20171222Donohue Direct.pdf

BEFORE THE
IDAHO PUBLIC UTILITIES C
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
AUTHORITY TO ESTABLISH NEW
SCHEDULES FOR RESIDENTIAL AND
SMALL GENERAL SERVICE
CUSTOMERS WITH ON.SITE
GENERATION
RilCEIVED
?01? il[l 22 PH 2: 33
oMMrssroN :ll-iC,il,iissl0N
CASE NO. !PC-E-17-13
DIRECT TESTIMONY OF STACEY DONOHUE
IDAHO PUBLIC UTILITIES COMMISSION
DEGEMBER 22, 2017
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O. Please state your name and business address for
the record.
A. My name is Stacey Donohue. My business address is
472 West Washington Street, Boise, Idaho.
O. By whom are you employed and in what capacity?
A. I am employed by the Idaho Public Utilities
Commission as the Program Manager of t.he Technical Analysis
Secti-on in the Utilities Di-vislon.
a. What is your education, experience and background?
A. I received a B.A. in History from ,James Madison
University in 1-999 and a Master's of Public Administration
(M.P.A.) from Boise State University in 20:..0. Prior to
joining the Commission Staff in 2010, I was employed as an
Energy Specialist at the Idaho Office of Energy Resources
where I managed the administration of energy efficiency and
renewable projects. I have attended the New Mexico State
University Center for Public Utilities' course in Practical
Regulatory Training.
I serve on Idaho Power's Integrated Resource
Planning Advisory Council and its Energy Efficiency Advisory
Group, AvisLa's Energy Efficiency Advisory Commj-ttee, and
the Regional Technical Forum's Policy Advisory Committee. I
have filed comments representing Staff's position on
integrated resource pIans, community so1ar, fixed cost-
adjustment mechanism designs and associated recovery,
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electric and gas demand-side management (DSM) program design
and prudency, and 1ow-income weatherization programs. In
addition, I have filed testimony in three general rate
cases.
O. What. is the purpose of your testimony?
A. My test.imony will address the Company's request to
create new rate classes for R&SGS (Residential and Sma11
General Service) net metering customers.
O. Please summarize the Company's request.
A. The Company has requested authorization to
separate R&SGS net metering customers into two new customer
classes. The Company claims that these customers are
different than standard service customers and benefit from
an unfair cost shift from standard service customers.
a. Please summarj-ze your testimony.
A. I will provide some background information on
Idaho Power's neL metering offering, and I wil-I show t.hat
St.aff's analysis of consumption data finds no evidence
justifying a separate rate class for net metering customers.
I will- show that the Company's calculation overstates the
future cost shift and present Staff's analysis of t,he cost
shift. drj-ven by excess generation. I will then explain
Staff's proposal to modify Schedule 84 to remove the cost
shift caused by excess generation and show how Staff's
proposal a11ows net metering to grow while preserving the
CASE NO. IPC-E-17-13
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ability of customers to offset. their own consumption.
Fina11y, I will show t.hat net metering does not harm 1ow
income customers and the process proposed by the Company in
this case is faulty.
IDAHO POWER'S NET METERING OFFERING
O. Please describe the size of the net met.ering
resource currently on the Company's system.
A. Residential solar makes up 94 percent of the
Company's net metering resource and tot.als 8.3 megawatts
(MW) of nameplate capacit.y as of .fune 20L7. That. is
approximately 0 . 3 percent of the Company' s 3 ,40 0 MW syst.em
capacity. If the Company's median growth project.ion for
residentj-aI solar is realized, the Company will have 40 MW
of residential- solar in 2022. For context, Idaho Power's
system peak-hour load requirement is forecast to grow by
50MW for each of the next twenty years.l
O. Ts the Company financially harmed by net metering?
A. No. The Fixed Cost Adjustment (FCA) aI1ows the
Company to recover its fixed costs associated with
reductions in energy usage for the R&SGS classes for any
reason. The FCA ensures that. the Company remains
indifferent to reductions in energy sales regardless of the
reason. Economic downturns, weather, expansion of natural
gas space heat, energy efficiency, and net. metering can all
1 Idaho Power's 20L7 Integrated Resource P1an, page 2l
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cause declines in energy sa1es.
a. On page 20 of his testimony, Mr. Tatum states t.he
"Company's f iling is intended t.o facilitat.e t,he expansion of
on-site generation in a way that is both scalable and
sustainable into the future...." Do you agree with this goal?
A. Yes. I beli-eve that. scalable and sustainabl-e
expansion of the Company's net metering offering is a
reasonable goaI.
O. Why do you support scalable and sustainable
expansion of t.he Company's net metering of f ering?
A. Because it aI1ows customers to offset their own
consumption in t,he same way that customers have always been
able to offset their own electric consumption through
reduced usage, energy efficiency, natural gas and wood space
heat, and all other methods. The Company does not concern
itself with what happens on the customer's side of the meter
for any other customers, and I do not believe it appropriat,e
in this case either.
Additionally, the Company has shown that net
metering lowers costs for all customers. According to the
Company's presentation at the .Tune 27 , 201,6, "NeL Metering
Customer and St.akeholder Workshop" (originally included as
Exhibit 10, page l-l- of Ms. Aschenbrenner's direct testimony,
j-ncluded here as Exhibit No. 1-l-2) , an average net meterlng
customer is 25 percent less expensive to serve t,han an
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average standard service residential customer.2 Net
metering lowers costs to serve because it, reduces capacity
and energy costs the Company would otherwise incur to serve
that 1oad.
NO EVIDENCE iIUSTIFYING SEPARATE RATE CLASSES
O. On what basis did the Company support
its position t,hat net metering customers should be moved
into a separate rate class?
A. On page 25 of her testimony, Ms. Aschenbrenner
states that
til t is long standJ-ng ratemaking practice toestablish separate customer classes to set ratesfor segments of customers with different costs ofservice or where the nature or type of load isdistinctly different from their current customerclassification.
On the same page, she adds "pattern of use" as anoLher
dif f erentiat.ing fact.or .
O. Did t.he Company include a cost of service (CoS)
study to provl-de evj-dence for its claim that net metering
cusEomers should be in separate customer classes?
A. No, the Company did not provide a COS study.
InsLead, it provided t.he load profiles of average net
meterj-ngr customers compared to average standard service
customers on a single peak day in 201"6.
O. Did the Company analyze annual consumption for its
2 The figures presentsed at t,he Stakeholder workshop are Companystatements, not the resuLt,s of a cost of service study.
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net metering and standard service customers in this filing?
A. No.
O. Would you agree that the "two-way relationship
with the grid" (Application at 8) is a fundamental
difference between net metering and standard servj-ce
customers?
A. No. Dr. Morrison's test.imony shows that the
average residential net metering customer pushes very 1itt1e
energy onto t,he grid. Most of the energy produced is used
to offset the customer's consumption.
Further, the Company did not claim that net
metering could increase maintenance or pose a safety hazard
to its system, and it did not specify additional investments
that it would be required to make to accommodate net
meteri-ng growth or ident.ify at what Ievel of penetration any
investments would be needed.
In fact, the Company's 20l-7 Annual Net Metering
Status Report. (attached as Exhibit 9 to Ms. Aschenbrenner's
direct test.imony, included here as Exhibit No. l-10)
described a loca1 distribution circuit that is sti11
performing up to required standards with 32 percent solar
penetration. The report also states that the Company
"reviews several facLors" (page 15) when considering net
metering applicatj-ons, which include confJ-rming "adequate
transformation and conductor capacity, ds well as phasing
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(single versus three phase) match." (Id). The Company
confirmed that it "has not denied any net meterlng
applications due to system limitations, but continues to
carefully monitor requests.... " (Id. )
This suggest,s that the Company could deny a net
meterj-ng application rather than incur substantj-aI system
cost. It makes sense that net metering has minimal grid
impacts sj-nce most of the energy produced is consumed on-
site rather than pushed back onto the grid.
Because most of the energy produced by net
met,ering is consumed on sit,e, grid operations are not
impacted, and there are no quantifiable cost impacts to
other cusLomers, it is difficult to conclude that net
metering customers are different from other customers in any
meaningful way.
O. Did Staff conduct an analysis to determine if net
metering customers are different from standard service
residential customers in the nature, type, or pattern of
use?
A. Yes. Dr. Morrison analyzed annual consumption
dj-fferences between all of the Company's 20L6 net metering
cusLomers and a stratified random sample of the Company's
standard residential service customers. Dr. Morrison found
that "the distribution of individual consumption patterns
from both groups is nearly identical" and "consumption
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patterns of both groups are simiIar. " Morrison Dj-rect at
1,7. The finding that these cusLomers are almost,
indistinguishable contradj-cts the Company's claim that net
metering and resident.ial standard service customers are
different in their nature, type, or pattern of 1oad.
