20180824Closing Brief on Reconsideration.pdf

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Lisa D. Nordstrom
An loAcoRP company
1221 W. ldaho St. (83702)
PO. Box 70
Boise, lD 83707
LISA D. NORDSTROM
Lead Counse!
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Enclosures
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August 24,2018
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 Closing Brief on
Reconsideration
Dear Ms. Hanian
Enclosed for filing in the above matter please find an origina! and seven (7) copies
of Idaho Power Company's Closing Brief on Reconsideration.
Very truly yours,
?4-^ur""*t
LISA D. NORDSTROM (lSB No. 5733)
ldaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
lnordstrom@ idahopower. com
!N THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
AUTHORIW TO ESTABLISH NEW
SCHEDULES FOR RESIDENTIAL AND
SMALL GENERAL SERVICE CUSTOMERS
WITH ON.SITE GENERATION
CASE NO. IPC-E-17-13
IDAHO POWER COMPANY'S
CLOS!NG BRIEF ON
RECONSIDERATION
RECEIVED
I$1fi fiUG 2l+ PH tr: l+B
0l'lSS
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UT!LITIES COMMISSION
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The standard rate design in place since net metering's inception in 1983 does not
properly recover the costs to serve customers with on-site generation. The ldaho Public
Utilities Commission ("Commission"), its Staff ("Staff'), and Idaho Power Company
("ldaho Power" or "Company") shared the belief in 2001 that the resulting cost shift was
tolerable up to a 2.9 megawatt ("MW") capacity limit butthat itwould need to be addressed
in the future.l Nearly 2,500 participants2 and 17 years later, this rate design issue remains
1 ln the Matter of the Application of ldaho Power Company for Approval of a New Schedule SLNet
Metering Tariff, Case No. IPC-E-O1-39, Order No. 28951 at 12 (February 13, 2002) ("The Commission
recognizes that in the program we approve today for Schedules 1 and 7 customers, the full cost of the
program may not be born[e] by participants. Raising the cap, we realize, increases the level of
subsidization.")
2 As of July 31 ,2018, ldaho Power has 2,407 active customers with on-site
service under Schedules 1 and 7 with 16.738 MW of generation capacity. An additiona
wilh 2.437 MW of generating capacity were pending completion.
eneration taking
325 applications
IDAHO POWER COMPANY'S CLOSING BRIEF ON RECONSIDERATION - 1
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I
unresolved. Many utilities and regulatory commissions in other jurisdictions have taken
steps to resolve this issue;3 it is time that ldaho does as well.
The tariffs approved by Commission Order No. 340464 appropriately established
an "in parallel connection" as the criteria to include all customers with on-site generation
in Schedules 6 and 8.s This criterion recognizes the mechanical coupling of devices to
the electrical grid that enables all self-generators to take energy and grid services-and
allows the Commission to determine a non-preferential rate design for them.
To more fully respond to the issues raised in the parties' opening briefs, Idaho
Power submits this Closing Brief on Reconsideration ("Closing Brief') pursuant to ldaho
Code S 61-626(2),6 Procedural Rule 332,7 and Commission Order No. 34098.8
Recommendationss to exclude customers who limit self-generation exports from
Schedules 6 and 8 would perpetuate cost shifting from partial service customers who self-
3 Tr. at 737,1.2. -741, l. 13.
4 ln the Matter of the Application of ldaho Power Company for Authority to Establish New Schedu/es
for Residential and Small General Seruice Customerswith On-Site Generation, Case No. IPC-E-17-13,
Order No. 34046 (May 9, 2018).
s ldaho Power Tariff Schedule 6, Sheet No. 6-1.; ldaho Power Tariff Schedule 8, Sheet No. 8-1.
6 When reconsideration is granted, "the matter must be reheard, or written briefs, comments or
interrogatories must be filed, within thirteen (13) weeks after the date for filing petitions for reconsideration."
7 Rule of Procedure 332 states in part, "When the order for reconsideration finds that the grounds
upon which the petition is granted present on issues of law and not of fact or issues of fact not requiring
hearings, the Commission may direct that the grounds be considered on reconsideration by submission of
briefs, memoranda, written interrogatories or written statements and not by further submission of evidence
at hearing." IDAPA 31.01.01.332.
8 ln the Matter of the Application of ldaho Power Company for Authority to Establish New Schedu/es
for Residential and Small General Seruice Customers with On-Site Generation, Case No. IPC-E-17-13,
Order No. 34098 (June 28, 2018).
s Staffs Technical Brief in Response to Commission Order No. 34098, filed August 10, 2018; Vote
Solar's Brief on Reconsideration, filed August 10, 2018; City of Boise City's Brief in Response to Order
Granting Reconsideration, filed August 10, 2018; ldaho Conservation League ("lCL'), the ldaho Chapter of
the Sierra Club ("Sierra Club"), ldaho Chapter ldaho Clean Energy Association ("lCEA"), Northwest Energy
Coalition ("NEC') Reconsideration Brief, filed August 10,2018.
IDAHO POWER COMPANY'S CLOSING BRIEF ON RECONSIDERATION - 2
generate to standard service customers without on-site generation. The three analyses
presented in ldaho Power Company's Opening Brief on Reconsideration ("Opening
Brief')-along with information provided in Rocky Mountain Power's Comments in
Opposition of Vote Solar's Petition for Reconsideration and the ldaho !rrigation Pumpers
Association, lnc.'s Brief in Opposition-demonstrate that customers who limit their
exports with devices, batteries, or other technologies have much more in common with
other partial requirements customers than full requirements customers. Neither Vote
Solar's nor Staffs proposal promotes safety, enforceability, or the proper assignment of
costs for services received.
Consequently, the Commission should deny requests by Vote Solar and others to
carve out non-exporting self-generators from Schedules 6 and 8 for continued preferential
treatment for the reasons described in greater detail below.
t.
