20171222Morrison Direct.pdf

BEFORE THE RECE IVED
?fill0[C 22 PH 2: 3h
IDAHO PUBLIC UTILITIES COMMISSION, i.,,JC
t .: r.., ,ri,,isSlOu
IN THE MATTER OF THE APPLIGATION
OF IDAHO POWER COMPANY FOR
AUTHORITY TO ESTABLISH NEW
SCHEDULES FOR RESIDENTIAL AND
SMALL GENERAL SERVICE
CUSTOMERS WITH ON.SITE
GENERATION
CASE NO. IPG.E-17.13
DIRECT TESTIMONY OF MICHAEL MORRISON
IDAHO PUBLIC UTILITIES COMMISSION
DECEMBER 22,2017
)
)
)
)
)
)
)
)
1
2
3
4
5
6
7
8
9
10
11
1-2
13
1,4
15
15
17
l_8
t9
20
21,
22
23
24
25
A. Please state your name and address for the
record.
A. My name is Mike Morrison. 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 (Commission) as a Staff Engineer.
O. Please give a brief description of your
educational background and experience.
A. I received a Bachelor of Science degree in
Chemical Engineering from the University of Southern
California in l-983, a Master of Science degree in
Mechanical Engineering from the University of Idaho in
2002, and a Doctor of Philosophy in Geophysics with a
Civil Engineering emphasis from Boise State University in
201-4. I have been a registered professional engineer in
Idaho since L998. I attended the Electrical Utility
Basic Practical Regulatory Program offered by New Mexico
State University's Center for Public Utilities.
Between 1988 and 2009, I held a number of
engineering positions at Micron Technology, Inc. From
1990 through 1996, I was also a facilities engineer in
the fdaho Army National Guard. In that capacity, I
oversaw the design, construction, repair, and maintenance
of facilities and roads at Gowen Fie1d, the National
CASE NO. IPC-E-I7-L3
L2/22/17
MORRISON, M
SIAFF
(Di) 1
l-
2
3
4
5
6
7
8
9
10
l_ t_
t2
13
1,4
15
L6
t7
l_8
l_9
20
21,
22
23
24
Guard's Orchard Training Range, and other National Guard
facilities in Southern Idaho.
I began work at the ldaho Public Utilities
Commission in 20L4. I am the Commlssion Staff's
principal witness in cases involving Cost of Service.
O What is the purpose of your testimony?
A. I will discuss the Company's proposal to
establish two new rate classes for its Residential and
Sma11 General Service Net Metering Customers. I will
also discuss the Company's proposal to reguire the
installation and operation of smart inverters for all new
customer-owned generator interconnections .
O. Please summarize your testimony.
A. In its Application, the Company argues that
there is an intraclass cost shift from net metering to
non-net metering customers, and that the consumption
patterns of net metering customers are sufficiently
different from those of non-net metering customers to
warrant the creation of two new net metering classes. I
will show that any intraclass cost shift is due to the
method by which net metering customers are compensated,
and not to any inherent differences in the consumption
patterns of net metering and non-net metering customers.
I will present Staff's proposal to modify Schedule 84,
Customer Energy Production Net Metering Service, so that
cAsE NO. rPC-E- l-7 - 13
L2/22/17
MORRISON, M
STAFF
25
(Di) 2
1
2
3
4
5
6
7
8
9
10
LL
t2
l-3
l4
l_5
15
a7
18
1,9
20
2t
22
23
24
25
net metering customers are compensated for the excess
energy they provide at avoided cost rates while
continuing to pay for the energy that they obtain from
the Company under their current rate schedule. I will
explain how Staff's proposal will correct any intraclass
cost shift without requiring any new rate classes. I
will recommend that the Commission initiate a docket in
which all interested partj-es can work together to
determine the appropriate avoided cost methodology used
to compensate net metering customers.
I will show that the Company's analysis using
its rrnet zero customerrr overstates the differences in the
consumptive patterns of net metering and non-net metering
customers, and that there is actually Iitt1e difference
between Ehe consumption patterns of these two groups.
The Company also proposes that all new
customer-owned generator interconnections be eguipped
with smart j-nverters conforming to the grid reguirements
of the Institute of Electrical and Electronic Engineers
(IEEE) standards 1-547 and l-547.1. Unfortunately, both of
these standards are sti11 being drafted by the IEEE, and
the Company was unable to provide draft copies for my
review, so I am unable to provide an analysis of either
the costs or benefits of the Company's proposal. I will
recommend that the Commission postpone a decision on this
CASE NO. IPC-E- 1,7 -]-3
L2/22/1,7
MORRISON, M
STAFF
(Di) 3
1
2
3
4
5
6
7
I
9
t-0
11
L2
13
1,4
l_5
l_5
l7
18
1"9
20
21,
22
23
24
25
proposal until such time as Commission Staff can review
them.
The Company also seeks to revise Schedule 72,
both to synchronize it with proposed changes to its net
metering program and to permit on-site inspection of
newly installed on-site generation systems when
cj-rcumstances beyond the Company's control exist. In
fact, the Company's proposed revisions to Schedule 72 are
guite substantial, and I will recommend that they be
considered in a separate docket.
O. What factors justify establishment of new rate
classes?
A. On pages 7 and 8 of its Application, the
Company explains that different rates may be justified by
factors such as cost of service, quantity of electricity
used, differences in conditj-ons of service, or the time,
nature, and pattern of use.
O. Has the Company met this standard?
A. No. The Company did not provide a Cost of
Servj-ce Study. fn j-ts response to Staff 's Production
Request No. 3, the Company indicated that it does not.
intend to perform a Cost of Service study until after the
Commission approves the Company's new rate classes
(Exhibit No. 101) .
As I will show, there are no meaningful
CASE NO. IPC-E-17-13
t2/22/t7
MORRISON, M
STAFF
(Di) 4
l_
2
3
4
5
5
7
8
9
10
11
12
13
l4
t-5
1,6
L7
18
19
20
2L
22
23
24
25
differences between net metering and non-net metering
customers in the quantities of electricity used,
differences in conditions of service, time, nature, and
pattern of use.
a. Who would be affected by the Company's
proposal?