COST SHIFT CALCULATION
O . Is the cosL shift driving the Company's request to
separat,e net metering customers into new customer cl-asses?
A. No. Ms. Aschenbrenner states on page 35 of her
testimony:
As discussed in Mr. Tatum's testimony, otherintra-cIass subsidies do exist and continue toexist. absent fu1Iy unbundled cost-based rates;however, the distinct dj-fferences beLween thetime, nature, and pattern of use by st.andardservice customers and R&SGS customers with onsitegeneration is what is driving the need forseparate rate classes.
Further, oD page 25 of her test.imony, Ms. Aschenbrenner
writes that "R&SGS customers who take standard service from
Idaho Power are set apart in a separate customer class not
because of the amount of energy they use but because the
nature of energy use is different from one another."
O. If t.he request. to separate rate cl-asses is not
driven by the need to correct a cost shift from standard
service customers to net metering customers, why is the
Company concerned with the cost shift?
A. That is not entirely clear. The current cost
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shift is extremely small, and even under the Company's
growth projections it is anticipated to remain very small in
proportion to resident.ial class revenues.
O. Did the Company include an analysis of the cost
shift in this filing?
A. None of the three Company witnesses testified to
the size or calculation of the cost shift. However, Ms.
Aschenbrenner included the Company's 2017 Annual- Net
Metering Status Report as Exhibit No. 9 to her testimony.
That report claimed the cost shift from standard service
customers to net. meterj-ng customers in 2015 was $116,682,
which is 0.023 percent of the $515 million generated by the
residential class in the same year.
While this is very sma11, the Company's 201-6
Annual Net Metering Report claimed t.he cost shift could grow
to between $755,000 and $1.9 million by 2021 (Exhibit No.
1l-1) . Assuming t.he residential class revenue generation
remains at 20L6 1eve1s, the projected $1.9 million cost
shift would constitute 0.37 percent of future residential
saIes.
O. Do you agree with how the Company calculated this
projected cost shift?
A. No. In order to estimate the projected per-
customer cost shift, the Company created a "strawman" future
net metering customer using usage data from non-neL metering
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residential customers with average usage.
The Company's data provided to Dr. Morrison shows
t.hat average net metering customers have higher usage than
average standard service customers even after accounting for
their own on-site generation. After offsett.ing their
consumption through their own on-site generation, an average
net metering cust,omer consumes 13,113 kilowatt hour (kWH)
annually from the Company. By comparison, an average non-
net metering customer consumes 11,781 kWh annually from the
Company.
Nevertheless, the Company then applied the effects
of a 5kW solar photovoltaic (PV) system t,o the average
residential customer usage to create its "strawman" future
net metering customer.
Because any customer with below average usage
receives a subsidy from any customer with above average
usage, applying a 5kW solar PV system to average usage
significantly reduced usage below what is observed with
actual net metering customers in the sample the Company
provided to Dr. Morrison.
Based on t.his methodology, the Company calculated
a $444 subsidy per its future "strawman" net metering
customer. This estimate is highly speculative because it. is
not based on observed actual usage of net metering
customers.
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The Company then multiplied this figure across iLs
projected growt.h in net metering customers and determined
that the future cost shift could range from $755,000 to $1.9
million over the next five years.
O. How should t,he cost shift have been calculated?
A. Fut,ure net metering customer usage should have
been forecast using actual net meterj-ng customer
consumption After offsetting theJ-r consumption from the
Company with their own on-site generaLion, the average net
metering customer uses 1,332 kwh more energy annually than
an average residential customer.
O. Did Staff conduct its own analysis of the cost
shift ?
A. Yes. Staff does not believe that power consumed
by the customer at the time it is produced by the customer's
own generation should be included in the cost shift
calculation. The only transactions that should be
considered are those that happen at the meter: l-) the power
supplied by the Company, and 2) excess generation supplied
by the customer.
The Company is currently paying net metering
customers retail rates for the energy net metering cusLomers
push across the meter and back onto the grid. Any payment
amount that exceeds the cost the Company would have incurred
to acquire that energy is a subsidy to net metering
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customers.
By applying avoided cost rates to the excess
generation on1y, Dr. Morrj-son calculated the current subsidy
from the body of standard service ratepayers to an average
net metering customer to be $l-00.53 annua11y.
Using the Company's most aggressive forecast for
net metering growth, the cost shift in 2022 would be about
$708,000. Assuming that residential class revenue remains
stable at $515 mi11ion, the cost shift represents 0.L4
percent of the annual residential class revenues.
O. Why do you believe t.he cost shift should be
addressed even t,hough it j-s relatively smaI1?
A. The cost shift should be addressed because it i-s
caused by an inappropriate valuation of energy delivered to
the grid by net met,ered residential customers and not, for
example, by certain inevitable subsidies created by
consumption patterns, which cannot be controlled by the
Company or the Commission.
O. Company witness Tatum claims that "Cost shifting
is generally accepted and regulators nationwide have
attempt,ed to address it." Tatum Direct at 14. Please
respond to t.he suggestion that the Idaho Commission should
foI1ow the lead of other states on this issue.
A. I have not reviewed the consumption data, cost
shift calculations, and evidence presented in other states.
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I have, however, reviewed the consumption data, cost shift
calculations, and evidence presented by the Company in t.his
case. The evidence in this case shows that net metering
customers as a group are nearly indistinguishabl-e from
st.andard service customers and create a de minimis cost
shift relative to class revenues, but that cost shift should
nevertheless be addressed because it relates to the fairness
of the cost the Company is paying for a resource.
O. Why do you recommend that the Commission address
this cost shift?
A. If the cost shift were caused by 1ow usage, I
would not support addressing it because that would single
out one type of customer who reduces usage from all others
who reduce usage. However, over-valuing the excess
generation produced by net metering customers creaLes a
small cost shift. Since this is the only way that net
metering cusLomers are different from other customers and
has the potential- to harm other customers if that generatj-on
is over-valued, I recommend addressing it.
STAFF'S PROPOSAL TO CORRECT THE COST SHIFT
O. Please describe Staff's proposal to correcL the
cost shift.
A. In order to correct this cost shift, Staff
proposes to value excess generation produced by net metering
customers at an avoided cost rate. This does two things:
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l-) it more fairly compensates net metering customers for the
resources they are contributing to the system, and 2) it
eliminates t,he cost shift assocj-ated wit.h excess generation.
Dr. Morrison used the Company's DSM avoided costs in his
analysis because they are public and readily available, but
he and I both recommend a new docket be initiated to
determine the avoided cost value that most accurately
reflects the value of this resource.
DSM avoided cost rates occur in five time blocks
(Summer On-Peak, Summer Mid-Peak, Summer Off-Peak, Non-
Summer Mid-Peak, and Non-summer Off-Peak) to reflect t.he
marginal resource the Company would use or acquire to meet
load in those hours. fn order to use those hourly time
blocks to value excess generation for net metering,
consumption and generation must be metered on a net-hourly
basis. This is a change from the Company's current practice
of metering on a net-monthly basis.
In addition, metering on a net-hourly basis
addresses the Company's concern that meterj-ng on a neL-
monthly basis a11ows net. metering customers to escape paying
for the grid in the hours they are net consumers.
CrJ-tica11y, neither of t.hese changes require a new
raLe cIass. Both can be made with modifications to
Schedule 84.
fL is also important to note that Staff's proposal
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only eliminates the cost shift caused by excess generation,
which is the only way that net metering customers are
different from standard customers as a c1ass. Other cosL
shifts associated with other-than-average bil-led consumption
remain, just as they remain for any other standard service
resi-denti-aI customer.
O. How will this impact current net metering
customers?
A. Using the Company's DSM avoided cost rate as a
placeholder for the revised excess generation credj-t, Dr.
Morrison calculated that these two changes would increase
the average net metering customer's bill by $S.39/mont.h,
which is $100.53 annua1Iy. This amount exact.ly offsets the
current subsidy received by net metering customers described
earlier.
O. The Company states that the current net metering
pricing strucLure does not adequately reflect the cost to
serve net metering customers who use grid services every
hour of the month, but pay less than their respective share
of costs when generat.ion is valued at the fuII retail rate
and netted against consumption on a monthl-y bas j-s.
Application at 3. Does Staff's proposal addresses that
concern?
A. Yes. By adjusting the credit for excess
generatj-on from the retail rate to an avoided cost rate and
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billing on a net-hour1y, rather than a net-monthly basis,
Staff 's proposal addresses bot.h of these concerns.
O. Net metering consists of several different
t,echnologies, how does an avoided cost rate approach address
different technologies?