PARALLEL CONNECTION IS THE
APPROPRIATE CRITERTA. NOT B!-DIRECTTONALLTY
10 Rocky Mountain Power's Comments in Opposition of Vote Solar's Petition for Reconsideration,
filed August 10, 2018, at 2 (emphasis in original).
IDAHO POWER COMPANY'S CLOSING BRIEF ON RECONSIDERATION - 3
As correctly stated by Rocky Mountain Power, "An 'in parallel' connection
facilitates the ability or capability to export,"1o The only way to ensure that no electricity
is exported back to the utility and that no other services are provided to residential and
small generalservice ("R&SGS") generators is if the customer's generation system is not
connected in parallel to the utility. That is, if the customer's generation system is not
connected in parallel, then it is not connected to the utility and there is no electrical path
for the customer-generated energy to flow onto the utility's distribution system nor is there
an electrical path for ldaho Power to serve the customer's generation system.11
Therefore, the parallel connection of an on-site generation system is the appropriate
criteria to determine whether customers should be included in the new customer classes.
A.@"
In Staff's Technica! Brief in Response to Commission Order No. 34098 ("Staff's
Technical Brief'), Staff recommends that "the Company's definition of 'parallel' be
updated, after a full analysis under the prong of the generic docket related to the non-
export classification, to include the eventuality of a customer preventing the exportation
of energy to the Company's system."l2 The Commission should reject this
recommendation.
First, Staffs suggestion that the Company or the Commission could simply choose
to "update"l3 the definition of "parallel" fails to recognize that the definition of a parallel
connection is based on the physical electrical configuration of the customer generation.
Writing a definition that excludes certain parallel configurations (such as one that does
not export) does not change the physical configuration, but confuses the term "parallel
connection" as it is commonly used in the industry. The exchange of power in any
direction is not part of the definition of parallel nor is it a requirement to run in parallel;
rather, as depicted in Figures 71a and 915 in ldaho Power's Opening Brief, parallel
connection means there is an electrical coupling between a generation system and the
11 Tr. at670, ll. 1-19.
12 Staff s Technical Brief at 3.
13 ld.
1a ldaho Power's Opening Brief on Reconsideration at 19
15 ld. at22.
IDAHO POWER COMPANY'S CLOSING BRIEF ON RECONSIDERATION - 4
grid. A generation system in parallel could be operating in any one of the following modes:
(1) injecting powerto the grid; (2) supplying the customer load; or (3) operating in a stand-
by mode without any exchange of power.
Second, the distinction of a "parallel" connection is also a commonly recognized
term within the Company's tariff as well as other utilities' tariffs. ldaho Power's tariff
Schedule 45, Standby Service, which is available to Schedule 9 and 19 Primary and
Transmission Customers with on-site generation, provides that "parallel operations will
only be authorized by the Company under the terms of a Standby Service Agreement
with the Customer."16 A Schedule 45 arrangement provides for interconnection of a
customer's on-site generation in the third "mode" described above-the utility is operating
in a stand-by mode without any exchange of power. Schedule 72, lnterconnections to
Non-Utility Generation, also uses the term "parallel" to describe the interconnection
between a seller and the Company; this arrangement operates in the first mode described
above-generation injecting power to the grid.17 Further, both Rocky Mountain Powerls
and Avista Corporationle currently use the term "parallel" to define the type of customer
to which their respective net metering tariffs apply. To maintain consistency within ldaho
Power's tariff and between the tariffs of ldaho's utilities, it is most appropriate to continue
16 l.P.U.C. No. 29, Tariff No. 101, Schedule 45, Sheet No. 45-2.
17 l.P.U.C. No. 29, Tariff No. 101, Schedule 72, Sheet No. 72-19.
18 Rocky Mountain Power, l.P.U.C. No. 1, Electric Service Schedule No. 135, Net Metering Service.
("Application: On a first-come, first served basis to any customer that owns and operates an Eligible
Generating Plant that is located on the Customer's premises, on the Customer's side of the Point of
Delivery, is interconnected and operates in parallel with the Company's existing transmission and
distribution facilities and is intended primarily to offset part of all of the Customer's own electrical
requirements.")
1e Avista Utilities, l.P.U.C. No. 28, Tariff Schedule 63, Net Metering Option, Section (1) Customer
Eligibility, "(D) Operates in parallelwith the electric utility's transmission and distribution facilities."
IDAHO POWER COMPANY'S CLOSING BRIEF ON RECONSIDERATION - 5
to use the parallel criteria to determine applicability of the newly established schedules
available for R&SGS customers with on-site generation.
Finally, changing the definition of "parallel" to apply only non-exporting customers
fails to recognize that it is the same "parallel" connection through which essential grid
services and standby service are provided to all non-exporting customers.2o Non-
exporting customers with self-generators who operate in parallel take the same grid
services as other customers with self-generators who export in Schedules 6 and 8.
B. Bi-Directional Flow of Enerqv.
Both Vote Solar and Staff argue that ldaho Power's case to establish separate
customer classes for R&SGS customers with on-site generation was based on the bi-
directional flow of energy. This is an overly selective view of ldaho Power's case.
Vote Solar suggests that Idaho Power's case "relied on customer exports."21 Citing
a 2016 Public Utilities Fortnightly article attached as Exhibit No. 5 to Mr. Tatum's direct
testimony, Vote Solar argues that "The [Company's] 'subsidy' claim relied on industry
literature that looks to the level of credit customers receive on their bill for exported
electricity."22 Further, Vote Solar implied that "defining the'subsidy'as the'credit on [net
metering customers'l billwhen their rooftop panels generate excess power and sell it back
to the utility' . . . purporting to 'quantify[] the subsidy' based on the value of exports
compared to the credit provided."23 This mischaracterizes the Company's position. Mr.
