20220429Compliance Filing.pdf

3EHH.
An |DTOORP OofiitrrlY
Connie Aschenbrenner
Rate Design Senior Manager
[e-mail]
April29,2022
VIA ELECTRONIC FILING
Jan Noriyuki, Secretary
!daho Public Utilities Commission
PO Box 83720
1 1331 W. Chinden Boulevard
Building 8, Suite 201-A(83714)
Boise, ldaho 83720-0074
Compliance Filing in Case No. IPC-E-12-27
Annual 2022 Distributed Energy Resources Status Report
Dear Ms. Noriyuki:
Pursuant to Order Nos. 32846 and 32925 in the above-mentioned case and Order
No. 34955 in Case No. IPC-E-20-30, attached for electronic filing is ldaho Power
Company's Annual Distributed Energy Resources Status Report for 2022.
!f you have any questions regarding this filing, please contact Regulatory Consultant
Grant Anderson at [phone] or [e-mail].
Very truly yours,
C^"& &l^-^,"^r^r^-
Connie Aschenbrenner
LDN/sg
Enclosures
cc: Terri Carlock, ldaho Public Utilities Commission
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RE
I DISTRIBUTED ENERGY
RESOURCES
ANNUAL
REPORT April 29 2022
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lntroduction & Table of Contents
INTRODUCTION
ldaho Power Company ("ldaho Power" or "Company'') presents its annual Distributed Energy
Resources ("DER") Status Report to the ldaho Public Utilities Commission ("Commission") as
required by Order Nos.32845 and 32925 in Case No. !PC-E-12-27 and Order No.34955 in Case
No. IPC-E-20-30.1The report begins with an update on participation levels and growth rates since
the Company's last DER Status Report filed with the Commission in April 2O2L (April 1, 2O2L -
March 3L,2022l,. The report then discusses system reliability considerations and concludes with
an update on accumulated excess net energy credits and meter aggregation activity.
TABLE OF CONTENTS
lntroduction 1
Table of Contents 1
List of Tables 2
List of Figures
l. Customer Generation in ldaho
......2
......3
Current Participation and Growth Rates (Exporting Systems).... .........3
ll. System Reliability Considerations............ ....................5
lnstallation Concentration versus Capacity.... ................... 6
Smart lnverter lnstallation ............7
lll. 2021 Excess Net Energy Credit Transfers ....................8
Meter Aggregation Eligibility.... .......................8
Credit Transfer Requests for CalendarYear 2021,...........9
Credit Tra nsfer Magnitude ...9
1 On page 19 of Order No. 32846, the Commission directed ldaho Power to "file an annual status report with the
Commission discussing the net metering service. The report shall discuss, without limitation, the net metering
service provisions and pricing and how distributed generation may be impacting system reliability." On page 11
of Order No. 34955, the Commission found "it prudent to require that the Company's annual Net Metering Report
include any known or foreseeable DER related distribution circuit issues or costs and potential smart inverter
functionality updates that could address the issues or lower the costs."
Distributed Energy Resources 2022 Annual Report Page 1
IV
<IIMIOPCT'I'ER.
Accumulated Excess Net Energy Credit Balances
Conclusion.
lntroduction & Table of Contents
t0
L2
3Table 1
Table 2
Figure 1
Figure 2
Figure 3
Figure 4
LIST OF TABLES
tdaho Active and Pending Exporting Systems as of March 3L,2022
ldaho Active and Pending Exporting Systems Nameplate Capacity (MW)as of
March 3t,2022
LIST OF FIGURES
Cumulative Exporting System Counts by Customer Type, 2OL2 - LQ2022..................4
Cumulative Exporting System Capacity by Customer Type, }OLZ - LQ2O22................ 5
Excess Net Energy CreditTransfers by Customer Class, 2OL4-202L........................10
Accumulated Unused Excess Net Energy Credlt Balance, 2OL4-202L LL
4
Distributed Energy Resources 2022 Annual Report Page 2
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Customer Generation in ldaho
I. CUSTOMER GENERATION IN IDAHO
Current Participation and Growth Rates (Exporting Systems)
As of December 3L, 2021, ldaho Power's On-Site Generation and Net Metering Service
("Exporting Systems")2 consisted of 9,580 total active systems with a cumulative nameplate
capacity of gg.Zf megawatts ("MW") in its ldaho service area. During the calen dar year 202L,
actlve Exporting Systems increased by 2,843 (a 42 percent increase) and an incremental
nameplate capacity of 33.01 MW. All new systems interconnected in 2021 were solar
photovoltaic ("PV").
