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HomeMy WebLinkAbout20160429Annual Net Metering Report.pdffiEffi* An TDACORP Company LISA D. NORDSTROM Lead Counsel I nordstrom@idahopower. com April29, 2016 Ms. Jean D. Jewell Secretary ldaho Public Utilities Commission PO Box 83720 Boise, lD 83720-0074 RICEIVED ;il16,*.PR 29 PH 3: 35 l-...: l l:l l::r l:*: 1,-r t i,'r_j ._i, .,ii1sla+ RE: Compliance Filing in Case No. IPC-E-12-27 Annual2016 Net Metering Status Report Dear Ms. Jewell: Pursuant to Order Nos. 32846 and 32925 in the above-mentioned case, ldaho Power Company ("ldaho Powe/' or "Company") hereby submits its 2016 Annual Net Metering Status Report. On page 19 of Order No. 32846, the ldaho Public Utilities Commission ('Commission') indicated that "the report shall discuss, without limitation, the net metering service provisions and pricing and how distributed generation may be impacting system reliability." The attached report responds specifically to the Commission's directive to provide such information. ldaho Power recognizes that in Order No. 32846 the Commission directed the Company to raise issues related to rate design in the context of the Company's next general rate case. However, for the reasons described in the report, ldaho Power believes its net metering service has reached a pivotal point; that is, the Company is able to quantify that cost shifting is occurring between residential net metering customers and residential standard service customers and can reasonably predict that future cost shifting between these customer groups will grow exponentially in the next few years. Because the Company does not know when it will next file a general rate case, Idaho Power believes it is prudent to begin the net metering conversation now. ldaho Power plans to hold customer and stakeholder workshop(s) during 2016 to share the results of this report and solicit feedback on a potential rate design proposal for future net metering customers that the Company may consider filing with the Commission. !f the Commission wishes to open a docket and issue a Notice of Workshop(s) to facilitate customer participation, ldaho Power willwork with the Commission to establish a mutually agreeable schedule. lf you have any questions regarding this filing, please direct procedural questions to me and substantive inquiries to Senior Regulatory Analyst Connie Aschenbrenner at (208) 388-5994 or caschenbrenner@idahopower. com. Very truly yours, "(,^. !fl^,at ^, LDN/KKI Enclosures cc: Kar! Klein, IPUC Lisa D. Nordstrom ldaho Power Company Annual Net Metering Status Report April 29,2016 ldaho Power Company ('ldaho Powef or "Company') presents its annual net metering status report to the ldaho Public Utilities Commission ("Commission') as required by Order Nos. 32846 and 32925 in Case No. IPC-E-12-27. The report begins with updated participation and growth data since the Company's last update to the Commission in April 2015 and a discussion about ldaho Power's average residential net metering customer and how that customer segment's usage profile is changing over time. The report then details key issues related to the Company's net metering service, including a quantification of the current and potential future amount of cost shifting occurring between the net metering residential customer segment and the residential standard service customer class, an update on excess net energy credit transfers, and an assessment of the impact of distributed generation on system reliability. l. Existinq Net Meterinq Service Current Participation and Growth As of December 31,2015, ldaho Power's net metering service consisted of 731 active systems with a cumulative nameplate capacity of 5.31 megawatts ("MW'). During calendar year 2015, participation in net metering service increased by 234 active systems (a 47 percent increase) with incremental nameplate capacity totaling 1.79 MW. The additional systems were entirely comprised of new solar photovoltaic ("PV') installations. During the first quarter of 2016, growth continued with the Company adding 59 new active systems with aggregate nameplate capacity of 0.827 MW. ln addition, the Company has 77 pending applications totaling 0.938 MW of nameplate capacity. At the end of the first quarter 2015,ldaho Power reported 584 active and pending systems, and at the end of the first quarter of 2016, ldaho Power has 867 active and pending systems, which represents a 48 percent growth rate since this time last year. Tables 1 and 2 provide the total number of active and pending net metering systems and nameplate capacity by resource type, jurisdiction, and customer class. IDAHO POWER COMPANY'S ANNUAL NET METERING STATUS REPORT - 1 ldaho Solar PV Wind Hydro/Other Tota! Residential 658 55 6 719 Commercial & lndustrial 105 6 4 115 lrrioation 3 1 4 Total ldaho 766 62 10 838 Oregon Residential 11 1 12 Commercial & lndustrial 8 I lrrioation I 9 Total Oreoon 28 1 29 Total Company Residential 669 56 6 731 Commercial & lndustrial 113 6 4 123 lrrigation 12 1 13 TotalCompanv 794 53 10 867 Tabte 1: Number of Net Metering Systemsr - Pending and Active as of March 31, 2016 Table 2: Nameplate Gapacity (MW) - Pending and Active as of March 31, 2016 Chart 1 details cumulative net metering system counts by customer class from 2001 through the first quarter of 2016 (including pending applications). 