20171113Answer to ICEA Motion to Dismiss.pdf

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An IDACORP Company
LISA D. NORDSTROM
Lead Counsel
I nordstrom@ida hopower.com
RECEIVED
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November 13,2017
VIA HAND DELIVERY
Diane Hanian, Secretary
ldaho Public Utilities Commission
472 West Washington Street
Boise, ldaho 83702
Re Case No. IPC-E-17-13
New Schedules for Residential and Small General Service Customers with
On-Site Generation - ldaho Power Company's Answer to the ldaho Clean
Energy Association's Motion to Dismiss
Dear Ms. Hanian
Enclosed for filing in the above matter please find an original and seven (7) copies
of ldaho Power Company's Answer to the ldaho Clean Energy Association's Motion to
Dismiss.
lf you have any questions about the enclosed documents, please do not hesitate to
contact me
Very truly yours,
X;4ru"a-/,*r,J
Lisa D. Nordstrom
LDN:kkt
Enclosures
lnordstrom@id ahopower.com
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UT!LITIES COMMISSION
LISA D. NORDSTROM (lSB No. 5733)
ldaho Power Company
1221West Idaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
AUTHORITY TO ESTABLISH NEW
SCHEDULES FOR RESIDENTIAL AND
SMALL GENERAL SERVICE CUSTOMERS
WITH ON.SITE GENERATION
RECEIVED
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CASE NO. IPC-E-17-13
IDAHO POWER COMPANY'S
ANSWER TO THE IDAHO CLEAN
ENERGY ASSOCIATION'S
MOTION TO DISMISS
Idaho Power Company ("ldaho Power" or "Company") and the electric industry are
currently transforming to integrate new technologies and respond to changing customer
preferences. Significant changes have occurred nationally and locally in the five years
since the ldaho Public Utilities Commission ("Commission") last addressed customer-
owned distributed energy resources ("DER"). Most intervenors in this case argue that the
Commission should narrowly interpret its authority and/or delay responding to the
opportunities and challenges posed by customers taking bi-directional services until a
general rate case is filed. Yet as a regulator that performs both legislative and judicial
IDAHO POWER COMPANY'S ANSWER TO THE IDAHO
CLEAN ENERGY ASSOCIATION'S MOTION TO DISMISS. 1
functions, the Commission is empowered by the ldaho Legislature to set and adapt
regulatory policy as circumstances require to promote and protect the public it serves.
Arguments that res judicata or conditions precedent prevent the Commission from acting
ignore the state of ldaho's utility regulatory framework and should be denied.
Pursuant to RP 57, ldaho Power files this Answer to the ldaho Clean Energy
Association's ("|CEA") Motion to Dismiss and Joinders filed by multiple intervenors. The
Company requests the Commission deny the Motion and allow its Application to proceed
as scheduled in Order No. 33901.
BACKGROUND
Five years ago, ldaho Power filed Case No. IPC-E-12-27 in November 2012
requesting authority to modify its net metering service to approximately 350 customers.
ldaho Power's Application ("2012 Application") asked the Commission to approve four
changes to the net metering service: (1) increasing the net metering cap; (2) changing
the net metering pricing structure; (3) changing how excess net energy is billed; and (4)
changing tariff provisions regarding interconnection with net metering customers.
ln Order No. 32846 issued in July 2013, the Commission declined to make
changes to ldaho Power's net metering pricing structure. The Commission stated, in
relevant part on pages 12-13:
Commr.ssion Decision: Based on our review of the
record, we believe that net metering customers have some
characteristics that could justify moving them into a separate
rate class and onto a different schedule from the general
residential and small general service rate classes. However,
we are concerned that the Company's proposal is inconsistent
with State policy as expressed in the ldaho Energy Plan, will
discourage investment in distributed generation, and
encourage rate-gaming. Further, we believe dramatic
changes such as those proposed in this case-including
increasing the monthly customer charge, imposing a new BLC
IDAHO POWER COMPANY'S ANSWER TO THE IDAHO
CLEAN ENERGY ASSOCIATION'S MOTION TO DISMISS - 2
charge, and reducing the energy charge for the residential
and small general service customers-should not be
examined in isolation but should be fully vetted in a general
rate proceeding. Accordingly, at this time we decline to make
these changes, change the rate design, or separate the net
metering customers from the standard residential service and
small genera! service classes. lf the Company wishes to raise
these issues again, then it should do so in the context of a
general rate case. We agree with the Company that net
metering customers do escape a portion of the fixed costs and
shift the cost burden to other customers in their class.
However, we find that more work needs to be done to
establish the correct customer charge for those who net
meter.
Case No. IPC-E-12-27, Order No. 32846, pp. 12-13.
As directed by the Commission, the Company has filed an annual status report for
each of the past four years discussing "the net metering service provisions and pricing
and how distributed generation may be impacting system reliability."l
On July 27 ,2017, ldaho Power filed an Application ("2017 Application") for an order
authorizing: (1) closure of Schedule 84, Customer Energy Production Net Metering,
("Schedule 84") to new service for residential and small general service ("R&SGS")
customers with on-site generation after December 31,2017, (2) establishment of two new
customer classifications applicable to R&SGS customers with on-site generation that
request to interconnect to ldaho Power's system, with no pricing changes at this time, (3)
acknowledgement that smart inverters provide functionality that is necessary to support
the ongoing stability and reliability of the distribution system by ordering the Company to
amend its applicable tariff schedules to require the installation and operation of smart
inverters for all new customer-owned generator interconnections within 60 days following
1 ln the Matter of ldaho Power Company's Application for Authority to Modify /fs Nef Metering
Seryrce and to lncrease the Generation Capacity Limit, Case No. IPC-E-12-27, Order No. 32846 at 19.
IDAHO POWER COMPANY'S ANSWER TO THE IDAHO
CLEAN ENERGY ASSOCIATION'S MOTION TO DISMISS.3
the adoption of an industry standard definition of smart inverters as defined by the lnstitute
of Electrical and Electronic Engineers ("|EEE"), and (4) commencement of a generic
docket at the conclusion of this case to establish a compensation structure for customer-
owned DER that reflects both the benefits and costs that DER interconnection brings to
the electric system.
