20190502Comments.pdf

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May 2,2019
VIA HAND DELIVERY
Diane M. Hanian, Secretary
ldaho Public Utilities Commission
47 2 W est Wash ington Street
Boise, ldaho 83702
Re: Case No. IPC-E-19-15
Study of Net Excess Energy for On-site Generation Under Schedule 84 and
Temporary Suspension of Schedule 84 for New ldaho Applicants - ldaho
Power Company's Comments
Dear Ms. Hanian
Enclosed for filing in the above matter please find an original and seven (7) copies
of ldaho Power Company's Comments.
Very truly yours,
LISA D. NORDSTROi'I
Lead Counsel
I [e-mail]
LDN:csb
Enclosures
Lisa D. Nordstrom
@
An IDACORP Company
1221 W. ldaho 5t. (83702)
P.O. Box 70
RECEIVED
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Boise, lD 83707
LISA D. NORDSTROM (lSB No. 5733)
ldaho Power Company
1221\Nest ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
I nordstrom @ ida hopower. com
RECEIVED
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Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER'S
APPLICATION TO EVALUATE SCHEDULE
84 - NET METERING
CASE NO. !PC-E-19-15
]DAHO POWER COMPANY'S
COMMENTS
As the ldaho Public Utilities Commission ("Commission") observed in May 2018,
"The increasing technological and financial feasibility of on-site generation, and its
adoption by customers, is rapidly increasing and evolving."l With the active and pending
capacity groMh for all Schedule 84 customers increasing by 150 percent in the first four
months of this year (for the irrigation class alone, the increase was 470 percent), ldaho
Power Company ("ldaho Power" or "Company") is increasingly concerned that flawed
economic signals and incentives provided through retail rate net metering may mislead
1 ln the Mafter of the Application of ldaho Power Company for Authority to Establish New
Schedu/es for Residential and Small General Service Customers with On-Site Generation, Case No.
IPC-E-17-13, Order No. 34046 at 16 (May 9, 2018).
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IDAHO POWER COMPANY'S COMMENTS - 1
customers considering multi-million-dollar investment decisions in on-site generation.
This concern prompted the Company to request the Commission review modifications to
the compensation structure and excess net energy value applied under Schedule 84, as
well as temporarily suspend service under Schedule 84 to new ldaho commercial,
industrial, and irrigation ("CI&1") applicants during the pendency of this case.
Commission Order No. 34315 directed interested parties to submit comments
regarding the procedural aspects in Case No. IPC-E-19-15 (.19-15 Case"). The
Company's comments first provide background for the establishment and scope of two
current dockets relevant to the 19-15 Case. Then, the Company describes several
important distinctions between residentia! and small general service ('R&SGS')
customers with on-site generation taking service under Schedules 6 and 8 and Cl&l
customers taking service under Schedule 84, and provides further evidence supporting
its request for a temporary suspension of Schedule 84. Finally, the Company comments
on each of the statements listed on page 3 of Order No. 34315.
I. BACKGROUND
On July 27,2017, the Company filed Case No. IPC-E-17-13 seeking authority to
establish two new customer classes for R&SGS customers with on-site generation. At
that time, both the R&SGS and Cl&l customers with on-site generation were included
within Schedule 84, Net Metering Service ("Schedule 84"). ln its filed Application and
testimony in Case No. IPC-E-17-13, the Company described its concerns regarding the
potential for cost-shift specifically in the R&SGS customer classes caused by the rate
design applicable to those customer classes:
IDAHO POWER COMPANY'S COMMENTS - 2
Currently, the Company's R&SGS customers are billed two
types of charges: (1) a flat monthly service charge of $5.00
and (2) per kWh energy charges that vary by season and total
monthly consumption. Due to the limited billing components
associated with these rate classes, most of the Company's
revenue requirement is collected through the volumetric
energy rates.2
When the Company filed Case No. IPC-E-17-13 in July 2017, grov'rth in the
Company's Schedule 84 was primarily attributed to new residential applications. The
rapid growth in Schedule 84 monthly net metering, coupled with rate design and metering
differences applicable to R&SGS customers, prompted the Company to focus its request
on addressing concerns related to the R&SGS customer segments.