1 The net metering database the Company maintains reports a new application as a "system." Some customers have increased capacity of an existing system or have installed a second system that is a different resource type; these expansions or additional systems would be counted in Tables 1 and 2 as its own system. This allows the Company to report capacity in the year in which it came online. Additionally, because an expansion of an existing system requires the filing of a new application, it is treated separately for tracking purposes. IDAHO POWER COMPANY'S ANNUAL NET METERING STATUS REPORT - 2 ldaho Solar PV Wind Hvdro/Other Tota! Residential 3.53 .29 .06 3.88 Commercial & lndustrial 1.89 .05 .09 2.03 lrrioation .21 .04 .25 Total Idaho 5.63 .38 .15 6.16 Oreqgn Residential .08 .08 Commercial & lndustrial .15 .15 lrrioation .69 .69 TotalOreoon .92 0 0 .92 TotalGomoanv Residential 3.61 .29 .06 3.96 Commercial & lndustrial 2.04 .05 .09 2.18 lrrioation .90 .04 .94 Total Comoanv 6.55 .38 .15 7.08 Ghart 1: Gumulative Net Metering System Gounts (by Customer Type) From a capacity perspective, interconnected net metering generation expanded in accordance with the increasing system counts described above. Chart 2 details cumulative capacity growth from 2001 through the first quarter of 2016 (including pending applications). Ghart 2: Cumulative Net Metering Gapacity (by Customer Type) The majority of growth in the Company's net metering service is related to the installation of residential PV systems. PV has comprised 90, 98, 99, and 100 percent of the 1,00o 900 800 700 500 500 400 300 200 100 0 2016 (YrD) r Residential r C&l r lrrigation -I200s 2006 I 2002 2003 2004. :rr,iiill 2007 2008 2009 2010 20tt 2012 2013 2014 2015 n-: 2002 2003 2004 2005 2006 8i 7:- 6i l 5 ;-.. 3.i 2: 1 0 2001 20t6 (YTD) r Residential r C&l r$e lrrigation IDAHO POWER COMPANY'S ANNUAL NET METERING STATUS REPORT - 3 incremental resource mix in the years between 2012 and 2015, respectively. All but one of the incremental active and pending installations in 2016 are PV. The exponential growth in net metering service since 2001 demonstrates how the Company's grid is evolving, and underscores the need to evaluate the associated service provisions and pricing to ensure that ldaho Power can continue to offer safe, reliable, fair-priced electrical service now and in the future. ldaho Power also anticipates that as participation in its net metering service continues to grow, it may require additional staff to facilitate both the processing of net metering applications at the time of interconnection, as we!! as processing the annual transfer of excess net energy credits. Gharacteristics of the Average Residential Net Metering Customer ldaho Power examined the load characteristics of its current residential net metering service customers to determine differences, if any, between them and current residential standard service customers for a few reasons. The Company determined the current residential net metering customers were different for a few reasons: the most obvious difference is that they use the Company's electrical system bi-directionally, both to take service from the utility and to put excess generation back onto the grid. Further, because net metering customers are billed based on net energy consumed over the course of a month, a net metering customer may be billed for net zero consumption and avoid paying for fixed costs associated with service during hours of the month they consumed energy from the grid and other hours of the month they supplied excess net energy to the grid. Based on an analysis of 2015 actual billing data, the net metering customers also tend to be larger energy users, with an average monthly kilowatt-hour ("kWh") usage of 9952 compared to an average residential standard service customer who used approximately 9473 kWh per month during 2015. While this relationship may appear counter-intuitive on its face, a further examination of the usage characteristics of 2 This is the monthly average of the total 2015 actual billed kWh for these customers (net of net metering system generation). Because the Company uses a single meter to measure consumption over a billing period, it does not have the ability to measure total consumption and total generation separately. 