A. Using an avoj-ded cost structure to value the
excess generation is resource agnostJ-c: It j-s valued no more
or less than the cost the Company would have otherwise
incurred to meet load according to its generation profile.
O. Does St.aff 's proposal respond to the Company's
goal of making net metering "both fair and sustainable into
the fuLure"? (Tatum at 4.)
A. Yes. It a11ows net metering to expand, which
according to the Company lowers costs for all customers,
while making standard service customers indifferent to costs
they pay for excess generation provided by these systems.
NET METERING IS SfMILAR TO CABIN USAGE AI{D ENERGY EFFICIENCY
O. Ms. Aschenbrenner's test,imony clai-ms that net
metering customers whose usage nets to zero are noL t.he same
as vacation homes (i.e. cabins) with no kWh usage j-n a
month. Do you agree with her characterizat.ion?
A. No. In her example, Ms. Aschenbrenner maintains
that cabins are different from net metering customers
because when cabins do not receive an energy bi11, it is
because they did not. use the grid. But that overlooks the
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fact that all other customers paid for the cabin's stand-by
service (i.e., fixed costs) in the month that the cabin's
energy use did not cover its fixed costs. As Exhibit 10,
page 5 of Ms. Aschenbrenner's testimony shows (included as
Exhibit No. 1l-l- to my testimony) , fixed costs are 67 percent
of service costs for residential customers.
The cost shift that the Company claims t.o be
addressing
met.ering -
for net metering cusLomers is not uni-que to net
it happens with any cust.omer who uses less
energy for any reason. In addit.ion to cabins,
than
thisaverage
i-ncludes homes with natural gas or wood space heat, fewer
occupants, and energy efficiency measures.
However, Staff's proposal to meter net metering
cusLomers on a net-hourly basis resolves the issue
metering cusLomers not paying for the grid in hours
they are net consumers.
O. On page 31 of her testimony, Ms. Aschenbrenner
states that:
A customer with on-site generation and a customer
who installs an energiy efficiency measure aresimilar in that. t,hey are both able to reduce the
amount that. t.hey are bi1Ied for energy; however, a
customer who instal-l-s an energiy efficiency measurei-s reducing their reliance (and lowering their
cosL to serve) in every hour that measure iscalled upon. That is, the energy efficiency
measure is always delivering energy reduction.On-site generation only reduces the demand forgrid energy in the hours the system is operating.
When the system is not generating, the grid isrelied upon to serve the fu1I demand.
of net
when
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Do you agree with this assessment?
A. No. A customer who installs a net metering system
is almost identical to a customer who installs an energy
efficiency measure. An energy efficiency measure only
delivers energy reduction in the hours that it is
funct,ioning, which is t.he same as a net metering system.
For example, if a customer chooses to override the
efficiency setting on a smart thermostat, the device does
not provide savi-ngs during that time and the grid is caI1ed
upon to serve higher demand.
O. On page 29 of her testimony, Ms. Aschenbrenner
claims that. a net metering customer's usage is not similar
to a standard service residential customer who has 1itt1e
monthly kWh usage. Do you agree?
A. No. To defend this statement, the Company
provides a chart showing the differing load patterns between
net metering and standard service residential customers on a
single day. One day of load pattern data does not support a
claim about. monthly usage. Further, Ms. Aschenbrenner's
statement assumes that net metering customers are 1ow usage,
but Dr. Morrj-son's analysis shows t.hat after offsetting
their consumption with their own on-site generation, the
average net metering customer uses l-,332 kwh more annual
energy from the Company than non-net metering customers.
A. Ms. Aschenbrenner admj-ts on page 35 of her
CASE NO. IPC-E-17-13
t2/22/L7 DONOHUE, S. (Di) 18
STAFF
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testimony that net-zero customers are not representative of
all net metering customers. Do you agree? What percentage
of the Company's net metering customers are net-zero?
A. I agree with Ms. Aschenbrenner on this point. Dr.
Morrison's analysis of the data provj-ded by the Company
shows that only about 11.5 percent of net metering customers
are net-zero and the remaining 88.5 percent are not.
O. Do you believe it is appropriat,e to create a
separate customer class for a group of customers based on
Ll-.5 percent of that group?
A. No.
THE COMPA]{TY'S PROPOSED PROCESS AI{D CONSIruER PROTECTION
O. Ms. Aschenbrenner suggests on page 24 of her
testimony that the Company's plan to study the costs and
benefits after establishing separate rate classes for net
metering: customers aligns with feedback from stakeholders
gathered j-n advance of this filing. Do you agree?
A. No. Stakeholders were in favor of a study to
determine the costs and benefit.s of net meterj-ng, but the
Company made no indication that it might conduct the study
after determining t.he need for separate rate classes. As a
participant in those meetings, iL was clear that
stakeholders were interested in that study happening before
a significant decision such as a rate class determinat,ion or
pricing change was proposed.
CASE NO. IPC-E-17-13t2/22/17 DONOHUE, S. (Di) 1"9
STAFF
1
2
3
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O. The Company claims that creating a new customer
class will enable it to study these customers and understand
how they use the Company's system. Do you believe that is
necessary?
A. No. The Company has advanced metering
infrastructure data for a1l- of t.hese customers right now -
the same data Dr. Morrison used in his analysis. Separating
these customers j-nto different rate classes has no impact on
the amount of available data. The Company could have, but
chose not to, use t.his data to study net metering customers
in advance of request.ing separate rate classes.
O. The Company has requested a generic docket to
develop the compensation structure that reflects both
benefits and costs of net metering. Do you support this
generic docket even t,hough you recommend that the Commission
deny the Company's request for separate rate c1asses?
A. No. Because this case is limited to Idaho Power
and the other utilit.ies have not filed net metering cases, I
do not believe a generic docket is justified. However, I
recommend a future docket that. includes a study of costs as
well as benefits, as long as the primary goal is
establishing the resource value of excess generation.
O. The Company claims that separating net metering
customers into separate classes now will limit the issue in
a future general rate case proceeding. Do you believe t.hat
CASE NO. IPC-E-17-13
t2/22/1,7
DONOHUE, S. (Di) 20
STAFF
1
2
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9
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is a reasonable approach?
A. No. Limiting or expanding a future proceeding is
not the correcL basis on which t,o determine creation of new
customer classes. That. decision should be made based on
evj-dence, not a desired process outcome.
O. On page 18 of his testimony, Mr. Tatum expressed
concern that "some customers may be investing in
[distributed energy resource] systems under the assumption
that rate design changes or compensation for excess net
energy will never occur; that misunderst.anding may
negatJ-ve1y impact, the economics of their decision." If you
share Mr. Tatum's concern, do you have recommendations for
addressing this potential mj-sunderstanding?
A. I share Mr. Tatum's concern that customers may not
have complete information before investj-ng in a system
capable of net metering, specifically in rooft.op solar. To
help minimize the potential for misunderstanding, the
Company could augment its current customer outreach by
developing a closer relationship with soLar installers, much
as they have with trade a11ies (such as HVAC installers) who
support the Company's energy efficiency programs. To make
sure that. its customers participating in its energy
efficiency programs are dealing with a reputable dealer, the
Company hosts a list of "Participating Contractors" on its
website (Exhibit, No. 11,2) . The same could be done for solar
CASE NO. IPC-E-17-13
1-2/22/1,7
DONOHUE, S
STAFF
(oi1 27
1
2
3
4
5
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8
9
10
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installers who support the Company's net metering offering.
Lastly, the Company could add an on-line solar
calculator to its "My Account" 1og in page to help customers
understanding the impact of possible net metering rate
changes to their bi11.
O. The Company expresses concern that " [f] rom a
consumer prot.ection perspective" the current net metering
rate sLructure "a1so acts as a regressive wealt,h transfer
from lower-income customers to higher-j-ncome customers."
(Application at 5) Please comment on the impact net
meterj-ng has on low income customers.
A. I'm very glad to see that the Company is concerned
about its low income customers and I share that concern.
However, Exhibj-t No. ll2 of my testimony shows that Idaho
Power believes net metering customers are 26 percent less
expensive to serve than sLandard service customers. This
l-owers costs for all customers, including 1ow income
customers. Staff's proposal eliminates the cost shift
associated with excess generation, thereby making all
customers, including Iow income customers, j-ndifferent to
the effect.s of excess generat.ion.
O. Please summarize your recommendations in this
case.