On May 9,2018, the Commission issued Order No. 34046 finding it fair, just, and
reasonable for the Company to separate R&SGS on-site generation customers into
Schedules 6 and 8, respectively. Furthermore, the Commission ordered the Company
and interested parties to undertake a process to "study the costs and benefits of net
metering on ldaho Power's system, proper rates and rate design, alongside the related
issues of compensation for net excess energy provided as a resource to the utility."3 On
September 21,2019, the Commission issued its Reconsideration Order No. 34147,
directing the Company to expand the discussions in the forthcoming docket to include
studying the feasibility of a non-export option. Order Nos. 34046 and 34147 were the
impetus for the following two cases: IPC-E-18-15 and IPC-E-18-16.
2 Case No. IPC-E-17-13, Tatum Dl at 13.
3 Order No. 34046 at 22.
IDAHO POWER COMPANY'S COMMENTS - 3
A. Gase No. !PC-E-18-15.
On October 19, 2018,ldaho Power filed Case No. IPC-E-18-15 ('18-15 Case";a
asking the Commission to initiate a docket to study the costs, benefits, and compensation
of on-site generation on Idaho Power's system, as well as proper rates and rate design,
transitional rates, and related issues of compensation for net excess energy provided as
a resource to the Company. The Company's focus for this study was for the newly
established Schedules 6 and 8 created through Order No. 34046. As reported in the Staff
Report filed in the 18-15 Case with the Commission on February 28,2019, the Company
and intervening parties have held severa! settlement meetings to discuss those matters.
ln an effort to facilitate discussion in the 18-15 Case, prior to filing its Application
in October 2018, the Company prepared several studies to use as a basis for discussion:
(1') 2017 ldaho Report of Operations ("2017 ROO'), (2) Class Cost-of-Service Study
('COS Study") based upon the 2017 ROO, (3) a 25-year levelized, solar-based Value of
Distributed Energy Resources ('VODER"), and (4) an analysis of moving the newly
established Schedules 6 and 8 to a net hourly billing structure. The Company prepared
those studies to provide parties with a "strawman" that may facilitate settlement
negotiations in the case and provided these studies to all parties in the 18-15 Case on
December 12,2018, in response to a Commission Staff ("Staff') discovery request.
The Company has continued, at the request of Staff, to prepare additional
materials and presentations to share with parties during the settlement meetings. lt has
been the Company's position that changes to the compensation structure (measurement
interval for billing and compensation for net excess generation) could be reasonably
4 ln the Matter of the Petition of ldaho Power Company to Study fhe Cosfs, Benefits and
Compensation of Net Excess Energy Supplied by Customer On-Site Generation, Case No. IPC-E-18-15.
IDAHO POWER COMPANY'S COMMENTS.4
studied and implemented by January 1,2020. The Company has prepared information
for the workshop discussions and has been responsive to parties' requests for formal and
informal data inquiries. However, the Company is concerned that progress made to date
is not occurring at a pace that will lead to timely resolution of the matters being discussed
for the benefit of its customers.
B. Case No. I 8-16.
On October 19, 2018, ldaho Power filed Case No. IPC-E-18-16 ('18-16 Case")
asking the Commission to initiate a docket to facilitate stakeholder input on a
comprehensive customer fixed-cost analysis performed by the Company.s To date,
parties have met in the 18-16 Case for one prehearing conference and three settlement
meetings. At this time, the Company believes it has received the necessary input to draft
its initial study and has commenced work on the fixed cost recovery study, which it plans
to file with the Commission by September 30, 2019. Prior to finalizing its study for
submission to the Commission, the Company intends to circulate a draft to the parties to
the 18-16 Case to solicit feedback for consideration in the fina! version to be filed with the
Commission.
il. GASE NO. IPC-E-I9-15
While the Company and parties have been focused in the 18-15 Case on
addressing the compensation structure and VODER to be applied to excess net energy
for Schedule 6 and 8 customers, as well as proper rates and rate design (if necessary,
evaluating transitional considerations associated with changes to rates), it has continued
s ln the Mafter of the Petition of ldaho Power Company to Study Fxed Cosfs of Providing Electric
Servlce to Customers, Case No. IPC-E-18-16.
IDAHO POWER COMPANY'S COMMENTS - 5
to monitor activity in the Cl&l customer segments taking service and filing applications
under Schedule 84.
