20180810PacifiCorp Comments.pdf

ROCKY MOUNTAIN
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August 10,2018
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1407 W. North Temple, Suite 330
Salt Lake Ci$, Utah 84116
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Diane Hanian
Commission Secretary
Idaho Public Utilities Commission
472W. Washington
Boise,lD 83702
RE: CASE NO. IPC-E-17-13
IN TIIE MATTER OF THE APPLICATION OF IDAHO POWER COMPAI\IY FOR
AUTHORITY TO ESTABLISH NMW SCIMDTILES FOR RESIDENTIAL AI\[D
SMALL GEI\IERAL SERYICE CUSTOMERS WITH ON.SITE GENERATION
Attention: Diane Hanian
Commission Secretary
Please find enclosed for filing an original and seven (7) copies of Rocky Mountain Power's
comments in the above-referenced matter.
Informal inquiries may be directed to Ted Weston,Idaho Regulatory Manager at [phone]
Very truly yours,
t^^D
Vice President, Regulation
Yvonne Hogle (ISB# 8930)
Rocky Mountain Power
1407 West North Temple, Suite 320
Salt Lake Ciry, Utah 84116
Telephone: [phone]
Fax: [phone]
Email : yvonne.hogle@nacifi corp.com
Attorneyfor Roclry Mountain Power
BEFORE TIIE IDAHO PUBLIC UTILITIES COMN{ISSION
IN TIIE MATTER OF TIIE
APPLICATION OF IDAHO POWER
COMPAI\'Y FOR AUTHORITY TO
ESTABLISH I\[EW SCHEDULES FOR
RESIDENTIAL AIID SMALL
GEI\IERAL SERVICE CUSTOMERS
WITH ON.SITE GENERATION
CASE NO.IPC.E.I7-I3
ROCKY MOUNTAIN POWER'S
COMMENTS IN OPPOSITION OF
VOTE SOLAR'S PETITION FOR
RECONSIDERATION
In accordance with Idaho Code $ 6l-626, Rule 331 of the Idaho Public Utilities
Commission Rules of Procedure, and Order No. 34098 of the Idaho Public Utilities Commission
(the "Commission") in Case No. IPC-E-17-13 (the "Reconsideration Order"), stating "[w]e now
order Vote Solar, Idaho Power, Commission Staff and any otherparty who desires to do so" to file
briefs by August 10, 2018 discussing whether a customer's ability to export energy should
determine if the customer should be included in Schedules 6 and 8, Rocky Mountain Power, a
division of PacifiCorp ("RMP" or "Company") respectfully submits these comments in opposition
to Vote Solar's Petition for Reconsideration of Order No. 34046 in Case No. IPC-E-I7-13 issued
May 9, 2018 ("Petition"). In support of its comments, the Company states as follows.
BACKGROUI\ID
Idaho Power Company ("Idaho Power") applied for authority to create new schedules for
residential and small general service customers with on-site generation ("R&SGS generators").
RMP typically does not intervene in other utilities' cases unless it determines that the case involves
a sufficiently broad issue that could potentially affect the Company; therefore, it did not intervene
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in this case. As expected, the Commission's OrderNo. 34046 approving Idaho Power's schedules
6 and 8 ("Final Order"), which apply to R&SGS generator classes, does not directly impact RMP.
However, Vote Solar's Petition requests that the Commission reconsider its Final Order
contending that the Commission must change the application of its Final Order so that new Idaho
Power schedules 6 and 8 apply only to customers that export electricity. A Commission decision
on Vote Solar's Petition could potentially impact RMP, in particular, a decision on "...the
meaning and repercussions of o'in parallel" connection" about which the Commission specifically
requested additional information. Reconsideration Order, at 3. For this reason and as explained in
detail below, and consistent with the Commission's invitation in its Reconsideration Order for any
pafty desiring to file a brief to do so by August 10, 2018, the Company responds to Vote Solar's
Petition. If the Commission determines that RMP must first intervene to respond to Vote Solar's
Petition, the Company respectfully requests that the Commission treat this filing as RMP's Petition
to Intervene and Comments in Opposition to Vote Solar's Petition for Reconsideration.
