20160623Application.pdf

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An IDACORP Company
LISA D. NORDSTROM
Lead Counsel
[e-mail]
June 22,2016
VIA HAND DELIVERY
Jean D. Jewell, Secretary
ldaho Public Utilities Commission
472 West Washington Street
Boise, ldaho 83702
LDN:csb
Enclosures
Dear Ms. Jewell:
Enclosed for filing in the above matter please find an origina! and
copies of ldaho Power Company's Application.
Also enclosed for filing are an original and eight (8) copies of
Testimony of Peter Pengilly. One copy of the aforementioned testimony
designated as the "Reporter's Copy." ln addition, a disk containing a Word
Mr. Pengilly's testimony is enclosed for the Reporter.
Case No. IPC-E-16-13
Schedule 62, Green Energy Purchase Program Rider, Modifications - ldaho
Power Company's Application and Testimony
seven (7)
the Direct
has been
version of
lf you have any questions about the enclosed documents, please do not hesitate
to contact me.
*(yreh
1221 W. ldaho St. (83702)
PO. Box 70
Boise. lD 83707
Lisa D.
LISA D. NORDSTROM (lSB No. 5733)
Idaho Power Company
1221 West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
lnordstrom@ ida hopower. com
Attorney for ldaho Power Company
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION TO MODIFY
OPTIONAL SCHEDULE 62, GREEN
ENERGY PURCHASE PROGRAM RIDER.
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BEFORE THE IDAHO PUBLIC UT!LITIES COMMISSION
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CASE NO. |PC-E-16-13
APPLICATION
Idaho Power Company ("ldaho Power" or "Company"), in accordance with ldaho
Code S 61-503 and RP 052, hereby respectfully makes application to the ldaho Public
Utilities Commission ("Commission") for an order approving the modification of
Schedule 62, the Green Energy Purchase Program Rider's ("Green Power Program" or
"Program") pricing structure, Renewable Energy Certificates ("REC") sourcing and
certification, and the treatment of certain program expenses. The Company does not
propose a change to customer rates associated with the ongoing funding of the
Program. ldaho Power requests that the program modifications become effective 60
days after Commission approval to allow adequate time to reprogram and test its billing
system in accordance with the Commission's order.
APPLICATION - 1
ln support of this Application, ldaho Power represents as follows:
I. BACKGROUND
1. Approved in Commission Order No. 28655, issued February 23, 2001,
Schedule 62's Green Power Program is an optional program designed to provide
customers and non-customerl participants an opportunity to participate in the purchase
of neral environmentally friendly green energy. "Green" energy, certified as such by
various organizations throughout the country, is primarily considered to be generated
from wind, solar, geothermal, and other renewable resource facilities.
2. Participant contributions to the Green Power Program go towards the
purchase of Green-e certified RECs. A REC is created when a megawatt-hour ('MWh')
of renewable energy is produced and delivered to the grid. A REC is a tradable, non-
tangible commodity that represents the environmental attributes associated with one
MWh of electricity generated from a renewable energy resource and can be sold
separately from the electricity commodity. The owner of the REC can legally claim to
have purchased renewable energy. Green-e Energy is the nation's leading independent
certification and verification program for renewable energy.
3. Currently, at the time of enrollment, participants may select a fixed
monthly payment amount (any dollar amount) based on their desired level of
participation ("Dollar Contribution Method"). The designated amount is in addition to all
other charges included in the service schedule under which the customer receives
electrical service and is added to the customer's monthly electric bill. The Company
has used the Bonneville Environmental Foundation ("BEF") to facilitate the purchase of
1 Non-customer participants may sign up to participate in the Green Power Program. When they
sign up, they receive an account number (not tied to any rate class) and are billed only for their
participation in the Program.
'The term "new" is defined, by Green-e Energy, to include any eligible renewable facility that
began operation or was repowered in the 15 years immediately preceding the sale of its generation.
APPLICATION .2
green energy for the Program. ldaho Power, BEF, and the Green Power Program
participants have also collaborated since 2003 to bring the renewable energy
educational program, "Solar 4R Schools," to k-12 schools located in ldaho Power's
service area. ldaho Power Customer Research and Analysis Leader Peter Pengilly
describes the evolution of the Green Power Program in greater detai! in his prefiled
direct testimony that accompanies this Application.
4. ln an effort to respond to what ldaho Power believes are some customers'
preferences, the Company is currently working towards offering a variety of green
power options. The Program modifications discussed below are the result of Company
and customer collaboration to modify the Program to make it a more attractive
renewable energy option for customers taking service under any rate schedule.