A. Cl&l Compared to R&SGS.
While the rate designs applicable to the Cl&! customer classes also include a
portion of fixed costs embedded in the volumetric energy rates, those customer segments
have additional billing components that provide better fixed cost recovery (e.9., Billing
Demand, Basic Load Capacity ("BLC"), On-Peak Billing Demand) as compared to the
R&SGS customer classes.
ln addition, the Cl&l customers have different interconnection requirements under
Schedule 84 than are required for R&SGS customers. A Cl&l customer interconnecting
on-site generation under Schedule 84 is required to install a separate meter to measure
the customer's consumption requirements independent from the amount of energy
generated by the customer's on-site generation system.
When the Company bills a Cl&l customer taking service under Schedule 84, it
subtracts the tota! kilowatt-hours ("kWh") generated during the billing month (measured
by the generation meter) from the total kWh consumed in that same month (measured by
the consumption meter) in order to determine the kWh usage for billing purposes. The
customer's billing demand measurement is determined by the kilowatt (.kW") reading
(measured on the consumption meter) for the applicable kW-related charges. This is a
different process than currently exists for R&SGS customers, where there is no demand
component measured and a single meter registers the nef monthly amount of kWh
transacted.
IDAHO POWER COMPANY'S COMMENTS.6
Cl&l customers are also allowed to install Iarger systems than R&SGS
customers-Cl&l customers are permitted to install systems up to 100 kW in size, where
R&SGS customers are limited to installing systems no larger than 25 kW.
B. Sisnificant Growth of lrriqation Net Meterinq.
While the Company had initially envisioned waiting until the outcome of the 18-15
Case was decided before asking the Commission to open a docket to investigate the
compensation structure and the VODER for Cl&l classes, the grovtrth of installed and
pending capacity in these customer segments, most notably within the irrigation segment,
has become of a magnitude that ldaho Power feh it was necessary to bring it to the
Commission's attention now. On April 5,2019, ldaho Power filed the 19-15 Case asking
the Commission to initiate a collaborative process to explore modifications to the
compensation structure and excess energy value applied under Schedule 84 for
implementation by January 1,2020.
For context, while the Company had 25 megawatts ("MW") of active and pending
R&SGS on-site capacity (comprised of 3,475 systems) in its ldaho service area as of
December 31, 2018, it had only 6.5 MW of active and pending Cl&l on-site generation
capacity (comprised of 146 systems) in its ldaho service area at the same time. Between
December 31,2018, and April 30, 2019, the active and pending capacity of on-site
generation in the Cl&l class had grown by 150 percent overall; the grov'rth in the irrigation
class was 470 percent. Additionally, at this time, the Company has received informal
inquiries6 for an additional 1 1 .5 MW of capacity-all from the irrigation customer segment.
6 Customers have requested the Company provide detailed information on their meter data points,
including geographic information system data flagging contiguous property, names of distribution feeders
for each meter, transformer sizes, and rate schedule detail.
IDAHO POWER COMPANY'S COMMENTS - 7
ln the last month alone, 14 individual irrigation customers have contacted ldaho Power
requesting information about their meters (presumably to determine aggregation
eligibility); these customers collectively have 128 irrigation meters. Figure 1 below shows
the activity in active, pending, and informal inquiries through the end of April, as compared
to the activity previously presentedT to the Commission through March 31,2019.
Figure 1: lrrigation Net Metering Capacity
ldaho Schedule 84 (lrrigation Only)
Total Nameplate Capacity
2012 - April 30, 2019 YTD
20 MW
15 MW
10 t\4w
5 r\4W
1.09 MW0.13MW n
2A12 2013 2014 2015 2016 2017 2018 2019 Q1 April 2019YTD YTDr Cumulative Capacity r Pending Capacity *lnformal lnquiry Capacity
C. lnaccurate and Misleadinq ln ation to Cl&l Customers.
While the 18-15 and 18-16 Cases proceed, R&SGS and Cl&l customers are
continuing to invest in on-site generation under the assumption that the monthly net
metering billing and retail rate compensation structure for excess net energy will continue.
As the Commission observed in Case No. IPC-E-17-13, "the evidence causes us a great
deal of concern that industry surrounding R&SGS on-site generation may be sending
price signals to ldaho consumers, including the Company's customers, that are not in {he
7 Case No. IPC-E-19-15, Application at 5, Tatum Dlat p. 16, l. 19 -p.19,1.2
- IVIW
0.04 Mw 0.04 MW 0.04 Mw 0.09 Mw 0.12 MW
3.29 MW
1.77 MW
4.42MW
1.77 MW
IDAHO POWER COMPANY'S COMMENTS - 8
ww&1i;li,
*,t,t {a
public interest."E The Company has similar concerns, which have since been validated
after having conversations with Cl&l customers, that the information Schedule 84
customers are relying on to make large investment decisions may not be accurate, and
in some cases is misleading.