On October 27 ,2017, ICEA filed a Motion to Dismiss and Memorandum in support
thereof, Auric Solar, LLC ("Auric Solar") filed a Joinder and Memorandum in Support of
ICEA's Motion to Dismiss, and the City of Boise ("Boise City") filed a Memorandum Joining
in Support of and Providing Comments to ICEA's Motion to Dismiss. Following the
October 27 deadline for dispositive motions established in Commission Order No. 33901,
the ldaho Conservation League ("lCL") filed a Partial Joinder on November 1, 2017. On
November 3, 2017, the ldaho Sierra Club filed its Partial Joinder to ICEA's Motion to
Dismiss, lntermountain Wind and Solar, LLC filed a Partial Joinder in Motion to Dismiss
and Memorandum in Support of Motion to Dismiss, and the Snake River Alliance ("SRA")
and NW Energy Coalition jointly filed a Joinder and Memorandum in Support of ICEA's
Motion to Dismiss. ldaho Power refers herein to these parties collectively as "Movants."
The Movants argue in ICEA's Motion to Dismiss and their Joinders thereto that the
above language in Order No. 32846 bars consideration of the issues presented in the
present docket. ldaho Power strongly disagrees.
ARGUMENT
l. The lmpact of Order No. 32846 on This Proceedinq
!CEA's Memorandum in Support of Motion to Dismiss and the Movants' Joinders
argue that the doctrine of res judicata applies to the Company's 2017 Application. The
IDAHO POWER COMPANY'S ANSWER TO THE IDAHO
CLEAN ENERGY ASSOCIATION'S MOTION TO DISMISS - 4
ICEA's Motion to Dismiss also moves the Commission for "an Order dismissing this case
with prejudice because Applicant ldaho Power Company has failed to satisfy the
conditions precedent to it applying to the Commission for other relief."2 Neither of the
arguments provide a reasonable basis to dismiss ldaho Power's 2017 Application.
A. Res Judicata. On pages 2-3 of its Memorandum, ICEA quotes Magee v.
Thompson Creek Mining Co. for the proposition that:
ln ldaho, 'res judicata' means that in an action between the
same parties upon the same claim or demand, the former
adjudication concludes parties and privies not only as to every
matter offered and received to sustain or defeat the claim but
also every matter which might and should have been litigated
in the first suit."3
ICEA argues that res judicata applies because ldaho Power's 2017 Application
presents the same set of operative facts as its 2012 Application and that the Commission
has previously decided the issue(s) that ldaho Power presents. ldaho Power disagrees
with this narrow interpretation of facts and Commission authority.
1. Same Set of Operative Facts. Much has changed in the five years
since ldaho Power filed its 2012 net metering case. When ldaho Power filed its 2012
Application, it was largely concerned about potential cost shifting to non-participants and
wished to address this issue while the number of customers was relatively small, and
before quantifiable cost shift was occurring.
At the time Order No. 32846 was issued, it is unlikely that any party
expected this issue to remain unaddressed five years later. ln addition to more recent
2 ICEA's Motion to Dismiss at 1
3 Magee v. Thompson Creek Mining Co., 152ldaho 196, 2O2,268 P.3d 464, 470 (2012) (internal
quotations omitted). Res judicata applies to decisions of ldaho administrative agencies. Magee, 152 ldaho
at202,268 P.3d at470 (2012).
IDAHO POWER COMPANY'S ANSWER TO THE IDAHO
CLEAN ENERGY ASSOCIATION'S MOTION TO DISMISS - 5
national trends discussed in Mr. Tatum's testimony,a ldaho Power believes that
circumstances in its service atea - particularly continued growth in participation and
misinformation to potential future net metering participants - have changed such that the
Commission should evaluate whether it wishes to address the requests set forth in the
Company's 201 7 Application.
2. Previouslv Decided the lssue ldaho Power Presents . ln 2012, ldaho
Power proposed substantial changes to its pricing structure applied to net metering
customers - "including increasing the monthly customer charge, imposing a new BLC
charge, and reducing the energy charge for the residential and small general service
customers" - such that the Commission believed they "should be fully vetted in a general
rate case proceeding."5
However, when the Commission declined in July 2013 to make changes "at this
time",6 the Commission clearly envisioned revisiting the issue in the future. lt "agree[d]
with the Company that net metering customers do escape a portion of the fixed costs and
shift the cost burden to other customers in their class" but that "more work needs to be
done to establish the correct customer charge for those who net meter".7
ln the instant case, ldaho Power proposed an approach that incorporated this
guidance from the Commission in Order No. 32846 as well as feedback received from
four stakeholder meetings. To best position customers, stakeholders, and the utility for
rate changes that will be proposed in a future rate proceeding, ldaho Power's 2017
a Direct Testimony of Timothy E. Tatum at 14-18.
5 Order No. 32846 at 12-13.
6 Order No. 32846 at 13.
7 /d. (emphasis added).
IDAHO POWER COMPANY'S ANSWER TO THE IDAHO
CLEAN ENERGY ASSOCIATION'S MOTION TO DISMISS - 6
Application requests that the Commission establish new rate classes and open a generic,
multi-utility case to investigate the proper methodology to value customer-sited distributed
generation.
The Movants argue that res judicata bars the Commission from revisiting the issue
of establishing new rate classes because it was finally decided in Order No. 32846. This
would be an absurd result that, if strictly applied, would prevent the Commission from
ever modifying rates, charges, or classifications once established. The Commission does
not forfeit its power under ldaho Code S 61-503 or its public duty under ldaho Code S 61-
502 to investigate and determine rates, charges, or classifications if it finds them to be
"unjust, unreasonable, discriminatory or preferential."s lndeed, the Commission
previously indicated on page 12 of Order No. 32846 that "net metering customers have
some characteristics that could justify moving them into a separate rate class
While res judicata is appropriately applied when adjudicating transactional matters
such as contracts and complaints, it is less suited to the Commission's legislative and
policy functions that must evolve over time.s Applying res judicata as the Movants
propose ignores ldaho Code S 61-624, which allows the Commission to "rescind, alter, or
amend any order or decision made by it." The Legislature clearly envisioned that the
Commission would need to modify orders to address changing circumstances that render
rates, charges, or classifications unjust or unreasonable. While the Commission found
that changes to rates and classification were premature in 2013, the Company's 2017
8 ldaho Code $ 61-502
e "Because regulatory bodies perform legislative as well as judicial functions in their proceedings,
they are not so rigorously bound by the doctrine of sfare decisls that they must decide all future cases in
the same way as they have decided similar cases in the past." Rosebud Enterprises v. ldaho PUC,128
ldaho 609, 618,917 P.2d766,775 (1996) citing lntermountain Gas Co. v. ldaho PUC,97 ldaho 113, 119,