During the first quarter of 2022, the Company added 863 active Exporting Systems with an
aggregate nameplate capacity of 6.95 MW and had 991 pending applications with an additional
8.05 MW of nameplate capacity. At the end of the first quarter of 2022,ldaho Power had 11,406
active and pending Exporting Systems, representing a 40 percent growth rate since the same
time last year.
Table 1 provides the total number of active and pending Exporting Systems in the Company's
ldaho jurisdiction by resource type and customer class.
Table 1 ldaho Active and Pending Exporting Systems as of March 3.L,2O22
Customer Segment Solar PV Wind Hydro/Other Total
Schedule 6
Residential On-Site Generation 10,906 27 7 10,94O
Schedule 8
Small General On-Site Generation 64 4 68
Schedule 84
Commercial & lndustrial
lrrigation
L87
2tr
t87
2tt
Totalldaho 11,368 27 11 tL,406
2 On-Site Generation and Net Metering Service includes all Exporting Systems under the terms of Schedule 5, 8, or
84, designed to provide the transfer of electric energy to the Company.
Distributed Energy Resources 2022 Annual Report Page 3
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Customer Generation in ldaho
Table 2 provides the total nameplate capacity of active and pending Exporting Systems in the
Company's ldaho jurisdiction by resource type and customer class.
Table 2 ldaho Active and Pending Exporting Systems Nameplate Capacity (MWl as of March 31,
2022
customer segment Solar PV Wind Hydro/Other Total
Schedule 5
Residentia I On-Site Generation 8L.79 0.11 o.o7 81.98
Schedule 8
Small General On-Site Generation 0.45 0.09 0.s3
Schedule 84
Commercial & lndustrial
lrrigation
6.18
t9.82
6.18
19.82
Totalldaho 108.25 0.11 0.16 108.52
Note: Totols moy not sum due to rounding.
Figure 1 and 2 detail the cumulative Exporting System counts and nameplate capacity,
respectively, by customer class in the Company's ldaho jurisdiction from 2012 through the first
q uarter ol 2022 (including pending a pplications).
Figure 1 Cumulative Exporting System Counts by Customer Type, 2Ot2- LQ2O22
12,000
10,000
8,000
6,000
4,000
2,000
Pc
oU
EoP
ttt
-
r I
2012 2013 2014
I Residential
201s 20t6 20t7 2018 2019 2020 202L 1Q2022
I Commercial & lndustrial I lrrigation
Distributed Energy Resources 2022 Annual Report Page 4
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Figure 2 Cumulative Exporting System Capacity by Customer Type, 2OL2- 1q2022
L20
100
Customer Generation in ldaho
2015 20L6 20L7 20L8 2019 2020 202L LQ2022I Commercial & lndustrial r lrrigation
t803b60.U
oCL840
20
20L2 2013 2014I Residential
Distributed Energy Resources 2022 Annual Report Page 5
-tmloP0,I,ER.System Relia bility Considerations
II. SYSTEM RELIAB!TITYCONSIDERATIONS
There are 589 electrical distribution circuits in the Company's service area. Considering all
customer-owned on-site generation installations across alljurisdictions, all rate classes, and all
resources, as of March 3L,2022, there were LO,524 active, customer-owned on-site generation
systems. These systems total approximately 104.72 MW on 467 distribution circuits - compared
to 7,460 active operational systems totaling approximately 58 MW across 467 distribution
circuits on March 3L,2O2L.
lnstallation Concentration versus Capacity
The circuits containing the greatest number of customer-owned on-site generation systems
continue to be in Ada County, with the densest concentrations in southeast and south Boise.
There are also several circuits in Elmore County with increased concentrations of customer-
owned on-site generation systems due to interconnections that occurred in 2O2L.
The largest customer-owned on-site generation connected capacity is on distribution circuits
with agricultural and rural customers. The largest number of customer-owned on-site generation
systems connected on a single distribution circuit is 154, with a total rated capacity of 980.2
kilowatts ("kW").
The distribution circuit in ldaho with the greatest customer-owned on-site generation
capacity has 28 solar PV systems with a total rated capacity of 2,623 kW (average system size
over 90 kW). This circuit primarily serves agriculture and rural customers in the Magic Valley with
a summer peak load of approximately 5,980 kW. The distribution circuit in ldaho with the second-
highest customer-owned on-site generation capacity has one solar PV Non-Exporting System
with a tota! rated capacity of L,7L6 kW. This circuit serves a single industrial customer.