Through conversations with C!&l customers, the Company understands that there
are instances where installers have presented customers with payback periods of as little
as five years-when inaccurate assumptions are corrected, the payback increases in
some cases to over 25 years. Specifically, several common misstatements that can
significantly understate the payback are:
a Elect ric Bill Savinqs. After discussions with installe rs, some customers are
left with the expectation that they will receive a $0.00 electric bill. This belief is inaccurate,
particularly in the Cl&l customer segments where those customers wi!! continue to receive
a service charge and kW-related charges (BLC, Billing Demand, and/or On-Peak Billing
Demand), even if they are able to entirely offset their monthly kWh consumption.
. Tax benefits. Some customers have been told by installers that they will
receive 100 percent of the potential tax credits in the year the investment is made.
Through conversations with irrigation customers, the Company understands these
customers typically have very low tax liabilities, limiting their ability to monetize the tax
credits until years into the future. The Company has also noted that the reduced tax
benefit associated with a Iower utility bill has been ignored. The combined impact of these
two assumptions alone can affect the investment payback period by up to 10 years.
8 Order No. 34046 at 19.
IDAHO POWER COMPANY'S COMMENTS - 9
. Equipment Deqradation. The effects of "degradation" (the quantification of
power decline over time) are frequently overlooked or ignored, which overstate the energy
production of a system over its lifetime. The United States Department of Energy's
National Renewable Energy Laboratory ('NREL") cites an annual degradation of 0.70
percent.s
o Operations and Maintenance ("O&M") Expense. After speaking with
installers, customers are often unaware that they will have ongoing O&M associated with
maintaining the system over time.
D. Gaminq of Meter Aqqreqation Criteria.
The Company received an inquiry from an installer in January 2019, requesting
information for a total of 71 meters to be evaluated-against the criteria provided in
Schedules 6, 8, and 8410-to determine which of these meters would be eligible for
transfer of Excess Net Energyll and which meters listed would be eligible to receive those
transfers. The list included nine commercial meters, 17 residential meters, and 45
s NREL, U.S. Solar Photovoltaic System
https://www. n rel. qov/docs/fu 1 9osti/72399. pdf (p 1 4)
Cost Benchmark: Q1 2018
10 To aggregate meters for the annual transfer of unused Excess Net Energy credits, the following
criteria must be met:i. The account subject to offset is held by the Customer; and
ii. The meter is located on, or contiguous to, the property on which the Designated Meter is
located. For the purposes of this tariff, contiguous property includes property that is separated
from the Premises of the Designated Meter by public or railroad rights of way; and
iii. The meter is served by the same primary feeder as the Designated Meter at the time the
Customer files the application for the Net Metering System; and
iv. The electricity recorded by the meter is for the Customer's requirements; and
v. For Customers taking service under Schedule 6 or Schedule 8, credits may only be transferred
to meters taking service under Schedule 1, 6, 7, or Schedule 8. For Customers taking service
under Schedule 9, Schedule 19, or Schedule 24, credits may only be transferred to meters
taking service under Schedule 9, Schedule 19, or Schedule 24.
11 "Excess Net Energy" is defined in Schedules 6, 8, and 84 as "the positive difference between the
kilowatt-hours (kWh) generated by a Customer and the kWh supplied by the Company over the applicable
Billing Period."
IDAHO POWER COMPANY'S COMMENTS - 1O
irrigation meters; the names on the accounts were attributed to several different
individuals and related business entities.
This situation highlights potential "gaming" that may be occurring as it relates to
the meter aggregation criteria established by the Commission in Order No. 32925.t2 To
qualify for aggregation, the criteria mandates that (1) the account subject to offset is held
by the Customer and (2) the electricity recorded by the meter is for the Customer's
requirements. The Company does not believe it was the Commission's intent when meter
aggregation was approved that a customer would simply be able to put service into
another name to be eligible for aggregation; that is, the Commission required that the
"electricity recorded by the meter is for the Customer's requirements."ts Further, as
described by Company witness Tatum, due to the unique characteristics of irrigation
customers, the current criteria for meter aggregation incentivizes these customers to
oversize their systems in order to generate Excess Net Energy to be transferred to other
sites, rather than installing generation that is more aligned with the customer's usage
needs.14
The Company is aware of other situations where this "gaming" may be occurring
in the R&SGS customer segments. During this year's period to transfer Excess Net
Energy credits,ls the Company was made aware that a customer with on-site generation
12 ln the Matter of ldaho Power Company's Application for Authority to Modify /s Net Metering
Servrbe and to lncrease the Generation Capacity Limit, Case No. IPC-E-12-27,Order No. 32925 (November
19, 2013).
