20180810Brief on Reconsideration.pdf

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Lisa D. Nordstrom
An IDACORP Company
P.O. 8ox 70 (83707)
1221 W. ldaho St.
Boise, lD 83702
LISA D. NORDSTROM
Lead Counsel ; :,
[e-mail]
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August 10,2018
VlA HAND DELIVERY
Diane Hanian, Secretary
ldaho Public Utilities Commission
472 West Washington Street
Boise, Idaho 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 Opening Brief on
Reconsideration
Dear Ms. Hanian
Enclosed for filing in the above matter please find an original and seven (7) copies
of ldaho Power Company's Opening Brief on Reconsideration.
lf you have any questions about the enclosed documents, please do not hesitate to
contact me.
Very truly yours,
,fl-C7^u,"*
LDN:kkt
Enclosures
LISA D. NORDSTROM (lSB No. 5733)
ldaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR
AUTHORITY TO ESTABLISH NEW
SCHEDULES FOR RESIDENTIAL AND
SMALL GENERAL SERVICE
CUSTOMERS WITH ON-SITE
GENERATION
RECIIVED
?0l8AUG l0 PH h: l0
,l r'--,qivi : :; . :, lCi,il'iiSSiOli
lnordstrom@id ahopower.com
Attorney for ldaho Power Company
BEFORE THE !DAHO PUBLIC UTILITIES COMMISSION
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CASE NO. IPC-E-17-13
IDAHO POWER COMPANY'S
OPENING BRIEF ON
RECONSIDERATION
ldaho Public Utilities Commission ("Commission") Order No. 34098 asked the
parties in this matter for "briefing related to whether a customer's ability to export energy
should determine if the customer should be included in new Schedules 6 and 8."t The
ability to export has several significant flaws as a criterion for exclusion from Schedules
6 and 8.
First, all self-generators, regardless of what other technology may be coupled with
the generation, are partial requirements customers. The load service requirements and
pattern of use for these partial requirements customers are much different than those of
I Order No. 34098 at 2. The Commission approved the creation of Schedule 6, Residential Service
On-Site Generation, and Schedule 8, Small General Service On-Site Generation ("Schedules 6 and 8"), in
Order No. 34046 issued on May 9, 2018.
IDAHO POWER COMPANY'S OPENING BRIEF ON RECONSIDERATION - 1
standard customers -- even if the partial requirements customer limits their ability to
export energy. The load service requirements of those customers are consistent with
those of other exporting self-generating customers in Schedules 6 and 8.
Carving out a subset of partial requirements customers, as Vote Solar suggests,
would simply provide that subset with an opportunity to continue the cost shifting between
customers with on-site generation and those without. ln Order No. 34046, the
Commission cited "evidence of cost shifting, or subsidization, and load and usage
characteristics" as to what informed its decision and went on to describe that "the history
of the Company's on-site generation program reveals an unfairness in how current and
future on-site generation customers avoid fixed costs. The ability these customers have
to 'net out' or net to zero their electricity use causes them to underpay their share of the
Company's fixed costs . . . ."2 A customer with on-site generation operating in parallel
who limits exports has the same ability to offset consumption which, under a largely
volumetric-based rate design, creates an opportunity for that customer to avoid paying
the full fixed cost to serve them.
Second, the parallel connection of an on-site generation system is the appropriate
criteria to determine inclusion in the new customer classes. Self-generation systems
connected in parallel to the grid, even those with battery storage or export limiting devices,
use grid services to operate. An export limiting device only limits energy senf to the utility;
these devices do not limit the customer's ability to receive energy or other grid services.
Consequently, self-generating customers who operate in parallel but limit the export of
2 Order No. 34046 at 16-17
IDAHO POWER COMPANY'S OPENING BRIEF ON RECONSIDERATION - 2
energy to the utility take the same services as other self-generators in Schedules 6 and
8 who do export.
Lastly, even if the Commission were to explore options for creating a subset of
customers with on-site generation without energy export in the standard rate classes,
there are several operational and safety considerations that would make enforceability of
that impractical and unadvisable, particularly given the limitations of ldaho Power's net
hourly consumption meters.
For these reasons, which are described in greater detail in the pages that follow,
the Commission should reject Vote Solar's request to require the Company to revise new
Schedules 6 and 8 to apply only to customers who export electricity.
t.
LOAD SERVICE REOUIREMENTS D PATTERN OF USE BY PARTIAL
REQUIREMENTS CUSTOMERS ARE DIFFERENT THAN STANDARD SERVICE
CUSTOMERS. REGARDLESS OF WHAT OTHER TECHNOLOGIES ARE PRESENT
ln its case-in-chief, ldaho Power provided evidence to demonstrate the difference
between the load service requirements and the pattern of uses of customers with on-site
generation as compared to residential customers who take standard service from ldaho
Power. The evidencer included comparisons of load factor, load profile, system-
coincident demand ('SCD"), and non-coincident demand ("NCD"); the bi-directional flow
of energy was only one component of the usage characteristics of a customer with on-
site generation. Likewise, customers with on-site generation who either prevent the
3 ldaho State Homebuilders v. Washington Water Power,107 ldaho 415, 690 P.2d 350 (1984).
Differences in rates charged to classes of customers are not per se unreasonable or unlavtrful under /daho
Code $ 61-315. The ldaho Supreme Court interpreted this statute in the Homebuilders decision and
explained that the setting of different rates may be justified by factors such as cost-of-service, quantity of
electricity used, differences and conditions of service, or the time, nature, and pattern of use.
a Tr. at 598-618.
IDAHO POWER COMPANY'S OPENING BRIEF ON RECONSIDERATION - 3
export of excess energy via an export limiting device, or who use battery storage to
eliminate the export to the grid, continue to have different load service requirements than
standa rd service customers.
To study the effects of preventing the export of excess energy, the Company
produced a Limited Export Simulation to simulate a residential customer before and after
the installation of on-site generation without the capability to export excess energy.s A
simulation was necessary because the Company is not aware of any residential or small
general service customers with parallel-connected on-site generation system that uses
an export limiting device to prevent the export of excess energy to the grid. The
methodology used by the Company to create the Limited Export Simulation is described
in Attachment 1.
The Limited Export Simulation demonstrates how the load service requirements and
usage characteristics differ for a customer before and after the installation of on-site
generation without the capability to export excess energy. lmportantly, even in the absence
of energy exports, the customer with on-site generation still has the ability to offset their
usage on an hourly basis; this reduction in energy consumption, coupled with a rate design
that collects fixed costs through a volumetric rate, creates the opportunity for shifting costs
from customers with on-site generation to standard service customers.
5 For the simulation, the Company used the hourly load data for 272 sample customers in the Boise
metro area from the 2016 load research sample as the reference load profiles. An additional data set was
created from this data set by offsetting the load with an annual production profile of a photovoltaic ("PV")
system appropriately sized for each customer. All hourly energy exports were replaced with zero. The
2016 load research data used for the Limited Export Simulation was previously provided to all parties in
response to Vote Solar's Data Request No. 27.