3 Based on 2015 actual billed kWh for the residential class. IDAHO POWER COMPANY'S ANNUAL NET METERING STATUS REPORT.4 the cunent net metering segment shows that there are a small number of unusually large energy users skewing the average consumption of the segment. Chart 3 demonstrates the load shape of the Company's residential customer class on June 29, 2015, the day of the 2015 Idaho Power adjusted system peak.a Chart 3 also includes the load shape of the Company's residential net metering customer segment on that same day. As mentioned above, Chart 3 illustrates that these customers are generally Iarger users than the Company's average residential standard service customer and demonstrates the residential net metering customer's ability to offset usage when, in the case of a PV system, the sun is shining. Chart 3: 20{5 Adjusted System Peak Day (June 29, 2015} 3.50 3.00 2.50 2.00 1.50 1.00 0.50 0.00 L 2 3 4 5 6 7 8 9 1011t213t4 1516171819202L222324 Hour ending -fts5idsntial Net Metering Customers -ftg5idgntial Customer Class ll. Quantification of Cost Shiftinq As discussed in Case No. IPC-E-12-27 and in prior net metering status reports to the Commission, the current practice of applying standard retail rates to net metering service is problematic because it creates the potentialfor inappropriate cost shifting between net metering customers and standard service customers. The potential for cost shifting is especially large within the Company's residential and small general service classes because a higher a The reported system peak was June 30, 2015, at 4:00 pm; the adjusted system peak day represents the hour at which the system would have peaked had the Company not dispatched its demand response programs. This methodology is consistent with the filed class cost-of-service study from the Company's last general rate case (lPC-E-11-08). IDAHO POWER COMPANY'S ANNUAL NET METERING STATUS REPORT - 5 percentage of fixed costs are collected through a volumetric energy rate from these customers as compared to other customer classes. Residential and small general service customers are currently billed through a two-part rate design consisting of a $5.00 monthly service charge and volumetric energy rates. Quantification of Current Cost Shift The Company performed an analysis of its residential net metering customer segment to determine what, if any, cost shifting is currently occurring.s First, the Company quantified the amount of base rate revenue collected during 2015 from its residential net metering customers.G Then, using a methodology similar to that used to assign costs to customers during a general rate case process, the Company determined the ldaho-jurisdictional revenue requirement for those same net metering customers. Cost allocation for the 366 customers used the hourly metered data to determine their use of the system by analyzing demand at the time of the monthly system peak, at the time of the residentia! class peak, as well as average energy consumed by month. The results of this analysis was an estimated cost-of-service specific to how these customers utilize ldaho Power's electricalgrid. Table 3 details the results of the net metering revenue requirement analysis, which are functionalized by production, transmission, and distribution and classified by utility services provided as represented by customer, demand, and energy. Table 3 also presents the percentage difference in revenue requirement between existing residential net metering customers and residential standard service customers. u The Company focused its analysis on the residential customer class for two reasons: (1) the majority of the recent growth in the net metering service is in the residential class and (2) the residential customer class has a two-part rate design with most of the customer-related fixed costs and all of the demand- related fixed costs being recovered through a volumetric charge. Cost shifting may be occurring in other customer classes, but the focus of this year's annual status update to the Commission will be on the current and potential cost shift from residential net metering customers to residential standard service customers. 