20210428Compliance Filing.pdf

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An IDACORP Companv
LISA D. NORDSTROM
Lead Counsel
[e-mail]
April28, 2021
VIA ELECTRONIC FILING
Jan Noriyuki, Secretary
ldaho Public Utilities Commission
11331 W. Chinden Blvd., BIdg 8,
Suite 201-A(83714)
PO Box 83720
Boise, ldaho 83720-0074
Case No. IPC-E-12-27 - Annual 2021 Distributed Energy Resources
Status Report - Compliance Filing
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 Annua! Distributed Energy Resources Status Report for 2021. This report
renames the Net Metering Status Report to broaden the scope to include impacts from all
distributed energy resources in accordance with Order No. 34955.
lf you have any questions regarding this filing, please contact Senior Regulatory
Analyst Grant Anderson at [phone] or oanderson@ idahopower. com
Very truly yours,
RE
X*!.(,,*t,-^,
Lisa D. Nordstrom
LDN:slb
Enclosure
cc: Karl Klein, ldaho Public Utilities Commission
ldaho Power Company
Annual Distributed Energy Resources Status Report
Apri! 28,2021
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. 32846 and 32925 in Case No.
IPC-E-12-27 and Order No. 34955 in Case No. IPC-E-20-30.1 The report begins with an
update on participation levels and growth rates since the Company's last Net Metering
Status Report2 filed with the Commission in April 2020. The report then discusses system
reliability considerations and concludes with an update on accumulated excess net
energy credits and meter aggregation activity in 2020.
I. CUSTOMER GENERATION IN IDAHO
Current Participation and Growth Rates (Exporting Systems)
As of December 31, 2020, ldaho Power's On-Site Generation and Net Metering
Service ("Exporting Systems")s consisted of 6,898 total active systems with a cumulative
nameplate capacity of 60.66 megawatts ("MW') in its ldaho service area. During the
calendar year 2020, active Exporting Systems increased by 1,707 (a 33 percent increase)
and an incremental nameplate capacity of 17.41 MW. One new system interconnected
in2020 was hydropower, and al! others were solar photovoltaic ("PV').
During the first quarter of 2021, the Company added 466 new active Exporting
Systems with an aggregate nameplate capacity of 3.36 MW and had 785 pending
I 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."
2 This report renames the Net Metering Status Report to broaden the scope to include impacts from all
distributed energy resources in accordance with Order No. 34955.
3 On-Site Generation and Net Metering Service includes all Exporting Systems under the terms of Schedule
6, 8, or 84, designed to provide the transfer of electric energy to the Company.
IDAHO POWER COMPANY'S ANNUAL 2021 DER STATUS REPORT - 1
applications with an additional26.20 MW of nameplate capacity. At the end of the first
quarter ol 2021, ldaho Power had 8,145 active and pending Exporting Systems,
representing a 34 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 31,20214
Customer Segment Solar PV Wind Hydro/Other Total
Schedule 6
Residential On-Site Generation
Schedule 8
Smal! General OrrSite Generation
Schedule 84
Commercial & !ndustrial
lrrigation
Totalldaho
Schedule 6
Residentia! On-Site Generation
Schedule 8
Small General OnSite Generation
Schedule 84
Commercia! & !ndustria!
lrrigation
Total ldaho
7,582
182
281
8,101
55.96
0.42
6.90
26.58
89.85
0.13
0.02
0.04
0.19 0.16
6.90
26.62
90.20
4
31
156
7 7,620
61
11
182
282
8,145
0.07 56.16
0.09 o.52
;
33
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 Gapacity (ttllw) as
of March 31,2021
a The Company's customer generation database 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; an expansion or additional system would be counted in Tables 1 and2 as a separate system. This
allows the Company to report capacity in the year in which it came online. Because an expansion of an
existing system requires the filing of a new application, it is treated separately for reporting purposes.
Customer Segment Solar PV Wind Hydro/Other Total
IDAHO POWER COMPANY'S ANNUAL 2021 DER STATUS REPORT - 2
Chart 1 and 2 below detailthe cumulative Exporting System counts and nameplate
capacity, respectively, by customer class in the Company's ldaho jurisdiction from 2011
through the first quarter of 2021 (including pending applications).