A. A11 Schedule 1 Residential and Schedule 7 Sma11
General Servj-ce net metering customers would eventually
be moved to the Company's proposed net metering
schedules. In its Application, the Company indicated
that existing Residential and Small General Service net
metering customers would continue to take servj-ce under
Schedule 84 (Application at 10 and 11) ; however, in j-ts
response to Staff's Production Reguest No. 4, the Company
indicated that these customers would eventually be moved
to the Company's proposed net metering schedules (Exhibit
No. 702).
According to the Company's 201,7 net metering
report (Exhibit xo. 9), the majority of the net metering
systems in the Company's Idaho service territory are
owned by Schedule 1 Residential customers (1,137) .
Commercial and Industrial customers comprise the next
largest group of net metering customers (135). There are
also five irrigation customers.
Solar photovoltaic generators constitute 942 of
CASE NO . IPC-E- 1,7 -1,3L2/22/17
MORRISON, M
STAFF
(Di) s
the net metering systems currently connected to ldaho
Power's g'rid, followed by wind g'enerators (5?) , and
hydro/other generators (1?); however, the Companyrs
proposal would also apply to all Residentj-a1 and Sma11
General Service customers who generate their own power
using biomass, geothermal, or fuel ce11 technology.
O. What is the name plate capacity and growth rate
of Idaho Powerts net metering systems?
A. Between December 31 , 201-3 and March 31 , 20L7 ,
the cumulative nameplate capacity of Idaho Power's net
metering systems grew from 2.8L megawatt (MW) to 9.58 MV{,
which represents an annual growth rate of 45.8*. The
total nameplate capacity of wind/hydro/other decreased
slightly over this time period, so virtually all of this
increase was due to increases in the number of solar
systems installed in Idaho Power's service territory.
O. Please explain how customers are compensated
for the excess energy that they produce under
Schedule 84.
A. Schedule 84 is open to customers from all Idaho
Power rate classes except those taking service under
Schedule 4 (Residential Energy Watch Pilot Pl-an) and
Schedule 5 (Residential Time-of-Day Pilot Plan). Under
Schedule 84, net metering customers remain in their rate
class, but receive a kilowatt hour (kwh) credit for
CASE NO. IPC-E-17-13
L2/22/L7
(Di) 6MORRISON, M
STAFF
l_
2
3
4
5
5
7
B
9
10
11
!2
l_3
l4
15
1,6
L7
18
L9
20
2t
22
23
24
25
1
2
3
4
5
5
7
8
9
10
11
t2
13
t4
15
16
L7
18
t9
20
21,
22
23
24
25
excess energy that they produce. Currently, the energy
consumed and produced by net metering customers is netted
monthly: That is, at the end of each monthly billing
cyc1e, excess energy produced by the net metering
customer is subtracted from the energy provided by Idaho
Power, and the resulting difference applied to the rates
appropriate for that customer's rate c1ass. fn the event
that the customer produces more energy than they consume,
a kilowatt hour credit is carried forward and applied to
the subsequent billing cyc1e. Net metering customers
receive no monetary compensation for the excess energy
that they produce, but kilowatt hour credits may accrue
indefinitely. Schedule 1 (Residential) and Schedule 7
(General Service) customers are limited to generation
systems with a total nameplate capacity rating of 25 kw
or 1ess.
a. Why is the energy consumed and produced by net
meterj-ng customers netted monthly?
A. Prior to the advent of AI,II (Advanced Metering
Infrastructure), customer output was measured with a
meter that spun in one direction when power was being
consumed by a customer, and spun the other direction when
power was being put onto the grid by that customer, so
that the meter displayed the I'net" energy consumed by the
customer at the end of each monthly billing cycle. In
CASE NO. IPC-E-17-]-3
L2/22/L7
MORRTSON, M
STAFF
(Di) 7
1
2
3
4
5
5
7
I
9
10
11
L2
l_3
1,4
15
15
l7
18
1,9
20
2L
22
23
24
25
its response to Staff's Production Request No. 7, the
Company explained that its current AI,II meters record net
hourly consumption/generation, so it is now possible to
net consumption and production for each hour (Exhibit
No. 103).
O. Under Staff's proposal, how would Schedule 84
be modified?
A. In short, Staff proposes that Section 1 of
Schedule 84 be changed to take advantage of the Company's
AMI meters by netting consumption/generation hourly
rather than monthly. Under Staff's proposal, the net
metering customerrs bil1ed consumption would be
determined by summing the consumption from each hour in
which there j-s net consumption, and the result applied to
applicable Schedule l- or Schedule 7 rates. The net
metering customerrs excess energy credit would be
determj-ned by summing the production from each hour in
which there is net production and applying the result to
an avoided cost rate. The net metering customer's bill
would then be calculated by subtracting the excess energy
credit from the customer's biIled consumption.
O. What intraclass cost shifting currently occurs
within the Residential Schedule 1 and Sma11 General
Service Schedule 7 rate classes?
A. The Company's Residential and Small General
CASE NO. IPC-E- L7 -1,3t2/22/1,7
MORRISON, M
STAFF
(Di) 8
Service customers pay a $5.00 monthly service charge and
a per kWh energy charge. The $5.00 monthly service
charge is insufficient to cover either the Companyrs
customer related costs such as billing, customer service,
and service drops, or its fixed costs of generation,
transmission, and distributj-on, so that the per kWh
energy charge must be higher than the cost of energy in
order to assure that the Company recovers its revenue
requirement. Non-net metering customers with average
bi11ed consumption pay for the costs j-ncurred by the
Company on their behalf ,' however, customers whose bi11ed
consumption is below average don't completely pay for the
costs that the Company incurs serving them, and customers
whose biIled consumption is above averag'e pay more than
their share. Very few customers are rraverage, r' so most
Schedule 1 and Schedule 7 customers either subsidize, or
are subsidized by other customers within their class.
O. How does Schedule 84 create an intraclass cost
shift from net metering to non-net metering customers?