13 Order No. 32925 at 6.
1a Case No. IPC-E-19-15, Tatum Dl at p. 21, 1 . 11 - p. 24, 1.6.
1s Schedule 84 requires customers to submit requests to transfer unused Excess Net Energy credits
by January 31; the Company must execute qualifying transfers no later than March 31.
IDAHO POWER COMPANY'S COMMENTS . 11
who had excess net energy credits that would otherwise be unused intended to simply
"add" his/her name to his/her neighbor's residential account so the credits could be
transferred. This request was ultimately denied due to not meeting the contiguous
property criteria, but the action the customer initiated to modify the names on the service
account certainly suggests the opportunity to game is present-and as the criteria
currently exist, it is difficult for the Company to consistently enforce compliance.
III. RESPONSE TO COMMISSION REOUEST FOR INFORMATION
The remainder of the Company's comments wi!! specifically address the
Commission's request for comments on the list of six statements presented on page 3 of
Order No. 34315.
A.Whether and to What Extent this Application lmpacts or is lmpacted bv
IPC-E-1 8-1 5 and IPC-E-I 8-1 6.
First and foremost, the scope of the 18-16 Case remains unchanged. The 18-16
Case was initiated to facilitate stakeholder input on a comprehensive customer fixed-cost
analysis performed by the Company. This comprehensive customer fixed-cost analysis
will evaluate for a// customer classes. Nothing which has subsequently been filed in the
19-1 5 Case would change the scope of the 18-16 Case.
With regard to the other remaining dockets, the 18-15 Case (Schedules 6 and 8)
and the 19-15 Case (Schedule 84), the single issue common to each of them is the
appropriate VODER to be used in compensation for Excess Net Energy. Because of the
differences between R&SGS and CI&l customers with on-site generation in rate design,
billing components, interconnection and metering requirements, billing processes, and
size of installed systems allowed, every other issue, even if it may be similar in nature,
would be considered in the corresponding appropriate docket for that customer class.
IDAHO POWER COMPANY'S COMMENTS - 12
For the 18-15 Case, the scope includes the study of the costs, benefits, rates and
proper rate design, and compensation of on-site generation for Schedules 6 and 8. Any
changes to the compensation structure (measurement interval for billing and
compensation for net excess generation) would reflect the inherent nature of the single
meter configuration and could be reasonably studied and implemented by January 1,
2020.
The 19-15 Case, on the other hand, is only envisioned to evaluate the
measurement interval and compensation structure for the Cl&l customer classes; the
Company is not asking to evaluate proper rates and rate design or seek changes to rate
design for the Cl&l customer classes as part of the 19-15 Case. The Company believes
evaluation of the measurement interval and compensation structures for Cl&l in a docket
(19-15 Case) separate from the determination of the measurement interval and
compensation structure for R&SGS customers (18-15 Case) is most appropriate because
of the key differences that exist between the two customer segments that could lead to
differing outcomes for each: (1) differing interconnection requirements (meter
configurations and functionality) and (2) different system size limitations.
B. Whether and to What Extent the lssues Raised in !PC-E-18-15. IPG-E-18-16.
and this Docket Can and Should be Examined Holisticallv.
The VODER is the only common issue between the 18-15 Case and the 19-15
Case. As demonstrated by the Figure 2 below, the value of "compensation" for energy
can vary significantly by class and may be significantly greater than the value of a similar
resource. The Company believes that the VODER should be determined holistically for
all classes of customers for each resource type, not individually by class.
