20180605Response to Vote Solar Petition.pdf

SEAN COSTELLO
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03t2
IDAHO BAR NO. 8743
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
RECEIVED
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Street Address for Express Mail:
472W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THE TDAHO PUBLIC UTILITIES COMMISSION
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CASE NO. IPC.E.17-I3
STAFF'S RESPONSE TO VOTE
SOLAR'S PETITION FOR
RECONSIDERATION
BACKGROUND
On May 29,2018, Vote Solar filed a Petition for Reconsideration ("Petition") of
Commission Order No. 34046 ("Final Order"). The Final Order directed Idaho Power
("Company") to close Schedule 84 to all current and future Residential and Small General
Service ("R&SGS") customers with on-site generation meaning all customers with on-site
generation, whether they export energy to the grid or not, are now within the Company's new
Schedules 6 and 8. In its Petition, Vote Solar seeks reconsideration of the scope of Schedules 6
and 8 and requests that the Commission require the Company to revise Schedules 6 and 8 to
apply only to customers who export electricity to the Company's grid. Vote Solar's Petition for
Reconsideration at 1.
Vote Solar argues that the Commission's findings, conclusions, and reasoning were
specific to customers who both import and export energy, and do not support a decision to place
customers who generate, but who do not export, into the new rate classes. Id. at3-6.
ISTAFF RESPONSE JUNE 5,2018
STAFF RECOMMEDATIONS
Staff generally concurs with the analysis presented in Vote Solar's Petition for
Reconsideration. Staff maintains that those customers who are incapable of exporting energy to
the grid should be exempt from inclusion in Schedules 6 and 8. Therefore, Staff recommends
that the Commission require the Company to revise its new Schedules 6 and 8 to apply only to
customers with on-site generation who do not eliminate their ability to export power to the
Company's grid by means of a Grid Tie Limiter, Grid Inverter with Export Control, or similar
device.
Staff also believes correcting this portion of the record may have the effect of fostering
compromise in the forthcoming Idaho Power net metering docket related to costs, benefits, rates,
rate design, and compensation for net excess energy. By making customers in Schedules 6 and 8
more similar to each other, disagreements over the appropriate inputs and analysis to utilize in
that docket may be limited. More homogenous customer classes would also reduce Schedule 6
and 8 intra-class subsidies because on-site generation customers who do not export energy to the
grid will not be assigned rates that include any costs associated with customers who export
energy.
5e day ofJune 2018Respectfully submitted this
Umisc/Comments/ipce I 7. l3sc reconsideration response
Sean Costello
Deputy Attorney General
2STAFF RESPONSE JUNE 5,2018
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 5TH DAY OF JLINE 2018,
SERVED THE FOREGOING STAFF'S RESPONSE TO VOTE SOLAR'S PETITION
FOR RECONSIDERATION, IN 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 rD 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 83701
E-MAIL : torn.arkoosh@,arkoosh.com
erin. ce c i I (r?arko o sh. com
ELIAS BISHOP
AURIC SOLAR LLC
2310 s 1300 w
W VALLEY CITY UT 84I19
E-MAIL: [e-mail]
ANTHONY YANKEL
I27OO LAKE AVENUE
LINIT 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 ID 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 NI.]NEZLLC
920 N CLOVER DR
BOISE ID 83703
E-MAIL: kelse)r@kelse)rj 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 537I I
E-MAIL: [e-mail]
JOHN R HAMMOND JR
FISHER PUSCH LLP
PO BOX 1308
BOISE ID 83701
E-MAIL : j rh@fi sherpusch.com
RYAN B FRAZIER
BRIAN W BURNETT
KIRTON McCONKIE
PO BOX 45120
SALT LAKE CITY UT 84I I I
E-MAIL : rfrazier@kryrqlaw. cam
bburnett@.kmclaw.com
PRESTON N CARTER
DEBORAH E NELSON
GIVENS PURSLEY LLP
601 W BANNOCK ST
PO BOX2720
BOISE ID 83701
E-MAIL: [e-mail]
den@ givenspursley. com
BRIANA KOBOR
VOTE SOLAR
986 PRINCETON AVENUE S
SALT LAKE CITY UT 84105
E-MAIL: [e-mail]
ELECTRONIC ONLY
SNAKE RIVER ALLIANCE
wwil son@snakeriveralliance. org
NW ENERGY COALITION
diego@nwenerg),.org
DOUG SHIPLEY
INTERMOUNTAIN WIND AND
SOLAR LLC
I953 WEST 2425 SOUTH
WOODS CROSS UT 84087
E-MAIL: [e-mail]
-t*a*r^r
CERTIFICATE OF SERVICE