There are currently nine circuits with a total customer-owned on-site generation capacity of
more than 1,000 kW. Other than the one circuit which serves a single industrial customer, all
others are circuits serving irrigation and rural customer loads in the Magic Valley. As a
comparison, ldaho Power had one distribution circuit with more than 1,000 kW of generation
capacity on a single distribution feeder in 2O2O. This is primarily driven by the recent
concentration of large Exporting Systems (i.e., 90-100 kW) interconnected in 2O2L.
The customer-owned on-site generation connected capacity on the Company's distribution
system continues to grow and has increased year-over-year from 2.0 to 2.7 percent of the total
system peak load. The Company has managed the impacts on these circuits, when necessary, by
requiring customer-funded distribution upgrades pursuant to Rule H and, in more rare instances,
requiring customer-funded substation upgrades.
Distributed Energy Resources 2022 Annual Report Page 6
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System Relia bility Considerations
Smart lnverter lnstallation
All new systems applying to interconnect are required to install smart inverters3 to support
the distribution system's ongoing stability and reliability. ldaho Power will continue monitoring
and updating the Commission on any known or foreseeable DER-related distribution circuit issues
or costs and potential smart inverter functionality updates that could address these issues or
lower the costs.
3 Order No. 34955 issued in Case No. IPC-E-20-30 approved Schedule 68, effective March 23, 2021. Schedule 68
requires smart inverter functionality to be enabled for all new applications for customer generation.
Distributed Energy Resources 2022 Annual Report PageT
SIIMH'PO'I'ER,
2021 Excess Net Energy Credit Transfers
III. 2O2I EXCESS NET ENERGY CREDIT TRANSFERS
Meter Aggregation Eligibil ity
Schedule 5, ResidentialService On-Site Generation ("Schedule 5"), Schedule 8, SmallGeneral
On-Site Generation ("Schedule 8"), and Schedule 84 Customer Energy Production Net Metering
Service ("Schedule 84,') provide for customers with Exporting Systems to submit requests to
transfer excess net energy credits between January 1 and January 31 of each year. The Company
applies the following criteriaa from Schedules 6, 8, and 84 (collectively referred to as "aggregation
criteria") to all requests received:
i. The account subject to offset is held by the customer; and
ii. The meter is located on, or contiguous to, the property on which the Designated Meters
is located. For the purposes of the tariff, contiguous property includes property that is
separated from the premises of the Designated Meter by public or railroad rights of way;
and
iii. The meter is served by the same primary feeder as the Designated Meter at the time the
customer files the application for the Exporting System;6 and
iv. The electricity recorded by the meter is for the customer's requirements; and
v. For customers taking service under Schedule 1 or Schedule 7, credits may only be
transferred to meters taking service underSchedule 1or 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 3,202L, Schedule 6, Schedule 8, and Schedule 84 customers with an excess net
energy balance were sent a postcard reminding them of the meter aggregation process and
directing them to a website with the requirements, an online form, and the deadlines for
customers to apply for the transfer of eligible excess net energy credits. The Company also posted
a The aggregation criteria were established by Order No. 32925 in Case No. IPC-E-L2-27.
s Schedules 6, 8, and 84 define the Designated Meter as the retail meter physically connected to the Exporting
System.
6 Schedule 5, 8, and 84 define an Exporting System as "a Customer-owned DER under the terms of Schedule 5, 8, or
84, which is designed to provide for the transfer of electric energy to the Company."
Distributed Energy Resources 2022 Annual Report Page 8
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2021 Excess Net Energy Credit Transfers
a message on all Schedule 6, Schedule 8, and Schedule 84 customers' December bills informing
them of the upcoming transfer window.
Credit Transfer Requests for Calendar Year 2O2l
In Order No. 32925, the Commission directed ldaho Power to keep it apprised of the number
of customers choosing to transfer excess net energy credits under the meter aggregation rules.
As of the application deadline, January 3L, 2022, the Company received 158 applications for
transfer, and those applications were reviewed during February against the aggregation criteria.