IDAHO POWER COMPANY'S OPENING BRIEF ON RECONSIDERATION - 4
A. Load Service Requirements
Load factor analysis is an important measure to compare the load service
requirements of one segment of customers to another. The Ioad factor is the average load
divided by the maximum load for a specified time period.6 lt is a computation that captures
the degree of demand variation; a load factor approaching one hundred percent represents
less variation in the demand pattern, and a load factor near zero portrays more demand
variation. Over the period of measurement, a low load factor identifies a customer with
infrequent maximum demand and the capacity required to serve that peak demand is idle
for long periods. Under a rate design that collects most fixed costs for system capacity
through volumetric kilowatt-hour charges, customers with a lower load factor are
subsidized by customers with higher load factors.
Using the Limited Export Simulation, the Company calculated the load factor for
each sample customer before and after the installation of on-site generation without the
capability to export excess energy. The average of the monthly load factors of the sample
customers before and after the installation of on-site generation without the capability to
export excess energy are shown in Figure 1.
6 Tr. at 601, ll. 1-15.
IDAHO POWER COMPANY'S OPENING BRIEF ON RECONSIDERATION - 5
Figure 1. Load Factor - Simulated for No Energy Exports
Load Factor
28%
26%
24o/o
22%
20%
18%
16%
14%
L2%
L0%
Feb Mar Apr
r Before On-Site Generation r After On-site Generation with No Energy Exports
The Company's load factor analysis of each sample customer before and after the
installation of on-site generation without the capability to export excess energy
demonstrates that load factor is notably lower in all 12 months after the installation of on-
site generation -- even without the capability to export excess energy. For the months of
April through September, the load factor is reduced by roughly 33 percent after the
installation of on-site generation without the capability to export excess energy.
B. Pattern of Use
1. Load Profile - Simulated for No Enerqv Exports
The load profile portrays the pattern of demand through a particular period of time.
Using the Limited Export Simulation, the Company developed the load profile for each
sample customer before and after the installation of on-site generation without the
capability to export excess energy. The average load profile of the sample customers for
a winter month, a spring month, and a summer month are shown in Figures 2,3, and 4,
respectively. For the three graphs, each hour data point is the average for that hour
throughout the month.
IDAHO POWER COMPANY'S OPENING BRIEF ON RECONSIDERATION - 6
ll,l,l,
May Jun DecNovOctsepAugJulJan
Figure 2. January 2016 Simulated Load Profiles
January Load Profiles
2.50
2.00
1.50
1.00
0.s0
0.00
I.40
L.20
1.00
0.80
0.60
0.40
0.20
0.00
2.50
2.00
1.50
1.00
0.50
0.00
12345678 9 10 11 12 13 74 15 16 t7 18 19 20 2t 22 23 24
-trf1s1On-site
Generation with No Energy Exports
-
$sf6r.s On-Site Generation
Figure 3. April 2016 Simulated Load Profiles
April Load Profiles
t2345678 9 10 11 L2 t3 t4 Ls L6 77 18 19 20 21 22 23 24
-trfts1
On-site Generation with No Energy Exports
-
ggf61s On-Site Generation
Figure 4. June 2016 Simulated Load Profiles
June Load Profiles
72345678 9 10 11 L2 t3 14 t5 L6 r7 18 19 20 2t 22 23 24
-trftgp
On-site Generation with No Energy Exports
-
$6fe1s On-Site Generation
IDAHO POWER COMPANY'S OPENING BRIEF ON RECONSIDERATION - 7
The Company's load profile analysis of each sample customer before and after the
installation of on-site generation without the capability to export excess energy
demonstrates that the load profile changes significantly after the installation of on-site
generation -- even without the ability to export excess energy. The on-site generation
causes a downward ramp after the sun rises and generation from the utility is replaced
by the on-site generation for several hours. Then, as the sun sets and solar generation
ends, a significant upward ramp occurs. This is vastly different than the load curve before
the installation of on-site generation, where the transition from hour-to-hour is smoother
with significantly lower rate of change in usage during the morning and evening hours.
The results of the load profile analysis illustrate the additional requirements of the
Company to meet the ramping needs of these customers, when the Company must
reliably forecast load and efficiently dispatch the generation fleet to maintain the balance
between production and forecasted use.7
The Limited Export Simulation's load profile analysis also illustrates that, while
customers with on-site generation who limit their export energy consume less volumetric
energy from the utility, the maximum demand over the course of a day is not necessarily
reduced. This load service characteristic is consistent with customers who export
energy.s Consequently, it is appropriate to include customers with on-site generation who
limit their exports in Schedules 6 and 8 which will provide the Company an opportunity to
apply a rate design that will not shift the collection of costs through the standard service's
current volumetric rate design.
7 Tr. at 568, ll. 14-25.
8 Tr. at 614,11.5-7.
IDAHO POWER COMPANY'S OPENING BRIEF ON RECONSIDERATION - 8
2. Svstem-Coincident Demand - Simulated for No Enerqv Exports
The SCD is the average demand for a segment of customers at the time of ldaho
Power's system peak.s The analysis of SCD is important for cost allocation purposes
because: (1) production plant costs associated with serving base and intermediate load
are allocated using an average of the 12 monthly SCDs, (2) production plant costs
associated with serving peak load are allocated using an average of the three monthly
SCDs occurring in June, July, and August, and (3) transmission costs are allocated using
an average of the 12 monthly SCDs.
Using the Limited Export Simulation, the Company calculated the SCD for the
group of sample customers before and after the installation of on-site generation without
the capability to export excess energy. The monthly SCDs for the group of sample
customers before and after the installation of on-site generation without the capability to
export excess energy are shown in Figure 5.
Figure 5. System-Goincident Demands - Simulated for No Energy Exports
System-Coincident Dema nd
4.00
3.50
3.00
2.50
2.00
1.s0
1.00
0.50
0.00
Jan Feb Mar
r Before On-Site Generation r After On-site Generation with No Energy Exports
s Tr. at 715, ll. 3-5.
llil I'
Apr
llllililrr
Aug Sep Oct Nov DecJulJunMay
IDAHO POWER COMPANY'S OPENING BRIEF ON RECONSIDERATION - 9
The Company's SCD analysis of the group of sample customers before and after
the installation of on-site generation without the capability to export excess energy
demonstrates that the SCD is lower in nine out of 12 months after the installation of on-
site generation - even without the capability to export excess energy.
The results of this analysis suggest that the allocation of production plant costs
associated with serving peak load would decrease after the installation of on-site
generation without the capability to export excess energy because these costs are
allocated using an average of the three monthly SCDs occurring in June, July, and
August. Consequently, the resulting different allocation of costs supports the argument
that it is appropriate for all customers who install on-site generation -- even without the
capability to export excess energy -- to be included in Schedules 6 and 8.
3. Non-Coincident Demand - Si ated for No Enerov Exports
The NCD is the maximum average demand for a segment of customers in any
given hour, regardless of when it happens.lo Similar to SCD, the analysis of NCD is
important for cost allocation purposes because NCDs are used to allocate ldaho Power's
d istribution system costs.
Using the Limited Export Simulation, the Company calculated the NCD for the
group of sample customers before and after the installation of on-site generation without
the capability to export excess energy. The monthly NCDs for the group of sample
customers before and after the installation of on-site generation without the capability to
export excess energy are shown in Figure 6.
