HomeMy WebLinkAbout20230928IPC to Staff Supp 55-56.pdf
MEGAN GOICOECHEA ALLEN
Corporate Counsel
mgoicoecheaallen@idahopower.com
September 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 Supplemental 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
2023 SEPTEMBER 28, 2023 3:08PM
IDAHO PUBLIC
UTILITIES COMMISSION
IDAHO POWER COMPANY’S SUPPLEMENTAL 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
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CASE NO. IPC-E-23-14
IDAHO POWER COMPANY’S
SUPPLEMENTAL 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 supplemental
information:
IDAHO POWER COMPANY’S SUPPLEMENTAL RESPONSE TO THE NINTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 2
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.
SUPPLEMENTAL RESPONSE TO STAFF’S REQUEST FOR PRODUCTION
NO. 55: After filing its initial response, Staff requested additional information regarding
any study or review required for a customer-generator. Idaho Power provides this
supplemental response to address potential study costs or system review costs and how
those would be funded by the customer/applicant.
Pursuant to Schedule 68, an initial Feasibility Review occurs for all customer-
generator applications, after which, as discussed in Response to Staff’s Request for
Production No. 46, there are up to three interconnection studies that may be required as
part of the interconnection process consisting of (1) Feasibility Study, (2) System Impact
Study, and (3) Facility Study. These steps and associated costs are described in more
detail as follows:
(1) Feasibility Review: Standard engineering review of a proposed customer-
generator system intended to ensure the Company’s system is equipped to
incorporate the proposed facilities. The Feasibility Review may determine
that upgrades are necessary. Funding, construction, installation, and
maintenance of required upgrades will be subject to the Company’s
standard Rule H regarding New Service Attachments and Distribution Line
Installations or Alterations. The cost of the Feasibility Review is covered by
the cost of the $100 application fee.
IDAHO POWER COMPANY’S SUPPLEMENTAL RESPONSE TO THE NINTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 3
(2) Feasibility Study: More detailed engineering assessment for Distributed
Energy Resources (“DERs”) as determined by the Feasibility Review. This
study includes protection coordination and system voltage management
requirements necessary for the project. For projects under 3 MVA,
Schedule 68 does not require a deposit, but the $100 application fee does
not cover the cost of the study. For projects 3 MVA or greater, the $1,000
application fee is applied against costs the Company incurs to perform the
Feasibility Study. The Company believes it would be appropriate, and
consistent with larger projects, to require a $1,000 deposit for any project
where the Feasibility Review determines that a Feasibility Study is required.
Please see the file labeled “Attachment – Supplemental Response to Staff
Request No. 55” for the Company’s proposed revision to Schedule 68.
(3) System Impact Study (only applicable for projects 3 MVA or greater): The
System Impact Study provides a detailed assessment of the distribution
and/or transmission system adequacy to accommodate the DER by
evaluating equipment capabilities and electrical performance requirements.
This step may not be necessary for some projects, depending on the size
and location of the project. The System Impact Study Agreement includes
a deposit of $2,000 for a distribution system impact study or a $10,000
deposit for a transmission system impact study.
(4) Facility Study (only applicable for projects 3 MVA or greater): The Facility
Study includes the engineering to determine the project's design
specifications. The Facility Study Agreement includes a deposit of 5% of the
total project costs specified in the System Impact Study Report ("SISR") or
the Feasibility Study Report if a SISR is not required, capped at $30,000.
The response to this Request is sponsored by Jared L. Ellsworth, Transmission,
Distribution & Resource Planning Director, Idaho Power Company.
IDAHO POWER COMPANY’S SUPPLEMENTAL RESPONSE TO THE NINTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 4
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.
SUPPLEMENTAL RESPONSE TO STAFF’S REQUEST FOR PRODUCTION
NO. 56: After filing its initial response, Staff clarified that the question was intended to
reference how the Company will account for its utility-scale battery storage or solar +
battery storage projects. The Company’s current proposal is to model ELRs and VERs +
ELRs using their hourly historical charge and discharge shapes. The 2020, 2021, and
2022 hourly load data utilized in the three-year rolling average ELCC calculation for
customer-generator exports included the megawatt reductions from the Company’s
demand response programs; this approach is consistent with how customer-generator
exports ELCC calculations will account for other utility-scale ELRs and VERs + ELRs.