A. Net metering customers are being
overcompensated for the energy that they produce. The
value of excess energy provided by net metering customers
is due, primarily, to the energy costs that it aIlows the
Company to avoid; however, net metering customers are
effectively compensated at full retail rates. As
(Di) eCASE NO. IPC-E- 17 -1.3
t2/22/17
MORRISON, M
STAFF
1
2
3
4
5
6
7
I
9
10
l_ l_
t2
13
1,4
15
t6
L7
18
L9
20
2t
22
23
24
25
discussed earlier, Idaho Power's Schedule 1 and
Schedule 7 retail rates are substantially higher than the
Company's energy costs. As explained on pages 5
through 9 of Ms. Aschenlcrenner's testj-mony, this concern
was raised by Staff in Case No. IPC-E-01-39 (Applicatj-on
for Approval of a New Schedule 84).
a. Briefly describe the data that you used to
evaluate potential cost shifting between net metering and
non-net metering customers.
A. The Company provided hourly consumption data
for all Idaho net metering customers who were connected
to Idaho Power f or the period ,January 1, 201,5 through
December 31, 201,6. This included data for 555 Schedule 1
Resi-dential customers and 23 Schedule 7 Sma11 Commercial
customers. Values were positi-ve for hours during which
net metering customers received power from the Company,
and negative during hours in which customers provided
excess energy to the Company (Staff Production Reguest
No. 8, Exhibit No. 104).
The Company also provided hourly consumption
data for a stratified random sample of 498 Residential
non-net metering customers (Staff Production Reguest
No. a2, Exhibit No. r05); however, data for 1-1 of these
customers was incomplete and not used. f used data from
the remaining 487 Resj-dential non-net metering customers
CASE NO. IPC-E-l.7-]-3
t2/22/t7
MORRTSON, M. (Di) 10
STAFF
1
2
3
4
5
6
7
8
9
10
l_ l_
L2
13
L4
15
15
1,7
18
1,9
20
2a
22
23
24
25
t_
2
3
4
5
6
7
I
9
10
11
t2
13
l4
15
15
l7
18
19
20
2L
22
23
24
25
in my analysis.
O. Please summarize your analysis.
A. Because residential customers account for most
net metering generation capacity, and virtually all net
metering growth, my analysJ-s focused on Residential
Schedule 1 customers. f used the Companyrs 201-6 rates
for all analyses. In order to estimate an average net
metering customer's bill under Staff's proposal, I
used 2016 DSM avoided cost rates,' however, as I indicated
earlier, I believe that the exact methodology for
calculating net metering avoided cost rates should be
determined in a separate docket. I have summarized my
analysis in Table 1.
Annual
kWh Consumed
Excess kWh
Billed kwh
Bill before Excess Generation Credit
Excess Generation Credit
Final Bill
Non-N EM
Customers
S r,mr.er
NEM Excluding
Schedule 84 Credit
NEM with Schedule
84Credit NEMStaffProposal
113
151.34
133.96
Table l-:
NEM)
S 1,164.34 s 926.75 s L,027.38
Consumption and billing for average non net metering (Non-
and Net Metering (NEM) cusLomers under current rates andStaff's ProposaJ-.
A. Currently, what is the magnitude of the cost
shift under Schedule 84?
A. Under Schedul-e 84, a net metering customer's
monthly excess generation is subtracted from her monthly
consumption, and so an average net metering customer pays
substantially less ($gZe.l5/yr) than she would pay
CASE NO. IPC-E-17-13
L2/22/L7
MORRISON, M
STAFF
tt,78t 13,113 13,113
0 3,44A 3,4A4
LL,78L t3,tt3 9,669
s 1,001.51 s 1,151.34 926.7ss
N/A N/A N/A
(Di) 11
1
2
3
4
5
6
7
I
9
t_0
11
1,2
13
l4
l_5
t_5
l7
t-8
19
20
2t
22
23
24
25
without the Schedule 84 excess energy credit
(#1,154.34/yr). A portion of the $237.59 difference
represents the avoided cost due to excess energy provided
by the net metering cusEomer ($135.96) , and is therefore
not a subsidy. The remaj-ning $100.63 represents the cost
shift from an average residential net metering customer
to the general body of residential ratepayers. A summary
of consumption, excess generation, and billing
information can be found in Table 1.
O. Does Staff's proposal eliminate all intraclass
subsidies?
A. Staf f 's proposal eliminates all j-ntraclass
subsidies that are due to the Schedule 84 Net Metering
program; however, intraclass subsidies that are not
related to net metering remain in pIace. By virtue of
their slightly greater average consumption (tab1e 1),
there would be a sma11 subsidy from averag,e net metering
customers to non-net metering customers,' however, as
discussed earlier, this type of cost shift is not unique
to net metering customers.
THE COMPAIIYIS NET ZERO CUSTOMER AIVAI,YSIS
O. What are net zero customers, and why are they
important?
A. As we have already discussed, Schedule 84
aIlows net metering customers to rrbankrr energy credits
CASE NO. IPC-E-17-13
t2/22/1-7
MORRTSON, M
STAFF
(Di ) 1"2
for use at a later time, day, or month. Under
Schedule 84, some net metering customers are able to bank
enough credits during one tj-me period to cover their
consumption for the entire year: These customers, with
no net annual consumption, are ca1Ied net zero customers.
Net zero customers only pay their $5.00 monthly service
charge, and because the monthly service charge is
insufficient to cover the Company's fixed and customer
related costs, net zero customers are recj-pients of a
large intraclass subsidy from other members of their rate
cIass.
O. In their testimonies, Ms. Aschenbrenner and Mr.
Ange11 discuss the effects of net zero customers on the
system (Aschenbrenner Di, pages 32 through 36; Ange11 Di,
pages l-1 through l-4). What is wrong with this analysis?
A. The Company's analysis compared consumption of
a single net metering customer to that of a nearby non-
net metering customer (Ange11 Di, page 11). Neither the
net zero net metering customer nor the non-net metering
customer used for comparison were typical customers.