1o Tr. at 614,1l.7-9
IDAHO POWER COMPANY'S OPENING BRIEF ON RECONSIDERATION - 1O
Figure 6. Non-Coincident Demands - Simulated for No Energy Exports
Non-Coincident Demand
3.50
3.00
2.s0
2.00
1.50
1.00
0.s0
0.00 llllil
Jan Feb Mar May Jun Jul
!r
Apr
ll llil
Aug Sep
llll
Oct Nov Dec
r Before On-Site Generation I After On-site Generation with No Energy Exports
The Company's NCD analysis of the group of sample customers before and after
the installation of on-site generation without the capability to export excess energy
demonstrates that the installation of on-site generation has very little impact on the NCD;
that is, a customer's monthly peak is not necessarily reduced by the installation of on-site
generation -- even without the capability to export excess energy. The customers load
over the course of the month will continue to place the same level of peak demand on the
system.
This is an important observation because NCDs are used to allocate distribution
costs. While customers who install on-site generation without the capability to export
excess energy contribute to distribution costs in a similar manner, the collection of these
costs through the volumetric charge for standard service customers will result in cost
shifting if customers with on-site generation were to remain in the standard service
schedules. To mitigate this impact, all customers with on-site generation -- even those
who have no ability to export energy - should be included in new Schedules 6 and 8 to
appropriately assign and collect costs and address cost shifting.
IDAHO POWER COMPANY'S OPENING BRIEF ON RECONSIDERATION - 11
C. Validation of the Limited Export Simulation Using Actual Gustomer Data
To verify and validate the results of the Company's Limited Export Simulation, the
Company performed a supplementary analysis on the effects of preventing the export of
excess energy. For the supplementary analysis, the Company obtained actual data from
a segment of 18 residential solar customers in ldaho Power's Oregon service area who
participate in a Solar Photovoltaic Pilot Program ("Pilo1";.,, The metering requirements
for the Pilot require the Company to record separately the amount of generation produced
by the solar PV system, the amount of energy consumed from the utility, and the amount
of excess energy exported to the grid. Because the amount of excess energy exported
to the grid was recorded separately, the Company was able to set the energy exports to
zero. The same analyses were performed on the load service requirements and pattern
of use to determine if the results differ for a residential customer who installs on-site
generation and then prevents the export of excess energy.
The results of the supplementary analyses were consistent with the results of the
Limited Export Simulation, validating the results of the Company's Limited Export
Simulation. The Company's resulting analysis, "Pilot Customer Load Shapes With No
Energy Exports," can be found in Attachment 2.
11 On July 22,2009, Oregon House Bill (.HB') 3039 was signed into law. This legislation required
the Public Utility Commission of Oregon to establish a pilot program for each investor-owned electric
company to demonstrate the use and effectiveness of volumetric incentive rate payments for electricity
delivered from solar PV energy systems. The pilots were intended to apply to solar PV energy systems
permanently installed in the state of Oregon by retail electricity consumers and first became operational on
or after July 1 , 2010. HB 2893, enacted in 2013, revised the cumulative nameplate capacity from
25 megawatts ("MW") to 27 .5 MW. Each electric utility was assigned a share of the capacity goal based
upon their individual retail sales; ldaho Power's share of the pilot program's capacity is 0.450 MW.
IDAHO POWER COMPANY'S OPENING BRIEF ON RECONSIDERATION - 12
D. Cost Shifting and Subsidization
ln its case-in-chief, the Company argued that the outdated volumetric rate structure
intended for residential and small general service ("R&SGS") customers who take
standard full-requirements service from Idaho Power, does not provide a reasonable
opportunity for the utility to recover grid-related fixed costs of serving R&SGS customers
with on-site generation.tz Customers who install on-site generation do so with the intent
to offset their own usage and reduce or eliminate the volume of energy they consume
from ldaho Power. These customers, or "prosurners,"ts both produce their own energy
and consume energy from the utility. The Company's consumption-based rates were
intended for customers who take fully-bundled service from the utility and are designed
to collect generation, transmission, distribution and customer-related costs primarily
through a volumetric rate. That is, the services used by these customers are not priced
individually. Because the R&SGS customer classes both have a two-part rate design
with most of the customer-related fixed costs and all the demand-related fixed costs being
recovered through a volumetric charge, the current rate design has the potentialto create
a cost shift between self-generators and those that do not self-generate, as well as under
collect fixed costs. Vote Solar's recommendation to exclude non-exporting customers
would only perpetuate the cost shift by sustaining a financial carve out for self-generating
customers.
From a policy standpoint, regardless of energy exports, the load service
requirements and the usage characteristics of any R&SGS customer who installs on-site
12 Aschenbrenner REB at 18, ll. 1-9.
13 Tr. at 780 and 1068-1088.
IDAHO POWER COMPANY'S OPENING BRIEF ON RECONSIDERATION - 13
generation justify a separate and unique rate structure. The usage characteristics of
customers with on-site generation are not based on volumes of energy but rather on
capacity. Customer classes are determined by grouping customers with similar usage
patterns because customers with similar usage characteristics impose similar costs on
the utility. When customers impose similar costs on the utility, rates can be designed for
that segment of customer to recover the costs of providing utility service.
As demonstrated in the Company's case-in-chief,ta R&SGS customers who install
on-site generation are different than R&SGS standard service customers - this is true
regardless if the on-site generation system is coupled with battery storage or an export
limiting device to prevent the export of excess energy. Nevertheless, the Commission
orderedts the Company to provide additional information about the effects of battery
storage and export limiting devices for its consideration in this matter.
1. Batterv Storaqe
The addition of battery storage to a customer's parallel-connected on-site
generation system will further reduce the volume of energy they consume from the utility
and cause an even greater under collection of fixed costs. This under collection of fixed
costs will perpetuate the cost shifting between customers with on-site generation and
those without that the Commission seeks to avoid.ro
1a Tr. at 598, l. 6 - Tr. at 618, l. 2
15 Order No. 34098 at 3.
16 Order No. 34046 at 16-17. "The ability these customers have to 'net out' or net to zero their
electricity use causes them to underpay their share of the Company's fixed costs to serve customers, and
this inequity will only increase as more customers choose on-site generation."
IDAHO POWER COMPANY'S OPENING BRIEF ON RECONSIDERATION - 14
To study the effects of battery storage as a means to eliminate the export of excess
energy, the Brattle Group performed a simulation of the net load shapes of such
customers.tz A simulation was used because ldaho Power is not aware of any residential
customers with an on-site generation system connected in parallel with the addition of a
battery storage system to eliminate the export of excess energy. The Brattle Group's
resulting analysis, "The Effect of Storage on Customer Load Shapes when Coupled with
Distributed Generation," can be found in Attachment 3.
The analysis performed by the Brattle Group finds that coupling battery storage
with on-site generation to eliminate the export of excess energy results in similar reliance
on the utility infrastructure to that of a customer with on-site generation that does export
excess energy to the grid.ts The key takeawaystg from the Brattle Group's analysis of
customers that combine distributed generation and battery storage are:
o the installation of battery storage moderately flattens the average daily load
shape;
o the customer's maximum demand remains high relative to the customers'total
usage;
. the median load factor is still 50 percent lower than that of the standard service
residential customer class; and
17 The Brattle Group used the same net metering customer data that was previously provided to all
parties in response to Vote Solar's Data Request No. 90 to simulate the net load shape of a customer that
combines distributed generation and battery storage.
18 Brattle Group, The Effect of Storage on Customer Load Shapes when Coupled with Distributed
Generation at 1 (August 8, 2018).