A. I recommend that the Commission deny the Company's
request t.o establish new rate classes for net metering
CASE NO. IPC-E-17-13
L2/22/17
DONOHUE, S. (Di) 22
STAFF
1
2
3
4
5
6
7
I
9
10
1_1
L2
L3
L4
15
16
l7
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t9
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21,
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23
24
25
customers based on Dr. Morrison's analysis that their
consumption patterns are almost indistinguishable from
standard service customers. However, I also recommend that,
the Commission initiate a docket in which the Company and
interested parties can work together to determine the
compensation structure for excess generation based on the
avoj-ded cost of the resource. When that process is
complete, I recommend that the Commission direct the Company
to file a revj-sed Schedule 84 reflecting the agreed-upon
avoided cost rate and the net-hourly metering.
O. Does this conclude your testimony in this
proceeding?
A. Yes, it does.
CASE NO. IPC-E-17-13
t2/22/1,7
DONOHUE, S. (Di) 23
STAFF
r'J
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Exhibit No. 10
Case No.|PC-E-17'13
C. Aschenbrenner, IPC
Page 1 'l of 20
ExhibitNo. 109
Case No. IPC-E-17-13
S. Donohue, Staff
12/221r7
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April29, 2016
Ms. Jean D. Jewell
Secretary
ldaho Public Utilities Commission
PO Box 83720
Boise, lO 83720-0074
RE: Compliance Filing in Case No. IPC-E-12-27
Annual2016 Net Metering Status Report
Dear Ms. Jewell:
Pursuant to Order Nos. 32846 and 32925 in the above-mentioned case, ldaho Power
Company ("ldaho Powe/ or "Company') hereby submits its 2016 Annual Net Metering Status
Report. On page 19 of Order No. 32&46, the ldaho Public Utilities Commission ("Commission')
indicated that 'the report shall discuss, without limitation, the net metering service provisions and
pricing and hor distributed generation may be impac{ing system reliability.' The attached report
responds specifically to the Commission's directive to provide such information.
ldaho Power recognizes that in Order No. 32846 the Commission direcled the Company to
raise issues related to rate design in the context of the Company's next general rate case. However,
for the reasons described in the report, ldaho Power believes its net metering service has reached a
pivotal point; that is, the Company is able to quantify that cost shifting is occuning between
residential net metering customers and residential standard service customers and can reasonably
predicl that future cost shifting between these customer groups will grow exponentially in the next
few years. Because the Company does not know when it will next file a general rate case, ldaho
Power believes it is prudent to begin the net metering conversation now.
ldaho Power plans to hold customer and stakeholder workshop(s) during 2016 to share the
results of this report and solicit feedback on a potential rate design proposal for future net metering
customers that the Company may consider filing with the Commission. lf the Commission wishes to
open a docket and issue a Notice of Workshop(s) to facilitate customer participation, ldaho Power
will work with the Commission to establish a mutually agreeable schedule.
lf you have any questions regarding this liling, please direct procedural gueslions to me and
substantive inquiries to Senior Regulatory Analyst Connie Aschenbrenner at [phone] or
caschenbrenner@idahopower. com.
Very truly yours,
LISA D. NORDSTROM
Lead Couneel
I [e-mail]
RECEIVED
?tl6 tpR 29 pH 3, 35
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, ,I L .' ',./\'r .; ; . t, - w( f ;. r,.lSSrCf{
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An loAcoRP company
Exhibit No. I l0
Case No. IPC-E-17-13
S. Donohue, Staff
l2l22ll7 Page I of 19
LDN/KKt
Enclosures
cc: Karl Klein, IPUC
Lisa D. Nordstrom
ldaho Power Gompany
Annual Net Metering Status Report
April 29,2016
ldaho Power Company ('ldaho Power' or'Company') presents its annual net metering
status report to the ldaho Public Utilities Commission ("Commission') as required by Order Nos.
3284O and 32925 in Case No. IPC-E-12-27. The report begins with u@ated participation and
growth data since the Company's last update to the Commission in April 2015 and a discussion
about ldaho Powe/s average residential net metering customer and how that customer
segment's usage profile is changing over time. The report then details key issues related to the
Company's net metering service, including a quantification of the cunent and potential future
amount of cost shifting occurring between the net metering residential customer segment and
the residential standard service customer class, an update on excess net energy credit
transfers, and an assessment of the impact of distributed generation on system reliability.
l. Existino Net Meterinq Service
Current Participation and Growth
As of December 31, 2015, ldaho Powe/s net metering service consisted of 731 active
systems with a cumulative nameplate capacity of 5.31 megawatts ("MW'). During calendar year
2015, participation in net metering service increased by 234 active systems (a 47 percent
increase) with incremental nameplate capacity totaling 1.79 MW. The additional systems were
entirely comprised of new solar photovoltaic ('P\f) installations.
During the first quarter of 2A16, growth continued with the Company adding 59 new
active systems with aggregate nameplate capacity of 0.827 MW. ln addition, the Company has
77 pending applications totaling 0.938 MW of nameplate capacity. At the end of the first quarter
2015, ldaho Power reported 5&4 active and pending systems, and at the end of the first quarter
of 2016, ldaho Power has 867 active and pending systems, which represents a 48 percent
growth rate since this time last year.
Tables 1 and 2 provide the total number of aciive and pending net metering systems and
nameplate capacity by resource type, jurisdiction, and customer class.
Sxll"llJi;113.,,.,,
tDAHo powER coMpANy's ANNUAL NET METERING STATUS REpoRT - 1 S' Donohue' Staff
12122/17 Page2 of 19
daho Solar PV Wind Hvdro/Other Total
Residential 658 55 6 719
Commercial & lndustrial 105 6 4 115
lnigation 3 1 4
Totalldaho 766 62 l0 838
Oregon
Residential 11 1 12
Commercial & lndustrial 8 I
lnigation o o
Total Oregon 28 1 29
Total Coopam
Residential 669 56 6 731
Commercial & lndustrial 113 6 4 123
lrrigation 12 1 13
Total Company 794 63 10 867
Table l: Number of Net Metering Systemsr - Pending and Active as of iiarch 31, 2016
Table 2: Nameplate Capacity (ilw) - Pending and Active as of March 31, 2016
Chart 1 details cumulative net metering system counts by customer class from 2001
through the first quarter of 2016 (including pending applications).
1 The net metering database the Company maintains reports a new application as a 'system.' Some
customers have increased capacig of an existing system or have installed a second system that is a
different resource type; these expansions or additional systems would be counted in Tables 1 and 2 as its
own system. This allows the Company to report capacity in the year in which it came online. Additionally,
because an expansion of an existing system requires the filing of a new application, it is treated
separately for tracking purposes'
Exhibit No. l r0
IDAHO POWER COMPANY'S ANNUAL NET METERING STATUS REPORT - 2 case No' IPC-E-17-13
S. Donohue, Staff
l2l22ll7 Page 3 of l9
ldaho Solar PV Wind Hydro/Other Total
Residential 3.53 29 06 3.88
Cornmercial & lndustrial 1.89 05 .09 2.03
lrrigation .21 04 .25
Total ldaho 5.63 .38 .15 6.16
Oreoon
Residential 08 .08
Commercial & lndustrial 15 15
lrrigation .69 .69
Total Oregon .92 0 0 .92
Total Companv
Residential 3.61 .29 06 3.96
Commercial & lndustrial 2.04 .05 09 2.18
lrrigation 90 .u .94
Total Company 6.55 .38 .15 7.O8
Chart 1: Cumulative Net Metering Syetem Counts (by Customer Type)
Lm0
9(x,
8m
7(n
600
5(n
00
300
200
100
0 t
200t 2(n2 2003 2flt4 2005 ZX,S 20i,7 2008 2qr9 2010 20tt 2012 2013 20t4 2015 2016
rIDI
r Resldential r C&l * lrrigation
From a capactty perspecfive, interconnected net metering generation expanded in
accordance with the increasing system counts described above. Chart 2 details cumulative
@pacity growth from 2001 through the first quarter of 2016 (including pending applications).
Chart 2: Cumulative Net illetering Capacity (by Customer Type)
8
7
6
5
!a
3
2
1
0
200t 2(n2 2003 2004 2005 2006 2007 2008 2009 2010 207t 2012 20t3 20l| 2015 2016
(lrTD)
r Residential r C&l a' lrrigation
The majority of growth in the Company's net metering service is related to the
installation of residential PV systems. PV has comprised 90, 98, 99, and 100 percent of the
Exhibit No. I l0
Case No. IPC-E-17-13
S. Donohue, Staff
12122117 Page 4 of l9
IDAHO POWER COMPANY'S ANNUAL NET METERING STATUS REPORT - 3
r_r
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I
I
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II,
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incremental resource mix in the years between 2012 and 2015, respectively. All but one of the
incremental active and pending installations in 2016 are PV.
The exponential growth in net metering service since 2001 demonstrates how the
Company's grid is evolving, and underscores the need to evaluate the associated service
provisions and pricing to ensure that ldaho Power can continue to offer safe, reliable, fair-priced
electrical service now and in the future. ldaho Power also anticipates that as participation in its
net metering service continues to grow, it may require additional staff to facilitate both the
processing of net metering applications at the time of interconnection, as well as processing the
annual transfer of excess net energy credits.