Given the tremendous diversity within the Residential
cIass, it isn't surprising that the Company was able to
find a pair of customers to demonstrate its point;
however, it is inappropriate to use data from a single
pair of customers to establish a new rate c1ass.
CASE NO. IPC-E-17-13t2/22/L7 MORRTSON, M. (Di) 13
STAFF
1
z
3
4
5
6
7
8
9
10
1L
L2
13
l4
l_5
15
L7
18
1"9
20
21-
22
23
24
25
1
2
3
4
5
6
7
I
9
10
11
L2
13
L4
l_5
16
l7
18
1"9
20
2L
22
23
24
25
About l-1.5? of Idaho Power's Residenti-a1
Schedule l- Net Metering customers are net zero customers,
so while net zeyo customers constitute an important
group, their consumption patterns are not representative
of typical net metering customers. A more representative
comparison j-s obtained by comparing consumption patterns
of averag'e net metering customers with those of average
non-net metering customers.
On page L2 of his testimony, Mr. Ange11
provides a graph comparing the hourly consumption of the
Company's selected net metering customer to that of a
nearby non-net metering customer on its system peak day
(.fune 29, 2OL6) . I have reproduced Mr. Ange11 's graph as
Figure 1 of my testimony. For comparison, Figure 2 j-s a
graph of hourly consumptj-on of average net metering and
average non-net metering customers on the same day. We
note that peak consumption of the Company's selected
customers (Figure 1) is much greater than that of average
customers (Figure 2). The most striking difference
between these two graphs is seen at 1:00 pm when the
Company's selected net zero customer's net production
peaked at about 4.5 kW (Figure 1). By contrast, the
average net metering customer's generation peaked at
0.74 kW, or only about one sixth the peak generation of
the Company's net zero customer (Figure 2) .
CASE NO. IPC-E-]-7-]-3
L2/22/1,7
MORRISON, M
STAFF
(Di ) 1,4
t_
2
3
4
5
6
7
I
9
10
11
t2
l-3
t4
15
1,6
l7
L8
19
20
2L
22
23
24
25
lrrrr,Jf
ft
L 2 3 4 5 6 7 8 I r0111213141516171819202L222324
Hor Endha
r "l{et Zero" ltet Meterlng Customer r Standard Senrice Resld€fltiel Customer
=I II
I'
8
6
4
2 IJJ
{2t
{{l
{61
Figure 1: Company's comparison of hourly consumption for a
selected net zero cusUomer to a nearby non-neE metering customer onthe Company's system peak day. Reproduced from Angell Di, Figure 1-.
Average Net Metering and Non-Net Metering Hourly
Consumption (System Peak Dayl
8
5
4
2
3x I r r h h h h r,r .r.r.r,t.l I .l I il il [ ll II I I
{2}
(4)
(6)I 2 3 4 5 6 7 8 I 101112131415161718192021222324
Hour Ending
I Net Meterirg I Standard Service (NoftNet ireterirEl
Fi-gure 2: Staff's comparison of consumption of average net metering
customers to average non-net metering customers on the Company's
system peak day (ilune 29th, 201,6) .
CASE NO. IPC-E-]-7-13
L2/22/t7
MORRISON, M
STAFF
(Di ) 1s
1
2
3
4
5
5
7
8
9
t-0
11
a2
13
t4
15
15
L7
18
t9
20
21
22
23
24
25
a. Would Staff's proposal correct the intraclass
cost shift from net zero customers to non-net metering
customers?
A. Yes. Under Staff's proposal, net zero
customers would pay fu1I retail rates during hours in
which they are net consumers of energy, and receive
credit for excess energy at avoided cost rates. Because
avoided cost rates compensate customers only for costs
that they a11ow the Company to avoid, there would be no
impact to non-net metering customers.
NET METERING VS. NON-NET METERING CONSI'MPTION PATTERNS
a. How do consumption patterns of net metering
customers differ from those of non-net metering
customers?
A. There is Iitt1e dj-fference in the consumption
characteristics that cause the Company to incur fixed
costs. The primary consumption characteristics that
cause the Company to incur fixed costs are contribution
to coincident peak (CP), group non-coincident peak (NCP),
and indivj-dual peaks. These are summarized in Table 2.
Peak
lndividual
Contribution to CP 7:00
Non-Net Non Coincident Peak 7:00
Net Meteri ng Grou p Non Coi ncident Peak ll2/ 78/ 2OL6, 9:00 am)
Table 2: Peak magnitudes and times for net metering and non-netmetering customers.
CASE NO . IPC-E- 1,7 -L3
t2 / 22 /17
MORRISON, M
STAFF
9.13 7L.42
2.867 2.31L
2.992
2.33
(Di ) L6
Schedule l- Residential customers are a diverse
class; however, the distribution of individual
consumption patterns from both groups is nearly
identical. Figures 3 and 4 allow us to compare the
magnitude and timing of individual customer peaks.
Consumption patterns of both groups are similar, with
individual peaks occurring throughout the year and
concentrations of peaks occurring in summer and winter
months. For both net metering and non-net metering
customers, most individual peaks are less than 35 kW.
Net Metering Peak Load by Month (2016)
80
70
60
isod!!,|o
iro
m
10
a
a
hi*," -. ..'r.. 6. rl:'r'tirr.i $. . :.:i.. . ,r;
a a
taa.#
a
a a
a a
f.
-a
o or aaaf,r rB
a
a
'IMAMJJASOTID Month
Figure 3: Net. metering Peak Load by Month for all 201-5 residentialnet metering customers.
(Di ) 1,7CASE NO. IPC-E-L7_I3
L2/22/1-7
MORRISON, M
STAFF
1
2
3
4
5
6
7
I
9
10
L1
L2
13
t4
15
15
1,7
18
1,9
20
2t
22
23
24
25
1
2
3
4
5
5
7
I
9
t-0
11
t2
13
t4
l-5
l_5
1,7
18
l_9
20
2t
22
23
24
25
g)
m
60
isoi1!8{0
E30c
20
10
0
Non-Net Metering Peak Load by Month (2015)
M
*: . #r,r6i.rrl ..:.'.".' l'tj{il
a
iXFi;,il;r
o
DoA
Mo.th
Figure 4: Non-Net Metering Peak Load by Month for Stratified
Random Sample of residential non-net metering customers.