Vote Solar argues that the Commission's findings and reasoning do not support inclusion
of non-exporting customer-generators in schedules 6 and 8. Vote Solar's argument fails-the
record supports the finding that all R&SGS generators (i.e., those that operate "in parallel" with
the utility's grid and are therefore able to export) are distinct from those without on-site generation,
for a variety ofreasons.
ARGUMENT
A.An "in parallel" connection facilitates the ability or capability to export, consistent
with Idaho Power's applicable tariff schedules 6 and 8 and RMP's Net Metering
Tariff. Any change to its meaning would require changes to RMP's currently
approved and effective Net Metering Tariff and would be inappropriate; therefore,
the Commission should endorse Idaho Power's and RMP's definition and use of "in
parallel" connection.
RMP's applicable tarifl net metering schedule 135, uses the phrase "in parallel" in the
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application section which describes the type of customer to which the tariff applies:
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 or all of the Customer's own electrical
requirements.
Emphasis added. Electric Service Schedule No. 135, effective July 31, 2016 ('Net Metering
Tariff'). The Net Metering Tariff applies to any customer with on-site generation that is
interconnected and operates in parallel with the Company's grid. Any customer that is
interconnected and operates in parallel to the utility grid is capable of exporting electricity. The
Net Metering Tariff makes no distinction based on whether or not the customer does, in fact,
export. Any decision that naffows the scope of the phrase "operates in parallel" in the currently
effective Net Metering Tariff will impact the Net Metering Tariff, RMP's interconnection
agreements (drafted consistent with the Net Metering Tariff), and ultimately RMP's net metering
customers.
In addition, back-up and other ancillary services the Company provides under the Net
Metering Tariff are made possible because of the R&SGS generating plants' interconnection and
operation in parallel to RMP's grid. All R&SGS generators are receiving these back-up and other
ancillary services. Narrowing the definition of "in parallel" connection to mean only that
connection that is used to "export" electricity under the Net Metering Tariff would probably
require the creation of a separate tariff for R&SGS generators that do not export since they
otherwise receive back-up and other ancillary services. Otherwise, RMP will not be able to capture
the costs to serve these types of customers. Thus, the Company recommends that the Commission
endorse Idaho Power's and RMP's use of "in parallel" connection as a connection that facilitates
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the ability or capability to export.
B. "In-parallel" connection, as used by RMP and Idaho Power, should be the
determining factor on whether R&SGS generators qualify for service under
schedules 6 and 8. All R&SGS generators use services for which they should, but do
not fully, pay as a consequence of generating some of their own electricity with on-
site generation.
While R&SGS generators take less electricity from the utility grid, their overall demand
requirements may remain relatively unchanged. Their usage results in lower load factors which
means more variability in usage which is more costly to serve. In other words, R&SGS generators
do not stop using electicity but instead, they offset a portion of their requirements with on-site
generation, which requires back-up services from the utility for which they are not paying when
they generate their own electricity with on-site generation.
From RMP's perspective, with the exception of large customers, the costs of infrastructure
necessary to support R&SGS generators' access to the grid are included in volumetric rates.
R&SGS generators can offset charges for infrastructure they relied on for their own consumption
through the netting and banking process as well as by reducing their consumption of energy
supplied from the grid. The majority of costs in rates are fixed costs of facilities which do not vary
with changes in customer usage; therefore, these are costs that do not go away, regardless of
consumption levels.
As noted in the Company's 2016 Net Metering report filed October 31,2017, Idaho's
contribution to the system peak was 575 megawatts, after accounting for irrigation load control
curtailment. Net metering customers' on-site generation reduced Idaho's contribution to that peak
by 482 kilowatts, or approximately 0.08 percent. Under the current rate stucture, R&SGS
generators are avoiding a disproportionate amount of fixed costs even if they are not exporting to
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the grid. In the Company's last general rate casel the cost of service study supported a monthly
customer charge to recover fixed costs of $29.86 per month. Currently the monthly customer
charge is $5.00, leaving almost $25.00 per month of fixed costs recovered through volumetric
charges. This creates a significant potential for costs to be shifted from R&SGS generators to non-
participating customers even if they do not export energy.