6 ln order to compare a full year of billed revenue with an estimated annual revenue requirement, the analysis contains all residential net metering customers who had a full 12 months of billing data availabb for 2015. This data set is comprised of 366 customers. IDAHO POWER COMPANY'S ANNUAL NET METERING STATUS REPORT - 6 Table 3: Functionalized and CIassified Residential Net Metering Customer Segment Revenue Requirement Compared to Average Residential Standard Service Custome/ Residential Net Metering Customers 54O,296 81,516 35,721 t2L,647 47,294 Compared to Avg Residential Standard Se rvice Customer PRODUCTION Demand, Summer Demand, Non-summer Energy, Summer Energy, Non-summer -l3o/o 36% 5%o L7% 2L% 8%o OYo Lt% DISTruBIMON Demand Customer 50,458 87,6LL TOTAT The net metering revenue requirement compared to the revenue collection for those same customers is represented in Chart 4. Chart 4: 2015 Residential Net Metering Cost Shift Using the above described process, the Company quantified the revenue requirement for the 366 residential net metering customers to be $464,532. The total base rate revenue received from these customers during 2015 was $408,820, resulting in an estimated cost shift of $55,712, or 12 percentof thetotal revenue requirement. As denoted in Chart4, the $464,532 'The "Compared to Avg Residential Standard Service Custome/'column in Table 3 represents the "per custome/' net metering customer segment revenue requirement relative to the "per customer'' residential customer class revenue requirement. IDAHO POWER COMPANY'S ANNUAL NET METERING STATUS REPORT. 7 $q6q,s3zs500,000 s400,000 s300,000 s200,000 Sloo,ooo So Revenue Requirement Revenue Collection r Variable : Fixed revenue requirement is comprised of 66 percent fixed costs and 34 percent energy costs; however, only 5 percent of the total revenue was collected through the fixed service charge and the remaining 95 percent was collected through the volumetric energy kWh charge. While the current cost shift is relatively small, it is important to consider the demographics of the 366 residential net metering customers who make up the $408,820 of base rate revenue collection in order to assess the risk for future potential cost shift. The kWh usage varies significantly between the 366 customers, from one customer who consumed (net of generation) over 179,000 kWh during 20'15 (annual base rate revenue collected $17,785) to 40 customers who were not billed for any kWh during 2015 (these customers netted usage to zero and only paid the $5.00 monthly service charge). ln fact, approximately three percent of the customers accounted for 20 percent of the 2015 revenue collection. The Company believes that a few large energy users in this group are muting the cost shift of the net zero customers who effectively avoid paying most of the customer-related costs required to serve them, and do not pay any of the cost of the distribution, transmission, or generation systems, even though they may still use these throughout the year. The Company does not believe the 366 residential net metering customers analyzed for quantification of the current amount of cost shifting is representative of the future potential for cost shift. As the economics of installing a residential PV system improve, the Company expects the installation of these systems will become more attractive and attainable to the Company's average residential customer. Potential for Future Cost Shift To project potential future cost shift that could occur in the residential customer class, the Company quantified an estimated cost shift per new net metering customer and applied that quantification against future potential adoption rates of residential net metering. Estimated Cost Shift Per Customer To quantify the estimated cost shift per customer, the Company looked at recent installations of net metering systems within its residential customer class to determine what IDAHO POWER COMPANY'S ANNUAL NET METERING STATUS REPORT. 8 system sizes are most commonly installed. Chart 5 shows the percentage of systems according to size installed by ldaho Power's residential customers in each of the last five years. The data shows that as the costs of PV have declined over the last several years, the size of PV systems being installed by residential customers has increased. The most commonly installed system in 2015 was a 6 kilowatt ('kW") system and the second most commonly installed system was a 5 kW system. Based on estimates from the National Renewable Energy Laboratory (NREL') PV Watts@ Calculator, a 6 kW standard fixed (open rack) system located in Boise, ldaho, will generate approximately 8,731 kWh/year and a 5 kW standard fixed (open rack) system located in Boise, ldaho, will generate approximately 7,276 kWh/year. Ghart 5: System Size of Residential Net Metering Customer lnstallations (PV Systems Only) ln order to quantify the potential for future cost shifting, the Company compared a calculated revenue requirement for an average residential customer before and after the installation of a net metering system. First, the Company looked at the average hourly load profile of its residential customer class in order to estimate a per customer revenue requirement (based on the same methodology explained on page 6). The Company then used the hourly output profile provided by the NREL PV Watts@ Calculator to quantify the net hourly usage of an average residential customer who installs a 6 kW PV system. Using the net hourly usage, the Company quantified the estimated annual revenue requirement for an average residential IDAHO POWER COMPANY'S ANNUAL NET METERING STATUS REPORT. 