20171101Partial Joinder.pdf

Benjamin J. Otto (ISB No. 8292)
710 N 6th Street
Boise,ID 83701
Ph: [phone]x12
Fax: [phone]
botto @idahoc onservation. org
IN THE MATTER OF IDAHO )
POWER COMPANY'S AUTHORITY )
TO ESTABLISH NEW SCHEDULES )
FOR RESIDENTIAL AND SMALL )
GENERAL SERVICE CUSTOMERS )
WITH ON-SITE GENERATION. )
RECEIVED
t$ll HOY - I At{ 9: Ztr
rr-iiiii0 iiU3LlC
J ; i t- tTi fl -1'C cM M I S s I oN
Attorney for the Idaho Conservation League
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO.IPC.E-I7-13
IDAHO CONSERVATION LEAGUE
PARTIAL JOINDER
The Idaho Conservation League (ICL) hereby joins a portion of the Motions filed
by the Idaho Clean Energy Association, Auric Solar, and City of Boise. Specifically, ICL
joins in requesting the Alternate Relief to address the fundamental question underlying
Idaho Power's Application - the costs and benefits of distributed energy in Idaho.
Understanding the costs and benefits attributable to distributed energy is a necessary
precondition to making a informed decision about changes to existing rate classifications,
designs, and amounts. Despite three attempts since 2013 to engage the Company
regarding this fundamental issue, Idaho Power continues to disregard stakeholders'
suggestions and instead asks this Commission to approve changes to rate classifications
that will only chill economic activity and consumer choice with no corresponding public
benefit. Regarding the Motions before you, we urge the Commission to exercise the
power vested in you by the Idaho Public Utilities Commission Rules of Procedure to
"invite settlement of an entire proceeding." IDAPA 31.01.01.273
IPC-E-17-13
ICL PARTIAL JOINDER
November 1,2017I
Background
This docket is the third time ICL has engaged Idaho Power regarding distributed
energy. In2013,Idaho Power asked this Commission to segregate distributed energy
customers. ICL joined all other parties to oppose this request and offered an alternative
method to assess the costs and benefits of distributed energy. See Direct Testimony of R.
Thomas Beach on Behalf of ICL,IPC-E-12-21. The Commission correctly ruled that
considerations of customer classification and rate design must be vetted in a general rate
case and after consultation with stakeholders. Order No. 32846.
In20l6,Idaho Power hosted a meeting at the Company headquarters to put
forward a substantially similar proposal to change classifications and rate designs for
distributed energy users. ICL participated in that meeting and followed up our verbal
comments with a letter to the Company proposing to use the 2017 lntegrated Resource
Plan as an appropriate venue to consider the full range of costs and benefits distributed
energy may provide. More specifically ICL wrote:
The Integrated Resource Plan is the appropriate venue to develop credible
forecasts of potential distributed energy groMh; understand the full range of
impacts to the grid, energy demands, and capacity needs; and compare distributed
energy to other resource options. This basic information is a precursor to making
informed policy decisions about distributed energy resources.
See Exhibit 401.
As a member of Idaho Power's 2017 Integrated Resource Plan Advisory Council,
ICL attests the Company, despite verbal requests to the IRP team from a range of council
members, did not meaningfully address distributed energy in the 2017 IRP.
In June of 2017,ICL attended a meeting convened by Idaho Power to inform a
limited group of stakeholders about the Company's plans for proposed classification and
rate changes for distributed energy. Again, ICL supplemented our verbal comments with
IPC-E-17-13
ICL PARTIAL JOINDER
November 1,20172
a letter to the Company proposing a process to consider the costs and benefits of
distributed energy. Specifically ICL wrote:
ICL believes the key question in this issue is the value of distributed energy on
Idaho Power's system. If stakeholders agreed to the value, then the pricing
conversation would be easier. But because stakeholders do not know if distributed
energy adds or avoids costs, the pricing conversation is difficult at best. ICL
encourages Idaho Power to work with stakeholders to determine an accurate value
of distributed energy on the system.