II. PROPOSED PROGRAM MODIFICATIONS
5. The Company met with a group of customers from the Wood River Valley,
from February 2014 into early 2016, who offered insight and opinion on a variety of
Program modifications. Based on all the information gathered, the Company ultimately
decided on modifications that, if approved, would not only satisfy changes in customer
preference but would also align the Green Power Program with the best practices of
other green programs in the industry. These proposed modifications are set forth in
both clean and legislative formats in the Schedule 62 tariff, Green Power Purchase
Program Rider, included as Attachment 1 to this Application.
A. Prooram Participation Options.
6. The Company is proposing to replace the existing Dollar Contribution
Method with both a block option and a 100 percent of usage option for customers who
wish to participate in the Program. Under the block option, a customer will pay a
premium of $1.00 per 100 kilowatt-hour ("kwh") block of renewable energy. The 100
APPLICATION .3
percent of usage option will allow customers to purchase renewable energy equal to
their total monthly kWh usage.
7. The Company believes this change to the participation options will benefit
participants by allowing the RECs purchased and retired for customers through the
Program to be Green-e Energy certified.3 It will also create a more transparent program
for current and prospective participants to help them evaluate which of the Company's
green energy programs best fits their needs. ln addition, the proposed block option
aligns the Green Power Program with similar programs offered by utility peers in the
Northwest.
8. lf its Application is approved, the Company plans to send each participant
a letter detailing the changes to the Program. The majority of the approximately 1,700
Program participants contribute a whole dollar amount each month. Those participants
will be transferred over to the block option. Those that do not contribute a whole dollar
amount will be transferred over to the block option rounded down to the nearest dollar.
B. REG Sourcinq and Certification.
9. Currently, BEF sources RECs used in the Green Power Program primarily
from large-scale wind projects located in the Northwest with a small portion sourced
from small solar projects. Going forward, RECs will still be sourced from the Northwest,
but in response to customer preferences, ldaho Power will direct BEF to give preference
to RECs from sources located closest to or within ldaho Power's service territory, when
possible.
3 The Green-e Energy standard requires that Green-e Energy certified products sold to customers
must be a "percentage-of-use" or "block" product. The Company does not believe that the Dollar
Contribution Method complies with the standard necessary to be Green-e certified. (Green-e Energy
National Standard Version 2.8 Section lll, Part A, page 10, http://www.qreen-e.org/docs/energv/Green-
eEnerqyNationalStandard. pdf. )
APPLICATION - 4
10. ln keeping with industry best practices, ldaho Power will seek Green-e
certification of the RECs purchased through BEF to ensure that the marketing and
claims about renewable energy comply with the Federal Trade Commission's truth in
advertising rules. Currently, ldaho Power purchases Green-e certified RECs through
BEF; however, they are not re-certified before being retired by ldaho Power for the
Program. While Idaho Power certification would add to the cost of the Program, it
provides an extra layer of assurance to participants that the RECs were not used for
multiple purposes and that the certification complies with the national standards detailed
above.
C. Proqram Expenses.
11. Under the design of the current Program, the funds received are only used
to purchase green energy and support Solar 4R Schools. No customer amounts are
currently used to cover program overheads or marketing expenses. All marketing and
overhead expenses of the Program are currently funded through the Company's
operations and maintenance expenses. Thus, the Program has operated to date with a
minimal marketing budget from which to grow the Program.
12. ln this Application, the Company proposes that up to 15 percent of the
total Program funds be used for Program marketing expenses. This change allows
additional funds to be spent specifically on marketing for the Program and be borne by
the Program participants. The additional marketing dollars will allow the Company to
reach more customers and purchase more renewable energy and align the Program
with industry best practices. However, if REC prices change significantly, the Company
may choose to use these funds to cover the increase in REC prices rather than change
the tariff price to participants. ln no case would these funds be used for purposes other
than the Green Power Program.
APPLICATION - 5
13. ldaho Power does not propose a change to customer rates associated
with the ongoing funding of the Program. The Company believes that the current leve!
and method of recovery will adequately fund the ongoing operation of the Program for
the foreseeable future. A comparison of the existing Green Power Program to the
proposed Green Power Program with modifications can be found as Exhibit No. 1 to Mr.
Pengilly's direct testimony.
III. MODIFIED PROCEDURE
14. ldaho Power believes that a hearing is not necessary to consider the
issues presented herein and respectfully requests that this Application be processed
under Modified Procedure; i.e., by written submissions rather than by hearing. RP 201
ef seg. lf, however, the Commission determines that a technical hearing is required, the
Company stands ready to present the direct testimony of Peter Pengilly, Customer
Research and Analysis Leader, that accompanies this Application and support the
Application in such hearing.