Tatum referenced Exhibit No. 5 of his direct testimony for the proposition that "Others in
20 ldaho Power's Opening Brief on Reconsideration at 20
21 Vote Solar's Brief on Reconsideration at 2-3.
22 ld. at3.
23 ld. al3.
IDAHO POWER COMPANY'S CLOSING BRIEF ON RECONSIDERATION - 6
the industry have concluded that the net metering policy is also regressive in nature."2a
His reference to the article was not an effort to quantify the subsidy. On the contrary, the
Company's testimony about the net metering subsidy, or "cost shift" as Mr. Tatum refers
to it,25 was centered around the current rate structure for R&SGS customers. Mr. Tatum
explained that:
Currently, the Company's R&SGS customers are billed two
types of charges: (1) a flat monthly service charge of $5.00
and (2) per kilowatt-hour ("kwh") energy charges that vary by
season and total monthly consumption. Due to the limited
billing components associated with these rates classes, most
of the Company's revenue requirement is collected through
the volumetric energy rates. This includes costs associated
with all components of the electrical system, from investment
in generation resources to the meters installed on customers'
premises. Consequently, energy rates for R&SGS customers
reflect not only the energy-related components of the revenue
requirement, but fixed costs associated with generation,
transmission, and distribution as well.
For this type of rate design, recovery of fixed costs from an
individual customer declines with any reduction in net energy
usage. This creates a potential inequity between net metering
customers and standard service customers as net metering
customers, who still rely heavily upon the grid to both
purchase power and transfer excess generation, are provided
the opportunity to unduly reduce collection of class revenue
requirement by reducing a portion or even all of their net kWh
usage while other residential customers are left to
compensate for the fixed costs that transfer to them through
this revenue shortfall.26
Like Vote Solar, Commission Staff submits that the rate structure for customers in
Schedules 6 and 8 would be "predicated on a bi-directional relationship with the grid."zt
24Tr. at 190, ll. 17-18.
2s Tr, at 188, l. 23.
26 Tr. at. 189, ll. 1-25.
27 Staffs Technical Brief at 3
IDAHO POWER COMPANY'S CLOSING BRIEF ON RECONSIDERATION - 7
ldaho Power disagrees. The bi-directional flow of energy is only one consideration among
many when implementing the proper rate structure for customers with on-site generation.
Utility rates and rate design are established by (1) determining what costs are
appropriately allocated to each segment of customers and (2) deciding the most effective
and fair way to collect those costs from each segment of customers. Cost allocation is
determined by examining when, what, and how much each customer class uses of the
utility's services. A rate design is then established by determining how to best collect
those costs from each segment of customers depending on how they use energy.
Based only on the energy that the self-generators consumed from the utility, ldaho
Power provided evidence in its Opening Brief that the load service requirements and the
usage characteristics of R&SGS customers who install on-site generation justify a
separate and unique rate structure.2s The evidence of reduced load factor and different
load service requirements for these partial requirements customers remains
unchanged-regardless if the customer prevents the export of excess energy. The
average usage characteristics of customers with on-site generation are not based on
volumes of energy but rather on capacity, as evidenced by the Company's load factor
analysis.2s
il.
The evidence presented in the Company's case-in-chief was developed using the
interval data for all ldaho residential customers with on-site generation. This data
28 ldaho Power's Opening Brief on Reconsideration at 3-1 1, Attachments 2 and 3
2e /d. at 6.
IDAHO POWER COMPANY'S CLOSING BRIEF ON RECONSIDERATION - 8
SUFFICIENT EVIDENCE EXISTS TO INCLUDE ALL R&SGS
ON.SITE GENERATION IN SCHEDULES 6 AND 8
included customers who did not generate excess energy for extended periods of time. In
response to Commission Order No. 34098's request for information, ldaho Power's
Opening Brief presented additional evidence that demonstrates customers with on-site
generation, who either prevent the export of excess energy via an export limiting device
or battery storage, would be expected to have load service requirements more similar to
those with on-site generation who export energy to the grid than those of standard service
customers without on-site generation.
A. Non-Exportinq Customers were lncluded in ldaho Power's Gase-in-Chief.
In its Petition for Reconsideration, Vote Solar argues that "All of the Company's
evidence related to different load shapes--or time, nature, and pattern of use-was
limited to net metering customers" and excluded evidence of customers who self-
generate but do not export any electricity to the Company's distribution system.30 ldaho
Power disagrees; customers with significant non-exporting periods were indeed included
in the Company's evidence.
The evidence presented in the Company's case-in-chieFl was developed using
the interval data for all ldaho residential customers with on-site generation-including
customers who did not export excess energy for extended periods of time, !n any given
month, there are residential customers who do not export excess energy. Staff witness
Donohue alluded to this fact in her direct testimony stating, "most of the energy produced
[by net metering customers] is consumed on-site rather than pushed back onto the grid.'sz
30 Vote Solar's Petition for Reconsideration at 2.
31 Tr. at. 598, l. 6 - Tr., p. 618, l. 2.
32 Tr. at 1482,11.7-9.
IDAHO POWER COMPANY'S CLOSING BRIEF ON RECONSIDERATION - 9
ldaho Power quantified the amount of excess energy that flowed onto the grid and
showed that, in January and December, "the average residential customer with on-site
generation consumes most of their generation and has very little excess
generation .'33 Table 2 of Mr. Angell's rebuttal testimony quantified the average
monthly excess generation per residentia! customer.3a Hence, in its case-in-chief, ldaho
Power did include customers with no energy exports and demonstrated R&SGS
customers who install on-site generation are different than R&SGS standard service
customers.
B. Vote Solar's Visualization of the Removal of Exports is Not a Proxv.
!n its Brief on Reconsideration, Vote Solar suggests Dr. Faruqui provided a
"theoretical proxy" for evidence during Mr. Bender's cross-examination that compares the
loads of bi-directional customer-generators when their exports are removed from their
load shapes.3s This is misleading because no data was presented by Dr. Faruqui during
cross-examination regarding the removal of export flows.