Characteristics of the Average Residential Net Metering Customer
ldaho Power examined the load characteristics of its curent residential net metering
service customers to determine differences, if any, between them and current residential
standard service customers for a few reasons. The Company determined the cunent residential
net metering customers were different for a few reasons: the most obvious difference is that
they use the Company's electrical system bi-directionally, both to take service from the utility
and to put excess generation back onto the grid. Further, because net metering customers are
billed based on net energy consumed over the @urse of a month, a net metering customer may
be billed for net zero consumption and avoid paying for fixed costs associated with service
during hours of the month they consumed energy from the grid and other hours of the month
they supplied excess net energy to the grid. Based on an analysis ol 2015 actual billing data,
the net metering customers also tend to be larger energy users, with an average monthly
kilowatt-hour ("kWh') usage of g952 compared to an average residential standard seruice
customer who used approximately 9473 kWh per month during 2015. \Mile this relationship
may appear counter-intuitive on its face, a further examination of the usage characteristics of
' This is the monthly average of the total 2015 actual billed kWh for these customers (net of net metering
system generation). Because the Company uses a single meter to measure consumption over a billing
period, it does not have the ability to measure total consumption and total generation separately'.
3 Based on 2015 actual billed kWh for the residential ctass.
ExhibitNo. 110
Case No. IPC-E-17-13
S. Donohue, Stai'f
l2l22ll7 Page 5 of 19
IDAHO POWER COMPANY'S ANNUAL NET METERING STATUS REPORT - 4
the cunent net metering segment shows that there are a small number of unusually large
energy userc skewing the average consumption of the segment.
Chart 3 demonstrates the load shape of the Company's residential customer class on
June 29, 20'15, the day of the 2015 ldaho Power adjusted system peak.1 Chart 3 also includes
the load shape of the Company's residential net metering customer segment on that same day.
As mentioned above, Chart 3 illustrates that these customers are generally larger users than the
Company's average residential standard service customer and demonstrates the residential net
metering customeds ability to oftset usage when, in the case of a PV eystem, the sun is shining.
Chart 3: 2015 Adfusted System Peak Day (June 29,20151
3.x
3.50
3.00
2.50
2.OO
1.50
1.00
0.50
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7 2 3 4 5 6 7 8 9 1011t2L3t4t5t617 1819202L222324
Hour endlng
-ftgsilsntial
Net Metering Customers
-fts5i(gntial
Customer Class
ll. Quantification of Cost Shiftins
As discussed in Case No. IPC-E-12-27 and in prior net metering status reports to the
Commission, the cunent practice of applying standard retail rates to net metering service is
problematic because it creates the potentialfor inappropriate cost shifting between net metering
customers and standard service customers. The potential for cost shifting is especially large
within the Company's residential and small general service classes because a higher
a The reported system peak was June 30, 2015, at 4:00 pm; the adjusted system peak day represents the
hour at which the system would have peaked had the Company not dispatched its demand response
progmms. This methodology is consistent with the filed class cost-of-service study from the Company's
last general rate case (!PC-E-11-08).
Exhibit No. 110
Case No. IPC-E-17-13
S. Donohue, Staff
l2l22ll7 Page 6 of l9
IDAHO POWER COMPANY'S ANNUAL NET METERING STATUS REPORT. S
percentage of fixed costs are collected through a volumetric energy rate from these customers
as compared to other customer classes. Residential and small general service customers are
currently billed through a two-part rate design consisting of a $5.00 monthly service charge and
volumetric energy rates.
Quantification of Current Cost Shift
The Company performed an analysis of its residential net metering customer segment to
determine what, if any, cost shifting is currently occurring.5 First, the Company quantified the
amount of base rate revenue collected during 2015 from its residential net metering customers.o
Then, using a methodology similar to that used to assign costs to customers during a general
rate case process, the Company determined the ldaho-jurisdictional revenue requirement for
those same net metering customers.
Cost allocation for the 366 customers used the hourly metered data to determine their
use of the system by analyzing demand at the time of the monthly system peak, at the time of
the residential class peak, as well as average energy consumed by month. The results of this
analysis was an estimated cost-of-service specific to how these customers utilize ldaho Power's
electricalgrid.
Table 3 details the results of the net metering revenue requirement analysis, which are
funclionalized by production, transmission, and distribution and classified by utility services
provided as represented by customer, demand, and energy. Table 3 also presents the
percentage difference in revenue requirement between existing residential net metering
customers and residential standard service customers.
u The Company focused its analysis on the residential customer class for two reasons: (1) the majority of
the recent growth in the net metering service is in the residential class and (2) the residential customer
class has a two-part rate design with most of the customer-related fixed costs and all of the demand-
related fixed costs being recovered through a volumetric charge. Cost shifting may be occuning in other
customer classes, but the focus of this year's annual status update to the Commission will be on the
curent and potential cost shift from residential net metering customers to residential standard service
customers.
6 ln order to compare a full year of billed revenue with an estimated annual revenue requirement, the
analysis contains all residential net metering customers who had a full 12 months of billing data available
for 2015. This data set is comprised of 366 customers. Exhibit No. I l0
Case No. IPC-E-17-13
rDAHo powER coMpANy's ANNUAL NET METERTNG STATUS REpoRT - 6 S' Donohue' Staff
12/22/17 Page 7 of l9
Compared to Avt Residentlal
47,284 2t%
8%
%
TRANSMESION
-13%
36%
5%
L7%
Demand
Customer
50,458
97,511
Residentlal ilet
Itlleterlng Customers
s40,296
81,516
35,721
721,647
Dernand, Summer
Demand, Non-summer
Energy, Summer
Energy, Non-summer
Tab,le 3: Functionallzed and Glassified Residential Net Metering Customer Segment
Revenue Requirement Compared to Average Residential Standard Sewice Gustomer'
The net metering revenue requirement compared to the revenue collec{ion for those
same customers is represented in Chart 4.
Ghart 4: 2O15 Residential Net Metering Cost Shift
Using the above described pro@ss, the Company quantified the revenue requirement
for the 366 residential net metering customers to be $464,532. The total base rate revenue
received from these customers during 2015 was $408,820, resulting in an estimated cost shift of
$55,712, or '12 prernt of the total revenue requirement. As denoted in Chart 4, the $464,532
'The'Compared to Avg Residential Standard Service Custome/ column in Table 3 represents the "per
customef net metering customer segment revenue requirement relative to the "per customer'residential
customer class revenue requirement.
Exhibit No. 110
IDAHO POWER COMPANY'S ANNUAL NET METERING STATUS REPORT - 7 case No. IPC-E-17-13
S. Donohue, Staff
12122117 Page 8 of 19
ss00,000
s400,000
s300,000
s200,(D0
s100,000
5o
$46/.,slz
Revenue Requirement
r Variable r Fixed
II
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!
I
Revenue Collection
I
I
revenue requirement is comprised of 66 percent fixed costs and 34 percent energy costs;
however, only 5 percent of the total revenue was collected through the fixed service charge and
the remaining g5 percent was collected through the volumetric energy kWh charge.
While the cunent cost shift is relatively small, it is important to consider the
demographics of the 366 residential net metering customers who make up the $408,820 of base
rate revenue collection in order to assess the risk for future potential cost shift. The kWh usage
varies significantly between the 366 customers, from one customer who consumed (net of
generation) over 179,000 kwh during 2015 (annual base rate revenue collected $17,785) to 40
customers who were not billed for any kWh during 2015 (these customers netted usage to zero
and only paid the $5.00 monthly service charge). ln fac1, approximately three percent of the
customers accounted tor 20 percent of the 2015 revenue collection.
The Company believes that a few large energy users in this group are muting the cost
shift of the net zero customers who effectively avoid paying most of the customer-related costs
required to serve them, and do not pay any of the cost of the distribution, transmission, or
generation systems, even though they may still use these throughout the year. The Company
does not believe the 366 residential net metering customers analyzed for quantification of the
cunent amount of cost shifting is representative of the future potential for cost shift. As the
economics of installing a residential PV system improve, the Company expects the installation
of these systems will become more attractive and attainable to the Company's average
residential customer.
Potential for Future Cost Shift
To project potential future cost shift that could occur in the residential customer class,
the Company quantified an estimated cost shift per new net metering customer and applied that
quantification against future potentialadoption rates of residential net metering.