1s /d. at 9.
IDAHO POWER COMPANY'S OPENING BRIEF ON RECONSIDERATION - 15
o customers who combine distributed generation and battery storage and
continue to take service under the current rate structure for standard service
customers will pay less than their share of the cost of using the grid.
o Without an alternative rate design, customers who combine distributed
generation and battery storage would not have a financial incentive to operate
their battery in a way that would significantly reduce their reliance on the power
grid.
Regardless of whether a customer with on-site generation stores their excess
energy in a battery, because they generate some or all of their own energy, they continue
to be a partial requirements customer who offsets the volume of energy they consume
from the utility. !t is appropriate to include all customers with parallel-connected on-site
generation in the newly established Schedules 6 and 8 customer classes, for which a rate
structure can be developed that will provide customers flexibility in meeting some of their
own energy needs while allowing the utility a reasonable opportunity to appropriately
assign and collect costs without cost shifting to standard service customers.
2. Export Limitinq Devices
Available technology, in the form of an export limiting device, can be used to
prevent the intentional export of energy to the grid.zo Such devices include dynamically
controlled inverters and reverse power relays. A dynamically controlled inverter
continually monitors the customer load and adjusts the on-site generation production
20 While ldaho Power is not aware of any existing residential or small general service customers
with an export limiting device to prevent exporting energy to the grid, other utilities serve such customers.
For instance, Hawaiian Electric's Customer Self-Supply (CSS) program enables customers to only install
private rooftop solar systems that do not export power to the utility grid. All power produced by the customer
either must be used as it is produced or stored in energy storage devices for later use. Credits are not
available for CSS systems and minimum billing requirements apply.
IDAHO POWER COMPANY'S OPENING BRIEF ON RECONSIDERATION - 16
down if the load drops below a specific threshold. A reverse power relay is installed at
the meter location and will disconnect the generation system if power flows toward the
utility.
Even if customers with on-site generation prevent the export of excess energy with
an export limiting device, they continue to be partial requirements customers who offset
the volume of energy they consume from the utility by generating some or all of their own
energy. ln order to develop a rate structure that will provide customers flexibility in
meeting their own energy needs, yet allow the utility a reasonable opportunity to
appropriately assign and collect costs without cost shifting to standard service customers,
all customers with parallel-connected on-site generation should be included in the newly
established Schedules 6 and 8 customer classes.
il.
PARALLEL CONNECTION IS THE APPROPRIATE CRITERIA
FOR INCLUSION IN SCHEDULES 6 AND 8
Establishing the parallel connection as the criteria for a different service offering is
not a new concept. Since 1983, when the Company began offering net metering service
under Schedule 86, Cogeneration and Small Power Production Non-Firm Energy,zt the
Company has required customers with parallel-connected on-site generation systems to
take service under a different tariff schedule in addition to the standard service tariff
schedule. Prior to the establishment of Schedules 6 and 8 on June 1 ,2018, all customers
with an on-site generation system connected in parallel with Idaho Power's system were
21 ln the Matter of the Application of ldaho Power Company for Approval of Revised Rates fo Be
Paid for Power and Energy So/d to ldaho Power Pursuant to Section 210 of the Public Utility Regulatory
Policies Act of 1978, Case No. U-1006-200, Order No. 18358.
IDAHO POWER COMPANY'S OPENING BRIEF ON RECONSIDERATION - 17
required to take service under Schedule 84, Customer Energy Production Net Metering
Service.22
A. Parallel Connection
"Parallel connection" means the customer's on-site generation system is
connected to, and operating in conjunction with, the utility's electric grid. A generation
system that is connected in parallelto the utility's electric grid is commonly referred to as
a "grid-tied" system or an "on-grid" system. A customer with an on-grid system uses
electricity from their on-site generation system, as well as from the utility's electric grid.
The customer can draw energy from the grid at times when their system is not generating
enough to meet their energy demand or when their system is not generating energy at all
due to maintenance or a lack of resource.
A parallel-connected on-site generation system is connected to the utility's electric
grid through a gridtie inverter. ln the case of a PV generation system, the grid-tie inverter
converts the direct current electricity generated by the PV solar panels into alternating
current electricity required by customer electrical appliances.
ln order for the on-site generation system to operate in parallel with the electric
grid, the on-site generation system must synchronize with the grid. To synchronize the
two systems, the alternating current waveforms of the on-site generator and grid must
match in time, voltage magnitude, and frequency. Connecting an on-site generator
22 ln the Matter of the Application of ldaho Power Company for Approval of a New Schedule 84 -Net Metering, Case No. IPC-E-O1-39, Order No. 28951.
IDAHO POWER COMPANY'S OPENING BRIEF ON RECONSIDERATION - 18
without matching these parameters may result in significant on-site generator mechanical
damage as the power grid suddenly enforces alignment.zs
The grid-tie inverter relies on the grid voltage and frequency to produce power that
is synchronized with the grid. As a result, the parallel-connected system cannot operate
without the grid, and therefore, when the utility experiences an outage, the parallel-
connected system will also experience an outage.
Per ldaho Power's Schedule 72, lnterconnections to Non-Utility Generation
("Schedule 72"), a generation disconnect switch is required to provide isolation of the on-
site generation from the customer's load service.z+ Figure 7 illustrates an on-site solar PV
connected in parallel to the utility's electric grid.
Figure 7. On-Grid lnstallation Gonnected in Parallel: The inverter delivers energy when
synchronized and the solar panels are producing direct current power
Grid-tie lnverter
+
Disconnect
Switch
Closed
Meter
Solar
Produces power
when the grid
provides ac
voltage and
frequency for
synchronized
operation
Power
Grid
Power
Flow
t--
Customer
E lectrica I
Loa d
Power
Flow
23 The 2007 ldaho National Lab's Aurora Generator Test demonstrated how a cyberattack could
destroy physical components of the electric system. When a computer program opened and closed a
generator's circuit breakers out of phase from the rest of the grid, the torque from the forced system
synchronization caused the generator to explode apart. www.cnn.com/2007/US/09/26lpower.at.risk or
https://en. wiki ped ia. oro/wi ki/Au rora Generator Test
2a "Disconnection Equipment is required for all Seller Generation Facilities. The Disconnection
Equipment shall be installed at an electrical location to allow complete isolation of Seller's Generation and
lnterconnection Facilities from the Company's system. Disconnection Equipment for Net Metering Systems
or Small On-Site Generation Systems will be installed at an electrical location on the Seller's side of the
Company's retail metering point to allow complete isolation of the Seller's Generation and lnterconnection
Facilities from the Seller's other electrical load and service." Schedule 72, Sheet No. 72-5.
1"dc
IDAHO POWER COMPANY'S OPENING BRIEF ON RECONSIDERATION - 19
The gridtie inverter is not able to supply power independent from the power grid,
thus, the disconnect switch location isolating the solar PV system from the grid and
customer load allows the customer to service the PV solar system without adversely
impacting the customer load service, as shown in Figure 8.