It is a reach for Vote Solar to conclude that Dr. Faruqui's response to a series of
questions about the impacts of removing energy exports represents a proxy for actual
evidence comparing bi-directional customer-generators' load shapes with and without
their respective exports. During Mr. Bender's cross-examination of Dr. Faruqui, Dr.
Faruqui used phrases such as "by and large, you would expect that to be the case" 36 and
"it may not be exactly the same"37 when describing his envisioning of the theoretical
33 Tr. at 634, ll. 17-20.
Y Tr. at 635, l. 1.
35 Vote Solar's Brief on Reconsideration at 4.
36 Tr. at 770,11. 15-16.
37 Tr. at 771,1.6.
IDAHO POWER COMPANY'S CLOSING BRIEF ON RECONSIDERATION - 1O
removal of exports from the load shapes. Vote Solar goes as far as suggesting that "data"
was presented and inaccurately concludes, "Therefore, even to the extent the
Commission were to look to evidence of bi-directional customer-generators after their
export flows have been stripped from load data, those data actually show no
distinguishing load and usage characteristics that could justify a new class to include non-
exporting customers."38 Vote Solar's visualization of the remova! of energy exports does
not constitute "data" and does not provide a proxy for evidence as to the load and usage
characteristics of non-exporting customers.
C. The Evidence Provided on Reconsideration Continues to Show that On-Site
Generators Have Different Load Service Requirements Reqardless of
Exports.
ln response to Commission Order No. 34098's direction to file "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,"3e ldaho Power provided evidence that demonstrates
customers with on-site generation, who either prevent the export of excess energy via an
export Iimiting device or battery storage, continue to have different load service
requirements than standard service customers.a0
ldaho Power conducted three separate analyses to study the effects of preventing
the export of excess energy. The three separate analyses consisted of two simulations,
the Limited Export Simulational and The Effect of Storage on Customer Load Shapes
38 Vote Solar's Brief on Reconsideration at 4
3s Order No. 34098 at 2.
a0ldaho Power's Opening Brief on Reconsideration at 3-17.
41 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. The
methodology used by the Company to create the Limited Export Simulation is described in Attachment 1 to
ldaho Power's Opening Brief on Reconsideration.
IDAHO POWER COMPANY'S CLOSING BRIEF ON RECONSIDERATION - 11
when Coupled with Distributed Generationa2 Simulation, and one analysis using actual
data - Pilot Customer Load Shapes with No Energy Exports.a3 Table 1 summarizes the
additional analyses performed by the Company.
Table 1. Results of c the Effects of Limitin Self-Generator
The results of the three additional analyses demonstrate that the load service
requirements and the usage characteristics of R&SGS customers who install on-site
generation are distinctly different for a residential customer before and after the
installation of on-site generation-even without the capability to export excess energy.
42 The Brattle Group performed a simulation of the net load shapes of customers who install battery
storage as a means 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," dated August 9,
2018, can be found in Attachment 3 to ldaho Power's Opening Brief on Reconsideration.
a3 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.
The Company's resulting analysis, "Pilot Customer Load Shapes With No Energy Exports," can be found
in Attachment 2 to ldaho Power's Opening Brief on Reconsideration.
44 ldaho Power's Opening Brief on Reconsideration at 5-6
a5 /d at 6-8
ao /d., Figure 5.
a7 /d, Figure 6.
Load Service
Requirements
The load factors of partial requirements customers are lower than those
of full-requirements customers-even without the capability to export
excess energy. The usage characteristics are not based on volumes of
energy but rather on capacity.4
Load Profile The load profile changes significantly after the installation of on-site
generation-even without the ability to export excess energy. The rate of
change in usage is larger than customers without on-site generation.4s
System-Coincident
Demand
The system-coincident demand is lower in nine out of 12 months after
the installation of on-site generation-even without the capability to
export excess energy. 4o
Non-Coincident
Demand
A customer's monthly peak is not necessarily reduced by the installation
of on-site generation-even without the capability to export excess
energy.47
IDAHO POWER COMPANY'S CLOSING BRIEF ON RECONSIDERATION - 12
Partial requirements customers who limit their ability to export excess generation have
more in common with partial requirements customers who export than standard
customers without on-site generation. These differences justify including all customers
with parallel-connected on-site generation-regardless of energy exports-in Schedules
6 and 8. This will provide the Company, other interested stakeholders, and the
Commission an opportunity to evaluate options for a rate structure that wil! allow a
reasonable opportunity to appropriately assign and collect costs without cost shifting to
standard service, ful! requirements customers.
ilt.
STAFF'S PROPOSAL WILL NOT SOLVE THE
PROBLEM WITH THE CURRENT RATE STRUCTURE
Staff argues that, "if a customer is incapable of exporting she should be able to
remain in Schedules 1 and 7 for purposes of scheduling and rates" and that "a voluntary,
applied-for,'non-export' categorization be incorporated into Schedules 1 and 7 ."48
A. Staffs ProposalWill Perpetuate Cost Shift.
Staffs proposal will not solve the rate design issue in this case. Staffs proposal
to create a voluntary, non-export category within standard service Schedules 1 and 7 will
only continue the opportunity to shift costs from those customers who choose to install
on-site generation to reduce the volume of energy they consume from the grid to
customers in those classes who cannot afford to or choose not to install on-site
generation.