540 P.2d 775,781 (1975). See a/so Commission Order No. 30955 at 21.
IDAHO POWER COMPANY'S ANSWER TO THE IDAHO
CLEAN ENERGY ASSOCIATION'S MOTION TO DISMISS - 7
Application gives the Commission the opportunity to revisit the limited issue of customer
classification if it believes circumstances warrant doing so.
B. Conditions Precedent. Similar to arguments put forth by |CEA1o and Auric
Solar,1l Boise City's Joinder to ICEA's Motion to Dismiss contends that "ldaho Power has
failed to follow the Commission's Order No. 32846 requiring certain conditions related to
a filing of this sort, including obtaining customer and stakeholder feedback and presenting
its application as a general rate proceeding.'12 ldaho Power will now address each of
these arguments.
1. Stakeholder Ensaqement. ICEA argues on page 5 of its
Memorandum that ldaho Power has not met the condition precedent set by the
Commission in Order No. 32846 to "inform and obtain feedback from its customers and
stakeholders" before proposing major program-specific changes. As explained in the Ms.
Aschenbrenner's testimony,l3 ldaho Power has not only solicited feedback from
interested parties, but it also incorporated this feedback into the case strategy. However,
ICEA implies that stakeholder engagement is deficient if it does not "craft a consensus."14
ldaho Power's actions were more than "going through the motions" and did in fact
"meaningfully consider public input and shape its application accordingly."l5 The
10 ICEA Memorandum in Support of Motion to Dismiss at 5.
11 Auric Solar, LLC's Joinder and Memorandum in Support of ICEA's Motion to Dismiss at 2.
12 Boise City's Memorandum Joining in Support of, and Proving Comments to, ICEA's Motion to
Dismiss at 3.
ts Direct Testimony of Connie G. Aschenbrenner at 15-24.
14 ICEA Memorandum in Support of Motion to Dismiss at 5.
15 Auric Solar, LLC's Joinder and Memorandum in Support of ICEA's Motion to Dismiss at 5.
IDAHO POWER COMPANY'S ANSWER TO THE IDAHO
CLEAN ENERGY ASSOCIATION'S MOTION TO DISMISS - 8
Company has solicited feedback (and incorporated the feedback received) from
customers and stakeholders regarding potential changes that would impact net metering
customers on at least four occasions.
a. Fall 2015 Customer Focus Groups / Stakeholder Meetinq.
During 2015, ldaho Power contemplated a filing that would have sought to implement
mandatory demand charges for all R&SGS customers. ln evaluating whether to proceed
with the filing, ldaho Power held 12 customer focus groups across the Company's service
area,16 with each session attended by seven to eight customers. At each focus group, a
Company representative delivered a short presentation explaining the concepts of
demand and energy and discussed a potential rate design that would incorporate a
mandatory demand charge for those customer classes. After those focus groups, the
Company held meetings with stakeholders to share the Company's strawman rate design,
discuss the feedback it received at the focus groups, and listen to additional feedback
from those stakeholders. Several parties in this current docket, including the Commission
Staff, lCL, and SRA, participated in those discussions. After considering input it obtained
from customers and stakeholders, the Company ultimately decided not to move fonarard
with a filing at that time.
b. Julv 2016 Stakeholder and Customer Meeting. As described
more fully on pages 15-18 of Ms. Aschenbrenner's direct testimony, ldaho Power held a
customer meeting in July 2016 to (1) share the results of the cost shifting analysis
presented to the Commission in the 2016 Net Metering Status Report ("2016 Report"), (2)
raise awareness among the Company's R&SGS net metering customers about the issue
16 Focus groups were held in Boise (4), Caldwell (2), Pocatello (2), Twin Falls (2), and the Wood
River Valley (2).
IDAHO POWER COMPANY'S ANSWER TO THE IDAHO
CLEAN ENERGY ASSOCIATION'S MOTION TO DISMISS - 9
of cost shifting and that the Company was considering making a filing that would seek to
modify rate design, and (3) solicit input, feedback, and concerns from customers and
stakeholders. The Company mailed an invitation to all active and pending R&SGS net
metering customers, and invited parties from the 2012 net metering case.17 At the
meeting, the Company described the analysis it performed in preparation for the 2016
Report, and presented a straw-man rate design that it was considering filing. The
Company provided participants with an opportunity to ask questions, voice concerns, and
to propose potential alternative suggestions for consideration. Participants at the meeting
strongly opposed any modifications to rates - generally, participants felt that the rate
changes proposed would be punitive for net metering customers. After carefully
considering the input received at that meeting from customers and stakeholders, the
Company decided not to make a filing in 2016 and instead contemplated alternate case
strategy while continuing to monitor the participation in the net metering service.
c. June 2017 Stakeholder Meetinq. The Company filed its 2017
Net Metering Status Report ("2017 Report") with the Commission in April 2017. ln the
2017 Report, the Company determined: (1)the estimated cost shift from net metering
customers to non-participating customers continued to grow throughoul2016, (2) that
cost shift coupled with an updated forecast demonstrating significant growth on the
horizon prompted ldaho Power to engage with stakeholders to provide an update of the
recent growth in the net metering service, and (3) described an alternative case strategy
than what had been proposed the prior year. Contrary to the Movants' claims that the
17 Case No. IPC-E-12-27
IDAHO POWER COMPANY'S ANSWER TO THE IDAHO
CLEAN ENERGY ASSOCIATION'S MOTION TO DISMISS - 1O
Company has not "informed or obtained feedback in any meaningful way'ta or that the
Company has simply gone "through the motions" rather than "meaningfully consider
public input and shape its application accordingly,"ls the Company's 2017 Report
described2o that ldaho Power had carefully considered the input it received from
customers in 2016 and ultimately determined it would not seek pricing changes in
customer rates as part of a proposal. The Company subsequently presented a much
more limited proposal for consideration at the June 2017 Stakeholder Meeting - one that
would not have an immediate impact on customers, but one that would position the
Company, and parties, to address the rate structure at a date in the future in a general
rate proceeding or another docket where pricing was considered.
d. June 2017 lnstaller Meetinq. ldaho Power also held a meeting
with installers to understand what the impact would be (if any) of the Company's planned
proposal to seek an eventual inclusion of a smart inverter requirement in Schedule 72.