The response to this Request is sponsored by Jared L. Ellsworth, Transmission,
Distribution & Resource Planning Director, Idaho Power Company.
IDAHO POWER COMPANY’S SUPPLEMENTAL RESPONSE TO THE NINTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 5
DATED at Boise, Idaho, this 28th day of September 2023.
MEGAN GOICOECHEA ALLEN
Attorney for Idaho Power Company
IDAHO POWER COMPANY’S SUPPLEMENTAL RESPONSE TO THE NINTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 6
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 28th day of September, 2023, I served a true and
correct copy of Idaho Power Company’s Supplemental 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
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U.S. Mail
Overnight Mail
FAX
FTP Site
X Email elo@echohawk.com
IDAHO POWER COMPANY’S SUPPLEMENTAL RESPONSE TO THE NINTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 7
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
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U.S. Mail
Overnight Mail
FAX
FTP Site
X Email jswier@micron.com
IDAHO POWER COMPANY’S SUPPLEMENTAL RESPONSE TO THE NINTH PRODUCTION
REQUEST OF THE COMMISSION STAFF - 8
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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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
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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
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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. 55
SUPPLEMENTAL ATTACHMENT
Idaho Power Company First Revised Sheet No. 68-11
Cancels
I.P.U.C. No. 29, Tariff No. 101 Original Sheet No. 68-11
IDAHO Issued by IDAHO POWER COMPANY
Issued per Order No. 34955 Timothy E. Tatum, Vice President, Regulatory Affairs
Effective – March 23, 2021 1221 West Idaho Street, Boise, Idaho
SCHEDULE 68
INTERCONNECTIONS TO CUSTOMER
DISTRIBUTED ENERGY RESOURCES
(Continued)
SECTION 2: INTERCONNECTION PROCESS REQUIREMENTS FOR DISTRIBUTED ENERGY
RESOURCES LESS THAN 3 MVA (Continued)
APPLICATION PROCESS (Continued)
c. If the Company determines that additional time is necessary to determine
satisfactory system capability or that Upgrades are necessary to accommodate the proposed
project, the Company will notify the Customer. The Company will perform within fifteen (15)
business days the additional studies to complete the Feasibility Review.
4. If the results of the Feasibility Review require the need for a Feasibility Study, the
Company will perform the Feasibility Study within 15 business days. If the results of the Feasibility Study
indicate that Upgrades or Protection Equipment are necessary to accommodate the proposed project,
the Company will notify the Customer of such Upgrades or Protection Equipment. The Feasibility Study
Agreement includes a deposit of $1,000.
a. Installation and funding of the construction, installation, and maintenance of
required Protection Equipment will be subject to the following provisions:
i. Protection Equipment Requirements (Rotating Machines): Generation
Facilities up to 500 kVA Total Nameplate Capacity may not require additional Protection
Equipment but will be evaluated on a case-by-case basis. Generation Facilities greater
than 500 kVA Total Nameplate Capacity will require additional Company-Furnished
Protection Equipment.
ii. Protection Equipment Requirements (Other DER): DER up to 3 MVA Total
Nameplate Capacity may not require additional Protection Equipment but will be evaluated
on a case-by-case basis.
iii. When it is determined Company-owned Protection Equipment is required,
the Customer shall pay the actual costs of all required Protection Equipment prior to the
start of Parallel operations. The Customer will also pay a Maintenance Charge of 0.59
percent per month times the investment in the Protection Equipment.
5. Following receipt of “Approval to Proceed,” the Customer is responsible for completing the
installation of the Customer Generator System and fulfilling all applicable federal, state, and local
inspection requirements. Customers must also provide the Company with a completed System
Verification Form detailing the specifications of all installed components of the completed Customer
Generator System. System Verification Forms can be found on the Company’s website or will be
provided upon request. Upon completion, the Company reserves the right to request the Customer to
provide forms of documentation outlined in Section 1, verifying that all federal, state, and local
requirements have been met.