An export limiting device only limits energy sent to the utility; these devices do not
limit the customer's ability to receive energy or other grid services. Consequently,
48 Staffs Technical Brief at 2
IDAHO POWER COMPANY'S CLOSING BRIEF ON RECONSIDERATION - 13
customers who self-generate in parallel but limit the export of energy to the utility take the
same services as other customers who self-generate in Schedules 6 and 8 who do export.
ln its Opening Brief, ldaho Power provided evidence that demonstrates how the
load service requirements and usage characteristics differfor a customer before and after
the installation of on-site generation without the capability to export excess energy. 4e The
Company found that "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." 50
!n Order No. 34046, the Commission expressed its desire "for the Company to
address fixed-cost apportionment across its system."51 ln response to Staffs initial
proposal to alleviate the cost shifting by changing the compensation for excess energy
exported to the grid,s2 the Commission stated, "We appreciate Staffs attempt to quantify
potential cost shifting and then alleviate it But we disagree this solution
completely fixes the rate design issue."53 Staffs proposal to create a non-export
categorization in Schedules 1 and 7 has the same inherent flaw as its initial proposal-it
fails to completely fix the rate design issue. The Commission rejected Staff's initial
proposal and should reject Staffs latest proposal for the same reason.
as ldaho Power's Opening Brief on Reconsideration at 4.
50 ld.
s1 Order No. 34046 at 17.
52 Tr. at 1489, l. 23 - p. 1492, l. 7.;Tr. at 1450, ll. 8-21.
53 Order No. 34046 at 17.
IDAHO POWER COMPANY'S CLOSING BRIEF ON RECONSIDERATION - 14
B. Export Limitinq Devices.
!n its Answer to Vote Solar's Petition for Reconsideration, ldaho Power expressed
concern that "lt is not adequate to depend on a customer configurable device, such as a
dynamically controlled inverter, a grid tie limiter, or a grid inverter with export control,
because the device could be reconfigured at any time to allow the customer to export
energy.sa Staffs and Vote Solar's arguments overlook or unduly minimize the
administrative challenges of allowing a select non-exporting group of self-generators to
remain in Schedules 1 and 7.
As an initial matter, the Company does not agree with Staffs characterization of
how export limiting devices are configured and operate.ss To avoid the outcome where
customers utilizing export limiting devices could reconfigure them at any time to allow
customer export, Staff suggested that "any limiting device be certified, either by the
manufacturer, or, in the future, using generally recognized standards, or something akin
to the UL 1741 Non-Export Certification Requirement Document ('CRD') depending on
applicability and availability."56 This is not a solution to prevent a customer from
s4 ldaho Power's Answer to Vote Solar's Petition for Reconsideration at 4.
s5 On page 4 of Staffs Technical Brief, Staff claimed that "Because electrical current flows from
higher voltage to lower voltage, most grid limiting or non-export devices work by regulating voltage on a
customer's side of the limiter. ln normal operation, the customer's voltage is slightly less than the
Company's, leaving a small amount of electricity flowing from the Company to the customer, even when
the customer's generating system is operating, but it is occasionally possible for a very small quantity of
energy to flow back to the grid. The quantity that may flow back is negligible."
ldaho Power disagrees with Staffs description of electrical current flow and how an export limiting
device works. The direction of real power (Watts) current flow is due to a difference in the alternating
current ("AC') voltage phase relationship between the inverter and utility supplied voltage at the customer
location. The direction of the reactive power (VARs) current flow is caused by a difference in voltage
magnitude between the two. The most common method to limit power export is to controlthe photovoltaic
('PV') inverter power output. A customer would need to install a device that monitors the direction of the
power flow at the utility customer meter (point of interconnection/common coupling). Once this monitor
detects power flowing to the grid, the export limiter would cause the PV inverter to reduce the power
converted from the PV panels to AC, thus reducing the invert voltage phase and cease the power flowing
to the grid.
56 Staffs Technical Brief at 4
IDAHO POWER COMPANY'S CLOSING BRIEF ON RECONSIDERATION - 15
reconfiguring their device to allow exports. A certification only means that the customer
owned and operated device is capable of certain functionality. lf an inverter is certified to
perform a function such as export limiting, the certification means the inverter is capable
of export limiting. A certification does not guarantee that the device has been properly
configured or that it is locked at that configuration. Likewise, a certification does not
prevent the customer from changing the settings at will.
Vote Solar argues that a requirement to use export limiting devices may not be
needed if "Customer-generators opting out of Schedules 6 and 8 will not receive credit
for any exports-meaning that any electricity incidentally delivered to the grid provides no
value to the customer-generator and constitutes a financial loss to the customer and a
benefit to lPC."s7 Vote Solar goes on to claim "That financial disincentive will ensure any
actual exports from customers opting out of Schedules 6 and 8 are minimal."s8 ldaho
Power disagrees. A financial incentive will exist for those customers with on-site
generation who could benefit from continued access to the cross-subsidy that exists in
volumetric standard service rates.
C. Actual and Virtual Batterv Storaqe.
ldaho Power disagrees with Staffs belief that "customers who choose to generate
and store energy on-site are less likely to want to use to the Company's grid as a battery,
and, therefore, would likely attempt to limit export.'se lf customers' on-site generation
57 Vote Solar's Brief on Reconsideration at 7
58 ld.
5e Staff's Technical Brief at 5.
IDAHO POWER COMPANY'S CLOSING BRIEF ON RECONSIDERATION - 16
systems are connected in parallelto the grid, they will likely choose to use the Company's
grid as a virtual battery unless physically6o or legally prohibited from doing so.
To better understand to what degree a customer who installs their own battery
would use the grid as a battery, The Brattle Group further analyzed the effects of battery
storage specifically to understand if or when a self-generator with a battery would use the
grid as a battery. The Brattle Group's resulting analysis, "The Effect of Storage on
Customer Load Shapes when Coupled with Distributed Generation SUPPLEMENTAL
ANALYSIS" can be found in Attachment 1 to this Closing Brief.