IV. COMMUNICATIONS AND SERVICE OF PLEADINGS
15. Communications and service of pleadings with reference to this
Application should be sent to the following:
Lisa D. Nordstrom
ldaho Power Company
1221West ldaho Street (82702)
P.O. Box 70
Boise, ldaho 83707
I no rd strom @ ida h opower. com
dockets@ idahopower. com
Matt Larkin
Peter Pengilly
ldaho Power Company
1221West ldaho Street (82702\
P.O. Box 70
Boise, ldaho 83707
m larki n@ idahopower. com
ppenq illv@ ida hopower. com
V. REQUEST FOR RELIEF
16. ldaho Power respectfully requests that the Commission issue an order
authorizing: (1) this matter to be processed by Modified Procedure; (2) ldaho Power to
APPLICATION - 6
implement the proposed modifications to optional Schedule 62, Green Power Purchase
Program Rider; and (3) the program modifications become effective 60 days after the
Commission's approva!.
DATED at Boise, ldaho, this 22nd day of June 2016.
Attorney for ldaho Power Compiny
APPLICATION - 7
BEFORE TNE
IDAHO PUBLIC UTILITIES COMMISSION
GASE NO. IPC-E-16-13
IDAHO POWER COMPANY
ATTACHMENT 1
CLEAN FORMAT
ldaho Power Company First Revised Sheet No. 62-1
Cancels
|.P.U.C. No. 29. Tariff No. 101 OrioinalSheet No. 62-1
SCHEDULE 62
GREEN ENERGY PURCHASE
PROGRAM RIDER
(oPTroNAL)
PURPOSE
The Green Energy Purchase Program (the Program) is an optional, voluntary program designed
to provide Customers and non-customer participants an opportunity to participate in the purchase of
new environmentally friendly "green" energy.
APPLICABILITY
Service under this schedule is applicable to all Customers and non-customer participants who
choose to participate in the Program.
RENEWABLE ENERGY
For the purpose of this schedule, renewable energy will be in the form of Renewable Energy
Certificates (REC) from new renewable projects as defined by the Center for Resource Solutions
Green-e Energy standard. Renewable energy will be sourced from projects located in the Western
Electricity Coordinating Council's geographic area of authority with preference given to projects located
in ldaho Powe/s service area and the northwest. Renewable energy types will be primarily wind but
may include other certified types such as solar, geothermal, low-impact hydroelectric, landfill gas, and
biomass.
PURCHASE
Customer participants will designate one of two billing options upon enrollment. Non-customer
participants may participate under Option 1.
Option 1: Block
Block Size: One Block equals 100 kWh of renewable energy
Charge Per Block: $1.00 per month
Option 2: Total Usaqe
Customers may purchase renewable energy equalto their monthly usage each month at
a price premium of 1.0 cent per billed kWh.
MONTHLY BILL
For a Customer who chooses Option 1, the monthly bill shall be the number of blocks the
Customer has agreed to purchase multiplied by the Charge Per Block. For a Customer who chooses
Option 2, the monthly bill shall be the Customer's usage, times the price premium per kWh. The
monthly bill is in addition to all other charges contained in the Customer's applicable tariff schedule. A
non-customer participant who chooses Option 1, will be issued a monthly invoice that reflects their
designated fixed dollar per month amount.
IDAHO
lssued per Order No
Effective -
-,20'16
lssued by IDAHO POWER COMPANY
Timothy E. Tatum, Vice President, Regulatory Affairs
1221 West ldaho Street, Boise, ldaho
ldaho Power Company
I.P.U.C. No. 29, Tariff No. 101 Oriqinal Sheet No. 62-2
SCHEDULE 62
GREEN ENERGY PURCHASE
PROGRAM RIDER
(oPTroNAL)
(Continued)
PROGRAM ADMINISTMTION
No funds collected from the Program Rider may be used for program administration (program
management). A portion of the funds may be used to support program communications, participant
outreach, and marketing.
QUALIFYING IN]TIATIVES
ln an effort to promote local project development and build awareness of renewable energy, if
available, funds collected from the Program Rider but not otherwise required to meet program
obligations may be distributed to support renewable demonstration projects at schools located in ldaho
Powe/s service area. Demonstration projects may include renewable generation systems, data
monitoring, renewable energy curriculum, and teacher training.
SPECIAL TERMS AND CONDIT]ONS
Program participants may apply for, or terminate participation from, the Program anytime during
the year. The Company may limit availability of the Program subject to available renewable power at
the cost incurred under the terms described above.
No electric service disconnections will result in the event of non-payment of program
commitments.