Estimated Cost Shift Per Customer
To quantify the estimated cost shift per customer, the Company looked at recent
installations of net metering systems within its residential customer class to determine what
Exhibit No. I 10
Case No. IPC-E-17-13
IDAHO POWER COMPANY'S ANNUAL NET METERING STATUS REPORT - 8 S. Donohue, Staff
12/22117 Page 9 of l9
system sizes are most @mmonly installed. Ghart 5 shows the percentage of systems according
to size installed by ldaho Powe/s residential customers in each of the last five years. The data
shours that as the costs of PV have declined over the last several years, the size of PV systems
being installed by residential customers has increased. The most commonly installed system in
2015 was a 6 kilouatt ('k\M) system and the second most commonly installed system was a 5
kW system. Based on estimates from the National Renewable Energy Laboratory fNREL") PV
Watts@ Calculator, a 6 kW standard fixed (open rack) system located in Boise, ldaho, will
generate approximately 8,731 kWh/year and a 5 kW standard fixed (open rack) system located
in Boise, ldaho, will generate approximately 7.276 kWh/year.
Ghart 5: Syctem Size of Residential Net Metering Cuetomer lnstallations (PV Systems
Only)
ln order to quantfi the potential for future cost shifting, the Company compared a
calculated revenue requirement for an average residential customer before and after the
installation of a net metering system. First, the Company looked at the average hourly load
profile of its residential customer class in order to estimate a per customer revenue requirement
(based on the same methodology explained on page 6). The Company then used the hourly
output profile provided by the NREL PV Watts@ Calculator to quantify the net hourly usage of an
average residential customer who installs a 6 kW PV system. Using the net hourly usage, the
Company quantified the estimated annual revenue requirement for an average residential
Exhibit No. I l0
IDAHO POWER COMPANY'S ANNUAL NET METERING STATUS REPORT - 9 case No' IPC-E-17-13
S. Donohue, Staff
l2l22ll7 Page l0 of 19
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11,810
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iesldentlal
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(5 kwStseml
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Demand, Non-summer
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customer afier the installation of a 6 kW PV system. The results of that analysis are presented
in Table 4.
Tabte 4: Annual Potential Gost Shift Per Residential Net tetering Gustomer
Table 4 demonstrates that while a residential net metering customer's self{eneration
reduces the cost to serve that customer, it does not eliminate the costs entirely and it does not
reduce them as much as the utility bill is potentially reduced. However, the price signal sent to
the customer through the cunent rate design may inappropriately send a signal that the cost to
serve them is lower than it actually is. The average sized ldaho Power residential customer
who installs a 6 kW PV system is able to reduce his or her revenue requirement by 26 percent,
however, that same customefs bill is redued by 71 percent. The potential cost shift of $444
per customer is quantified by subtracting the amount paid to the Company ($308) from the total
estimated annual revenue requirement of $848 and subtracting the $96 existing intra-class
subsidy that exists for a customer of this size.
Exhibit No. I l0
Case No. IPC-E-17-13
S. Donohue, Staff
12122117 Page 1l of 19IDAHO POWER COMPANY'S ANNUAL NET METERING STATUS REPORT. 1O
i
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Future Potential Adootion Rates
As reported in the 'Cunent Participation and Growth' section of the report, the
residential customer segment has seen a tremendous rate of growth in the adoption of net
metering. Chart 6 represents the number of ldaho Power residential net metering customers
through the end ot 2015.
Chart 6: Cumulative Growth in Residentlal Net Metering CustomersE
Using the historical growth trends, the Company projected residential net metering
customer counts through the scheduled 2021 expiration of the federal investment tax credit
CtTC').e Three forecasted growth scenarios were developed based on the distribution of year-
over-year growth rates by month as experienced over the past 18-months. The 'Median'
scenario represents the median of the growth rate distribution, the 'LorV" growth scenario is
E Chart 6 represents cumulative growth in residential net metering customers. \Mrile Tables 1 and 2
counted expansions of existing systems or installation of multiple resouroe types as separate systems, for
purposes of forecasting net metering customer groMh, the Company is reporting counts based on
customer agreements.
s A tiaxpayer may claim a credit of 30 percent of qualified expenditures for a system that serves a dwelling
unit located in the United States that is owned and used as a residence by the taxpayer, The
Consolidated Appropriations Act, signed in December 2015, extended the expiration date for PV and
solar thermal technologies, and introduced a gradual step down in the credit value for these technologies.
The 30 percent ITC was extended through 2019 and it will reduce to 26 and 22 percnnt in 2020 and 2021 ,respectively. The credit for all other technologies will expire at the end of 2016.
(http://eneroy.gov/savinos/residential-renewable-eneroy-tiax-credit)ExhibitNo. It0
Case No. IPC-E- I 7- l 3
S. Donohue, Staff
12/22/17 Page l2of l9
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-Residentlal Net Metering Customers
IDAHO POWER COMPANY'S ANNUAL NET METERING STATUS REPORT - 11
based on the 10h percentile of groMh rates and the "High" growth scenario is based on the 70n
percentile of growth rate.
The year in Chart 7 represents the year the customer installs a system.
Chart 7: Forecasted Growth in Residential Net Metering Customerc
7,000;
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Potential lmoact of Grid Paritv
'Grid parit/ refers to the point in time when the levelized cost of energy ("LCOE') from a
PV system becomes cost competitive with the retail rate of energy. The LCOE is determined by
performing a net present value ('NP\f) calculation that takes into account the total cost of the
system (up front capital cost, ongoing operations and maintenance costs, inverter replacement,
etc.), as wellas benefits received via state and federaltax incentives, and divides the quantified
NPV by the average annual energy output from the system.
While the Company only considered historical adoption rates to predict possible future
adoption of residential net metering systems, it is important to consider what lhe potential
impact of the cost of rooftop PV reaching grid parity may be. At the point the LCOE is lower
than the retail cost of energy supplied by the utility, it becomes more economical for customers
to install PV and it is reasonable to predict that the growth in the PV net metering systems will
accelerate considerably. The Company also expec{s that a broader range of customers may
Exhibit No. I l0
IDAHo powER coMpANy's ANNUAL NET METERTNG srATUs REpoRT - 12 case No' IPC-E-17-13
S. Donohue, Staff
12/22/17 Page 13 of l9
consider installing PV once the cost of installing that system becomes cost competitive with the
utilily rate.
Future Potential Cost Shift
The starting point in Chart I represents the residential net metering customers the
Company had at the end ol 2014 who had a tull year of billing data for 2015. That is, the
Company's quantified cunent cost shift of $55,712 conesponds to the customer count at the
end of 2014 (366 customers). ln order to project potential future cost shift, the Company
applied the average per-residential net metering customer cost shift of $444 to the potential
near-term adoption of residential net metering service.
Ghart 8 shows the potential future cost shift by 2021 could be as high as $1.9 million per
year or as low as $755,000 per year, with the median growth rate yielding a potentialfuture cost
shift of $1.3 million Wr yeat by 2021.
Chart 8: Cumulative Annual Potential Cost Shift
s2,000,0o0
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Addressing the potential cost ehift
The Company believes its net metering service has reached a pivotal point; that is, the
Company is able to quantify that cost shifting is occurring and can reasonably predic{ that future
cost shifting will continue to occur at an increasing rate. The current rate design of billing
residential and small general service customers a nominal service charge coupled with the
Exhibit No. I l0
Case No. IPC-E-17-13
S. Donohue, Staff
12/22/17 Page 14 of l9
IDAHO POWER COMPANY'S ANNUAL NET METERING STATUS REPORT - 13
.
S1,5OO,00O I ---
remaining variable and fixed cost recovery through a volumetric rate is conceming for two
reasons: (1) new residential customers installing PV systems are creating a real and
quantifiable cost shift to residential standard service customers who either choose not to install
PV systerns or do not have the means to do so, and (2) the cunent rate design sends an
incorrect price signal to residential and small general service customers who are evaluating
whether or not to install a PV system. The Company's analysis demonstrates that while the
revenue requirement associated with serving a residential PV net metering customer is
estimated to be reduced by 26 percent, that same custome/s bill is reducedby 71 percent.