Figure 8. On-Grid lnstallation: No energy is produced untilthe inverter is synchronized
with the power grid
Grid-tie lnverter Disconnect
Switch Meter
i
Solar PV
No energy
output until
synchronized
with the grid
Open
Customer
Electri ca I
Load
1. Essential Grid Services
The grid provides many benefits to the customers who choose to connect their on-
site generation in parallel to the utility's electric grid. These services include reliability,
voltage reference and voltage control, frequency reference and frequency control, motor
starting current, and reactive power support.2s
All customers currently taking services under Schedules 6 and 8 are connected in
parallel to ldaho Power's electric grid. lt is that parallel connection that allows these
customers to enjoy the essential services offered by the grid. While benefiting from the
essential grid services listed above, these customers can both consume energy
generated from their own on-site generation system and consume energy from the utility
when their system is not generating sufficient energy to meet their energy demands.
2s Tr. at 566, l. 6 - Tr. at 574,1. 8; Tr. at 60, ll. 3-1 1
IDAHO POWER COMPANY'S OPENING BRIEF ON RECONSIDERATION - 20
Power
Grid
Power
Flow
dc 1"
2. Backup and Standbv Service
The grid also acts as backup generation for customer systems in the event their
system fails. The grid also stands ready to provide standby service when the customer's
system is not large enough to meet the customer's demand or when, in the case of a PV
system, the sun is not shining. The electric power grid is in many ways like a battery to
customers with on-site generation, but at a much lower cost to the customer than installing
and maintaining their own battery.
B. Parallel Connection with Backup Capability
As discussed in Mr. David Angell's testimony, there are "off-grid" inverters which
produce alternating current voltage and frequency for operation independent of the grid.zs
Additionally, "grid-forming" inverters exist that may operate in parallel with the grid and
yet have the ability to regulate alternating current voltage and frequency and supply power
independent of the grid. Grid-forming inverters are often used in conjunction with
batteries and on-site generation. When operating in parallel with the grid, these grid-
forming inverters synchronize to the grid alternating current voltage and frequency as
shown in Figure 9.
26 Tr. at 572,11. 3-10.
IDAHO POWER COMPANY'S OPENING BRIEF ON RECONSIDERATION - 21
dc 1"
Figure 9. Grid-Forming lnstallation Connected in Parallel: The inverter delivers energy from
the solar PV and battery when synchronized to the grid
Batterv G rid-forming
I nverter
Disconnect
Switch
Closed
Disconnect
Switch
Closed
Meter
Power
Flow
Meter
i
Solar PV
i
+Produces power
in synchronism
with the grid ac
voltage and
freq uency
Grid-formine
lnverter
Disconnect
Switch
Closed
Customer
Electri ca I
Load
Customer
Electri ca I
Load
Disconnect
Switch
Open
Power
Grid
Power
Grid
T
When grid supply ceases, the grid-forming inverter senses the loss of supply and
automatically disconnects from the grid at which time the grid-forming inverter develops,
regulates, and supplies voltage and power to the customer load as shown in Figure 10.
Figure 10. Grid-Forming lnstallation Off-Grid Operation: The inverter delivers energy from
the solar PV and battery when the grid is disconnected
Power
Flow
Power
Flow
Batterv
+Produces power,
ac voltage and
frequenry
independent of
the grid
Solar T
During this off-grid operating mode, the customer will not experience the parallel
operation grid benefits of energy balancing, voltage and frequency regulation, and motor
starting capacity. The on-site generation system must supply energy to the largest
combination of customer loads, which may be reduced through a well-planned load
management system. Additionally, the customer will need to size the system for motor
starting currents or replace larger motors with electronically commutated motors to reduce
IDAHO POWER COMPANY'S OPENING BRIEF ON RECONSIDERATION -22
dc 1"
the starting currents. ln summary, configuring and managing a system to operate in the
off-grid mode can be difficult and costly.
C. Non-Parallel Connection
Unlike the prior on-site generation configurations, a generation system that is not
connected in parallel to the utility's electric grid is completely independent of the utility
grid. A generation system that is not connected in parallelto the electric grid is commonly
referred to as an "off-grid," or a "standalone" system. An off-grid system may be required
to provide backup supply for critical customer systems in the event the grid service is
interrupted. Because there is no connection between the off-grid system and the utility's
grid, an off-grid system is incapable of providing excess energy to the grid and it is also
incapable of receiving energy from the utility. Because an off-grid system is not
connected to ldaho Power's electric grid, the customer load is not served by ldaho Power,
and is therefore not required to take service under new Schedules 6 and 8.
Figures 11 and 12 illustrate the installation of an off-grid system that is not
connected to the utility's electric grid. Note that the switch is designed to automatically
transfer the load from the grid, during the loss of grid supply to the on-site generator to
supply the customer load independent of the power grid.
IDAHO POWER COMPANY'S OPENING BRIEF ON RECONSIDERATION - 23
Figure 11. Backup "Off-Grid" lnstallation: Normal Operation - the grid supplies the
customer load
Meter Power
Grid
Power
Flow
Figure 12. Backup "Off-Grid" lnstallation: Backup Operation .- the on-site generator
supplies the customer load
Meter Power
Grid
Power
Flow
Tra nsfer
Equipment
Normal mode-
grid supply
ln standby mode Customer
E lectrica I
Load
Tra nsfer
Equipment
Backup mode-
self supply
Customer
E lectrica I
Load
Produces power,
ac voltage and
independent of
ncy
grid
IDAHO POWER COMPANY'S OPENING BRIEF ON RECONSIDERATION .24
Backu o
Generator
Backu p
Generator
An example of a standalone, off-grid system would be a hospital with a backup
generation system that is not intended to offset consumption. The hospital's automatic
transfer switch is configured to isolate the hospital's load from the electric distribution
system when it senses very low or no voltage.
ilt.
EXCLUDING ANY ON.SITE GENE FROM SCHEDULES 6 AND 8 CREATES
OPERATIONAL AND SAFETY CONCERNS
A. lntra-Hour Usage Not Detectable in Net Hourly Consumption
Finally, ldaho Power explained in its Answer to Vote Solar's Petition for
Reconsideration that: "Even if the Commission granted Vote Solar's request, using the
export of electricity as the criterion to determine the applicability of Schedules 6 and 8 is
not enforceable because intra-hour usage is not detectable."zT Because ldaho Power
measures the hourly net consumption with one meter, the Company cannot measure the
total of energy exported to the grid separately from how much energy the customer
consumes from the Company. To determine net consumption, the amount of energy
exported to the grid is deducted from the amount of energy from the utility consumed by
the same customer. lf the sum at the end of the hour is greater than zero, the customer
consumed more energy from the utility than they exported to the grid. lf the sum at the
end of the hour is less than zero, the customer exported more energy to the grid than they
consumed from the utility. As a result, there is no way to know if any energy has been
exported to the grid within the hour if the customer always consumes more energy from
the utility on an hourly basis.
27 ldaho Power Company's Answer to Vote Solar's Petition for Reconsideration at 4
IDAHO POWER COMPANY'S OPENING BRIEF ON RECONSIDERATION - 25
To illustrate this, ldaho Power obtained the data for a single customer from March
2016 where a power quality meter was temporarily installed at the customer's request to
record data on a 30-second basis. Figure 13 illustrates the net hourly consumption over
a 24-hour period at the customer's premise.