Chart 1: Gumulative Exporting System Counts by Customer Type, 2011 - 1Q2021
9,000
8,000
7,000
2,000
1,000 IIII
2011 2012 2013
I Residential
000
000
000
000
E6,
ooc,
F94,oBg,
20'14 2015 2016 2017
r Commercial & !ndustrial
2018 2019
r lrrigation
2020 1Q2021
Chart 2: Cumulative Exporting System Capacity by Customer Type, 2011 - 1Q2021
==
'6
(E
CL(!o
100
90
80
70
60
50
40
30
20
10
- - -2011 2012 2013
I Residential
-I2014 2015 2016 2017
I Commercial & lndustrial
2018 2019 2020 1Q2021
r lrrigation
IDAHO POWER COMPANY'S ANNUAL 2021 DER STATUS REPORT - 3
lncreased Gapacity of Exporting Systems
ln December 2020 alone, the Company received applications for Exporting
Systems totaling over 18 MW. ln comparison, new Exporting Systems that
interconnected over the entire year in 2020 accounted for approximately 17.6 MW. The
recent growth in the Exporting System capacity is primarily attributable to Schedule 84,
Customer Energy Production Net Metering Service ("Schedule 84"). Charts 1 and 2
generally illustrate that while Schedule 84 Exporting Systems only account for over 5
percent of the system count, they make up approximately 37 percent of the total Exporting
System capacity. The Company will continue to monitor any impacts from the growth and
concentration of larger Exporting Systems.
II. SYSTEM RELIABILITY CONSIDERATIONS
There are 678 electrical distribution circuits in the Company's service area.
Considering all customer-owned on-site generation installations across all jurisdictions,
all rate classes, and all resources, as of March 31, 2021, there were 7,460 active,
customer-owned on-site generation systems. These systems total approximately 67.80
MW on 467 distribution circuits - compared to 5,596 active operational systems totaling
approximately 47 MW across 449 distribution circuits on March 31,2020.
lnstallation Concentration vensus Capacity
The circuits that contain the greatest number of customer-owned on-site
generation systems continue to be in Ada County, with the densest concentrations
primarily in east, southeast, and south Boise. However, in general, the greatest
customer-owned on-site generation connected capacity is on circuits with both
agricultural and rural customers. The largest number of customer-owned on-site
generation systems connected on a single distribution circuit is 115, with a total rated
capacity of 736.7 kilowatts ('k\A/'). The distribution circuit in ldaho with the second
IDAHO POWER COMPANY'S ANNUAL 2021 DER STATUS REPORT - 4
greatest customer-owned on-site generation capacity has only nine solar PV systems
with a total rated capacity of 849.7 kW. This circuit serves both agriculture and rural
customers with a summer peak load of approximately 10,300 kW. The distribution circuit
in ldaho with the greatest customer-owned on-site generation capacity has one solar PV
Non-Exporting System with a total rated capacity o11,716 kW. This circuit serves a single
industrial customer.
Applications from irrigation customers in December 2020 accounted for about 15
MW of capacity, primarily located on ten Magic Valley distribution circuits. The
concentration of these large Exporting Systems, averaging 98 kW per system, required
more rigorous interconnection analysis. For six distribution substations, the Feasibility
Reviews determined that there would be reverse flow through the substations onto the
transmission system for a significant period of the year when there is minimal irrigation
load. For three circuits, the reverse flow requires upgrades to the substation transformer
load tap changer controls. ln some cases, the circuit voltage regulator controls also
require upgrades to mitigate high voltage issues. The use of smart inverters would not
mitigate the need for the upgrades for these three circuits.
Although growing quickly, the customer-owned on-site generation connected
capacity on the Company's distribution system at the time of this report continues to
remain relatively small at 2.0 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 one instance where two irrigation customers
were required to fund substation upgrades.
IDAHO POWER COMPANY'S ANNUAL 2021 DER STATUS REPORT - 5
Smart lnverter lnstallation
The Company anticipates the installation of smart inverters on all new systems
applying to interconnect on or after March 23,2021s will 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 the issues or lower
the costs.
III. 2O2O EXCESS NET ENERGY CREDIT TRANSFERS
Meter Aggregation Eligibility
Schedule 6, Residential Service On-Site Generation ("Schedule 6"), Schedule 8,
Small General On-Site Generation ("Schedule 8") and 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 criteria from
Schedules 6, 8, and 84 (collectively referred to as "aggregation criteria") to al! 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
Metef is located. For the purposes of the tariff, contiguous propefi 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;7 and
iv. The electricity recorded by the meter is for the customer's requirements; and
5 Order No. 34955 issued in Case No. IPC-E-20-30 approved Schedule 68, effective March 23,2021.
Schedule 68 requires smart inverter functionality be enabled for all new applications for customer
generation.
6 Schedules 6, 8, and 84 define the Designated Meter as the retail meter physically connected to the
Exporting System.