The company determined that 153 of the requests were eligible for transfer based on the
aggregation criteria. The total amount transferred was 4,627,989 kilowatt-hours ("kwh")
generated from Exporting Systems taking service under lrrigation (72 percent), Residential (18
percent), Large General (8 percent), and Small General (2 percent) rate schedules. The 4,627,989
kWh were transferred to customers taking service under lrrigation (72 percent), Residential (20
percent), Large General (7 percent), and Small General (less than 1 percent) rate schedules.T
The Company received 15 applications that were ineligible for transfer based on the
following:
o Six applicants did not have a meter to transfer excess net energy credits
o Five applicants requested a transfer to a meter that was not on contiguous property
o Three did not have credits available to transfer
o One applicant requested a transfer to a meter that was not on a compatible rate schedule
The Company contacted all customers who had requested a transfer but whose applications
were denied by phone and/or mail to explain why the requested transfer was ineligible.
Credit Transfer Magnitude
Following the implementation of the excess net energy credit transfers authorized by the
Commission in Order No. 32925, the Company has witnessed growth in the magnitude of excess
net energy transfers, specifically within the irrigation class. The Company transferred
approximately 200,000 excess net energy credits in 2OL4, increasing to over 4.5 million in 202L.
7 Totals may not sum due to rounding.
Distributed Energy Resources 2022 Annual Report Page 9
EIMIOPO'I'ER,
2021 Excess Net Energy Credit Transfers
The compound annual growth rate for excess net energy credit transfers between 2Ot4andlO?L
was 55 percent. Figure 3 shows the total kWh transfer for 2OL4 through 2O2Lby customer class.
Figure 3 Excess Net Energy Credit Transfers by Customer Class, 2014 - 2021
5,000,000
4,500,000
4,000,000
3,500,000
3,000,000
!
= 2,500,000
2,000,000
L,5oo,oo0
1,000,000
500,000
513,065478,99O
2,ll.g,7ag
874,493
2018 2019
r lrrigation
4,627,989
7,241,836
2020 2027
206,629I
20!4
25O,2U
I
2015
I
2016 2017I Residential I Commercial
Accumulated Excess Net Energy Credit Balances
After the implementation of the kwh crediting for excess net energy authorized by the
Commission in Order Nos. 32845 and 32872 in January 2014, the Company has accumulated
significant unused kWh credit balances.8 The excess net energy credit balance in 2014 was
approximately 0.5 million, increasing to over 17.1 million kWh credits in 2021. The compound
annual growth rate for the accumulated unused excess net energy credits from 2014 to 2021was
66 percent. Figure 4 shows the accumulated excess net energy credit balance for 2OL4 through
202L.
I ln Order No. 32846, the Commission stated, "we find it fair, just, and reasonable for the kWh credit to indefinitely
carry fonuard to offset future bills as long as the customer remains on the net metering service at the same
generation site. Allowing the credits to carry fonnard indefinitely ensures that customers will be able to use their
credits when they need them and thus receive the benefits of their systems."
Distributed Energy Resources 2022 Annual Report Page 10
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2021 Excess Net Energy Credit Transfers
Figure 4 Accumulated Unused Excess Net Energy Credit Balance, 2OL4-2O2le
18.0 mm 17.1mm
11.3 mm
7.5 mm
4.3 mm
2.3 mm 2.6 mm
1.3 mm
2015 2016 20L7 2018 20L9 2020 202L
At the current growth rate for these unused excess net energy credits, ldaho Power
recognizes there will likely be a need for some future regulatory action to resolve this increasing
liability that wil! not otherwise naturally be resolved under the current regulatory treatment at
the current growth rate for these unused excess net energy credits. ln Order No. 35284, the
Commission found it reasonable for an evaluation of expiring credits in the Company's
comprehensive study of costs and benefits of on-site generation that ldaho Power will file later
in 2022. The Commission recognized that the study of these issues would help address the value
and expiration of credits at the time of implementation and expects the Company to propose
how a transition to a new program can most effectively and efficiently occur.
9 The accumulated excess net energy credit balance represents all unused credits as of December 31. lt does not
reflect the potential reduction due to future offset at the premise generated or transferred to another meter for
offset.
C
E
E
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=.)z
15.0 mm
14.0 mm
12.0 mm
10.0 mm
8.0 mm
6.0 mm
4.0 mm
2.0 mm
0.0 mm
0.5 mm
-20L4
Distributed Energy Resources 2022 Annual Report Page 11
crmtoPcm,ER"
Conclusion
!V. CONCLUSION
ldaho Power continues to experience rapid growth in customer generation. The continued
expansion demonstrates how the Company's grid continues to evolve 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. The Company will
continue to monitor participation and growth in customer generation and keep the Commission
apprised of customer generation service provisions and impacts on system reliability.
Distributed Energy Resources 2022 Annual Report Page L2