There are some sma11 differences between the
two groups. On average, net metering customers demand
less power (2.311 kw) than non-net metering customers
(2.851 kW) at system coincident peak (,June 29t}r between
5:00 pm and 7:00 pm) . Power consumed at coinc j-dent peak
is an important component of the Coincident Peak factor
used to allocate fixed generation and transmission costs
in Cost-of-Service studies. Had the Company performed a
Cost-of-Service Study, it would likeIy have allocated
slightly less generation and transmj-ssion plant cost to
net metering customers. Given the large fraction (942)
of residential net metering systems using solar
greneration, it isn't surprisj-ng that summertime
coincident peak consumption of net metering customers is
reduced.
Class non-coincident peak is an important
component of the Non Coincident Peak factor used to
CASE NO. IPC-E- L7 -1.3
L2/22/L7
MORRTSON, M
STAFF
(Di) 18
a
1
2
3
4
5
6
7
8
9
10
1L
1-2
13
t4
15
t6
t7
l-8
L9
20
2t
22
23
24
25
allocate distribution plant in cost-of-service studies.
Using data provided by the Company, we find that net
metering customers' average non-coincident peak was less
(2.330 kW) than that of non-net metering customers
(2.992 kW). As a group, net metering customers peak
during the winter rather than during the summer.
On the other hand, individual peak loads are
important determinants of costs that the Company expends
on distribution p1ant, and in particular, on the costs of
secondary transforTners and service drops. Average
individual net metering peaks are somewhat higher
(1-1-.420 kW) than those of non-net metering customers
(e.130 kw) .
Had the Company performed a Cost-of-Service
Study, it is difficult to determine whether it would have
allocated more or less distribution plant to net metering
customers than to non-net metering customers.
I should reiterate that these differences are
guite smaI1 relative to the total variability among
Schedule 1 customers. Had the Company conducted a Cost-
of-Service study, it is 1ikeIy that they would have
determined the differences in the overal-I costs of
serving these two groups to be very smaII.
CASE NO. IPC-E-17-13
t2/22/1-7
MORRISON, M
STAFF
(Di ) Le
1
2
3
4
5
5
7
I
9
10
1,2
11
l-3
t4
15
16
L7
18
L9
20
2t
22
23
24
THE COMPAIiIY I S PROPOSAL TO REQUIRE ALL NEW NET METERING
CUSTOMERS TO INSTALL Al{D OPERATE SMART INVERTERS
O. Why do you oppose the Company's proposal to
reguire all new net metering customers to use smart
inverters?
A. The Company proposes that all new net metering
customers be required to install and operate smart
inverters as defined by the Institute of Electrical and
Electronic Engineers. Unfortunately, the applicable IEEE
Standards and definitions (IEEE 1-547 and IEEE t547.1-\
won't be published until 201-9 (Company's Response to
Production Request No. 1, Attachment 2, Page 15, Exhibit
No. 105), so there is no way to evaluate either the
benefits or costs of the Company's proposal. In fact,
the IEEE hasn't even released a draft copy of the
standard. In short, the Company is reguesting that
Commission adopt IEEE 1,547 and IEEE 1547.1 before these
standards have been released.
O. Was the Company able to provide any information
about the proposed content of IEEE L547 and IEEE 1,547.L?
A. The Company provided two draft power point
presentations (Exhibit Nos. 1-07 and 108) . Both
presentations included disclaimers that the presentations
and views expressed in them are those of individuals, and
not the formal- position of the IEEE, so the Company
CASE NO. IPC-E-17-13
t2/22/t7
MORRISON, M
STAFF
25
(Di ) 20
didnrt provide any hard information about either of the
proposed smart meter standards.
THE COMPAT{Y' S PROPOSAIS TO }ODIE:T SCEEDI'LE 72
O. Pl-ease summarj-ze the Company's proposed changes
to Schedule 72.
A. In its Application, the Company states that it
seeks to revise Schedule 72 to j-ncorporate defined terms
necessary to slmc the interconnection reguirements
between Schedule 72 and proposed Schedules 6 and 8. The
Company also states that it proposes to make one minor
revision to Schedule 72 to a1low the Company additional
time to complete the on-site inspection of a newly
installed on-site generation system when circumstances
beyond the Company's control- arise (Application at 11. )
In fact, the Company's proposed modlflcations
are not minor, and constitute a major revision to
Schedule 72 (Company Exhibit No. 5). Schedule 72 applies
to all energy providers who j-nterconnect with the
Company's grid, lncluding its PURPA and net metering
customers. Because the Company's proposed modifications
to Schedule 72 go far beyond the scope of its
application, the Company's proposed changes should be
considered in a separate case that would ensure input
from all stakeholders.
CONCLUSIONS AIID RECOMMEIIDATIONS
(Di) 2tCASE NO. IPC-E-17-].3
t2 / 22 /17
MORR]SON, M
STAFF
t_
2
3
4
5
5
7
8
9
10
11
1,2
13
t4
15
15
17
18
19
20
2t
22
23
24
25
1
2
3
4
5
6
7
8
9
10
11
1,2
13
L4
15
15
l7
18
t9
20
2L
22
23
24
25
a. Please summarize your recommendations regarding
the Company's proposal to establish two new rate classes
for its Residential and Sma11 General Service net
metering customers.
A. The new rate classes provided by the Company
are unnecessary. Any intraclass cost shift from net
metering to non-net metering customers arises from
Schedule 84' s compensation methodology, which effectively
compensates net metering customers at rates that are
g'reater than the value of the energy that they provide to
the Company. The simplest way to eliminate this
intraclass subsidy is to modify Schedule 84 so that net
metering customers pay fuII retail rates for the hours in
which they are net consumers of energy, and receive
credit at avoided cost rates for the hours in which they
produce excess energy. I recommend that the Commission
initiate a docket in which the Company and interested
parties can work together to determine the appropriate
avoided cost methodology used to compensate net metering
customers.
