Response to the Ninth 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 NINTH 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 NINTH 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