Figure 13. Net Hourly Consumption for lndividual Customer
2.50
2.00
1.50
r..00
0.50
0.00
-0.50
-1.00
r,.llr
10 LL t2 13 14 15 16
llr
678
ll
34
ll
I llro2t222324
Note that the net consumption in hour 16:00 is just barely positive -- the net
consumption is 22 watt-hours. However, what is not obvious by looking at the total net
energy consumption for the hour is that the customer did export excess energy to the grid
during that hour. To understand what happens on a moment-by-moment basis, the
Company plotted hour 16:00 using 3O-second intervals. The intra-hour usage for hour
16:00 is shown in Figure 14. The usage for each 30-second interval is plotted over the
course of the hour.
IDAHO POWER COMPANY'S OPENING BRIEF ON RECONSIDERATION - 26
Figure 14. lntra-Hour Gonsumption for lndividual Customer
5.00
4.00
3.00
2.00
=-v.
1.00
0.00
+'0 300 L800 2700 3000 3300
-1.00
-2.00
Seconds
The blue area of the graph indicates intervals where the customer consumed
energy from the utility - totaling 251 watt-hours. The red area indicates intervals where
the customer generated more energy than they could consume and the excess energy
was exported to the grid - totaling 229 watt-hours. As indicated previously, the total net
energy consumption for the hour was22 watt-hours - this is the value ldaho Power would
receive from the net meter for hour 16:00. ldaho Power would have no way to detect that
this customer had in fact exported energy to the grid within the hour.
Given that intra-hour exports cannot be detected using current metering
configurations, Vote Solar's request to use energy exports as the criteria for inclusion in
new Schedules 6 and 8 is not enforceable.
IDAHO POWER COMPANY'S OPENING BRIEF ON RECONSIDERATION - 27
12AO
B. Safety
Since 2002, Schedule 72 has required that all customers with on-site generation
notify ldaho Power when a net metering system and small on-site generation system is
interconnected (in parallel) to the Company's system. Net metering systems and small
on-site generation systems interconnected to the Company's system without Company
approval are considered unauthorized installations that jeopardize the reliability of ldaho
Power's system and the safety of its employees.2s This includes, but is not limited to,
newly installed systems and unapproved expansions of approved systems.
The utility must be aware of any system connected in parallel to its electric grid to
ensure that all systems have passed the proper electrical inspections and include the
proper safety equipment to disconnect the system from the grid. Once ldaho Power is
notified of a newly installed system or of an expansion of an approved system, the
Company then has the opportunity to perform a feasibility reviewze to determine the
capability of the Company's electricalsystem to incorporate the on-site generation system
and determine if upgrades are necessary.
Upon installation of its on-site generation system, the customer must provide
documentation to the Company verifying that all federal, state, and local requirements
have been met.30 The customer must also provide the Company with a System
Verification Form detailing the specifications of all installed components of the system.
The Company will then perform an on-site inspection to verify all requirements have been
28 Schedule 72, Sheet No. 72-10
2s ld. at Sheet No.72-7.
30 ld. at Sheet No. 72-8.
IDAHO POWER COMPANY'S OPENING BRIEF ON RECONSIDERATION - 28
met.31 Upon successful completion of the on-site inspection, the Company will move the
customer to either the net metering service or small on-site generation service rate
schedule.sz
lf the Commission were to grant Vote Solar's request to allow customers who do
not export to continue to take service undertheir standard service schedule, the Company
would not have an opportunity to verify those systems are interconnected in a manner
that would not jeopardize reliability of ldaho Power's system or the safety of its
employees. The Commission should require all on-site generation systems operating in
parallel with the grid to continue to be subject to the interconnection requirements
contained in ScheduleT2 as set forth by Schedules 6 and 8.
tv.
CONCLUSION
It is imperative that the Commission establish the appropriate application of
Schedules 6 and 8 now so that as technology evolves, one definitive criteria exists that
makes sense for all forms of distributed energy resources. The Company believes the
Commission's Order in this matter, and the tariff schedules approved in this case,
appropriately establish the scope of the customers to be included in Schedules 6 and 8
as all customers whose on-site generation systems are connected in parallel to ldaho
Power's system.
Eligibility for Schedules 6 and 8 should be based upon the existence of on-site
generation that is connected in parallel with ldaho Power's system. This classification
31 ld.
32 ld. at Sheet Nos. 72-7 and72-8.
IDAHO POWER COMPANY'S OPENING BRIEF ON RECONSIDERATION - 29
approach will establish two unique groups of self-generating customers with load service
requirements that are distinctly different than customers without on-site generation. The
ability to export, or lack thereof, does not significantly impact the load service
requirements of these "prosumers." Separate classification for R&SGS customers with
on-site generation connected in parallel with ldaho Power's system will best position the
Commission to establish fair, just, and reasonable rates and compensation structures for
these groups of customers into the future.
ldaho Power recommends the Commission reject Vote Solar's request to require
the Company to revise new Schedules 6 and 8 to apply only to customers who export
electricity. While there are several cost-of-service, operational, and safety benefits to
including self-generating customers without exports in Schedules 6 and 8, there is no
downside -- except perhaps for those self-generators who could benefit from continued
access to the cross-subsidy that exists in volumetric standard service rates.
Respectfully submitted this 1Oth day of August 2018.
LISA D. NOR
Attorney for ldaho Power Company
IDAHO POWER COMPANY'S OPENING BRIEF ON RECONSIDERATION - 30
GERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 1Oth day of August 2018 I served a true and correct
copy of IDAHO POWER COMPANY'S OPENING BRIEF ON RECONSIDERATION 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 83720-0074
ldahydro
C. Tom Arkoosh
ARKOOSH LAW OFFICES
802 West Bannock Street, Suite 900
P.O. Box 2900
Boise, ldaho 83701
ldaho Conservation League
Matthew A. Nykiel
ldaho Conservation League
102 South Euclid #207
P.O. Box 2308
Sandpoint, ldaho 83864
Benjamin J. Otto
Idaho Conservation League
710 North 6th Street
Boise, ldaho 83702
Idaho lrrigation Pumpers Association, Inc.
Eric L. Olsen
ECHO HAWK & OLSEN, PLLC
505 Pershing Avenue, Suite 100
P.O. Box 6119
Pocatello, ldaho 83205
_Hand Delivered
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[e-mail]
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Anthony Yankel
12700 Lake Avenue, Unit 2505
Lakewood, Ohio 44107
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IDAHO POWER COMPANY'S OPENING BRIEF ON RECONSIDERATION.3l
Auric Solar, LLC
Preston N. Carter
Deborah E. Nelson
GIVENS PURSLEY LLP
601 West Bannock Street
Boise, ldaho 83702
Elias Bishop
Auric Solar, LLC
2310 South 1300 West
West Valley City, Utah 841'19
Vote Solar
David Bender
Earthjustice
3916 Nakoma Road
Madison, Wisconsin 537 11
Briana Kobor
Vote Solar
986 Princeton Avenue S
Salt Lake City, Utah 84105
City of Boise
Abigail R. Germaine
Deputy City Attorney
Boise City Attorney's Office
150 North Capitol Boulevard
P.O. Box 500
Boise, ldaho 83701-0500
ldaho Clean Energy Association
Preston N. Carter
Deborah E. Nelson
GIVENS PURSLEY LLP
601 West Bannock Street
Boise, ldaho 83702
Sierra Glub
Kelsey Jae Nunez
KELSEY JAE NUNEZLLC
920 North Clover Drive
Boise, Idaho 83703
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den@qivenspu rslev.com
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den@g ivenspu rsley. com
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IDAHO POWER COMPANY'S OPENING BRIEF ON RECONSIDERATION - 32
Tom Beach
Crossborder Energy
2560 9th Street, Suite 213A
Berkeley,CA 94710
Zack Waterman
Director, Idaho Sierra Club
503 West Franklin Street
Boise, ldaho 83702
Michae! Heckler
3606 North Prospect Way
Garden City, ldaho 83714
Snake River Alliance
NW Energy Goalition
John R. Hammond, Jr.