This Value of Distributed Energy study should have several key features:
Use a Technical Advisory Committee consisting of stakeholder appointees
and neutral experts
Review other similar studies to define and agree upon best methodologies
Rely on publicly available data and transparent processes to build
understanding
Agree to the type and quality of outputs before initiating study
The study then provides the basis for future discussion on the appropriate
regulatory model and rate designs. ICL encourages Idaho Power to engage in this
fact finding and analysis effort before designing possible customer classifications
and rates.
See Exhibit 402.
Idaho Power's Application here to create new customer classes is the same
request the Company made in20l3, and proposed informally in 2016 atd20l7.
Repeatedly stakeholders have expressed a desire to understand the costs and benefits of
distributed generation on Idaho Power's system as a precursor to considering possible
classification and rate changes. ICL has proposed three different processes to achieve this
understanding - a valuation based on avoided energy costs in 2013, using the 2017 IRP to
analyze the issue, and outlining a collaborative process akin to the successful efforts to
address Demand Response and Solar Integration. All of these proposals stem from
conversations with other stakeholders and would provide a foundation for an informed,
collaborative approach. Instead of working with customers, Idaho Power asks this
IPC-E-17-13
ICL PARTIAL JOINDER
November 1,2017
a
a
a
aJ
Commission to implement a change that only creates economic uncertainty for
companies and consumers with no commensurate public benefit.
One form of public benefit would be to address a verified and meaningful cost
shift. But Idaho Power's Application and testimony cannot establish this. The premise
underlying Idaho Power's alleged cost shift is that each residential or small commercial
customer causes the same fixed costs and consumes the same amount of energy as others
in the same class; rates are set accordingly. But this premise is demonstrably untrue. For
example, residents of Salmon,Idaho are an island separated from Idaho Power's main
service territory, yet the premise upon which rates are designed assumes the fixed costs to
serve a farm house in Salmon are equal to an apartment in Boise. Anyone who has looked
at a map knows this premise is not accurate. Similarly, the assumption that all residential
customers consume the same amount of energy each month is demonstrably false; for
example whether or not a home has air conditioning is a major determinate of total and
peak coincident consumption. Both of these examples teach us that current cost of service
and rate design embeds substantial costs shifts. Idaho Power makes no effort to calculate
these inaccuracies even though they represent observable and durable differences in
individual cost causation. ICL urges the Commission to consider Idaho Power's alleged
and controversial cost shift here in light of known and substantial inaccuracies embedded
in current rates.
Another public benef,rt could be the ability to collect necessary information to
address an issue. In response to Staff discovery asking what information that creating
new customer classes would provide Idaho Power responded: "The Company is currently
able to gather the information that is necessary to study various segments of customers
IPC-E-17-13
ICL PARTIAL JOINDER
November 1,20174
[.]" The response goes on to state, "should the Commission decline to authorize the
establishment of the requested new customer classes, the Company would have no reason
to modifu its class cost-of-service study or ratemaking processes." See Exhibit 403.
The Commission should reject this thinly veiled threat. Idaho Power, without
specific direction by the Commission, can and does consider changes to class cost-of-
service studies or ratemaking processes in every general rate case, and even outside of
rate cases. Instead of going far beyond what is necessary to address the question before
you, as Idaho Power asks, ICL urges the Commission to exercise the power vested in you
by the Idaho Public Utilities Commission Rules of Procedure to "invite settlement of an
entire proceeding." IDAPA 3 1.01.01.27 3.
Idaho Power Has Previously Meaningfully Engaged Stakeholders in Complex Issues
Engaging in a purposefully designed and inclusive procedure is a successful
method to understand complex issues and build consensus around solutions. When Idaho
Power sought to disband the Demand Response programs, ICL joined others in
negotiating a process to fully understand the issue and develop informed solutions. That
process began by analyzing the need for Demand Response in the 2013 IRP, established
an interim structure that preserved value for stakeholders while limiting risks perceived
by the Company, and concluded after informal public workshops created understanding
and consensus that was reflected in a Settlement Agreement. See Order No 32923. This
resolution of the issue has remained durable and effective since 2013.