Several installers in the Company's service area attended the meeting and none of those
present indicated concerns about a future requirement for smart inverters. ldaho Power
incorporated this feedback into its current request.2l
ln developing the scope of the Company's 2017 Application, the Company
considered the feedback provided by both customers and stakeholders. The Company's
decision to request the Commission to open a generic docket at the conclusion of this
case with the purpose of establishing a compensation structure for customer-owned
18 ICEA Memorandum in Support of Motion to Dismiss at 5.
1s Auric Solar, LLC's Joinder and Memorandum in Support of ICEA's Motion to Dismiss at 5.
20 2017 Report at 3-5.
21 Direct Testimony of Connie G. Aschenbrenner at21-24.
IDAHO POWER COMPANY'S ANSWER TO THE IDAHO
CLEAN ENERGY ASSOCIATION'S MOTION TO DISMISS - 11
DERs that reflects both the benefits and costs that DER interconnection brings to the
electric system was the direct result of what the Company heard from interested
stakeholders and installers.22
2. Timing of a General Rate Case. ldaho Power has not filed a general
rate case since 2011 and it is unknown when it will do so. In IDACORP's November 2,
2017, Q3 earnings release call, ldaho Power President and CEO Darrel Anderson was
asked for his thoughts on the Company's near-term rate activity. Mr. Anderson
responded that ldaho Power "would have to signal early in '18 if we're going to do
something for'19... given what we would hope to see as continued strong economic
activity and if we can continue to manage the expenses like we have done this year, we
would hope to not have to go in."2g Because the Company does not have definite near-
term plans to file a general rate case, ldaho Power's requested relief in the 2017
Application purposefully does not impact customer rates but will position the Company to
make appropriate rate proposals for Commission, customer, and stakeholder
consideration when that time comes.
ll. Chanqed Circumstances
A. Growth in Participation. When the Company filed for changes to its net
metering service in 2012, it did so based on a 2002 Commission Order directing the
Company to make a filing when the Company's net metering service reached the 2.9
22 ld. at24.
23 IDACORP lnc. Earnings Call transcript, November 2,2017, at7.
http://www.idacorpinc.com/-/media/Files/l/lDACorp/conference-calls/ida-usq transcript 2017-11-02.odf
IDAHO POWER COMPANY'S ANSWER TO THE IDAHO
CLEAN ENERGY ASSOCIATION'S MOTION TO DISMISS - 12
megawatt ("MW') cap imposed by that Order.24 At the time of the 2012 Application, the
Company had 353 net metering customers with installed generation capacity of 2.53 MW.
As of June 2017, the number of active and pending net metering systems had
grown to 1,468 with installed generation capacity of 11.11 MW.25 As shown in Chart 1,
as of October 31 ,2017, iust four months later, the number of active and pending systems
is 1,893 with installed generation capacity of 15.77 MW; net metering customer
generating capacity has increased by 42 percent in those four months.
Chart 1: Count of Active/Pending Systems and lnstalled Capacity
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Chart 2 shows the number of applications, by month, received by ldaho Power
since 2012. The number of applications received by the Company has shown a steady
increase over the last three years; even pior to the Company filing its request at the end
of July 2017 , the Company had been experiencing growth in the number of applications
2a ln the Matter of the Application of ldaho Power Company for Approval of a New Schedule 84 -
Net Metering Tariff, Case No. IPC-E-O1-39, Order No. 28951 at 12.
2s Direct Testimony of Connie G. Aschenbrenner at 13.
IDAHO POWER COMPANY'S ANSWER TO THE IDAHO
CLEAN ENERGY ASSOCIATION'S MOTION TO DISMISS - 13
ff
L40
120
100
80
50
40
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processed monthly. ln fact, customer growth observed thus far in 2017 exceeds the high
grovuth forecast in the 2017 Report, which projects 7,032 residential net metering
customers by 2022.26
Ghart 2: Net Metering Applications Received, by month (2012-20171
B. Consumer Protection. While the Company has previously expressed its
concern about the potential for cost shifting to non-participants, ldaho Power is
increasingly concerned that potential net metering participants are relying on inaccurate
or misleading information to make decisions about investing in on-site generation.
Statements by the Movants suggest that customers investing in net metering systems
today believe as much: "lf ldaho Power's proposal is accepted, Auric Solar's potential
customers will be placed in an untenable position of incurring a known, substantial, up-
26 2017 Report at 9; Direct Testimony of Connie G. Aschenbrenner Exhibit No. 9 at 9
IDAHO POWER COMPANY'S ANSWER TO THE IDAHO
CLEAN ENERGY ASSOCIATION'S MOTION TO DISMISS. 14
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front cost without knowing the long-term return."27 This statement implies that today Auric
Solar's customers are left with the impression that electric rates will not change. Per an
online review, this is precisely the impression Auric Solar2s left with them: "we will lock
your power rate so that it never goes up again, ever." Attachment 1. The same comment
suggests that ldaho Power's rates are "increasing almost 10o/o ayeat." ln fact, since 2003
ldaho Power's residential rates have experienced a compound annual growth rate of 2.83
percent.