FISHER PUSCH LLP
101 South Capito! Boulevard, Suite 701
P.O. Box 1308
Boise, ldaho 83701
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 84111
Doug Shipley
lntermountain Wind and Solar, LLC
1953 West2425 South
Woods Cross, Utah 84087
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wwi lson @ s nakerivera I I ia nce. oro
[e-mail]
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o
, Executive Assistant
IDAHO POWER COMPANY'S OPENING BRIEF ON RECONSIDERATION .33
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-17-13
IDAHO POWER COMPANY
ATTACHMENT 1
ATTACHMENT 1
Methodology for Limited Export Simulation
ldaho Power Company ("ldaho Power" or "Company") developed a methodology,
described herein, to simulate a residential customer net load profile that assumes the
implementation of an export limiting device on a parallel-connected on-site generation
system. A simulation was necessary because the Company is not aware of any
application of an export limiting device on residential or small general service customer's
parallel-connected on-site generation system within its service area that could be
analyzed.
The simulation methodology encompassed selecting a sampling of residential
customers, creating a photovoltaic ("PV") generation profile, scaling the PV generation
profile per customer, producing the annual net hourly load profile for each sample
customer by subtracting the PV generation from the customer load, and calculating
monthly load factor, load shapes, system-coincident demand and non-coincident demand
for the segment of customers analyzed.
1. Selectinq a Sample of Residential Customers
The 2016 hourly load data from ldaho Power's residential load research sample
was used as the reference load profiles for the simulation.l The ldaho residential sample
is a stratified random sample that was designed using Oracle Utilities' LodeStar sampling
package. A multidimensional stratified sample was utilized, using the Delanius/Hodges
methodology to identify stratum breakpoints, and the Neyman allocation methodology
was used to determine sample size. The sample design target statistics were based on
1 The 2016 load research sample data was previously provided to all parties in response to Vote
Solar's Data Request No. 27.
1
10 percent reliability with 90 percent confidence. The sample consists of four usage strata
combined with six demographic strata resulting in 24 total strata (four usage by six
demographic). The usage stratifying variable was the average 30-day normalized billed
kilowatt-hour ("kWh"). The following usage stratum breakpoints were identified: 0-700
kwh,701-1,250 kwh, 1,251-2,150 kwh, and2,150+ kWh. The demographic stratifying
variable was based on the six weather stations across ldaho Power's service area. They
include the following weather stations: Boise, Ketchum, McCall, Ontario, Pocatello, and
Twin Falls. The simulation was limited to the 272 sample customers from the Boise
weather station.
An additional data set was created from this data set by offsetting the load with an
annual production profile of a PV system appropriately sized for each customer. All
hourly energy exports were replaced with zero.
2. Establishinq a Normalized PV Generation Profile
A normalized PV generation profile was created for a PV system in Boise, ldaho.
ldaho Power chose the National Solar Radiation Data Base, Typical Meteorological Year
3, Boise Air Terminal data set for the PV irradiance data. These data were applied to the
most common system configuration of 5.6kWdc/5kWac, with a due south azimuth and a
25 degree tilt. Each simulation production hour was divided by the maximum annual
production value to obtain a normalized annual PV generation profile.
3. Determininq an Export Limited PV Svstem Size
While the Company has found that a 6k\M system is the most commonly installed
residentialon-site generation size on ldaho Power's system, a customerthat limits energy
2 ldaho Power Company's 2016 Annual Net Metering Status Report at 9
2
exports will likely install a smaller PV system than those who export excess energy. This
is because a customer who can net their annual energy needs to zero through monthly
net metering is incented to size their system to generate enough energy credits in the
higher radiation months to cover the customer's energy requirements that exceed the
self-generation through the remainder of the year. On the other hand, a customer with
an export limiting device will size their PV system to limit most generation in excess of the
customer's hourly energy needs.
To determine the size of the simulated PV systems, the Company first scaled the
normalized annual PVgeneration profile by each sample customer's annual consumption.
Then the PV generation system size was optimized for reduction of grid energy
consumption while minimizing excess energy generation. A distribution of the resulting
PV system sizes is provided in Figure 1.
Figure 1. Distribution of Simulated PV Generation System Sizes
10 15
PV Size (kW)
60
50a
E
#oo
a
Eso
o
-oE20
z
01
5
3
0 20 25
The distribution of PV system sizes illustrates that a majority of simulated PV
systems were between 3 kW and 4 kW.
A scatterplot was used to illustrate the association between the PV system size
and the annual energy consumption for each sample customer. The relationship between
the PV system size and the annual energy consumption for each sample customer is
shown in Figure 2.
Figure 2. Relationship Between Simulated PV System Size and Annual Energy Use
25
20
5
0 0 10,000 20,000 30,000 40,000 50,000 60,000
Annual Energy (kwh)
The scatterplot shows a strong, positive, linear association between the PV system
size and the annual energy use.
4. Creatinq Zero-Export Load Shape for Each Sample Customer
The normalized PV production profile was scaled per sample customer by
multiplying the normalized PV load shape by the size of each sample customer's PV
1
1
F5
o
.N
U)
o-
5
0
4
system. The net hourly load shape was then created by subtracting the sample
customer's PV production from their load. Finally, the zero-export load shape was
created for each sample customer by taking the net hourly load shape and setting all
negative net usage hours to zero.
5. Calculatinq Load Factor and Load Shapes
The monthly load factors and monthly load shapes were calculated for both the
group of reference sample customers and for the simulated group of customers.
The average monthly load factor was generated by calculating the weighted
average of the monthly load factor for each month for both groups.3
The average monthly load shape was generated by calculating the weighted
average of the hourly energy consumption for each hour for both groups.a
6. CalculatinqSvstem-CoincidentandNon-CoincideotDemand
The monthly system-coincident demand and non-coincident demand were
calculated for both the group of reference sample customers and for the group of
simulated customers.
The monthly system-coincident demand was determined by finding the monthly
weighted average of hourly energy consumption at the time of the system peak for both
groups.s
The monthly non-coincident demand was determined by finding the monthly
maximum weighted average of hourly energy consumption for both groups.6
3 ldaho Power Company's Opening Brief on Reconsideration, Figure 1
4 /d., Figures 2, 3, and 4.
s /d., Figure 5.
6 /d., Figure 6.
5
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
GASE NO. !PG-E-17-13
IDAHO POWER COMPANY
ATTACHMENT 2
ATTACHMENT 2
Pilot Customer Load Shapes With No Enerqv Exports
To study the effects of preventing the export of excess energy and to verify the results
of ldaho Power Company's ("ldaho Power" or "Company") Limited Export Simulation of a
residential customer who installs on-site generation and then prevents the export of excess
energy, the Company performed the same load factor, load profile, system-coincident
demand (.SCD") and non-coincident demand ('NCD') analyses on a segment of 18
residential solar customers who participate in a Solar Photovoltaic ("PV") Pilot Program
("Pilot") in ldaho Power's Oregon service area.