O. Please summarize your recommendations regarding
the Company's proposal to reqr.rire all new net metering
installations to use smart inverters.
A. The Company is asking the Commission to approve
a standard that has not been released, and is thus
CASE NO. IPC-E- 17 -1,3
L2/22/L7
MORRISON, M
STAFF
(Di ) 22
1
2
3
4
5
5
7
I
9
l-0
11
L2
l4
13
15
l_6
77
18
19
20
2L
22
23
24
unavailable for revi-ew. I recommend that the Commission
deny the Company's request to reguire all new net
metering installations to use smart inverters.
O. Please summarize your recommendations regarding
the Company's proposed modifications to Schedul-e 12.
A. The Company's proposed modification to Schedule
72 includes a large number of revisions that were not
described in the Company's Applicatj-on or testimony.
Because Schedule 72 affects all generation facilities who
connect to the Company's grid, and not just net metering
customers, I recommend that these changes be submitted
and considered as part of a separate case.
O. Does this conclude your testimony in this
proceeding?
A. Yes, it does.
CASE NO. IPC-E- L7 -1,3
1-2/22/17
MORRTSON, M. (Di)
STAFF
25
23
REQUEST NO. 3: On page I of its Application, the Company states that
"Establishing separate customer classes now will position the Company to study this
segment of customers, providing the data necessary to understand how this customer
segment utilizes this system." What information will the Company be able to gather that
is not currently available for these customers?
RESPONSE TO REQUEST NO. 3: To provide context, the full quote from page
19 of Mr. Timothy E. Tatum's testimony stated that:
The establishment of sirnilarly situated cuslomers or
customer classes has been a long-standing and important
first step in the ratemaking process. Taking this important
first ratemaking step now will position the Company to study
this segment of customers, providing the data necessary to
understand how this customer segment utilizes the
Company's system. The data quantiffing the usage of the
system will inform what costs (revenue requirement) are
appropriately allocated to the newly established customer
classes in a future rate proceeding (class cost-of-service
process).
Tatum Dl, p. 19, lines 14-24.
The Company is currently able to gather the information that is necessary to
study various segments of customers; however, should the Commission decline to
authorize the establishment of the requested new customer classes, the Company
would have no reason to modify its class cost-of-service study or ratemaking processes.
lf the ldaho Public Utilities Commission ("Commission") determines there are
differences that warrant the establishment of new customer classes, the Company will
assign costs to the new customer classes in the class cost-of-service study and design
rates specific to those classes as part of a future rate proceeding. lf the Commission
detennines no differenoes exist that warrant the creation of a new customer class for
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF. S
Exhibit No. l0l
Case No. IPC-E-17-13
M. Morrison, Staff
12/22/17 Page I of 2
customers with on-site generation, the Company will continue to allocate costs to the
residential and small general service customer classes that exist today.
fhe response to this Request is sponsored by Tim Tatum, Vice President of
Regulatory Affairs, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REOUEST OF THE COMMISSION STAFF - 6
ExhibitNo. 101
Case No. IPC-E-17-13
M. Morrison, Staff
l2l22ll7 Page2 of 2
REQUEST NO. 4: On page$ I and 10 of its Application, the Company states
that "The data quantifying the usage of the system will inform what costs and benefits
(revenue requirement) are appropriately allocated to the newly established customer
classes in a future rate making process (class cost-of-service process)". Given that the
Company's proposed Schedules 6 and 8 would initially have zero customers, how many
years will be required before there are sufficient customers in these new classes to
d evelop a ccu rate cost-of-service a I locators?
RESPONSE TO REQUEST NO. 4: The Company cannot determine how many
years will be required before there are sufficient customers in Schedules 6 and 8 to
perform a stand-alone cost-of-service study. However, all customers with on-site
generation will be used to develop cost-of-service allocators for the new customer
classes, those who remain on Schedule 84 and those taking service under Schedules 6
and 8. The Company has proposed that existing residential and small general service
net metering customers remain on Schedule 84 for a period of time, where the term of
the transition period be determined by the Commission as part of a future rate
proceeding; however, they will transition to Schedules 6 and I at the end of the
transition period. Their usage characteristics accurately represent the segment of
customers with on-site generation, regardless of which tariff schedule they take service
under during the transition period.
The response to this Request is sponsored by Tim Tatum, Vice President of
Regulatory Affairs, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF. T
Exhibit No. 102
Case No. IPC-E-17-13
M. Morrison, Staff
t2/22/17
REQUEST NO.8: ln Exhibit 9, the Company states that, as of December 31,
2016, ldaho Power's net metering service consisted of 1,067 active systems. For each
system that was connected to ldaho Power for the entire period between January 1,
2016 through December 31 ,2016, please provide the following information:
a, The schedule under which the net metering customer takes power.
b. The County in which the customer is located.
c. Net hourly power consurnption/production data for the 2016 calendar year.
RESPONSE TO REQUEST NO. 8: Please see the attached Excel file which
includes the hourly net energy consumption for all net metered customers who had an
AMI meter and who were taking net metering service for the entire period between
January 1,2016, through December 31, 2016. The Company has provided the schedule
under which the net metering customer was taking service and the county in which the
customer was located.
It is important to note that the attached data is net hourly energy
consumption/production data by qustomer, not by system. A customer may have
multiple systems, possibly with different generation sources, attached to a service point
(meter). ln that case, each generation source is considered a different system;
however, because the energy consumption is metered at a single point, a customer with
multiple systems is one customer. Please reference footnote No. 3 in Exhibit 9.
The response to this Request is sponsored by David Angell, Transmission and
Distribution Planning Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISS]ON STAFF. 15
Exhibit No. 104
Case No. IPC-E-17-13
M. Morrison, Staff
12122117
REQUEST NO. 7: On page 4 of its Application, the Company states that it has
deployed Advanced Metering lnfrastructure (AMl) in its service area enabling the
Company to achieve more precise usage measurement and facilitate more
sophisticated, cost-based rate designs. Please explain how AMI might be used to
achieve more sophisticated, cost-based rate designs for its net metering customers.