For its analysis, The Brattle Group assumed the individual battery capacity of each
net metering customer to be large enough to store all net exports on any individual day
of the year.61 The supplemental analysis finds that low load during nighttime hours
prevents the customer's battery from fully discharging overnight. This eventually leads to
conditions where the battery is fully charged with no remaining capacity; consequently,
the excess energy would either be exported to the grid or the customer would use an
export limiting device to curtail their on-site generation.62
Figure 1 below illustrates the net load of an individual residential customer with on-
site generation with and without battery storage during a week in June 2016. The top
portion of Figure 1 illustrates the net load shapes for an individual residential self-
generating customer with and without battery storage and the bottom portion of Figure 1
illustrates the customer's battery state of charge over time. The light blue line represents
60 "Physically" refers to an electrical separation from the grid that is administratively enforceable
and not within the customer's ability to change.
et The Brattle Group, The Effect of Storage on Customer Load Shapes when Coupled with
Distributed Generation SUPPLEMENTAL ANALYS/S at 3 (August 21,2018).
62 ld.
IDAHO POWER COMPANY'S CLOSING BRIEF ON RECONSIDERATION - 17
the net load for the residential customer with on-site generation absent battery storage
and the red line represents the net load for the residential customer with on-site
generation with battery storage. The yellow area depicts the instances where the
customer would either export excess energy to the grid or otherwise curtail their on-site
generation system. Please note that (1) when the battery state of charge is depleted, this
coincides with the time when the customer consumes energy from the utility and (2) as
the customer's consumption from the utility goes to zero, the battery state of charge
increases. Over the course of the week, the battery state of charge increases until
eventually the battery is fully charged. One can see that with battery storage (the red
line) the customer continues to consume energy from the utility at times and exports
excess energy to the grid at other times-that is, the customer uses the grid as a virtual
battery.
Figure 1. lndividual Customer Net Load and Battery State of Gharge
8
6
4
2
o
-2
-4
-6
-8
DG + storage
=J
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Battery state
of charge
Thu,6/23/2ot6
l
IDAHO POWER COMPANY'S CLOSING BRIEF ON RECONSIDERATION - 18
Solar export or
curtailment
d1V
l,
tl
)nly
To maximize the output of their generation systems and their investments,
customers will choose to generate more energy than their batteries can hold and "store"
energy on the grid as a virtual battery. ln other words, sawy customers will continue to
depend on the utility for energy when their systems are not generating or when their
batteries are depleted and they will export excess energy to the grid in exchange for
credits against future consumption when their batteries are fu!!y charged.
Staff concludes that "a non-export option may have the effect of incenting battery
storage."63 Artificially limiting customer exports would be counter to the purpose of net
metering when no reliability issues prevent the grid's acceptance of excess energy
exports. Second, even with a lot of storage capacity (e.9., sized to store maximum net
energy exports on any given day of the year as in The Brattle Group's analysis),
customers have a financial incentive to export generation in excess of storage rather than
curtailing their on-site generation. That is unless, of course, there is a greater financial
incentive for those self-generators who could benefit from continued access to the cross-
subsidy that exists in volumetric standard service rates.
D. Safetv of lnterconnections.
ldaho Power shares Staff's concern that, "depending on rate structures, that
certain customers may install panels clandestinely to avoid being moved to and from
Schedules 6 and 8."il The current inclusion of a!! R&SGS customers with on-site
generation, regardless of energy exports, in Schedules 6 and 8 will address this concern.
However, ldaho Power is concerned that Staff's proposed creation of a
subcategory of non-exporting generating customers within Schedules 1 and 7 would
63 Staffs Technical Brief at 5.
il /d. at 6.
IDAHO POWER COMPANY'S CLOSING BRIEF ON RECONSIDERATION - 19
impair safe interconnection.65 When a customer installs electric generating equipment
that has the capability to energize ldaho Power's distribution lines (this includes export
limiting devices within the customer's control), it is imperative that ldaho Power know
about the installation and have the ability to protect its employees and system from injury
or damage. ldaho Power will continue to insist that customer-owned disconnection and
protection equipment be well designed and constructed with quality materials. Without
notice of the installation and an opportunity to review it, ldaho Power's qualified personnel
cannot verify that this equipment exists.
tv.
HAWAIIAN ELECTRIC'S RELIABILITY SOLUTION
WILL NOT SOLVE IDAHO'S RATE DESIGN PROBLEM
In their Reconsideration Brief, !CL, Sierra Club, ICEA, and NEC state that
"Hawaiian Electric has adopted a net metering policy that allows customers to elect a non-
export option.'66 Hawaiian Electric Company does indeed allow its customers to elect a
non-export option.67 However, Hawaiian Electric implemented this policy to solve a
reliability issue, not a rate design issue. On October 12,2015, the Hawaii Public Utilities
65 As the Commission noted in a previous case, "The Commission has a statutory responsibility to
ensure safety for the public and employees of the Company. We believe that reasonable safeguards such
as the one at question [interconnections be certified by a licensed electrician] are necessary to maintaining
the integrity of ldaho Power's system." ln the Matter of the Application of ldaho Power Company for an
Order Revr.srng the Rates, Terms and Conditions under which ldaho Power Purchases Non-Firm Energy
from Qualifying Facilities, Case No. IPC-E-95-15, Order No. 26850 at 5 (March 27, 1997).
66 lCL, Sierra Club, ICEA, and NEC's Reconsideration Brief at 2.
67 Hawaiian Electric Company Tariff, Rule No. 22, Customer Self-Supply; Section D
(lnterconnection Process) governs the interconnection process and requirements for "Eligible Customer-
Generator requests to interconnect and operate a Generating Facility in parallelwith the Company's electric
system . . . ." See also Hawaiian Electric Company Tariff, Rule No. 14, Service Connections and Facilities
on Customer's Premises.