9 LOO% 90%6 .E BO% tvi ToYoGE 60%, i, 50% i Eqox. 66 30% l-o 20% 0o/o : 20L2 t 1-3kW r4-5kW 20L3 * 7-9kW r 10kW+ customer after the installation of a 6 kW PV system. The results of that analysis are presented in Table 4. Table 4: Annual Potential Cost Shift Per Residential Net Metering Customer Standard Service Residential Customer Net Metering Residential Customer (6 kW Systeml Difference % PRODUCTPN Demand, Summer Demand, Non-summer ENERGY Summer Non-summer 5t27 L54 93 28s L07 128 239 s1,143 - 11,810 Sss 151 49 L7L 82 100 239 $72) -s7% (13) -8Yo l44l -47Yo (113) -40Yo l24l -23% (29) -22Yo 00% DISTRIBUNON Demand Customer Revenue Requirement -lE3g-11,810 (8,731) 3,O79 (s2esl kWh Usage (Before Net Metering) ation (6 kW System) Net kWh Usage 11,810 St,oqt Sgs I Utility Bill Ssoa Ss+o (s73el -71% Difference between Rev. Req. and Utility Bill UAt POTENTIAT COSTSHIFT PER CUSTOMER Table 4 demonstrates that while a residential net metering customer's self-generation reduces the cost to serve that customer, it does not eliminate the costs entirely and it does not reduce them as much as the utility bill is potentially reduced. However, the price signal sent to the customer through the current rate design may inappropriately send a signal that the cost to serve them is lower than it actually is. The average sized ldaho Power residential customer who installs a 6 kW PV system is able to reduce his or her revenue requirement by 26 percent, however, that same customer's bill is reduced by 71 percent. The potentia! cost shift of $444 per customer is quantified by subtracting the amount paid to the Company ($Oal from the total estimated annual revenue requirement of $848 and subtracting the $96 existing intra-class subsidy that exists for a customer of this size. IDAHO POWER COMPANY'S ANNUAL NET METERING STATUS REPORT - 10 Future Potential Adoption Rates As reported in the "Current Participation and Growth" section of the report, the residential customer segment has seen a tremendous rate of growth in the adoption of net metering. Chart 6 represents the number of ldaho Power residential net metering customers through the end of 2015. Ghart 6: Gumulative Growth in Residential Net Metering Customerss 700 600 ; s00 oe 400 o E soo tn =e 200 100 2oo2 2oo3 2004 2005 2006 2oo7 2oo8 20og 2070 20LL 20L2 20L3 20L4 20L5 -fts5idsntial Net Metering Customers Using the historical growth trends, the Company projected residential net metering customer counts through the scheduled 2021 expiration of the federal investment tax credit ('lTC").s Three forecasted growth scenarios were developed based on the distribution of year- over-year growth rates by month as experienced over the past 18-months. The "Median" scenario represents the median of the growth rate distribution, the "Lovl'' growth scenario is t Chart 6 represents cumulative growth in residential net metering customers. While Tables 1 and 2 counted expansions of existing systems or installation of multiple resource types as separate systems, for purposes of forecasting net metering customer growth, the Company is reporting counts based on customer agreements. s A taxpayer may claim a credit of 30 percent of qualifled expenditures for a system that serves a dwelling unit located in the United States that is owned and used as a residence by the taxpayer. The Consolidated Appropriations Act, signed in December 2015, extended the expiration date for PV and solar thermal technologies, and introduced a gradual step down in the credit value for these technologies. The 30 percent ITC was extended through 2019 and it will reduce to 26 and 22 percent in 2020 and 2021, respectively. The credit for all other technologies will expire at the end of 2016. (http://enerqy. qov/savi nqs/residential-renewable-enerqy-tax-cred it) IDAHO POWER COMPANY'S ANNUAL NET METERING STATUS REPORT - 11 based on the 1Otr percentile of growth rates and the "High' growth scenario is based on the 70s percentile of growth rate. The year in Chart 7 represents the year the customer installs a system. Chart 7: Forecasted Growth in Residential Net lf,etering Customers Potential lmpact of Grid Paritv "Grid parity" refers to the point in time when the levelized cost of energy ('LCOE') from a PV system becomes cost competitive with the retail rate of energy. The LCOE is determined by performing a net present value ("NPV') calculation that takes into account the total cost of the system (up front capital cost, ongoing operations and maintenance