In docket IPC-E-14-18 Idaho Power sought to implement new integration charges
for utility scale solar projects. ICL joined others in negotiating a purposefully designed
IPC-E-17-13
ICL PARTIAL JOINDER
5 November 1,2017
and inclusive method to build understanding and consensus. The key features of that
agreement were:
. Establishing a timetable that balanced the uncertainty faced by businesses against
Idaho Power's perceived risk of collecting inaccurate rates.
. Using a Technical Advisory Committee of experts designated by the Company,
the Commission, and stakeholders to develop robust methodologies, analysis, and
results.
. Agreeing to a framework for addressing the issue developed by a neutral third
party, there the National Renewable Energy Laboratory.
. Identiffing the specific elements the Technical Committee would analyze.
See Order No. 33227.
As a direct result of this robust and inclusive method, no one mounted a serious
challenge to the results of the study. While we suggested improvements to consider,
overall ICL joined Renewable Northwest in supporting the integration charges proposed
by Idaho Power. See Order No. 33563.
In both of these examples, Idaho Power found the ability to meaningfully engage
with stakeholders to building understanding and consensus around complex issues. In
neither case did the Company require a Commission order injecting uncertainty into the
service territory before engaging in the issue. While both processes had unique features,
they both ended in the same place - an agreement among stakeholders that has proven
durable and effective going forward. ICL proposes to achieve the same result here.
IPC-E-17-13
ICL PARTIAL JOINDER
6 November 7,2077
An Alternative Approach to Addressing Distributed Energy
Instead of injecting unwarranted uncertainty for consumers based on incomplete
analysis, ICL proposes the following as a more effective procedure to address the costs
and benefits of distributed energy - knowledge that is necessary to make any informed
decisions about rate classifications, designs, and amounts.' ICL's proposal builds upon
the Alternative Relief proposed by Idaho Clean Energy Association, Auric Solar, and the
City of Boise.
1. Establish obiective criteria to gauge meaningful impacts
Balancing the uncertainty facing business and consumers with Idaho Power's
perceived risk of rate inaccuracies is important. ICL suggests that parties establish
objective criteria by which to measure whether alleged negative impacts to the Company
are meaningful.
2. Convene a public, inclusive forum to consider the technical issues
In the Demand Response docket, stakeholders convened a series of public
workshops with a neutral facilitator. This format was essential to building understanding
and trust among participants. Other states that have considered distributed energy use a
neutral third party expert to guide the analysis of complex issues. For example, the firm
Energy+Environmental Economics (E3) developed a public tool2 to facilitate a robust,
transparent analysis of distributed resources for the California PUC and stakeholders.
3. Create a robust framework to fullv cons
' To b" clear, ICL supports Order No. 32846 instructing Idaho Power to file a general rate case to vet any
potential changes to classification or rates.
2 Mo., information available at: https://www.ethree.com/tools/acm-avoided-cost-model/
rPC-E-17-13
ICL PARTIAL JOINDER
7 November 1,2011
Because each utility system and state policy is unique, it is not possible to devise
a single, industry-wide framework to consider costs and benefits of distributed energy. It
is possible to find commonalities and best practices to adopt for Idaho. A meta-analysis
of l6 prior evaluations of distributed energy by the Rocky Mountain Institute found these
common best practices:3
Ensure a transparent process so that stakeholders have confidence in the
outcomes-
Examine the issue from a variety of perspectives by using the cost-benefit tests
developed for energy efficiency. This analytical framework has proven effective at
considering how changes in individual customer behavior impact other stakeholders.
These tests were recently updated in the 2017 National Standard Practice Manual, which
introduces a new variation the "Resource Value Test."4
Identifu a full range of elements that are relevant to consider. The attached
graphic from the Rocky Mountain Institute report, Exhibit 404, is a useful tool to identifu
and categorize common elements.
Identifr formulas and methodologies to value each of these elements. For some
elements, like avoided energy, Idaho has an existing methodology. For others, like
deferred distribution costs, Idaho utilities have begun devising methodologies. Some
elements have a clear qualitative impact, like local economic development, even if the
quantification is uncertain. A robust methodology searches for methods to quantify value,
and in the absence, establishes qualitative placeholders while stakeholders develop
additional quantitative tools.