IDAHO POWER COMPANY'S CLOSING BRIEF ON RECONSIDERATION - 20
Commission closed Hawaiian Electric's Net Energy Metering program6s and approved
new rooftop PV programs to allow customers the ability to install rooftop PV and not
further degrade service reliability.6s At that time, roughly 12 percent of Hawaii's homes
had rooftop solar systems.To ln other words, Hawaiian Electric offered net metering for
all customers until the distribution circuits reached a maximum penetration of distributed
generation based on distribution circuit voltage deviation beyond the allowedTl +l-
5 percent. A non-export option was created to allow additional customers with on-site
generation to interconnect and maintain distribution circuit voltage within the
+/- 5 percent.
An important bit of information that lCL, Sierra Club, ICEA, and NEC did not include
about Hawaiian Electric's non-export option for customers with on-site generation is that
the new rooftop PV program developed for non-exporting solar PV installations, the
Customer Self-Supply program, includes a minimum billing requirement.T2 The minimum
billing requirement allowed Hawaiian Electric to address a rate design deficiency for non-
export partial requirements customers. While closing the net metering program solved
the reliability issue, it was necessary to implement the minimum billing charge to address
the existing rate design issue.
68 Hawaiian Electric Company Tariff, Rule No. 18, Net Energy Metering (fully subscribed and closed
as of October 12,2015). One of the criteria to be considered an "Eligible Customer-Generator" is owning
or operating a generating facility "operated in parallel with the Company's transmission and distribution
facilities...."
6e ln the Matter of Public Utilities Commission lnstituting a Proceeding to lnvestigate Distributed
Energy Resource Policies, Public Utilities Commission of the State of Hawaii Docket No. 2014-0192, Order
No. 33258 (October 12, 2015).
70 New York Times, So/ar Power Battle Puts Hawaii at Forefront of Woldwide Changes, April 18,
2015 (citing data from the Energy lnformation Administration).
71 Hawaiian Electric Company Tariff, Rule No. 2, Character of Service, Revised Sheet No. 7.
72 Hawaiian Electric Company Tariff, Rule No. 22, Customer Self-Supply, Sheet No. 43A.
IDAHO POWER COMPANY'S CLOSING BRIEF ON RECONSIDERATION - 21
ldaho Power disagrees with lCL, Sierra Club, ICEA, and NEC's recommendation
to apply Hawaiian Electric's solution to ldaho Power customers. ldaho Power does not
currently have, nor did it present, a distribution circuit problem. To apply a Hawaiian
solution to ldaho Power's system is not a necessary or appropriate outcome; separate
classes with separate rate structures for all R&SGS customers with on-site generation is
the right solution for ldaho Power and its non-generating R&SGS customers.
V.
IDAHO POWER INSTALLS METERING INFRASTRUCTURE REQUIRED TO BILL
RATE SGHEDULES IN THE MOST ECONOMICAL MANNER FOR CUSTOMERS
A. Net Consumpti .
ldaho Power's net metering option was first offered in 1983 as part of Schedule
86, which governed non-firm energy purchases from Qualified Facilities.T3 The
Commission has been aware that the potential existed to shift costs to non-participants,
and approved a program that kept billing and metering costs low. !n 1997, the
Commission found that "a reasonable net metering option is one that . (a) allows the
Company to use its existing billing system, (b) allows the customer to use a conventional
single meter metering system . .D74 The Commission also agreed with Staffs
recommendation to more clearly revise the net metering option to more clearly exempt
participants from installing a second meter. ln the Commission's words, "To do otherwise
would defeat the very purpose of a net metering option."7s
73 ln the Matter of the Application of ldaho Power Company for Approval of Revised Rafes fo be
Paid for Power and Energy Sold to ldaho Power Pursuant to Section 210 of The Public Utility Regulatory
Policies Act of 1978, Case No. U-1006-200, Order No. 18358 (October 20, 1983).
74 ln the Matter of the Application of ldaho Power Company for an Order Revising the Rafes, Terms
and Conditions UnderWhich ldaho Power Purchases Non-Firm Energyfrom Qualifying Facilities, Case No.
IPC-E-95-15, Order No. 26750 at 9 (January 22,1997).
75 ld. at 10
IDAHO POWER COMPANY'S CLOSING BRIEF ON RECONSIDERATION.22
When the Company became concerned in 2006 that the requirement to have a
second meter separate from the retail load metering to measure customer generation
created a financial barrier to commercial, industrial, and irrigation ("Cl&!") customers
installing a small net metering systems, it proposed to a!!ow Cl&l customers to participate
in net metering on the same basis as the Company's R&SGS customers if their generation
facilities had a total nameplate capacity rating of less than 2 percent of their Basic Load
Capacity and the system was 25 kilowatts or smaller.T6 ln Order No. 30227, the
Commission again authorized a single meter option to Cl&l qualifying net metering
systems and concluded, "Financial impediments . are reduced in the Company's
proposal to extend the one-meter option to qualifying net metering systems. We
commend the Company for making its program more attordable."TT
ln short, ldaho Power installs metering infrastructure required to bill rate schedules
in the most economical manner for customers. This is in accordance with Rule D of ldaho
Power's tariff: "The Company will install and maintain the metering equipment required
by the Company to measure power and energy supplied to the Customer."78
B. Gtanularitv of lnterval Data.
lCL, Sierra Club, ICEA, and NEC suggest that "the utility elects to use a certain
level of granularity in the metering system for recording customer consumption." lCL,
Sierra Club, ICEA, and NEC argue that "lf the utility elects to use a more granular time,
76 ln the Matter of the Application of ldaho Power Company for Revision of Schedule SFNet
Metering, Case No. IPC-E-06-17, Order No. 30227 at 5-6 (January 25,2007).
77 ld. at8.
781.P.U.C. No.29, Tariff No. 101, Rule D, Metering.