Does the Company also propose updating rate designs for its non net metering
classes?
RESPONSE TO REQUEST NO. 7: Prior to the deployment of Advanced
Metering lnfrastructure ("AMl"), ldaho Power used mechanical and solid-state meters to
measure consumption for residential and small general service customers. These
meters measured only the kilowatt-hour ("kWh") consumption, and the Company
retrieved this data monthly according to the meter read date of the customer's billing
cycle. ldaho Power's AMI system collects additional data from the AMI meters that
enables the Company to better develop cost-based rate designs. The additional data
provided by the AMI system is listed betow:
o 1S-minute max demand - ldaho Power's AMI meters record the 1S-minute
maximum demand. The 15-minute maximum demand enables the Company
to implement demand rates for residential and small general service
customers using a 15-minute maximum demand.
. Hourly kwh - ldaho Power's AMI meters record the net hourly energy
consumption and/or generation. The hourly energy data enables the
Company to implement time-of-use rates for residential and small general
service customers with on-site generation.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF. 13
Exhibit No. 103
Case No. IPC-E-17-13
M. Morrison, Staff
12/22/17 Page I of 2
. Hourly kilowatt ("kW') - The hourly kWh can be used as a 60-minute
maximum demand. The 60-minute maximum demand enables the Company
to implement demand rates for residential and small general service
customers using a 60-minute maximum demand.
One of ldaho Power's objectives regarding rate design is to establish prices that
primarily reflect the cost of the services provided. While the Company is not currently
proposing pricing changes for net metering or standard service customers as part of its
proposal, ldaho Power will continue to evaluate and propose modifications to the rate
design of all customer classes in future rate case proceedings.
The response to this Request is sponsored by Tim Tatum, Vice President of
Regulatory Affairs, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF. 14
Exhibit No. 103
Case No. IPC-E-17-13
M. Morrison, Staff
l2l22ll7 Page2 of 2
REQUEST NO. 12: Please provide the following data for a stratified random
sample of ldaho Power's residential non-net metering customers who were connected
to ldaho Power for the entire period between January 1, 2016 through December 31,
2016'.
a. The County in which each customer is located.
b. Hourly power consumption data. Please explain how the Company
accounted for changes from MST to MDT and vice versa.
c. An explanation of the method used to determine sampling strata, sample
sizes, and weighting factors.
d. An explanation of any missing data.
RESPONSE TO REQUEST NO. 12:
a. The following table lists the county associated with each stratum.
County Strata
Ada 1,2,3, and 4
Blaine 5, 6, 7, and I
Valley 9, 10, 11, and 12
Payette 13,14,15, and 16
Bannock 17,18,19, and 20
Twin Falls 21,22,23, and 24
b. Please see Attachment 2 to the Company's response to Vote Solar's
Request No. 27 for the 2016 ldaho Residential Sample hourly data. To adjust for
Daylight Savings Time ("DST"), the Company formatted the data so that there are 24
hours/per day in both the spring and the fall" For the spring DST shift, the hour ending 3
a.m. is left blank. For the fall DST shift, the hour ending 3 a.m. is repeated, and
therefore, the Company calculates an average of the two hours, and reports the
average in the hour ending 3:00 a.m.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REOUEST OF THE COMMISSION STAFF.2 Exhibit No. 105
Case No. IPC-E-17-13
M. Morrison, Staff
l2l22ll7 Page 1 of 3
c. Please see the Company's response to Vote Solar's Request No. 36(d) for
a description of the sampling methodology used to determine sampling strata and
sample sizes. The strata weights are provided with the hourly data.
d. Missing data can be categorized in the following three scenarios:
r The Company's Advanced Metering lnfrastructure ("AMl") system,
which uses power line carrier technology, experiences occasional
communication issues when trying to retrieve data over the power line.
For example, if a feeder is taken out of service for maintenance or if a
section of line goes down due to an unplanned outage, the AMI system
may be temporarily unable to communicate with the meters on that line
depending on if there is an alternate path to get the readings. The
Company does attempt to go back and retrieve missing data but may
not be able to retrieve all missing data given that the system has
limited bandwidth. lt is important to note that the hourly data is not
used for billing purposes for Schedule 1, Residential Service Standard
Service, customers. The AMI system retrieves a different register,
called the daily register read, that is used for billing. lt is for this reason
that the Company over-samples when the samples are designed. As
stated in the Company's response to Vote Solar's Request No. 36, the
ldaho residential sample was designed to include 449 sample points;
however, the Company has a target sample size of 498 to ensure that
it has data for 449 sample points for each hour in the event that there
is missing data for some sample points.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF.3 Exhibit No. 105
Case No. IPC-E-17-13
M. Morrison, Staff
12/22/17 Page 2 of 3
. Demand response participants are removed from the sample in
months that demand response events are called. ln the case of the
residential customer class, demand response events were called in
June and July of 2016. This methodology is consistent with the filed
class cost-of-service study from the Company's last general rate case.
. There is missing data on March 13,2017, due to spring DST. Please
see part (b) of this response for an explanation of how the Company
handles the changes from Mountain Standard Time to Mountain
Daylight Time and vice versa.
The response to this Request is sponsored by Dave M. Angell, Transmission and
Distribution Planning Manager, ldaho Power Company.
DATED at Boise, ldaho, this 20th day of November zAfi.
SA D. NO OM
Attorney for ldaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REOUEST OF THE COMMISSION STAFF - 4
Exhibit No. 105
Case No. IPC-E-17-13
M. Morrison, Staff
12/22117 Page 3 of 3
,K;8. #,,,/-t,,*r*-
Dates lAetivrtreq Status
Tentative Timeline to Ballot for PL547.L
P1547.1 WG meeting - Draft 1 initiated
P1547.1 subgroups work and complete Draft 1
P1547.1 Draft 1 posted for WG consideration
Comments posted to iMeet Centra!