J https://rmi.org/wp-content luploadsl2}l7l04/eLab_DERBenefitCostDeck_Report_2013-l.pdf
https://nationalefficiencyscreening.org/national-standard-practice-manual/4
IPC-E-17-13
ICL PARTIAL JOINDER
8 November 1,2077
Use a timeframe that aligns with the resource under consideration. A cost of
service study is limited to a single test year. A distributed energy system, or any
generation system, has a lifespan of decades. A robust method must capture the costs and
benefits that accrue over the lifespan of the resource.
Respect state energy policy objectives. The Idaho Energy Plan establishes a state
policy to: "Encourage the development of customer-owned and community-owned
renewable energy and combined heat and power facilities that meet the Energy Plan
Objectives of the State of Idaho."5 Those objectives include: providing secure and
reliable energy; ensuring access to energy for all Idahoans; protecting public health,
safety and the natural environment; and promoting sustainable economic growth, job
creation, and rural economic development. A robust framework respects this broad range
of objectives when establishing energy policy in Idaho.
Conclusion
After years of arguing over assumptions and allegations, ICL believes it is time to
address the fundamental question - the costs and benefits of distributed energy in Idaho.
Since 2013,ICL has repeatedly met with stakeholders to develop and propose an
inclusive method to address the underlying question. Never the less Idaho Power persists
to submit a single solution based on incomplete accounting and faulty reasoning. Instead
of wading into the debate, ICL urges the Commission to use your inherent authority to
encourage Idaho Power to collaborate with their customers.
Respectfully submitted this l't day of November,2OlT
Benjamin J. Otto
Idaho Conservation League
5 Pug" 8, Idaho Energy Plan,2012.Available at: https://oemr.idaho.gov/wp-
contenVuploa dsl20 I 6 I 06 120 I 2_idaho_energyllan_fi nal_2.pdf
rPC-E-17-13
ICL PARTIAL JOINDER
9 November 1,2017
E^k_
Benjamin J. Otto (ISB No. 8292)
710 N 6th Street
Boise,ID 83701
Ph: [phone]x12
Fax: [phone]
[e-mail]
Attorney for the Idaho Conservation League
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO )
POWER COMPANY'S AUTHORITY )
TO ESTABLISH NEW SCHEDULES )
FOR RESIDENTIAL AND SMALL )
GENERAL SERVICE CUSTOMERS )wrTH oN-srTE GENERATTON. )
CASE NO. IPC-E-I7.I3
IDAHO CONSERVATION LEAGUE
PARTIAL JOINDER
Exhibit 401
Idaho Conservation League Letter to ldaho Power Regarding the July 27 ,2016 Net
Metering Workshop and Status Report
IPC-E-17-13
ICL PARTIAL JOINDER
November 1,2017
www.idahocon*rvation org
Conservation League
PO Box 8,14, Boise, ID 83701
m8.us.69i3
August 5,2016
To: Idaho Power Company
From: Benjamin Otto,Idaho Conservation League
Re: Comments regarding the |uly 27,2016 Net Metering Workshop and Status Report
Idaho Power,
Thank you for hosting a public workshop to apprise the public of the current status of distributed
energF in your service territory and your projections for future growth in this sector. The Idaho
Conservation League acknowledges the growth of distributed energy resources presents new
challenges to a traditional utility. Along with these challenges come new opportunities as
customers invest their own dollars to meet their own energy needs and develop a two-way
relationship with utilities. We look forward to being a part of a careful, comprehensive process
assessing the full range of challenges and opportunities presented by distributed energy.
ICL believes it is important to put the current scale of distributed energy into context. Idaho
Power's 2016 Net Metering Status Report shows 7.08 MW of cumulative distributed energy
capacity as of March 3l,2}l6.t This amounts to roughly 0.2o/o of the all-time system peak.2
Applying forecasts for 2021from the Net Metering Report and the 2015 IRP reveals that even
with an aggressive forecast of distributed energy growth this ratio could increase to 0.9olo by
2021.3 The potential cost shifting is even less meaningful. The Report alleges a current cost shift
within the residential class of $55,712 from some net meterers onto all non-net meters.4 This
amounts to 0.01% of the expected revenue from the residential class in 2}l6.s Clearly there is
plenty of time to study this issue and make careful decisions.