IDAHO POWER COMPANY'S COMMENTS - 13
Figure 2: Rates Paid for a Kilowatt-Hour Generated
Energy Rate Comparison
With PCA, Current Rates +20!9-2020 Test Year
s/kwh
I nd ustria I s0.04336
Large Commercial Primary So.o4s75
Large Commercial Secondary s0.0s921
lrrigatio n s0.05215
Residentia I so.0922s
Small Commercial 10934
Jackpot Solar so.0217s
schedule 86 Non-Firm
-
So.ozrzg
The Application in the 19-1 5 Case impacts or is impacted by the 18-15 Case to the
extent the Commission intends for a single resource-specific VODER to apply to customer
on-site generation. Parties to the 18-15 Case have only discussed issues in that case
specific to the R&SGS customer classes. Application of the result of the 18-15 Case to
Schedule 84 has not been discussed in that docket. Further, as more fully described
above, keeping the R&SGS and Cl&l discussions separate on the matters other than
VODER is most appropriate given the distinct differences that exist between those
customer segments.
IDAHO POWER COMPANY'S COMMENTS - 14
C. Whether this Docket Should be Processed According to ldaho Powefie
Proposal on Page 8 of the Application.
For the reasons outlined above, ldaho Power believes continuing to limit the
18-15 Case to R&SGS on-site generation issues (cost-of-service, rate design,
compensation structure, and value of excess net generation) and limiting the scope of the
newly established 19-15 Case to Cl&l on-site generation issues (measurement interval
and value of excess net generation) will allow these cases to be processed in an efficient
manner.
The single, overlapping issue these cases will each address is assigning a value
to the export of customer-sited generation, regardless of customer class. The scope the
Company laid out in its Application envisioned that on that single issue, the VODER,
parties from the 18-15 Case and the 19-15 Case would hold joint settlement meetings to
address that specific issue. The Company believed that to be a reasonable expectation,
given the collaborative process established in the 18-15 Case. However, in the
alternative, if the Commission believes the scope laid out by the Company in its initial
Application in the 19-15 Case creates confusion, ldaho Power would also support the
Commission establishing a separate case dedicated to determining the appropriate value
to be applied to excess net energy on the Company's system, removing the single issue
of the VODER from both the 18-15 Case and the 19-15 Case.
The 18-16 Case should continue in accordance with its current schedule,
unaffected by any changes to the other two dockets.
D. Whetherthe Commission Should Process this Docket bv Modified Procedure
or bv Hearings.
While the Company would like to reach a collaborative settlement of the issues
presented in the 18-15 and 19-15 cases, ldaho Power remains sensitive to the fact that
IDAHO POWER COMPANY'S COMMENTS - 15
its customers lack accurate export pricing information. Therefore, the Company believes
it is appropriate at this time for the Commission to establish a schedule in both the 18-15
and 19-15 Cases (and potentially, a stand-alone "VODER Case") to allow for settlement
of the specific issues in each case, but one that envisions technical hearings in the event
settlement cannot be accomplished.
The Company proposes that it file testimony and exhibits supporting its
recommended position in each of the cases; this will provide a more formal and detailed
basis for settlement discussions. To ensure a timely resolution to these issues, the
Company recommends the Commission establish a hearing schedule with multiple
settlement opportunities in each of the cases. For consideration, the Company has
provided the following illustrative case schedules:
Case IPC-E-I8-1 5 (R&SGS)
Company files Supplemental Direct Testimony, including
recommendations for: (1) Proposed Rate Design for
Schedules 6 and 8 (based on current COS methodology
most recently approved by the Commission, Case No.
IPC-E-08-1 0), (2) Measurement interval for consumption
and Excess Net Energy, (3) Transitional Considerations, (4)
Feasibility of Non-Export Options, and (5) VODER16
TBD Settlement Workshop(s)
August 5,2019 Staff and lntervenor Direct Testimony
TBD Settlement Workshop(s)
September 9, 2019 All Party Reply Testimony
TBD Settlement Workshop(s)
October 14,2019 Company Sur-Rebuttal Testimony
November 12, 13 Technical Hearing
January 1,2020 Proposed Effective Date of Modifications
16 VODER is proposed by the Company to be jointly considered in the 18-15 and 19-15 Cases;
however, in the alternative, the Company has proposed an alternative VODER-only case structure for the
Commission's consideration.
IDAHO POWER COMPANY'S COMMENTS - 16
July 1 ,2019
July 1 ,2019 Company files Supplemental Direct Testimony, including
recommendations for: (1) Measurement interval for
consumption and Excess Net Enerqy and (2) VODER1T
TBD Settlement Workshop(s)
August 5, 2019 Staff and lntervenor Direct Testimony
TBD Settlement Workshop(s)
September 9, 2019 All Party Reply Testimony
TBD Settlement Workshop(s)
October 14,2019 Company Sur-Rebuttal Testimony
November 14, 15 Technical Hearing
January 1,2020 Proposed Effective Date of Modifications
Case IPG-E-19-15 (Cl&l)
Potential Stand-Alone VODER Case
E. Whether the C@Suspend Schedule 84 for Uew appfieanls
While IPG-E-I9-15 is Beins Processed. and if the Commission Does Suspend
Schedule 84 in the lnterim. Wh ension Should be from the Date
of Filinq-April 5. 2019-or some other date.
While the Company continues to believe it is in the best interest of its customers
to determine the appropriate measurement interval for compensation and excess net
energy and VODER for exports before additional customers sign agreements to purchase
on-site generation systems, the Company understands enforcing a retroactive
suspension date could be difficult to implement. The Company respectfully requests that
17 VODER is proposed by the Company to be jointly considered in the 18-15 and 19-15 Cases;
however, in the alternative, the Company has proposed an alternative VODER-only case structure for the
Commission's consideration.
IDAHO POWER COMPANY'S COMMENTS - 17
July 1 ,2019 Company files Direct Testimony recommending VODER
TBD Settlement Workshop(s)
August 5,2019 Staff and !ntervenor Direct Testimony
TBD Settlement Workshop(s)
September 9, 2019 All Party Reply Testimony
TBD Settlement Workshop(s)
October 14,2019 Company Sur-Rebuttal Testimony
November 7, 8 Technical Hearing
January 1,2020 Proposed Effective Date of Modifications
if the Commission agrees that Cl&l customers are best served by a limited suspension of
Schedule 84 to new applicants until the Commission issues an order effective January 1,
2020, that the Commission issue the effective date of that suspension as of the date of
its procedural order.
Alternatively, if the Commission believes it would not be in the best interest of
customers to limit the availability of Schedule 84 while the 19-15 Case issues are being
evaluated, the Company respectfully requests that the Commission consider suspending
the availability of meter aggregation to Schedule 84's irrigation customers during the
pendency of the 19-15 Case if an order addressing the VODER is unlikely to be issued
by January 1, 2020.18 Excess Net Energy credits could still be accumulated for each
metered account but would not be eligible for transfer under Schedule 84's meter
aggregation criteria. Should the Commission determine a VODER to be applied to
Excess Net Energy, the accumulated Excess Net Energy credits could then be assigned
that value. Although meter aggregation implementation concerns exist in all customer
classes, differences in the condition of irrigation service and in the time, nature and
pattern of irrigation usage (i.e., consumption seasonality, large number of meters on
contiguous properties on a single primary feeder, and complex contiguous land ownership
and leasing relationships) support the differentiationrg from other classes if the
Commission wishes to narrow suspension of meter aggregation until the concerns
described on pages above are addressed.
18 Schedule 84 requires customers to submit requests to transfer unused Excess Net Energy
credits by January 31; the Company must execute qualifying transfers no later than March 31.
're Grindstone Butte Mutual Canal Company v. ldaho Power Company,98 ldaho 860, 867, 574
P.2d 902,909 (1978) and Building Contractors Association of Southwestern ldaho, lnc. v. ldaho Public
Utilities Commission et al.,128ldaho 534, 539, 916 P.2d 1259,1264 (1996).
IDAHO POWER COMPANY'S COMMENTS - 18
F. Whether the ive Date of Ja@
IPC-E-I9-15 is Feasible.
The Company initially filed its Applications in the 18-15 and 18-16 Cases in
October o12018, allowing 14 months for parties to discuss and develop positions on the
issues in the case to facilitate a January 1,2020, implementation of changes. As a point
of reference, the Commission is statutorily required2o to process a general rate case in
seven months. The issues the Company has been asked to study in eitherthe 18-15
Case or 18-16 Case are only a small subset of what would be considered by parties and
the Commission in a general rate case. ln the 19-15 Case, the Company asked the
Commission to consider modifying only the measurement interval for consumption and
exports of excess net energy and the VODER applied to excess net energy for Cl&l
customers-a subset of the issues being evaluated in the 18-15 Case for R&SGS
customers.
The Company believes eight months to study these issues is more than sufficient
for the Commission to establish an evidentiary record to make a determination-either by
reviewing a settlement agreement or hearing the issues presented at technical hearing.
As such, the suggestion2l by parties that the Company's recommended January 1,2020,
implementation date would be considered hasty is unfounded.
tv. coNcLUStoN
While the Company supports customers who wish to install on-site generation at
their businesses and farms, the current compensation structure provides an inaccurate
20 ldaho Code $ 61-622.
21 Case No. IPC-E-18-15, ldaho Conservation League Petition to lntervene at4 (April 15,2019),
City of Boise Formal Comments at 4 (April 18, 2019).
IDAHO POWER COMPANY'S COMMENTS - 19
economic signalthat may lead to significant uneconomic investment by customers, if not
modified. During the technical hearing in Case No. !PC-E-17-13, witnesses and
commissioners expressed concern that consumers are caught in a period of "limbo" or
"purgatory" until an on-site generation compensation structure and value are
established.22 More than a year has passed and ldaho electric consumers considering
installation of on-site generation do not yet have resolution of these issues. lf the
Commission establishes procedural schedules in the 18-15 and 19-15 Cases, ldaho
Power believes these issues can be timely resolved by negotiation or litigation such that
certainty can be had for everyone impacted, directly or indirectly, by January 1,2020.
As discussed in greater detail in its Application and these Comments, Idaho Power
requests the Commission review modifications to the compensation structure and excess
energy value applied under Schedule 84. lf the Commission does not find it in the public
interest to temporarily suspend service under Schedule 84 to new ldaho Cl&l applicants
during the pendency of this case and anticipates issuing an order after January 1,2020,
the Company requests the Commission suspend irrigation meter aggregation to
immediately address gaming of the criteria established by the Commission in Order No.
32925.
DATED at Boise, ldaho, this 2nd day of May 2019.
LI D. NOR
Attorney for ldaho Power Company
22 Case No. IPC-E-17-13 Tr. at 914-915 (King Redirect), 954-955 and 959-960 (White
Commissioner Examination).
IDAHO POWER COMPANY'S COMMENTS.20
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 2nd day of May 2019 I served a true and correct
copy of IDAHO POWER COMPANY'S COMMENTS upon the following named parties by
the method indicated below, and addressed to the following:
Gommission Staff
Edward Jewell
Deputy Attorney General
ldaho Public Utilities Commission
472 West Washington Street (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
ldaho lrrigation Pumpers Association, lnc.
Eric L. Olsen
ECHO HAWK & OLSEN, PLLC
505 Pershing Avenue, Suite 100
P.O. Box 6119
Pocatello, ldaho 83205
X Hand Delivered
_U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
_Hand DeliveredX U.S. Mail
_Overnight Mail_FAXX Email [e-mail]
Anthony Yankel
12700 Blake Avenue, Unit 2505
Lakewood, Ohio 44107
ldaho Conservation League
Benjamin J. Otto
ldaho Conservation League
710 North 6th Street
Boise, ldaho 83702
City of Boise City
Abigai! R. Germaine
Deputy City Attorney
Boise City Attorney's Office
150 North Capito! Boulevard
P.O. Box 500
Boise, ldaho 83701 -0050
Micron Technology, !nc.
Austin Rueschhoff
Thorvald A. Nelson
Holland & Hart, LLP
6380 South Fiddlers Green Circle, Suite 500
Greenwood Village, Colorado 80111
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_Overnight Mail
_FAXX Email [e-mail]
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FAX
Email [e-mail]
tnelson@holland ha rt. com
aclee@ holland hart. com
q lq a ro a n o-a ma ri@-h ollan dhar[cq m
IDAHO POWER COMPANY'S COMMENTS - 21
X
Jim Swier
Micron Technology, !nc.
8000 South FederalWay
Boise, ldaho 83707
ldaho Clean Energy Association
Preston N. Carter
GIVENS PURSLEY LLP
601 West Bannock Street
Boise, ldaho 83702
ldaho Sierra Club
Kelsey Jae Nunez
KELSEY JAE NUNEZLLC
920 North Clover Drive
Boise, ldaho 83703
Zack Waterman
Michael Heckler
ldaho Sierra Club
503 West Franklin Street
Boise, ldaho 83702
!ndividual
Russel! Schiermeier
29393 Davis Road
Bruneau, Idaho 83604
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m ichael. p. heckler@qmail. com
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Christa Bearry, Lega lAssistant
IDAHO POWER COMPANY'S COMMENTS -22