Boise City argues that "the structure of ldaho Power's Application is creating
uncertainty in the industry which is currently effecting solar installation and may
dramatically reduce the number of citizens who will pursue rooftop solar."2e While ldaho
Power has not observed a decline in net metering applications submitted after filing its
2017 Application (see Chart 2 above), ldaho Power agrees with the Movants that
uncertainty exists in the ldaho distributed generation industry. However, it is erroneous
to believe that ldaho Power's filing "creates" or "injects extreme uncertainty into the
market."30 Customer uncertainty has ALWAYS existed because all customer utility rates
are subject to change.31
27 Auric Solar, LLC's Joinder and Memorandum in Support of ICEA's Motion to Dismiss at 7.
28 Customers have identified Auric Solar as their installer on 40 percent of the net metering
applications received by ldaho Power in 2017 through October.
2s Boise City's Memorandum Joining in Support of, and Providing Comments to, ICEA's Motion to
Dismiss at 4.
30 Auric Solar, LLC's Joinder and Memorandum in Support of ICEA's Motion to Dismiss at 2 and 6.
31 ldaho Code $S 61-502 and -503.
IDAHO POWER COMPANY'S ANSWER TO THE IDAHO
CLEAN ENERGY ASSOCIATION'S MOTION TO DISMISS - 15
Even though ldaho Power provides its customers with information that rates can
change - on its website,32 the net metering application where the customer signs and
acknowledges an understanding that rates can change,33 the email notifying the customer
their net metering account is active, and on brochures provided to customers at trade
shows, the Movants suggest that new uncertainty would be created by the establishment
of new customer classes. Boise City maintains that the "adverse impact" of the
Company's filing "is undeniable and could eliminate Boise's progress towards an efficient
system driven by the customer's desires for renewable energy."3a
To clarify, the Company's filing does not change a customer's ability to install on-
site generation, nor did it request rate changes as a part of this filing. No additional
uncertainty will be created because of the Commission issuing a determination on
customer classifications. To the extent that installers in the Company's service area have
assured customers that installing on-site generation will protect them from future
increases or changes to rate structures, those statements have created a false certainty.
For example, Attachmenl2 is an online post submitted by an Auric Solar installer touting
32 https://www.idahopower.com/energy/renewable-enerqv/qreen-choices/net-meterinq/: "Future
changes in rates will impact the estimated net savings and payback.";
https://docs.idahopower.com/pdfs/BusinessToBusiness/SolarChecklist.pdf: "The net metering service,
including the current rate structure and interconnection requirements, is subject to change and current rates
do not represent a guarantee of future pricing.";
https://docs.idahopower.com/odfs/BusinessToBusiness/NetMeterinqFAQs.pdf: "The net metering tariff -including the current rate structure and interconnection requirements - is subject to change and does not
represent a guarantee of future pricing."
33 https://docs.idahopower.com/pdfs/BusinessToBusiness/netMeterinq Application.pdf: "l
understand that the net metering service - including the rate structure and interconnection requirements -
is subject to change and that current rates do not represent a guarantee of future pricing."
il Boise City's Memorandum Joining in Support of and Providing Comments to ICEA's Motion to
Dismiss at 4.
IDAHO POWER COMPANY'S ANSWER TO THE IDAHO
CLEAN ENERGY ASSOCIATION'S MOTION TO DISMISS - 16
that "you can lock in what you are paying now, and power rate hikes will no longer effect
you."
Customers' impression that rates will never change is also fostered by their
observation of other states that "grandfather" existing systems to historic rate treatment.
Many expect this to occur in ldaho as well. lnstallers also perpetuate this idea, as can be
seen on Auric Solar's website banner "lDAHO RESIDENTS: IDAHO SOLAR POLICY lS
CHANGING. ACT NOW TO LOCK lN CURRENT RATES." Attachment 3. Yet past
ldaho Supreme Court opinions suggest that grandfathering rates for existing net metering
customers cannot laMully occur.35
Further, ldaho Power is increasingly aware that customers are relying on a wide
range of investment payback information that could be misleading. Customer distributed
generation investments are substantial; the average residential, non-tracking photovoltaic
system installed in ldaho Power's service area in 2017 is7 .2 kW, a system that may cost
upwards of $30,000. ldaho Power believes that customers can recoup the average
investment in 15 years.36 Auric Solar's website indicates a period half as long - customers
purchasing its array can achieve a Return on lnvestment of 7-10 years. Attachment
4. Evengreen Technology estimates on its website that installing solar generation
equates to a savings of "7|,lkWh for life." Attachment 5.
One cannot reasonably conclude that dismissing or delaying the Company's
request will make any future changes easier for those that are considering becoming a
35 ldaho State Homebuilders v. Washington Water Power, 107 ldaho 415,421, 690 P.2d 350 , 356
(1984) and Building Contractors Association v. IPUC and Boise Water Corp., 128ldaho 534, 539, 916 P.2d
1259, 1264 (1996).
36 ldaho Power computed this payback period using the 1S-year residential compound annual
growth rate of 2.83 percent.
IDAHO POWER COMPANY'S ANSWER TO THE IDAHO
CLEAN ENERGY ASSOCIATION'S MOTION TO DISMISS - 17
net metering participant in the interim. To the contrary, continued inaction perpetuates
misinformation and could be especially harmful to customers who would benefit from
better signals concerning net metering rates that are many months, if not years, from
being established by the Commission.
ldaho Power believes it is possible to convey this message to the public so that
potential participants can make informed choices. Auric Solar references the following
comment from a member of the public:
Approving ldaho Power (lPC)'s request for a separate rate
class would send a message that the rate structure for
customers with on-site generation will fundamentally
change, but nobody has any idea what to plug in as an
assumption.3T
Although this result is viewed negatively by the commenter and by Auric Solar, at least it
would be an accurate reflection of the current state of net metering rates in ldaho until
more accurate assumptions are developed. lt also demonstrates that this commenter
clearly received the message that rate structure for customers with on-site generation will
fundamentally change. Waiting to make changes until a general rate case is filed or until
a technical study is complete encourages hundreds or thousands more customers to
make five digit investments under a faulty premise.
C. ldaho Enerqv Plan Page 9 of Order No. 32846 provided several reasons
why the Commission declined to make changes to ldaho Power's net metering pricing
structure - one of which was the Commission's concern "that the proposal was
inconsistent with State policy as expressed in the ldaho Energy Plan . . . ." Auric Solar
37 Auric Solar, LLC's Joinder and Memorandum in Support of ICEA's Motion to Dismiss at 6 (bolded
emphasis in original).