The current net metering pricing structure for R&SGS generators does not reflect the cost
of serving those customers, nor does it appropriately reflect the benefits and costs of
interconnecting customer owned on-site generation to the system. The existing retail pricing
structure does not accurately reflect the cost to serve customers with on-site generation that
continue to require services from the grid, but that also meet some of their own energy needs with
on-site, customer-owned systems. Therefore, "in parallel" connection, as used by Idaho Power and
RMP in each of their applicable tariffs, should be the determining factor on whether schedules 6
and 8 applies to R&SGS generators.
C. The Commission's linding that all R&SGS generator classes should be included in
schedules 6 and 8 (without distinction on whether they export or not) is supported by
the record.
In finding that all R&SGS generators are distinct from customers without on-site
generation, the Final Order stated, "the evidence as a whole, given the circumstances, supports the
differentiation, substantially, competently and with a just and reasonable result."2 Although the
Commission did not restate the whole record in the Final Order explaining why even those R&SGS
generators with the ability to, but that do not, export electricity are distinct from customers without
on-site generation, it incorporated all of the evidence on the record in support of its decision to
apply schedules 6 and 8 to all R&SGS generators. While the Final Order mentions R&SGS
rCaseNo. PAC-E-10-07
2 Final Order, at l5-16.
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generators that export electricity back to the utility several times and certainly more than those that
are able to and do not export, the Commission also "... recognize[d] the fundamental difference
between, as an example, a residential customer with no on-site generation and one that can both
import energy from, and export it to, the Company's grid using the same infrastructure."3 Emphasis
added. The Commission did not limit its decision to only those customers that export. Rather, it
understood that any R&SGS generator that has the ability to export electricity is distinct and should
be in a separate class from customers without on-site generation. Therefore, it is appropriate for
all R&SGS generator classes to be included in schedules 6 and 8.
D. All R&SGS generator classes use the utility's grid differently from customers without
on-site generation and should therefore qualify for schedules 6 and 8 service.
A variety of reasons support distinguishing all R&SGS generators from those without on-
site generation. Whether or not these customers actually export should determine whether they
qualiff for schedules 6 and 8 service.
For instance, in addition to noting R&SGS generators' "bi-directional [ ] use of the
Company's grid"; the Final Order also described Idaho Power's characterization of these
customers o'... as "partial requirements" customers, in that they generate all or some of their own
annual energy needs, while still relying on the utility for a variety of services." Final Order, at 5
(quoting Tr. at 493). While the Company will not restate the record here, Idaho Power witness Mr.
Angell's testimony explained the types of services provided to all R&SGS generators, even those
that do not export electricity, that distinguishes them from customers without on-site generation.a
In addition, the Commission's decision to include all R&SGS generators in schedules 6
3 Id., at 17.
a See Tr. at 598, ll. 17-600, and l. 15. (for example, Mr. Angell testified that so long as R&SGS generators remain
connected to the utility, they continue to take services from the utility, including capacity to meet the in-rush current
requirements for starting motor loads such as air conditioning compressors, supplemental services when solar is not
available at night, and frequency services to maintain power quality).
6
and 8 classes was also informed by recognition of their load and usage characteristics. For
example, the Final Order referenced Idaho Power's explanation that R&SGS generators have
lower load factors than standard customers, they also have higher evening and nighttime demand,
and their rate of change of usage is higher throughout the day.5 These load and usage factors are
the same for all R&SGS generators, whether or not they export, and support the creation of a
separate class from customers with no on-site generation, and switching them to schedules 6 and
8 service.
E. Export limiting devices are installed behind the meter which requires the utility to
expend time and resources to interconnect, monitor and prevent their reconfiguration
to allow customers to export electricity. Given the complexity involved in monitoring
and tracking metering and billing information to identi$ customers that may be
exporting and should not be, schedules 6 and 8 should apply to all R&SGS generators.
The Company agrees with Idaho Power that export limiting devices ("ELD") do not ensure
that electicity from R&SGS generators' on-site generation equipment is not exported because
they are installed behind-the-meter. The utility does not have direct control of the device.
Consequently, ELDs can be reconfigured to allow the customer to export electricity without
detection from the utility. These ELDs cannot realistically be used to keep R&SGS generators with
ELDs in the same class as those customers without on-site generation. In addition, interconnecting,
monitoring, and fracking these customers and their metering and billing information, would require
additional time and resources from the utility and add a level of complexity necessary to properly
account for utility service.