IDAHO
lssued per Order No.Effective ,2016
lssued by IDAHO POWER COMPANY
Timothy E. Tatum, Vice President, Regulatory Affairs
1221 West ldaho Street, Boise, ldaho
LEGISLATIVE FORMAT
ldaho Power Company First Revised Sheet No. 62-1
Cancels
|.P.U.C. No. 29. Tariff No. 101 OrioinalSheet No. 62-1
SCHEDULE 62
GREEN ENERGY PURCHASE
PROGMM RIDER
(oPTroNAL)
PURPOSE
The Green Energy Purchase Program (the Proqram) is an optional, voluntary program designed
to provide eCustomers and non-customer participants an opportunity to participate in the purchase of
new environmentally friendly "green" energy.
APPLICABILITY
Service under this schedule is applicable to all Customers and non-customer participants who
choose to participate in thislhg Program.
RENEWABLE ENERGY
For the purpose of this schedule, renewable enerqv will be in the form of Renewable Enerqv
Certificates (REC) from new renewable proiects as defined bv the Center for Resource Solutions
Green-e Enerov standard. Renewable enerqv will be sourced from proiects located in the Western
Electricitv Coordinatino Council's oeoqraphic area of authoritv with preference oiven to proiects located
in ldaho Power's service area and the northwest. Renewable enerqv types will be primarily wind but
mav include other certified tvpes such as solar, qeothermal. low-impact hvdroelectric, landfill qas. and
biomass.
MONTHTY GREEN ENER
Custemers designate their level ef partieipatien by eheesing a fixed dellar per menth ameunt,
The menthly Green Energy Purehase Pregram eentributien is in additien te all ether eharges ineludedin
the serviee sehedule under whieh the Custemer reeeives eleetrieal serviee and will be added te the
Custemer's menthly eleetrie bill, Nen Custemer partieipants will be i.ssued a menthly invei€e that
The Pregram funds will whelly be used te purehase green energy er eever the green energy
pri€efer€mium"
PRECRAM EONSIDERAT
___puBaHnsE
Customer participants will desiqnate one of two billino options upon enrollment. Non-customer
participants mav participate under Option 1.
Option 1: Block
Block Size: One Block eouals 100 kWh of renewable enerov
Charoe Per Block: $1.00 per month
IDAHO lssued by IDAHO POWER COMPANY
lssued per Order No. Timothy E. Tatum, Vice President, Regulatory Affairs
Effective -
-,2016
1221 West ldaho Street, Boise, ldaho
ldaho Power Company First Revised Sheet No. 62-1
Cancels
OrioinalSheet No 62-1l.P U C No 29 Tariff No 101
Option 2: Total Usaqe
Customers mav purchase renewable enerov eoualto their monthlv usaqe each month at
a price premium of 1.0 cent per billed kWh.
MONTHLY BILL
For a Customer who chooses Option 1. the monthlv bill shall be the number of blocks the
Customer has aoreed to purchase multiplied bv the Charoe Per Block. For a Customer who chooses
Option 2, the monthlv bill shall be the Customer's usaqe. times the price premium per kWh. The
monthlv bill is in addition to all other charoes contained in the Customer's applicable tariff schedule. A
non-customer participant who chooses Option 1. will be issued a monthlv invoice that reflects their
desionated fixed dollar per month amount.
IDAHO
lssued per Order No.
lssued by IDAHO POWER COMPANY
Timothy E. Tatum, Vice President, Regulatory Affairs
1221 West ldaho Street, Boise, ldahoEffective -2016
ldaho Power Company
LP.U.C. No. 29. Tariff No. 101 Orioinal Sheet No. 62-2
SCHEDULE 62
GREEN ENERGY PURCHASE
PROGRAM RIDER
(oPTroNAL)
(Continued)
PROGRAM ADMINISTMTION
No funds collected from the Prooram Rider mav be used for proqram administration (proqram
manaoement). A portion of the funds mav be used to support prooram communications. participant
outreach. and marketino.
QUALIFYING INITIATIVES
ln an effort to promote local proiect development and build awareness of renewable enerov. if
available. funds collected from the Prooram Rider but not othenffise required to meet proqram
oblioations mav be distributed to support renewable demonstration oroiects at schools located in ldaho
Power's service area. Demonstration proiects mav include renewable qeneration svstems, data
monitorino. renewable enerqv curriculum, and teacher traininq.
SPECIAL TERMS AND CONDITIONS
Prooram participants mav applv for. or terminate participation from, the Prooram anvtime durinq
the vear. The Companv mav limit availabilitv of the Prooram subiect to available renewable power at
the cost incurred under the terms described above.
No eedric service dl
cammitments.
IDAHO
lssued per Order No.Effective ,2016
lssued by IDAHO POWER COMPANY
Timothy E. Tatum, Vice President, Regulatory Affairs
1221 West ldaho Street, Boise, ldaho