IDAHO POWER COMPANY'S ANSWER TO THE IDAHO
CLEAN ENERGY ASSOCIATION'S MOTION TO DISMISS - 18
argues that the Company's case does not meet the terms of Order No. 32846 because
"ldaho Power does not demonstrate how its current Application complies with the State
Energy Plan any more than its 2012 application (which it did not)."s8 However, ldaho
Power appropriately did not reference the ldaho Energy Plan in its Application because it
no longer operates as state policy.
During its 2006 session, the ldaho Legislature passed House Concurrent
Resolution ('HCR") No. 623s which directed the Legislative Council lnterim Committee on
Energy, Environment and Technology ("lnterim Committee") to "develop an integrated
state energy plan that provides for the state's power generation needs and protects the
health and safety of the citizens of ldaho" and to report its findings and recommendations
to the Legislature the following year. ln the 2007 session, HCR No. 1340 adopted the
2007 ldaho Energy Plan prepared by the lnterim Committee and required that it be
updated a minimum of once every five years.
Five years later, the 2012 ldaho Energy Plan was submitted by the lnterim
Committee and adopted by HCR No. 34.41 Like HCR No. 13 from the 2007 session, the
preamble of HCR No. 34 stated that "it is the desire of the Legislature to ratify this plan,
while at the same time making it a living, breathing plan with the intent that it be revisited
at a minimum of once every five years." As it did five years earlier, the ldaho Legislature
in HCR No. 34 resolved to "formally adopt the ldaho Energy Plan" as adopted by the
38 Auric Solar, LLC's Joinder and Memorandum in Support of ICEA's Motion to Dismiss at 5-6.
3s http://leqislatu re. idaho. gov/sessioninfo/2006/leqislation/HCR062/
a0 https://leqislature.idaho.qov/sessioninfo/2007/legislation/hcr013/
41 https://leqislature.idaho.qov/sessioninfo/2012lleqislation/hcr034/
IDAHO POWER COMPANY'S ANSWER TO THE IDAHO
CLEAN ENERGY ASSOCIATION'S MOTION TO DISMISS - 19
lnterim Committee "as the State Energy Plan and that the Legislature update this plan at
a minimum of once every five years."
While the Interim Committee met in 2017 to discuss state energy issues,a2 the
lnterim Committee did not adopt a new or existing version of the ldaho Energy Plan.
Consequently, the matter did not come to a vote in the 2017 Legislative session. Because
the Legislature has not updated the ldaho Energy Plan in more than five years, it no
longer operates as state policy.
lll. Establishinq Glass Composition Before Cost-of-Service
ldaho Power disagrees with Boise City's argument that: "Before deciding whether
there is a need for a new rate class the value of solar must be studied and ldaho Power
should thoroughly examine the appropriate cost of service."43 To perform the very study
Boise City discusses, net metering customers would have to be separated from standard
service customers to isolate and measure their utilization of the system, a step needed to
understand what costs are appropriately assigned to these customers. This is precisely
the reason the Company proposed the scope and timing of its case in the manner it did
- to formally recognize that these customers should be separated into different
classifications based upon factors consistent with ldaho law.aa lf the Commission
determines that no differences exist that warrant the creation of new customer classes
for customers with on-site generation, the Company will continue to allocate costs to
42 https://leqislature. idaho.qov/sessioninfo/2017lstandingcommittees/HENV/
a3 Boise City's Memorandum Joining in Support of and Providing Comments to ICEA's Motion to
Dismiss at 4.
44 ldaho State Homebuilders v. Washington Water Power, 107 ldaho 415, 420 (1984). The
Commission has subsequently identified factors such as cost-of-service, quantity of electricity used,
differences in conditions of service, or the time, nature, and pattern of use "as guidelines for the Commission
to use to evaluate whether there is a reasonable justification for setting different rates and charges for
different classes of customers." Order No. 26780.
IDAHO POWER COMPANY'S ANSWER TO THE IDAHO
CLEAN ENERGY ASSOCIATION'S MOTION TO DISMISS - 20
those broader customer classes as it does today and will evaluate what pricing changes
may be necessary for all customers in order to mitigate the cost shift that occurs as a
result of an outdated net metering policy.
ldaho Power believes addressing the issue of separate classes today is the most
efficient way to process this issue in the long term. There are many other rate issues that
must be addressed in a general rate case proceeding and those issues must be fully
vetted and litigated in a seven-month time period.a5 To suggest the Commission should
ignore the issue until the next rate case because it would somehow be easier or less
controversial is irrational. As other utilities in the industry have found, the issue does not
become less contentious as more time passes. Asking the Commission to decide
whether a segment of customers should be considered their own class prior to a general
rate case is a reasonable first step that may more accurately inform potential participants'
expectations of future rates.
lV. Alternative Relief
The ICEA asserts "the resolution of net metering costs and benefits may best be
set by the same process used in the solar integration Case No. IPC-E-14-18, see
Attachment 2 hereto."a6 The Movants request the Commission provide "alternate relief
similar to the attached in timeline, methodology, source of inputs, and technical group to
study the costs and benefits of net metering, and would request a settlement conference
to discover whether the parties can agree on such a concept."aT ldaho Power finds this
a5 ldaho Code S 61-622
ao ICEA's Memorandum in Support of Motion to Dismiss at 6. The City of Boise City references the
IPC-E-14-18 settlement process in its Memorandum at page 2; Auric Solar's Memorandum references the
settlement at page 7.
47 ICEA's Memorandum in Support of Motion to Dismiss at 6.
IDAHO POWER COMPANY'S ANSWER TO THE IDAHO
CLEAN ENERGY ASSOCIATION'S MOTION TO DISMISS - 21
request confusing and believes the Movants have misrepresented what occurred in Case
No. IPC-E-14-18.