P1547.1 WG meeting - Draft 1 discussed
P1547.1 Draft 2 posted for WG meeting
P1547.1 WG meeting - Draft 2 discussed
P1547.1 Draft 3 posted for WG meeting
P1547.1 WG meeting - Draft 3 discussed
P1547.1 Draft 4 posted for WG meeting
P1547.1 WG meeting - Draft 4 discussed
P1547.1 Draft 5 posted for WG meeting
P1547.1 WG meeting - Draft 5 discussed
P1547.1 Pre-ballot draft sent to WG
P1547.1 WG meeting - Finalize Draft 6 for ballot
P1547.1 lnitial IEEE ballot
Resolve ballot comments
P1547.1 Published
Done
Done
Done
Done
Done
Done
Done
Done
Done
Ongoing
ercrrbfrrdng
fo.
Lffigl
Hunpnitl
Exhibit No. 106
Case No. IPC-E-17-13
M. Morrison, Staff
t2/22/17
June 16,2016
Summer 2016
September 30, 2016
October 15,2016
October 27-28,2016
January 31,2017
March 2,2017
May 19,2017
June 20-21,2017
September 2017
November 2017
January 2018
March 2018
May,2018
June,2018
Aug-Sept 2018
Oct 2018 - Jan 2019
2019
157
IEEE 1547, IEEE Standard for
lnterconnecting Distributed Energy
Resources
for IEEE's Renewable Energy Standards Tutorial
at2017 IEEE EPEC
Gharlie Vartanian, MEPPI,
IEEE 1547 Working Group Secretary
October 22,2017
Saskatoon, Saskatchewan OlreeMrryttugl,dtuNtiry
Exhibit No. 107
Case No. IPC-E-17-13
M. Morrison, Staff
12/22/17 Page I of 2
OrcgEM9t@,dntut*
Disclaimer
This presentation and drscussion here on IEEE 1547
are individual's views and are not the formal position,
explanation or position of the IEEE.
Exhibit No. 107
Case No. IPC-E-17-13
M. Morrison, Staff
12/22117 Page2 of 2
7
Update on IEEE P1547.L Revision:
Dr. Anderson Hoke, P.E., NREL, Chair P1547.1 Working Group(WG)
October 30, 20L7
Olese
MwNiq,
fot
ledlrrdggy
Humonity
Exhibit No. 108
Case No. IPC-E-17-13
M. Morrison, Staff
l2l22ll7 Page I of 2
Stondord Conformance Test Procedures for
Equipment lnterconnecting Distributed Energy
Resources with Electric Power Systems ond
Associoted lnteffoces
DISCLAIMER
This presentation and discussion here on
IEEE P1547 and IEEE P7547.7 are
individual's views and are not the formal
position or explanation of the IEEE.
e trrr
tfur&rglu Tdnologl
Exhibit No. 108
Case No. IPC-E-17-13
M. Morrison, Staff
12122117 Page I of 2
7
2 7
CERTIFICATE OF SBRVICE
I HEREBY CERTIFY THAT I HAVE THIS 22ND DAY OF DECEMBER 2017,
SERVED THE FOREGOING DIRECT TESTIMONY OF MICHAEL MORRISON, 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
BOISE 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]
erin.ceci [e-mail]
ELIAS BISHOP
AURIC SOLAR LLC
2310 S 1300 W
W VALLEY CITY UT 84119
E-MAIL: elias.bis@
ANTHONY YANKEL
12700 LAKE AVENUE
UNIT 2505
LAKEWOOD OH 44107
E-MAIL: [e-mail]
TOM BEACH
CROSSBORDER ENERGY
2560 9TH STREET, SUITE 2I3A
BERKELEY CA 94710
E-MAIL: tomb@,crossborderenergy.com
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
I02 S EUCLID #207
PO BOX 2308
SANDPOINT ID 83864
E-MAIL: mn),[e-mail]
ERIC L OLSEN
ECHO HAWK & OLSEN PLLC
PO BOX 6119
POCATELLO ID 83205
E-MAIL: [e-mail]
KELSEY JAE NLINEZLLC
920 N CLOVER DR
BOISE ID 83703
E-MAIL : kelsey@kelseyj aenunez.com
ELECTRONIC ONLY
MICHAEL HECKLER
michael.p.heckler@ gmail.com
ZACK WATERMAN
z,ack b.orq
CERTIFICATE OF SERVICE
ABIGAIL R GERMAINE
DEPUTY CITY ATTORNEY
BOISE CITY ATTORNEY'S
PO BOX 500
BOrSE rD 83701-0s00
E-MAIL : [e-mail]
DAVID H ARKOOSH
LAW OFFICE OF DAVID ARKOOSH
PO BOX 2817
BOISE ID 8370I
E-MAIL: [e-mail]
DAVID BENDER
EARTHJUSTICE
3916 NAKOMA ROAD
MADISON WI 53711
E-MAIL : dbender(@earthj ustice.orq
BRIANA KOBOR
VOTE SOLAR
986 PRINCETON AVENUE S
SALT LAKE CITY UT 84105
E-MAIL: [e-mail]
JOHN R HAMMOND JR
FISHER PUSCH LLP
PO BOX 1308
BOISE ID 83701
E-MAIL : jrh@fi sherpusch.com
ELECTRONIC ONLY
SNAKE RIVER ALLIANCE
wwil son@snakeri veral li ance.orq
NW ENERGY COALITION
[e-mail]
RYAN B FRAZIER
BRIAN W BURNETT
KIRTON McCONKIE
PO BOX 45t20
SALT LAKE CITY UT 841I I
E-MAIL : rfrazier(@kmclaw.com
[e-mail]
DOUG SHIPLEY
INTERMOUNTAIN WIND AND
SOLAR LLC
1953 WEST 2425 SOUTH
WOODS CROSS UT 84087
E-MAIL: [e-mail]
PRESTON N CARTER
DEBORAH E NELSON
GIVENS PURSLEY LLP
601 W BANNOCK ST
BOISE ID 83702
E-MAIL: [e-mail]
den@ givenspursley. com
SECRETAR
CERTIFICATE OF SERVICE