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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 ) ) ) ) ) ) ) ) ) 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 Hand Delivered 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 Hand Delivered 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 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 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.