costs, inverter replacement, etc.), as well as benefits received via state and federaltax incentives, and divides the quantified NPV by the average annual energy output from the system. While the Company only considered historical adoption rates to predict possible future adoption of residential net metering systems, it is important to consider what the potentia! impact of the cost of rooftop PV reaching grid parity may be. At the point the LCOE is lower than the retail cost of energy supplied by the utility, it becomes more economica! for customers to install PV and it is reasonable to predict that the growth in the PV net metering systems will accelerate considerably. The Company also expects that a broader range of customers may IDAHO POWER COMPANY'S ANNUAL NET METERING STATUS REPORT. 12 7,000 j-- -- I 6,000 +- I5,000 1-- - I t- I+- I 1I- 6b 4,000 Eo 3 g,ooo 2,000 1,000 0 2074 2015 2076 2017 2018 20L9 -lery -Median -High consider installing PV once the cost of installing that system becomes cost competitive with the utility rate. Future Potential Cost Shift The starting point in Chart 8 represents the residential net metering customers the Company had at the end of 2014 who had a full year of billing data for 2015. That is, the Company's quantified current cost shift of $55,712 conesponds to the customer count at the end of 2014 (366 customers). ln order to pQect potential future cost shift, the Company applied the average per-residential net metering customer cost shift of $444 lo the potential near-term adoption of residential net metering service. Chart 8 shows the potential future cost shift by 2021 could be as high as $1.9 million per year or as low as $755,000 per year, with the median growth rate yielding a potential future cost shift of $1.3 million per year by 2021. Chart 8: Cumulative Annual PotentialCost Shift s2,000,000 s1,500,000 s1,000,000 Ssoo,ooo So Addressing the potential cost shift The Company believes its net metering service has reached a pivota! point; that is, the Company is able to quantify that cost shifting is occuning and can reasonably predict that future cost shifting will continue to occur at an increasing rate. The cunent rate design of billing residential and small general service customers a nominal service charge coupled with the IDAHO POWER COMPANY'S ANNUAL NET METERING STATUS REPORT. 13 remaining variable and fixed cost recovery through a volumetric rate is concerning for two reasons: (1) new residential customers installing PV systems are creating a real and quantifiable cost shift to residential standard service customers who either choose not to install PV systems or do not have the means to do so, and (2) the current rate design sends an incorrect price signal to residential and small general service customers who are evaluating whether or not to install a PV system. The Company's analysis demonstrates that while the revenue requirement associated with serving a residential PV net metering customer is estimated to be reduced by 26 percent, that same customer's bill is reduced by 71 percent. The Company is not the first to look at addressing the potential for cost shift that exists with net metering customers and the Company continues to believe that proper rate design is the appropriate means for addressing the cost shift that is occurring and will grow with the continued adoption of distributed generation in its service area. Utilities across the country are examining how to best address the issues created by existing rate designs and the historical practice of a 1:1 kWh credit established at the retail rate and have started introducing means for better fixed cost recovery for their net metering customers.to tn 2015, other state commissions overseeing three utilities established a separate class for distributed generation customersll and three other requests by utilities to do the same are being considered.l2 lll. Billinq Svstem Capabilities While ldaho Power continues to believe its current rate designs cannot sustainably support the widespread expansion of net metering, it is important to consider billing system capabilities when evaluating proposed changes to the pricing of the Company's net metering service. ln general, utility billing systems are not initially configured to accommodate net 10 Alabama Power charges a capacity reservation fee, Arizona Public Service charges a grid access fee, California utilities (Pacific Gas and Electric, Southern California Edison, and San Diego Gas & Electric) charge an interconnection fee that was previously paid by all customers and future distributed generation customers will default to a time-of-use rate, Hawaiian Electric companies charge minimum bills, and Dominion Virginia and Appalachian Power charge standby fees. 11Westar, Nevada Power, and Sierra