ICEA refers to the settlement filed in Case No. IPC-E-14-18 as Attachment 2 to its
Memorandum.4s By the terms of that settlement, the parties in Case No. IPC-E-14-18
agreed to immediately implement the integration charges of ldaho Power's first solar
study as proposed in the Company's Application (paragraph 5) and to initiate a second
solar integration study (paragraph 6) where a different solar integration methodology
could be evaluated. The settlement set forth how the second solar study would be
conducted (paragraph 7) and what issues would be considered (paragraph 8). At no point
did the settlement in Case No. IPC-E-14-18 dismiss or delay resolution of the Company's
initial Application. The opposite occurred - the settlement implemented the requested
rates without delay and resolved the case so that the new study could begin. Once the
settlement was accepted by the Commission in Order No. 33227, the second solar study
occurred and its rates were later implemented in another proceeding, Case No. IPC-E-
16-1 1.
lf the parties to Case No. IPC-E-17-13 wish to engage in settlement discussions
that include separate customer classes for currenUfuture net metering participants as a
precursor to a multi-utility proceeding that explores the proper value of distributed
generation, ldaho Power would be pleased to facilitate these discussions. However, the
establishment of separate customer classes must come first for two reasons: (1) to send
a more accurate rate message to customers, and (2) to ensure that stakeholder efforts
are not wasted if the Commission were to later determine that net metering participants
aa The Memorandum's attachments were inadvertently omitted and subsequently filed on October
30,2017 , as an errata.
IDAHO POWER COMPANY'S ANSWER TO THE IDAHO
CLEAN ENERGY ASSOCIATION'S MOTION TO DISMISS - 22
and standard rate customers should remain unseparated in their current customer
classes.
CONCLUSION
Many customers are making investments in privately owned generation under the
false belief that they will continue to enjoy a rate design that was established to collect
costs from a group of customers who all took service in the same way; they received all
their energy from the utility. The issue at the center of this case is whether customers
who generate their own energy are fundamentally different than those who do not.
While the Movants disagree with the timing and content of ldaho Power's
Application, any party could have initiated a case to address any or all of these issues at
any time in the last five years. No party chose to do so. lt is appropriate that ldaho
Power's case be allowed to move forward to a Commission determination on the merits
without dismissal or substantial "restructuring"ae of ldaho Power's requested relief.
ldaho Power requests the Commission deny the Movants' Motion to Dismiss and
allow the Company's Application to proceed as filed and scheduled. The Commission
should approve the creation of new customer classes as soon as possible to more clearly
indicate to potential net metering customers and the distributed generation community
that future net metering rates will not be the same as standard retail rates and to formalize
classification for future cost of service studies.
DATED at Boise, ldaho, this 13th day of November 2017 .
LISA D
Attorney for ldaho Power Company
ae Boise City's Memorandum Joining in Support of, and Providing Comments to, ICEA's Motion to
Dismiss at 1 and 4.
IDAHO POWER COMPANY'S ANSWER TO THE IDAHO
CLEAN ENERGY ASSOCIATION'S MOTION TO DISMISS - 23
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 13th day of November 2017 I served a true and
correct copy of IDAHO POWER COMPANY'S ANSWER TO THE IDAHO CLEAN
ENERGY ASSOCIATION'S MOTION TO DISMISS upon the following named parties by
the method indicated below, and addressed to the following:
Commission Staff
Sean Costello
Deputy Attorney General
ldaho Public Utilities Commission
472 West Washington (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
Idahydro
C. Tom Arkoosh
ARKOOSH LAW OFFICES
802 West Bannock Street, Suite 900
P.O. Box 2900
Boise, ldaho 83701
ldaho Gonservation League
Matthew A. Nykiel
Idaho Conservation League
102 South Euclid #207
P.O. Box 2308
Sandpoint, Idaho 83864
Benjamin J. Otto
ldaho Conservation League
710 N.6th st.
Boise, Idaho 83702
ldaho lrrigation Pumpers Association, lnc.
Eric L. Olsen
ECHO HAWK & OLSEN, PLLC
505 Pershing Avenue, Suite 100
P.O. Box 6119
Pocatello, ldaho 83205
_Hand Delivered
_U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
_Hand Delivered
_U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
erin. cecil@arkoosh. com
_Hand Delivered
_U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
_Hand Delivered
_U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
_Hand Delivered
_U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
IDAHO POWER COMPANY'S ANSWER TO THE IDAHO
CLEAN ENERGY ASSOCIATION'S MOTION TO DISMISS - 24
Anthony Yankel
12700 Lake Avenue, Unit 2505
Lakewood, Ohio 44107
Auric Solar, LLC
Preston N. Carter
Deborah E. Nelson
GIVENS PURSLEY LLP
601 W. Bannock Street
Boise, ldaho 83702
Elias Bishop
Auric Solar, LLC
2310 S. 1300 W.
West Valley City, Utah 84119
Vote Solar
David Bender
Earthjustice
3916 Nakoma Road
Madison, Wisconsin 537 11
Briana Kobor
Vote Solar
360 22nd Street, Suite 730
Oakland, California 94612
Gity of Boise
Abigail R. Germaine
Deputy City Attorney
Boise City Attorney's Office
150 N. Capitol Blvd.
P.O. Box 500
Boise, ldaho 83701-0500
ldaho Clean Energy Association
C. Tom Arkoosh
ARKOOSH LAW OFFICES
P.O. Box 2900
Boise, ldaho 83701
_Hand Delivered
_U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
_Hand Delivered
_U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
den@q ivenspu rslev. com
_Hand Delivered
_U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
_Hand Delivered
_U.S. Mail
_Overnight Mail_FAXX Email [e-mail]
_Hand Delivered
_U.S. Mail
_Overnight Mail
_FAXXEmail @
_Hand Delivered
_U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
_Hand Delivered
_U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
erh. [e-mail]
IDAHO POWER COMPANY'S ANSWER TO THE IDAHO
CLEAN ENERGY ASSOCIATION'S MOTION TO DISMISS - 25
David H. Arkoosh
Law Office of David Arkoosh
P.O. Box 2900
Boise, Idaho 83701
Sierra Club
Kelsey Jae Nunez
KELSEY JAE NUNEZLLC
920 North Clover Drive
Boise, ldaho 83703
Zack Waterman
Director, ldaho Sierra Club
503 West Franklin Street
Boise, ldaho 83702
Michael Heckler
3606 North Prospect Way
Garden City, ldaho 83714
Snake River Alliance
NW Energy Goalition
John R. Hammond, Jr.