' 2016 Net Metering Status Report at page 2, Table l.
' 2.08 MW of cumulatiye net metering nameplate capacity divided by the Idaho Power all time
system peak of 3,407 MW as reported at:
https://www.idahopower.com/AboutUs/Companylnformation/Facts/
3 The Net Metering Report, on page 12, estimates 5,930 systems under the high growth forecast,
and on page 9 uses an assumed "common" system size of 6 kw resulting in a forecast of 35,580 kw
by 2021. The 2015 IRP forecasts peak loads in 2021 tobe3,922 MW at Appendix C, page 13.
4 Id at7.
s Based on the proposed residential class revenue of $500,504,200 for 2016 filed by Idaho Power
as Exhibit 6 of Mr. Harris's testimony in IPC-E-16-02.
The National Association of Regulatory Utility Commissioners is drafting a Manual on
Distributed Energy Resources Compensation.6 Section six of the draft manual gives a framework
to place distributed resource issues into perspective for stakeholders and regulators. At the
relatively low level of penetration today, "there is time to plan and take the appropriate steps and
avoid unnecessary policy reforms simply to follow suit with actions other jurisdictions have
taken."7 The manual further suggests that when penetrations reach 5olo of peak loads distributed
energy maybe significant enough to warrant policy changes.8 Most relevant to Idaho, the manual
suggests that during this time of growth stakeholders and utilities "look closely at data, analysis
and studies from its particular service territory before [implementing policy changes] since all
electric systems are impacted by DER penetrations differently."e
ICL submits that, because distributed energy is small today although growing, the 2017
Integrated Resource Plan is the most appropriate venue to assess the full range of potential costs
and benefits that may develop over time. We appreciate Idaho Power's acknowledgement in the
Net Metering Report that net metering customers are less costly to serve than typical residential
customers.'o However, the cost of service construct used in the Report does not capture the full
range of costs and benefits that may arise from increased distributed energF. Idaho Power
acknowledged at the Net Metering Workshop, in response to a customer question, that cost of
service does not assess resource values or options, rather just the cost to provide electric service.
The Integrated Resource Plan is the appropriate venue to develop credible forecasts of potential
distributed energy growth; understand the full range of impacts to the grid, energF demands, and
capacity needs; and compare distributed energy to other resource options. This basic information
is a precursor to making informed policy decisions about distributed energy resources.
We appreciate Idaho Power continuing to monitor the growth of distributed energy in Idaho.
We thank you for hosting a well-attended public workshop to begin discussing this important
issue. And we look forward to continuing this conversation in the 2017 Integrated Resource Plan.
Sincerely,
Benjamin J. Otto
Energy Associate
Idaho Conservation League
6 Available at http://pubs.naruc.org/pub/88954963 -0F0 I -F4D9-FBA3-AC93468 I 8FB2
'NLRUC Draft DER Manual at 61.t Id at 60.
e Id.
t0 Net Metering Report at page 10, Table 4.
Benjamin J. Otto (lSB No. 8292)
710 N 6th Street
Boise,ID 83701
Ph: [phone] x12
Fax: [phone]
botto @idahoconservation. org
Attomey for the Idaho Conservation League
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO )
POWER COMPANY'S AUTHORITY )
TO ESTABLISH NEW SCHEDULES )
FOR RESIDENTIAL AND SMALL )
GENERAL SERVICE CUSTOMERS )
WITH ON-SrrE GENERATION. )
CASE NO. IPC.E-I7-I3
IDAHO CONSERVATION LEAGUE
PARTIAL JOINDER
Exhibit 402
Idaho Conservation League Letter to Idaho Power Regarding the June 16, 2017 Net
Metering Workshop and Status Report
IPC-E-17-13
ICL PARTIAL JOINDER
November l,20ll
I IDAHO
CONSERVATION
LEAGUE
208.3+5.6933 . ft) Boi: 8-t.1. Borse,lD 81702 ' crw.iddhocon5c..vaton.o,'E
Tim Tatum
Connie Aschenbrenner
Idaho Power Company
Tim and Connie:lune20,2017
Thank you for convening the June 16,2017 meeting on Net Metering. ICL looks forward to
exploring the growth of distributed energy on Idaho Power's system.