Even if ELDs could be controlled by the utility, R&SGS generators with ELDs would still
be connected to the utility's grid requiring and relying on backup and other ancillary services that
are not fully paid for as a result of these customers' on-site generation. Therefore, schedules 6 and
7
5 Final Order, at 5
8 should also apply to R&SGS generators with ELDs, like all other R&SGS generators with onsite
generation.
F. Battery storage could be used by customers to avoid "in-parallel" connection to the
utility's grid for ancillary seruices. In such a case, it would be appropriate for R&SGS
generators with battery storage and no "in parallel" connection to utility grid to take
no service from the utility, including from schedules 6 and 8.
The only way to ensure that no electricity is exported back to the utility and that no other
services are provided to R&SGS generators is if there is no in-parallel connection to the utility. If
a customer installs battery storage and completely disconnects from the grid and stops relying on
the utility for backup and other ancillary services, then that customer would not utility service. In
this situation, it would be appropriate for this type of customer to be excluded from schedules 6
and 8 because this type of customer would not be connected to the utility and would not take utility
services. Like Idaho Power, the Company would support excluding this type of customer that has
no in-parallel connection to the utility from service under any schedule, including schedules 6 and
8. To be clear, if the customer connects abattery storage device to the utility's grid, and uses the
utility's grid for backup and other ancillary services, it would be appropriate for this customer to
be included with all R&SGS generators and served on schedule 6 or 8 service.
CONCLUSION
The Company has followed these proceedings and supports ldaho Power's position in the
case. Interconnection and "in parallel" connection gives R&SGS generators the ability to export
energy and allows the utility to provide valuable backup and other ancillary services required by
all R&SGS generators. Therefore, "in parallel connection" should determine if the customer
should be included in schedules 6 and 8.
Dated this lOn day of August, 2018.
8
RESPECTUFLLY SUBMIITED,
ROCKY MOUNTAIN POWER
R.
9
CERTIFICATE OF SERVICE
I hereby certiff that on this 10ft day of August, 2018, I caused to be served, via E-mail a
true and correct copy of Rocky Mountain Power's COMMENTS IN OPPOSITION OF VOTE
SOLAR'S PETITION FORRECONSIDERATION in IPC-E-17-13 to the following:
Service List
IDAHO POWER COMPAI\IY
Lisa D. Nordstrom
Tim Tatum
Connie Ashenbrenner
lnordstrom@,idahopower. com ;
dockets @ idahopower. com
ttatum@.idahoDower. com
caschenbrenner@ idahopower. com
COMMISSION STAFF
Sean Costello [e-mail]. gov
IDAIIYDRO
C. Tom Arkoosh tom. arkoosh@arkoo sh. com
[e-mail]
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC
Eric L. Olsen
AnthonyYankel
[e-mail]
[e-mail]
IDAIIO CONSERVATION LEAGUE
MatthewA. Nykiel mnykiel@idahoconservation. org
AURIC LLC
Elias Bishop
Preston N. Carter
Deborah E. Nelson
el [e-mail]
orestoncarter@ givenspursley.com
den@sivenspurs lev.com
SIERRA CLUB
Kelsey Jae Nunez LLC
Tom Beach
Michael Heckler
Zack Waterman
kel sev@kelseyj aenunez. com
tomb@crossborderener g.v.com
Michael.p.heckler@ gmail.com
[e-mail]
CITY OF BOISE
Abigail R. Germaine aeermaine @cityofbo ise.org
ID CLEAI\ ENERGY ASSOCIATION
Preston N. Carter
Deborah E. Nelson
prestoncarter@ givensoursley.com
den@ givenspursle],. com
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VOTE SOLAR
David Bender
Briana Kober
dbender@earthi ustice. org
[e-mail]
SNAKE RIYER ALLIAI\CE A}tD NW EI\"ERGY COALITION
John R. Hammond, Jr.
Snake River Alliance
NW Energy Coalition
[e-mail]
wwilson@ snakeriveralliance. org
[e-mail]
INTERMOUNTAIN WIND AI\ID SOLAR, LLC
Ryan B. Frazier
Brian W. Burnett
Intermountain Wind and Solar, LLC
[e-mail]
[e-mail]
[e-mail]
Dated this 10ft day of August,2018.
Operations
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