FISHER PUSCH LLP
101 South Capitol Boulevard, Suite 701
Boise, ldaho 83702
lntermountain Wind and Solar, LLC
Ryan B. Frazier
Brian W. Burnett
KIRTON McCONKIE
50 East South Temple, Suite 400
P.O. Box 45120
Salt Lake City, Utah 84'111
_Hand Delivered
_U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
_Hand Delivered
_U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
_Hand Delivered
_U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
_Hand Delivered
_U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
_Hand Delivered
_U.S. Mail
_Overnight Mail_FAXX Email [e-mail]
wwi I so n @s n a keriveral lia n ce. olq
[e-mail]
_Hand Delivered
_U.S. Mail
_Overnight Mail
_FAXX Email rtrazier@kmclaw,com
[e-mail]
IDAHO POWER COMPANY'S ANSWER TO THE IDAHO
CLEAN ENERGY ASSOCIATION'S MOTION TO DISMISS - 26
Doug Shipley
Dale Cravyford
lntermountain Wind and Solar, LLC
1953 West2425 South
Woods Cross, Utah 84087
_Hand Delivered
_U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
dale@imwindandsolar. com
6
Executive Assistant
IDAHO POWER COMPANY'S ANSWER TO THE IDAHO
CLEAN ENERGY ASSOCIATION'S MOTION TO DISMISS - 27
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
GASE NO. IPC-E-17-13
IDAHO POWER COMPANY
ATTAGHMENT 1
OVEHVIEW
.r Verizon ?3:36 PM
q g auric solar boise
n * 44o/" a
Danny O'Malley i
:, (; ;:. l
*****:vrjltl"5iti.tr
lmagine if ldaho Power came to you and said,
"We have a new program and we'd like to
invite you to participate. lf you are willing to
pay an extra $5-$10/mo, we will lock your
power rate so that it never goes up again,
ever. (By the way, our rates are increasing
almost lOYo a year, which is about $5-$1O/mo,
so you're going to pay this either way)Then,
depending on the program options that you
choose, after so many years we will
completely stop charging you for power. Also,
just to sweeten the deal, we'll plant 100 trees
ayeil in your name and add at least S10,000
to your home value... lnterested?"
Well, the utility isn't making that offer, but
Auric is!
IJ
https://www.soosle.com/search?ei=dlwHWri2AYHEiAPbgL2lBw&q=auric+solar+boise&oo=auric+solar+boise&ss
l=psv-ab.3..0i57k1i019.11415.14426.0.14520.24.13.0.0.0.0.390.1307.1i4i1i1.7.0....0...1.1.64.psv-
ab.. 18.6. 12 16...0i 131k1i0i46i67k1i46i57k1.0.V2rJcl IVZQQ%20-
%201 rd=0x54ae5441ab482877:0x1078b7f95c94a37f,1,..&sof=15 10431878588#lrd=0x54ae5441ab482877:0x1078b
7f95c94a37f, 1,,,&sof=15 10595841026
Printed November 4, 2017
REVIEWS
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BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
GASE NO. IPC-E-17-13
IDAHO POWER COMPANY
ATTACHMENT 5
PV Installation Company I PV Solar Panels I EvenGreen Technology
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Page I of2
888.200.3177
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HOME IECHNOLOGIES ENERGY SERVICES GALTERY COMPANY GOAI IERO CONIACT
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PV SOLAR
PHOTOVOLTAIC SOLAR BASICS
What tochnology can rellably gonorate electricity for
decadea without omltfrng any pollutanE and save you
monay in the proceas?
!rn
Solar electric panels, of murse. Solar electric, or
photololtaic panels transform the sun's energy directly into
electricity The energy generated by the panels can be
used to seamlessly power your home or business, or be
sent back into the grid for purchase by your utility provider
One of the best aspects of solar panel technology is lhat it
converts sunlight, an unlimited source of energy, into
electrlcity
So how doe3 thli cloan, gr€en, technology work?
1. Photovoltaic solar panels absorb the energy from the sun in the form of photons and convert the energy into
direct cunent electricity
2, This electricity travels oul of the panels and into a device called an inverter, which transforms direct current
(DC) electricity into altemating current (AC) electricity,
3. lt is then used in your home offsetting you electrical draw froryr your utility lf the Pv solar panels produce
more electricity than you use, the excess is sent back into the power gfid and bought by your utility company
ln this situation you can Iiterally watch your electric meter run backwards and eam ssdits for future u8e'
Evencreen Technology can easily install and integrate PV solar panels into any home's energy system Unlike
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way
ENERGY SAVTNGS (s0.07 pEn KWH fOR UrE)
The easiest way lo explain the savings you will generate
from solar energy is a lovelized cost of pow€r As we
know our utility prices are increasing every year and will
continue to do so at a utility estimated 4% annually With
solar you will create a consistent cost of pourer without
rate increases at 6-7 cents oer kyuh This is roughly a
50% savings per kWI on utility cost over 25 years These
savings are grater for lhose with large power bills The most effective way to see a realized savings amont is
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LONGEVIfY rmrxrmum 25 YEARs)
For many years solar panels were looked at as a very expensive, and often
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PV Installation Company I PV Solar Panels I EvenGreen Technology Page2 of2
decades. Wth the immensely increased cell efficiency and 75./6 lower prlclng over this time period, solar
panels are most often wanantied for 25 years thus providing consumers wilh a much more viable solution in
regards to the up fronl inveslment The Federal Governmenl has also done ils part to make solar a staple in
our society, pushing the limits of research and development to conlinually improve cell efficiency and have
also made lhe incentives/rebates very attractive to help home/business owners alike commit to reducing the
demand on the grid.
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Evencreen providet the mo!'l holistic opprooch to lrue energy
efficiency through culting edge lecnnologies, odvonced design
ond engineering processes, high quolity inslollolions. consumer
educolion, ond offordoble ond relioble products thot will conlinue
to cenefit our clienls for yeors to come.
EvenGreen Technology, lnc.
401 Norih Moin Street
Meridion. lD 83542
Phone: [phone]! 70
foll Free: 888 200 3l 77
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