IDAHO POWER COMPANY'S CLOSING BRIEF ON RECONSIDERATION - 23
like 15 minutes, then the customer is not'masking' usage any more or less; the utility is
just measuring consumption better."Te
ldaho Power agrees that measuring consumption in smaller increments is a better
measurement of consumption; however, when Idaho Power explained that "recording net
consumption would not provide the granularity necessary"8o it was not referring to the
Iength of the interval but rather to the fact that the Company uses a single meter to
measure the net consumption. Because ldaho Power currently measures net
consumption, it does not capture energy exports separate from energy consumption.
Decreasing the measurement increment, as suggested by lCL, Sierra Club, ICEA,
and NEC will not address the potential cost shifting and rate design issues at hand.
Moreover, any additional infrastructure costs would increase the cost shift from customers
with on-site generation if allowed to remain in Schedules 1 and 7. To implement the
recommendation by lCL, Sierra Club, ICEA, and NEC for "Schedules 6 and 8 to exclude
a customer who elects to be a non-exporting customer"sl would continue cost shifting
from customers with on-site generation who choose to prevent energy exports to
customers without on-site generation.
C. lntra-Hour Maskinq.
lntra-hour exports are not always detectable with ldaho Power's current single net
consumption meter configuration-and is not necessary to detect exports to solve the
rate design problem at issue in this case.
7s lCL, Sierra Club, ICEA, and NEC's Reconsideration Brief at 3.
80 ldaho Power's Answer to Vote Solar's Petition for Reconsideration at 4-6.
81 lCL, Sierra Club, ICEA, and NEC's Reconsideration Brief at 4.
IDAHO POWER COMPANY'S CLOSING BRIEF ON RECONSIDERATION - 24
lCL, Sierra Club, ICEA, and NEC mistakenly assert that "even if a customer did
[evade export limits], ldaho Power's metering system would alert the company instantly."ez
This statement is incorrect. As currently configured, Idaho Power's meters will not
instantly alert the Company because when consumption and production are equal, and
also in every hour when the amount of energy consumed from the utility is greater than
the amount of excess energy they exported to the grid, the power flow in the opposite
direction would be undetectable.
The Company utilizes the appropriate metering to gather the necessary billing
components according to each rate schedule. lf future rate design requires additional
meter data, ldaho Power would consider implementing additional metering infrastructure
necessary to capture the required data. However, any costs incurred to implement
additional metering requirements for any given customer class should be assigned
directly to that customer class.
vt.
CONCLUSION
Vote Solar's Petition for Reconsideration to carve out non-exporting, self-
generators would perpetuate the cost shift caused when a rate structure designed for full
requirements customers is applied to self-generating customers that require only partial
services. Staffs proposal would not solve this rate design problem; however, it would
unnecessarily limit customer self-generation when no reliability issues exist, introduce an
opportunity to game the differential between rate schedules, and perpetuate the cost shift
from R&SGS costs with on-site generation to standard service customers. Neither Vote
82lCL, Sierra Club, ICEA, and NEC's Reconsideration Brief at2-3.
IDAHO POWER COMPANY'S CLOSING BRIEF ON RECONSIDERATION - 25
Solar's nor Staffs proposal promotes safety, enforceability, or the proper assignment of
costs for services received and should be denied.
As demonstrated by the three analyses presented in ldaho Power's Opening Brief,
self-generating customers who limit their exports have much more in common with other
partial requirements customers than full requirements customers. The tariffs approved
by Commission Order No. 34046 appropriately established an "in parallel connection" as
the criteria to include all customers with on-site generation in Schedules 6 and 8. As
generation technology evolves, this criterion will support non-preferential rate design and
interconnection of on-grid devices and batteries employed by customers with on-site
generation.
Respectfully submitted this 24th day of August 2018.
/Ao*
LISA NORDST
Attorney for ldaho Power Company
IDAHO POWER COMPANY'S CLOSING BRIEF ON RECONSIDERATION - 26
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 24th day of August 2018 I served a true and correct
copy of IDAHO POWER COMPANY'S CLOSING 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
47 2 \N est Wash i ngton (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
ldahydro
C. Tom Arkoosh
ARKOOSH LAW OFFICES
802 West Bannock Street, Suite 900
P.O. Box 2900
Boise, ldaho 83701
ldaho Conseryation League
Matthew A. Nykiel
Idaho Conservation League
102 South Euclid #207
P.O. Box 2308
Sandpoint, ldaho 83864
Benjamin J. Otto
ldaho Conservation League
710 North 6th Street
Boise, ldaho 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
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_FAXxEmail sean.costello@puc. idaho.qov
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_U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
eri n. ceci l@arkoosh. com
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_FAXX Emai! [e-mail]
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FAX
X Email botto@idahoconservation.o rq
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_FAXX Email [e-mail]
Anthony Yankel
12700 Lake Avenue, Unit 2505
Lakewood, Ohio 44107
_Hand Delivered
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_FAXX Email [e-mail]
IDAHO POWER COMPANY'S CLOSING BRIEF ON RECONSIDERATION - 27
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 84119
Vote Solar
David Bender
Earthjustice
3916 Nakoma Road
Madison, Wisconsin 537 1 1
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 Glean 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, ldaho 83703
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den@givenspu rsley.com
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den@q ivenspu rsley. com
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IDAHO POWER COMPANY'S CLOSING BRIEF ON RECONSIDERATION - 28
_Hand Delivered
_U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
Tom Beach
Crossborder Energy
2560 9th Street, Suite 213A
Berkeley, California 947 10
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 Coalition
John R. Hammond, Jr.
FISHER PUSCH LLP
101 South Capitol 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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FAX
x Email michael. p. [e-mail]
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wwi lson@s na kerivera I I ia nce. org
[e-mail]
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C Bearry, LegalAssistant
IDAHO POWER COMPANY'S CLOSING BRIEF ON RECONSIDERATION - 29
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[e-mail]
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
GASE NO. IPC-E-17-13
IDAHO POWER COMPANY
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