The Company is not the first to look at addressing the potential for cost shift that exists
with net metering customers and the Company continues to believe that proper rate design is
the appropriate means for addressing the cost shift that is occurring and will grow with the
continued adoption of distributed generation in its service area. Utilities across the country are
examining how to best address the issues created by existing rate designs and the historical
practice of a 1:1kWh credit established at the retail rate and have started introducing means for
better fixed cost recovery for their net metering customers.'o ln 2015, other state commissions
overseeing three utilities established a separate class for distributed generation customerstl
and three other requests by utilities to do the same are being considered.l2
lll. Billins Svstem Capabillties
\Mile ldaho Power continues to believe its current rate designs cannot sustainably
support the widespread expansion of net metering, it is important to consider billing system
capabilities when evaluating proposed changes to the pricing of the Company's net metering
service. ln general, utility billing systems are not initially configured to accommodate net
'o Alabama Power charges a capacity reservation fee, Arizona Public Service charges a grid access fee,
California utilities (Pacific Gas and Electric, Southern California Edison, and San Diego Gas & Electric)
charge an interconnection fee that was previously paid by all customers and future distributed generation
customers will default to a timeof-use rate, Hawaiian Electric companies charge minimum bills, and
Dominion Virginia and Appalachian Power charge standby fees.
t'Westar, Nevada Power, and Siena Pacific Power
" UNS Electric and Tucson Electric in Arizona both filed to establish mandatory three-part rates for
distributed generation customers. El Paso Electric in Texas filed for establishment of three part rate
structures for partial-requirements customers. Exhibit No. I l0
rDAHo powER coMpANy's ANNUAL NET METERTNG STATUS REpoRT - 14 caseNo' IPC-E-17-13
S. Donohue, Staff
l2l22ll7 Page l5 of 19
I
metering transactions, and changes in net metering billing practices often require resource-
intensive customization that not only result in up-front costs, but require additional ongoing
maintenance costs as well.
lV. Svstem Reliabilitv Considerations
Net metering systems in ldaho Power's service area are dispersed across hundreds of
distribution feeders. Because the cunent penetration level is relatively small compared to
distribution feeder loads, as of the end of 2015, there was no significant impacl on distribution
system reliability attributed to net metering system operation.
As of March 31, 2016, the Company's 789 active net metering systems were dispersed
across roughly 282 of its approximately 650 distribution feeders. That compares to 550 active
systems across 229 distribution feeders that were reported on March 31,2015. The feeders
that contain the greatest number of net metering systems are largely located in northeast Boise
and in the Wood River area, while the feeders that contain the greatest amount of connected
net metering capacity tend to be located in mostly agricultural and rural areas. The greatest
number of active net metering systems that currently exist on a single distribution feeder is
sixteen. From a capacity perspective, eight generators (all solar) rated at approximately 398 kW
are located on a single distribution feeder. That feeder serves mostly rural customers with a
calculated summer peak load of approximately 1,600 kW. The percentage of connected net
metering kW capacity to the feeder's calculated summer peak load is approximately 24 percent.
The percentage of connected kW capacity to summer peak loads for the remaining 281 feeders
with active net metering systems remains less than 4 percent. The Company has not yet
experienced significant operational impacts on these feeders.
Because net metering installations are typically unique in both customer-specific system
attributes, as well as the Company's facilities in a particular location, the Company reviews
several factors when determining the feasibility of connecting a new net metering system. This
review may include determining if lhere is adequate transformation at the point of connection, if
the existing service conductor has adequate capacity to serve the total connected capacity of
ExhibitNo. 110
IDAHO PowER coMPANY's ANNUAL NET METERING STATUS REPoRT - 15 caseNo' IPC-E-I7-13
S. Donohue, Staff
12122117 Page l6 of l9
the generators, and if the phasing (single- versus three-phase) of the system matches the
service infrastructure. Additionally, in 2015, the Company performed its first feeder-level
feasibility study for a 75 kW system requesting interconnection onto the feeder that contains the
greatest amount of connected capacity (24 percenl) mentioned above. The result of that study
indicated that the system could be incorporated without any modification to the existing
distribution feeder. ln facl, the Company has not denied any net metering applications due to
system limitations, but continues to carefully monitor requests for connection to ensure ongoing
reliable service is available to both existing and new customers.
The Company will continue to monitor the effects of net metering service on its system
including tracking the locations and connected capacities of net metering customerc and
comparing connected capacities to minimum feeder loads. As net metering system penetration
increases, ldaho Power will keep the Commission apprised of experienced or anticipated
system reliability impacls and will propose mitigation as needed which may include additional
inverter req uirements, e. 9., smart i nverters.
V. 2015 Ercess Net Enerqv Credit Transferc (ilanual Meter AqqreEation)
Schedule 84, Customer Energy Produclion Net Metering Service ('Schedule 84')
provides for net metering customers to submit requests to transfer excess net energy credits
between January 1 and January 31 of each year. Applications received are reviewed against
the following criteria from Schedule 84:
o The account subject to offset is held by the customer; and
. The meter is located on, or contiguous to, the property on which the Designated
Meterr3 is located. For the purposes of Schedule 84, contiguous property includes
property that is separated from the premises of the Designated Meter by public or
railroad rights of way; and
. The meter is served by the same primary feeder as the Designated Meter at the time
the custorner files the application for the Net Metering System;ta and
" Schedule 84 states the Designated Meter'is the retail meter physically connected to the Net Metering
System."
'o Schedule 84 states the Net Metering System 'is a Customerowned Generation Facility interconnected
to the Company's system under the applicable terms of Schedule 72 and Schedule 84.'
Exhibit No. I l0
Case No. IPC-E-17-13
IDAHO POWER COMPANY'S ANNUAL NET METERING STATUS REPORT - 16 S. Donohue, Staff
12122117 Page 17 of 19
I
a The electricity recorded by the meter is for the custome/s requirements; and
For customers taking service under Schedule 1 or Schedule 7, credits may only be
transfened to meters taking service under Schedule 1 or ScheduleT. For customers
taking service under Schedule 9, Schedule 19, or Schedule 24, credits may only be
transfened to metere taking service under Schedule 9, Schedule 19, or Schedule 24.
a
On December 3, 20'15, all of the Company's net metering service customers were sent a
letter outlining the meter aggregation process, the requirements, and the deadlines for
customers to submit an application for transfer of eligible excess net energy credits. A copy of
the transfer request form and a Frequently Asked Questions document were sent with the letter
(both of which are availabte on the Gompany's website).1s Lastly, the Company posted a
message on all net metering service customers' December bills informing them of the upcoming
transfer window.
Given the costs associated with system customization, the Commission directed ldaho
Power in Order No. 32925 to keep it apprised of the number of customers choosing to transfer
excess net energy credits under the newly-approved meter aggregation rules. As of the
January 31, 2016, deadline, the Company received 26 applications for transfer and those
applications were reviewed during February against the Schedule M criteria.
Based on the above criteria, the Company determined that 19 of the requests were
eligible for transfer. The total amount transferred was 250,204 kWh generated from net
metering systems taking service under Residential (19 percent), Small General (60 percent),
and Large General (21 percent) rate schedules. The 250,2O4 kWh were transferred to
customers taking service under Residential (79 percent) and Large General (21 percent) rate
schedules.
The Company received seven applications that were ultimately found to be ineligible for
transfer based on the following:
. Six applicants did not have excess net energy credits.
o One applicant requested a transfer to a meter on a property that was not contiguous.
15 httos;//www.idahopower.com/AboutUs/BusinessToBusiness/GenerationlnterconnecUnetMeterino.cfm
Exhibit No. I l0IDAHO POWER COMPANY'S ANNUAL NET METERING STATUS REPORT - 17 Case No. rpC-E-17-13
S. Donohue, Staff
12122/17 page l8 of l9
The Company contacted by phone all of the customers who had requested a transfer but
whose applications were ultimately denied to explain the reason the requested transfer could
not be completed.
Vl. Conclusion
ldaho Power continues to believe that in order to facilitate the expansion of distributed
generation in a safe, reliable, and fair manner, net metering rate design must be addressed
sooner rather than later. Between the first quarters ol 2015 and 2016, pending and active net
metering systems in ldaho Power's service area have increased 48 percent. This growth brings
the potential for significant cost shifting to occur from the Company's net metering customer
segment to the standard service customer classes, most prominently within the residential and
srnall general service customer classes. As demonstrated by the analysis presented in this
report, an average-sized ldaho Power residential customer who installs a six kW system is able
to reduce his or her revenue requirement by 26 percenl, however, that same customer's bill is
reduced by 71 percent. As a result, the potentialfuture cost shifi by 2O21could be as high as
$1.9 million or as low as $755,000, with a median growth rate yielding potential future cost shifts
of $1.3 million by 2021,
As the economics of installing a residential PV system improve, the Company expects
the installation of these systems will become more attractive and attainable to the Company's
average residential customer. At the point the LCOE of rooftop PV is lower than the retail cost of
energy supplied by the utility, it becomes more economical for customers to install PV and the
grovth in the PV net metering systems may accelerate considerably. The Company also
expecls that a broader range of customers may consider installing PV once the cost of installing
that system becomes cost competitive with the utility rate.
The exponential growth in net metering service since 2001 demonstrates how the
Company's grid is evolving, and underscores the need to evaluate the associated service
provisions and pricing to ensure that ldaho Power can continue to offer safe, reliable, fair-priced
electrical service now and in the future.