7 Schedule 6, 8, and 84 define an Exporting System as "a Customer-owned DER under the terms of
Schedule 6, 8, or 84, which is designed to provide for the transfer of electric energy to the Company."
IDAHO PO\A/ER COMPANY'S ANNUAL 2021 DER STATUS REPORT - 6
v. For customers taking service under Schedule 1 or Schedule 7, credits may only
be transferred 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 November 23, 2020, 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 message on all Schedule 6, Schedule 8,
and Schedule 84 customers' December bills informing them of the upcoming transfer
window.
Credit Transfer Requests for CY 2020
ln 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 31,2021, the Company
received 149 applications for transfer, and those applications were reviewed during
February against the aggregation criteria.
Based on the aggregation criteria, the Company determined that 137 of the
requests were eligible for transfer. The total amount transferred was 3,241,836 kilowatt-
hours ('kwh") generated from Exporting Systems taking service under lrrigation (71
percent), Residential (17 percent), Large General (8 percent), and Small General (4
percent) rate schedules. The 3,241,836 kwh were transferred to customers taking
service under lrrigation (70 percent), Residential (21 percent), Large General (9 percent),
and Small General (less than 1 percent) rate schedules.
The Company received 13 applications that were ineligible for transfer based on
the following:
IDAHO POWER COMPANY'S ANNUAL 2021 DER STATUS REPORT - 7
. Five applicants did not have excess net energy credits
o Three applicants requested a transfer to a meter that was not on a compatible
rate schedule
o Three applicants did not have a meter to transfer excess net energy credits
. One applicant requested a transfer to a meter that was not on contiguous
property
o One applicant applied after the January 31 deadline
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 groMh in the
magnitude of excess net energy transfers, specifically within the irrigation class. ln total,
the compound annual growth rate for excess net energy credit transfers between 2014
and 2020 was 58 percent. The Company transferred approximately 200,000 excess net
energy credits in2014, increasing to over 3.2 million in2020. The following chart shows
the total kWh transfer for the years 2014 through 2020 by customer class.
IDAHO POWER COMPANY'S ANNUAL 2021 DER STATUS REPORT. 8
Chart 3: Excess Net Energy Credit Transferc by Customer Glass, 2014-2020
t
=v
3,500,000
3,000,000
2,500,000
2,000,000
1,500,000
1,000,000
500,000
874,493
2,119,709
2019
3,24{,935
2020
478,990 613,065
206,629I
2014
250,2O4I
20'ts
r Residential
I
2016 2017 2018
r Commercial I lrrigation
Accumulated Excess Net Energy Credit Balances
After the implementation of the k\Ml crediting for excess net energy authorized by
the Commission in Order Nos. 32&46 and 32872 in January 2014, the Company has
accumulated significant unused k\Mt credit balances.s ln total, the compound annual
growth rate forthe accumulated unused excess net energy credits trom2014 to 2020 was
68 percent. The excess net energy credit balance in2014 was approximately 0.5 million
k!\,h, increasing to over 11.3 million k\Mt in 2020. The following chart shows the
accumulated excess net energy credit balance for the years 2014 through 2020.
8 ln Order No. 32846, the Commission stated, 'we find it fair, just, and reasonable br the kWh credit to
indefinitely carry fonuard to ofbet future bi!!s for so long as the customer remains on the net metering
service at the same generation site. Allowing the credits to carry fonrard indefinitely ensures that customers
will be able to use their credits when they need them and thus receive the benefits of their systems.'
IDAHO POWER COMPANY'S ANNUAL 2021 DER STATUS REPORT - 9
Chart 4: Accumulated Unused Excess Net Energy Credit Balance, 2014 - 2020s
12.0 mm 11.3 mm
10.0 mm
7.6 mm
4.3 mm
otr
.9
=tr
=.Y
8.0
6.0
mm
mm
4.0 mm
2,0 mm
0.0 mm
0.5 mmI
2014
1.3 mm
2015 2016 2017 2018
r Excess Energy Credit Balance
TT
2019 2020
At the current grov'rth 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 thatwill not otherwise naturally be resolved underthe current regulatory
treatment at the current growth rate for these unused excess net energy credits.
!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 net metering service provisions and
impacts on system reliability.
e The accumulated unused excess net energy credit balance represents all unused credits as of December
31 and does not reflect the potential reduction due to future offset at the premise generated or transferred
to another meter for ofbet.
IDAHO POWER COMPANY'S ANNUAL 2021 DER STATUS REPORT - 1O