Pacific Power " UNS Electric and Tucson Electric in Arizona both filed to establish mandatory three-part rates for distributed generation customers. El Paso Electric in Texas filed for establishment of three part rate structures for partial-requirements customers. IDAHO POWER COMPANY'S ANNUAL NET METERING STATUS REPORT - 14 metering transactions, and changes in net metering billing practices often require resource- intensive customization that not only result in up-front costs, but require additional ongoing maintenance costs as well. lV. Svstem Reliabilitv Considerations Net metering systems in Idaho Power's service area are dispersed across hundreds of distribution feeders. Because the cunent penetration level is relatively small compared to distribution feeder loads, as of the end of 2015, there was no significant impact on distribution system reliability attributed to net metering system operation. As of March 31,2016, the Company's 789 active net metering systems were dispersed across roughly 282 of its approximately 650 distribution feeders. That compares to 550 active systems across 229 distribution feeders that were reported on March 31,2015. The feeders that contain the greatest number of net metering systems are largely located in northeast Boise and in the Wood River area, while the feeders that contain the greatest amount of connected net metering capacity tend to be located in mostly agricultural and rural areas. The greatest number of active net metering systems that currently exist on a single distribution feeder is sixteen. From a capacity perspective, eight generators (all solar) rated at approximately 398 kW are located on a single distribution feeder. That feeder serves mostly rural customers with a calculated summer peak load of approximately 1,600 kW. The percentage of connected net metering kW capacity to the feeder's calculated summer peak load is approximately 24 percent. The percentage of connected kW capacity to summer peak loads for the remaining 281 feeders with active net metering systems remains less than 4 percent. The Company has not yet experienced significant operational impacts on these feeders. Because net metering installations are typically unique in both customer-specific system attributes, as well as the Company's facilities in a particular location, the Company reviews several factors when determining the feasibility of connecting a new net metering system. This review may include determining if there is adequate transformation at the point of connection, if the existing service conductor has adequate capacity to serve the total connected capacity of IDAHO POWER COMPANY'S ANNUAL NET METERING STATUS REPORT - 15 the generators, and if the phasing (single- versus three-phase) of the system matches the service infrastructure. Additionally, in 2015, the Company performed its first feeder-level feasibility study for a75 kW system requesting interconnection onto the feeder that contains the greatest amount of connected capacity (24 percent) mentioned above. The result of that study indicated that the system could be incorporated without any modification to the existing distribution feeder. ln fact, the Company has not denied any net metering applications due to system limitations, but continues to carefully monitor requests for connection to ensure ongoing reliable service is available to both existing and new customers. The Company wil! continue to monitor the effects of net metering service on its system including tracking the locations and connected capacities of net metering customers and comparing connected capacities to minimum feeder loads. As net metering system penetration increases, ldaho Power will keep the Commission apprised of experienced or anticipated system reliability impacts and will propose mitigation as needed which may include additional inverter requirements, e.9., smart inverters. V. 2015 Excess Net Enersy Credit Transfers (Manual Meter Aqqreqation) Schedule 84, Customer Energy Production Net Metering Service ("Schedule 84") provides for net metering customers to submit requests to transfer excess net energy credits between January 1 and January 31 of each year. Applications received are reviewed against the following criteria from Schedule 84: o The account subject to offset is held by the customer; and . The meter is located on, or contiguous to, the property on which the Designated Meterl3 is located. For the purposes of Schedule 84, contiguous property includes property that is separated from the premises of the Designated Meter by public or railroad rights of way; and . The meter is served by the same primary feeder as the Designated Meter at the time the customer files the application for the Net Metering System;14 and '3 Schedule 84 states the Designated Meter "is the retail meter physically connected to the Net Metering System." 'o Schedule 84 states the Net Metering System "is a Customer-owned Generation Facility interconnected to the Company's system under the applicable terms of Schedule 72 and Schedule 84." IDAHO POWER COMPANY'S ANNUAL NET METERING STATUS REPORT - 16 The electricity recorded by the meter is for the customer's requirements; and For customers taking service under Schedule 1 or Schedule 7, credits may only be transfened to meters taking service under Schedule 1 or Schedule 7. For customers taking service under Schedule 9, Schedule 19, or Schedule 24, credits may only be transferred to meters taking service under Schedule 9, Schedule 19, or Schedule 24. On December 3, 2015, all of the Company's net metering service customers were sent a letter outlining the meter aggregation process, the requirements, and the deadlines for customers to submit an application for transfer of eligible excess net energy credits. A copy of the transfer request form and a Frequently Asked Questions document were sent with the letter (both of which are available on the Company's website).1s Lastly, the Company posted a message on all net metering service customers' December bills informing them of the upcoming transfer window. Given the costs associated with system customization, the Commission directed ldaho Power in Order No. 32925 to keep it apprised of the number of customers choosing to transfer excess net energy credits under the newly-approved meter aggregation rules. As of the January 31,2016, deadline, the Company received 26 applications for transfer and those applications were reviewed during February against the Schedule 84 criteria. Based on the above criteria, the Company determined that 19 of the requests were eligible for transfer. The total amount transferred was 250,204 kwh generated from net metering systems taking service under Residential (19 percent), Small General (60 percent), and Large General (21 percent) rate schedules. The 250,204 kwh were transferred to customers taking service under Residential (79 percent) and Large General (21 percent) rate schedules. The Company received seven applications that were ultimately found to be ineligible for transfer based on the following: o Six applicants did not have excess net energy credits. o One applicant requested a transfer to a meter on a property that was not contiguous. 15 https://www.idahopower.com/AboutUs/BusinessToBusiness/GenerationlnterconnecVnetMeterinq.cfm IDAHO POWER COMPANY'S ANNUAL NET METERING STATUS REPORT - 17 The Company contacted by phone all of the customers who had requested a transfer but whose applications were ultimately denied to explain the reason the requested transfer could not be completed. Vl. Conclusion ldaho Power continues to believe that in order to facilitate the expansion of distributed generation in a safe, reliable, and fair manner, net metering rate design must be addressed sooner ratherthan later. Between the first quarters ot2O15 and 2016, pending and active net metering systems in ldaho Power's service area have increased 48 percent. This growth brings the potential for significant cost shifting to occur from the Company's net metering customer segment to the standard service customer classes, most prominently within the residentia! and small general service customer classes. As demonstrated by the analysis presented in this report, an average-sized ldaho Power residential customer who installs a six kW system is able to reduce his or her revenue requirement by 26 percent, however, that same customer's bill is reduced by 71 percent. As a result, the potential future cost shift by 2021 could be as high as $1.9 million or as low as $755,000, with a median growth rate yielding potential future cost shifts of $1.3 million by 2021. As the economics of installing a residential PV system improve, the Company expects the installation of these systems will become more attractive and attainable to the Company's average residential customer. At the point the LCOE of rooftop PV is lower than the retail cost of energy supplied by the utility, it becomes more economical for customers to install PV and the groMh in the PV net metering systems may accelerate considerably. The Company also expects that a broader range of customers may consider installing PV once the cost of installing that system becomes cost competitive with the utility rate. The exponential growth in net metering service since 2001 demonstrates how the Company's grid is evolving, and underscores the need to evaluate the associated service provisions and pricing to ensure that ldaho Power can continue to offer safe, reliable, fair-priced electrical service now and in the future. IDAHO POWER COMPANY'S ANNUAL NET METERING STATUS REPORT - 18