Exhibir No. I l0
Case No. IPC-E-17-13
S. Donohue, Staff
12/22117 Page 19 of 19IDAHO POWER COMPANY'S ANNUAL NET METERING STATUS REPORT. 18
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Case No. IPC-E-17-13
C. Aschenbrenner, IPC
Page 6 of 20
ExhibitNo. lll
Case No. IPC-E-17-13
S. Donohue, Staff
t2/22/17
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(httos: 4www idahooower. com)
Pa rtici pati ng Ccntraclcrs
Below is a list of Participating Contractors for the ducted forced air heat pump incentives in the Heating and Cooling Efficiency
Program.
ldaho Power does not warrant or guarantee the work or services performed by any contractor iisted.
Locate a contractor by clicking on the arrow below and selecting an area.
NOTE: Participating companies are being added regularly. lf you are a company interested in participating in ldaho Power's Heating
and Cooling Efficiency Program, please contact Todd Greenwell at !208-388-6484 (tel:[phone]). or email E
[e-mail] (ma ilto:[e-mail]).
Areas
Select an Area
Treasure Valley
COMPANY NAME PHONE LICENSE#ADDRESS CITY
TML SERVICE EXPERTS
ASHLEY HEAT]NG & AIR CONDITIONING
(HTTP://WWW.ASHLEYHEATING.COM)
QUALITY HEATING & COOLING
WESTERN HEATING AND AIR CONDITIONING
(HTTP://WWW. WESTERN HVAC.COM)
TSS ONE HOUR HEATING & AIR CONDITIONING
(HTTP://WWW.TSSHVAC. COM/BolS E)
THE COMFORT SOURCE
(HTTP://WWW.COMFORTSOURCEHEATING.COM)
1 20 E 40th
St
Boise
Boise
t 208-342-681 3 (tel:[phone])
t 20 B-37 B-9 aa\ $el.208-37 8-9 44 5)
! 208-375-61 01 (tel:[phone]'l 01)
\ 208-9 0B- 4444 (tel:[phone])
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Exhibit No. I 12
Case No. IPC-E-17_13
S. Donohue, Staff
t2/22/17 page I of4
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ULTIMATE HEATING & AIR
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YMC. INC (HTTP://YMCINC.COM)
A.1 HEATING & AIR COND]TIONING
(HTTP://WWW.A1 HEATING. COM)
ADVANCED HEATING & COOLING
(HTTP://WWW.ADVANCEDHEATINGANDCOOLING.COM)
ADDRESS clw
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State St
Boise
814 S KCID
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25499
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123 Everett
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JIM.S HEATING & COOLING
(HTTP://WWW. J IMSHEAT.COM)
ARCTIC AIR (HTTP://WWW.ARCTICAIRl .COM)
BIG SKY HEATING AND AIR CONDITIONING
(HTTP://WWW. B IGSKYHEATING. COMI
CARTER COMFORT SYSTEMS
HEATING EOUIPMENT
(HTTP://HEATINGEOU IPM ENTCOM PANY. COM)
P]NNACLE COMFORT SYSTEMS
ROCKY MOUNTAIN MECHANICAL
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Exhibit No. I l2
Case No. IPC-E-17-13
S. Donohue, Staff
12122/17 Page 2 of 4
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PREMIER HEATING AND AIR CONDITIONING
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GREENS HEATING AND AIR CONDITIONING
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OWYHEE HEATING & AIR CONDITIONING
(HTTP://WWW. OWYHEEHEATING.COM)
MECH.MASTERS HEATING & AIR
LEGENDS MECHANICAL
WICKSTROM PLUMBING & HEATING
(HTTP://WWW.WICKSTROMPHC.COM)
ACTION HEATING & AIR
(HTTP://ACTIONANYWHERE.COM)
BEARS CLIMATE CONTROL
(HTTP://WWW. BEARSC Ll MATECONTROL.COM)
BAUER HEATING AND COOLING
(HTTP://WWW.BAUERHEATINGANDCOOLING.COM)
119S
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2603
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4121
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3712
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LICENSE#
HVC-C-CONTROL SENTRIES OF IDAHO Meridian
Duane Dr '
Search Contact Us (https://www.idahopower.com/contact-us/)
IDAHo GEoTHERMAL i 88O E Meridian t 208)-895-0925 (tel:[phone])
n u 20 8 - 697 -27 0 6 (tel :20 I - 697 -27 0 6)
t 20 B - 587 -20 6 6 (tel :20 B - 587 -20 6 6)
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Exhibit No. I t2
Case No. IPC-E-17-13
S. Donohue, Staff
12/22/17 Page 3 of 4
u208-482-0103(tel:[phone])' C4194
Last Update d'. 2011 -1 0-31 T0B:2i :52.94
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ExhibitNo. I l2
Case No. IPC-E-17-13
S. Donohue, Staff
l2l22l17 Page 4 of 4
CERTIFICATE OF SBRVICE
I HEREBY CERTIFY THAT I HAVE THIS 22ND DAY OF DECEMBER 2017,
SERVED THE FOREGOING DIRECT TESTIMONY OF STACEY DONOHUE, N
CASE NO. IPC-E-17.13, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO
THE FOLLOWING:
LISA D NORDSTROM
REGULATORY DOCKETS
IDAHO POWER COMPANY
PO BOX 70
BOrSE ID 83707-0070
E-MAIL: [e-mail]
dockets@idahopower. com
C TOM ARKOOSH
ARKOOSH LAW OFFICES
802 W BANNOCK ST STE 9OO
PO BOX 2900
BOISE ID 8370I
E-MAIL: [e-mail]
[e-mail]
ELIAS BISHOP
AURIC SOLAR LLC
2310 S 1300 W
W VALLEY CITY UT 84119
E-MAIL: elias.bishop@,auricsolar.com
ANTHONY YANKEL
I27OO LAKE AVENUE
LTNIT 2505
LAKEWOOD OH 44107
E-MAIL: [e-mail]
TOM BEACH
CROSSBORDER ENERGY
2560 9TH STREET, SUITE 2I3A
BERKELEY CA 94710
E-MAIL: [e-mail]
TIMOTHY E TATUM
CONNIE ASCHENBRENNER
IDAHO POWER COMPANY
PO BOX 70
BOISE rD 83707-0070
E-MAIL : [e-mail]
caschenbrenner@idahopower. com
MATTHEW A NYKIEL
ID CONSERVATION LEAGUE
IO2 S EUCLID #207
PO BOX 2308
SANDPOTNT ID 83864
E-MAIL: [e-mail]
ERIC L OLSEN
ECHO HAWK & OLSEN PLLC
PO BOX 6l 19
POCATELLO ID 83205
E-MAIL: elo(@echohawk.com
KELSEY JAE NLTNEZ LLC
920 N CLOVER DR
BOISE ID 83703
E-MAIL : kel sey@kelseyj aenunez.com
ELECTRONIC ONLY
MICHAEL HECKLER
michael.p.heckler@ gmail.com
ZACK WATERMAN
zack. waterman@ sierraclub.org
CERTIFICATE OF SERVICE
ABIGAIL R GERMAINE
DEPUTY CITY ATTORNEY
BOISE CITY ATTORNEY'S
PO BOX 500
BOISE ID 83701-0500
E-MAIL : [e-mail]
DAVID BENDER
EARTHJUSTICE
3916 NAKOMA ROAD
MADISON WI 5371I
E-MAIL: dbender@,earthjustice.org
JOHN R HAMMOND JR
FISHER PUSCH LLP
PO BOX 1308
BOISE ID 8370I
E-MAIL : j rh@fi shemusch.com
RYAN B FRAZIER
BRIAN W BURNETT
KIRTON McCONKIE
PO BOX 45120
SALT LAKE CITY UT 841I I
E-MAIL : rfrazier @l<rnclaw. cqln
bburnett@,kmclaw.com
PRESTON N CARTER
DEBORAH E NELSON
GIVENS PURSLEY LLP
60I W BANNOCK ST
BOISE TD 83702
E-MAIL: [e-mail]
den@ givenspursley. corn
DAVID H ARKOOSH
LAW OFFICE OF DAVID ARKOOSH
PO BOX 2817
BOISE ID 8370I
E-MAIL: [e-mail]
BRIANA KOBOR
VOTE SOLAR
986 PRINCETON AVENUE S
SALT LAKE CITY UT 84105
E-MAIL: [e-mail]
ELECTRONIC ONLY
SNAKE RIVER ALLIANCE
wwi I son@,snakeri veral I iansa.ary
NW ENERGY COALITION
[e-mail]
DOUG SHIPLEY
INTERMOLINTAIN WIND AND
SOLAR LLC
1953 WEST 2425 SOUTH
WOODS CROSS UT 84087
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE