20190412Decision Memo.pdf

DECTSION MEMORANDUM
TO COMMISSIONER KJELLANDER
COMMISSIONER RAPER
COMMISSIONER ANDERSON
COMMISSION SECRETARY
COMMISSION STAFF
LEGAL
FROM:EDWARD JEWELL
DEPUTY ATTORNEY GENERAL
DATE: APRIL ll,2019
SUBJECT: IN THE MATTER OF IDAHO POWER'S APPLICATION TO
EVALUATE SCHEDULE 84 - NET METERING; CASE NO. IPC-E-19-15.
On April 5,2019,Idaho Power Company ("Idaho Power" or "Company") filed an
Application requesting the Commission temporarily suspend Schedule 84 for new applicants and
"initiate a collaborative process to explore modification to the compensation structure and excess
energy value applied under Schedule 84[.]" Application at2. The Company requests changes to
Schedule 84 be implemented by January 1,2020. Id. The Company also requests Schedule 84
be retroactively suspended as of April 5,2019 during the pendency of the case. Id. at9.
BACKGROUND
In IPC-E-17-13, the Commission approved the Company's proposal to separate
residential and small general service customers with on-site generation into Schedules 6 and 8.
Order Nos. 34046, 34147. This left commercial, industrial, and irrigation ("CI&I") customers
with on-site generation in Schedule 84. Stemming from Commission orders in IPC-E-I7-13 are
two dockets currently underway, IPC-E-18-15 and IPC-E-18-16.
The Company's Application has implications for IPC-E-I8-15 and IPC-E-I8-16, in
which the Company and stakeholders have been working together since October 2018 to resolve
issues for customers in Schedules 6 and 8. Parties in those cases have expressed apprehension
regarding how this Application will interrelate with the ongoing dockets and are generally
concerned that merging the dockets, which share some common issues but also separate facts
and distinct interested parties, will derail progress made to this point or considerably slow the
pace of progress going forward.
1DECISION MEMORANDUM
THE APPLICATION
The Company states that, from year-end 2018 through March 2019, the capacity
under Schedule 84-including pending applications-has increased ll4o , from 1.09 MW to
5.06 MW. Id. at4. The Company is aware of an additional 5.79 MW of capacity from irrigation
customers who have requested the Company provide detailed system information. Id. at 4-5.
The Company states its concern "that flawed economic signals and incentives provided through
retail rate net metering may mislead customers considering multi-million-dollar investment
decisions in on-site generation." Id. at5.
The Company recommends the case be processed as follows:
CI&l dual meter measurement interval and compensation structure for Schedule 84 to
be determined in IPC-E-19-15.
Value of net excess energy for all on-site generation classes-Schedules 6, 8, and
84-to be determined in IPC-E-I8-15. And,
Rate design and rate structures for all classes, including CI&l customers to be
determined in IPC-E-1 8- I 6.
Application at 8.
STAFF RECOMMENDATION
Staff recommends the Commission not suspend Schedule 84 at this time prior to
receiving input from the parties.
Staff recommends the Commission issue a Notice of Application. Staff recommends
the Commission set an intervention and procedural comment deadline two weeks from the
service date of the Notice of Application. Staff recommends the Commission request comments
regarding:
l.) Whether and to what extent this Application impacts or is impacted by IPC-E-18-15
and IPC-E-18-16.
2.) Whether IPC-E-19-15 should be processed according to Idaho Power's proposal on
page 8 of the Application.
3.) Whether the Commission should process IPC-E-19-15 by modified procedure or by
hearings.
2DECISION MEMORANDUM
4.) Whether the Commission should suspend Schedule 84 while IPC-E-19-15 is being
processed, and if the Commission does suspend Schedule 84 in the interim, should it
be from the date of filing-April 5, 2019-or some other date?
5.) Whether the Company's proposed effective date of January 1,2020 in IPC-E-19-15 is
feasible.
COMMISSION DECISION
Does the Commission wish to issue a Notice of Application, set a two week
procedural comment and intervention deadline, and request comments on the above-stated
matters?
Does the Commission wish to suspend Schedule 84 at this time?
Edward J
Deputy General
L\Legal\ELECTRtC\lPC-E- I 9- | 5\IPCE I 9 I s_dec memo_ej
JDECISION MEMORANDUM