The metering requirements for the Pilot are such that the customer must have a
second, Company-owned, meter that measures only the net solar PV generation. The meter
must be placed at a location designated by the Company on the customer load side of the
retail meter and on the alternating current side of the inverter. Due to the required meter
configuration, the Company records separately the amount of excess energy exported to
the grid. This enabled the Company to set the energy exports to zero for these analyses in
order to determine if the results differ for a residential customer who installs on-site
generation and then prevents the export of excess energy, and without the installation of the
on-site generation.
The Company analyzed the data for these 18 residential customers for all 12 months
of 2016. The following results of the Company's supplementary analysis confirms that the
load service requirements and usage characteristics differ for a customer when they do not
have on-site generation as compared to when they do have on-site generation and prevent
the export of excess energy.
Load Service Requirements
Load Factor - Residential Pilot Participants with No Enerov Exports
Using the data from residential Pilot participants, the Company calculated the load
factor for each Pilot participant before and after the installation of on-site generation without
1
the capability to export excess energy. The average monthly load factors of the Pilot
participants before and after the installation of on-site generation without the capability to
export excess energy are shown in Figure 1.
Figure 1. Load Factor - No Energy Exports for Residential Pilot Participants
Load Factor
tllll
40%
35%
30%
25%
20%
t5%
LO%
5%
o%ffilw lw
3
r Without On-Site Generation .. On-Site Generation - No Energy Exports
The Company's load factor analysis of the Pilot participants demonstrates that load
factor is notably lower after the installation of on-site generation -- even without the capability
to export excess energy. This result is consistent with the Limited Export Simulation
performed by the Company.
Pattern of Use
Load Profile - Residential Pilot Participants with No Enerqv Exports
Using data from residential Pilot participants, the Company developed the load profile
for each Pilot participant before and after the installation of on-site generation without the
capability to export excess energy. The average load profile of the Pilot participant for a
winter month, a spring month, and a summer month are shown in Figures 2, 3, and 4,
respectively. For the three graphs, each hour data point is the average for that hour
throughout the month.
L2111098765421
2
r
Figure 2. January Load Shape - No Energy Exports for Residential Pilot Participants
January Load Profiles
5.00
4.00
3.00
2.00
1.00
0.00
3.50
3.00
2.50
2.00
1.50
1.00
0.50
0.00
s.00
4.00
3.00
2.00
1.00
0.00
L23456789 L0 11 t2 L3 L4 15 L6 t7 t8 t9 20 21 22 23 24
-On-Site
Gen with No Energy Exports
-$t3nfl31d
Service
Figure 3. April Load Shape - No Energy Exports for Residential Pilot Participants
April Load Profiles
123456789 10 1L t2 73 14 75 76 L7 18 19 20 2t 22 23 24
On-Site Gen with No Energy Exports
-standard
service
Figure 4. June Load Shape - No Energy Exports for Residential Pilot Participants
June Load Profiles
723456789 LO Lt L2 13 14 15 76 77 18 L9 20 27 22 23 24
-On-Site
Gen with No Energy Exports
3
-gt6nd31d
Service
\_
The Company's load profile analysis of the Pilot participants demonstrates that the
load profile changes significantly after the installation of on-site generation -- even without
the ability to export excess energy. The on-site generation causes a downward ramp after
the sun rises and generation from the utility is replaced by the on-site generation for several
hours. Then, as the sun sets and solar generation ends, a significant upward ramp occurs.
This is vastly different than the load curve of a standard service customer, where the
transition from hour-to-hour is smoother with significantly lower rate of change in usage
during the morning and evening hours. This result is consistent with the Limited Export
Simulation performed by the Company.
Svstem-Coincident Demand - Residential Pilot Participants with No Enerov Exports
The SCD is the average demand for a segment of customers at the time of ldaho
Power's system peak. The analysis of SCD is important for cost allocation purposes
because: (1) production plant costs associated with serving base and intermediate load are
allocated using an average of the 12 monthly SCDs, (2) production plant costs associated
with serving peak load are allocated using an average of the three monthly SCDs occurring
in June, July, and August, and (3) transmission costs are allocated using an average of the
12 monthly SCDs.
Using data from residential Pilot participants, the Company calculated the SCD for
the group of Pilot participants before and after the installation of on-site generation without
the capability to export excess energy. The monthly SCDs for the group of Pilot participants
before and after the installation of on-site generation without the capability to export excess
energy are shown in Figure 5.
4
Figure 5. System-Coincident Demand - No Energy Exports for Residential Pilot Participants
System-Coincident Dema nd
7.00
6.00
s.00
4.00
3.00
2.00
1.00
0.00 rercr l*I rerere
Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec
r Without On-Site Generation " On-Site Generation - No Energy Exports
The Company's SCD analysis demonstrates that the SCD of the group of Pilot
participants is lower for several months after the installation of on-site generation -- even
without the capability to export excess energy. This result is consistent with the Limited
Export Simulation performed by the Company.
The results of this analysis suggest that production plant costs associated with
serving peak load would decrease because these costs are allocated using an average of
the three monthly SCDs occurring in June, July, and August, and transmission costs
increased because they are allocated using an average of 12 monthly SCDs. Consequently,
the resulting different allocation of costs supports the argument that it is appropriate for all
customers who install on-site generation -- even without the capability to export excess
energy -- be included in Schedules 6 and 8.
Non-Coincident Demand - Residential Pilot Participants with No Enerqv Exports
The NCD is the maximum average demand for a segment of customers in any given
hour, regardless of when it happens. Similar to SCD, the analysis of NCD is important for
cost allocation purposes because NCDs are used to allocate ldaho Power's distribution
system costs.
5
TIt
Using data from residential Pilot participants, the Company calculated the NCD for
the group of Pilot participants before and after the installation of on-site generation without
the capability to export excess energy. The monthly NCDs for the group of Pilot participants
before and after the installation of on-site generation without the capability to export excess
energy are shown in Figure 6.
Figure 6. Non-Coincident Demand - No Energy Exports for Residential Pilot Participants
Non-Coincident Demand
10.00
9.00
8.00
7.00
6.00
5.00
4.00
3.00
2.00
1.00
0.00 llIrilr
Jan Feb Mar Apr May
r Without On-Site Generation
lrrllll
Nov DecJun Jul Aug Sep Oct
& On-Site Generation - No Energy Exports
The result of the Company's NCD analysis is consistent with the Limited Export
Simulation performed by the Company and continues to demonstrate that the installation of
on-site generation has very little impact on the NCD of the average residential customer who
installs on-site generation -- even with no energy exports. The customers load over the
course of the month will continue to place the same level of peak demand on the system.
This is an important observation because NCDs are used to allocate distribution
costs. While customers who install on-site generation without the capability to export excess
energy contribute to distribution costs in a similar manner, the collection of these costs
through the volumetric charge for standard service customers will result in cost shifting. To
minimize this, all customers with on-site generation -- even those who have no ability to
export energy - should be included in Schedules 6 and I to appropriately assign and collect
costs and address cost shifting.
6
r
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
GASE NO. IPC-E-17-13
IDAHO POWER COMPANY
ATTAGHMENT 3
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