We agree with the comment of Idaho PUC Staff Stacey Donohue that the first step in the process
is to define the scale and scope of distributed energy impacts in relation to other uncertainties
embedded into the current rate structure. Idaho Power's net metering report makes clear that the
level of impact today is quite small. ICL submits stakeholders have amble time to define the issue
and consider a range of responses.
It is essential when considering distributed energy to precisely define the issue. ICL submits the
only thing that makes a distributed energy customer unique from other customers is the ability to
push power onto the grid. Any distributed energy customer that merely reduces their own
consumption is not meaningfully different than other customers. Any analysis should focus on
the actual impact of pushing energy onto the grid, not merely the ability of distributed energy to
reduce consumption of utility power.
ICL believes the key question in this issue is the value of distributed energy on Idaho Power's
system. If stakeholders agreed to the value, then the pricing conversation would be easier. But
because stakeholders do not know if distributed energy adds or avoids costs, the pricing
conversation is difficult at best. ICL encourages ldaho Power to work with stakeholders to
determine an accurate value of distributed energy on the system.
This Value of Distributed Energy study should have several key features:
. Use a Technical Advisory Committee consisting of stakeholder appointees and neutral
exPerts. Review other similar studies to define and agree upon best methodologies. Rely on publicly available data and transparent processes to build understanding. Agree to the type and quality of outputs before initiating study
The study then provides the basis for future discussion on the appropriate regulatory model and
rate designs. ICL encourages Idaho Power to engage in this fact finding and analysis effort before
designing possible customers classifications and rates.
ICL looks forward to working with Idaho Power to refine ldaho's distributed energy policy and
programs.
Ben Otto
Energy Associate
Cc: Idaho PUC - Stacey Donohue, Mike Morrison, Jonathan Farley and Karl Kline
Benjamin J. Otto (lSB No. 8292)
710 N 6th Street
Boise,ID 83701
Ph: [phone]x12
Fax: [phone]
botto@idahoconservation. org
Attorney for the Idaho Conservation League
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO
POWBR COMPANY'S AUTHORITY
TO ESTABLISH NEW SCHEDULES
FOR RESIDENTIAL AND SMALL
GENERAL SERVICE CUSTOMERS
WITH ON.SITE GENERATION.
CASE NO. IPC.E-I7-I3
IDAHO CONSERVATION LEAGUB
PARTIAL JOINDER
Exhibit 403
Idaho Power Response to Staff Production Request Number 3
)
)
)
)
)
)
rPC-E-17-13
ICL PARTIAL JOINDER
November l,20ll
LEQUEST i.tel: On page 9 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 similarly situated customers 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 quantifying 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
determines no differences 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 - 5
customers with on-site generation, the Company will continue to allocate costs to the
residential and small general service customer classes that exist today.
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 - 6
Benjamin J. Otto (ISB No. 8292)
710 N 6ft Street
Boise, ID 83701
Ph: [phone]x12
Fax: [phone]
[e-mail]
Attorney for the Idaho Conservation League
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO )
POWER COMPANY'S AUTHORITY )
TO ESTABLISH NEW SCHEDULES )
FOR RESIDENTIAL AND SMALL )
GENERAL SERVICE CUSTOMERS )
WITH ON-SrTE GENERATION. )
CASE NO.IPC-E-I7-I3
IDAHO CONSERVATION LEAGUE
PARTIAL JOINDER
Exhibit 404
Chart of Elements Included in Distributed Energy Value Studies
From: A Review of Solar PV Benefit and Cost Studiesr 2'd Edition, Roclcy Mountain
Institute, September 2013.
IPC-E-17-13
ICL PARTIAL JOINDER
November 1,2017
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CERTIFICATE OF SERVICE
I hereby certit/ that on this l't day of November 2Ol7,I delivered true and correct
copies of the foregoing PARTIAL JOINDER to the following persons via the method of
service noted:
Diane Hanian
Commission Secretary (Original and seven copies provided)
Idaho Public Utilities Commission
427 W. Washington St.
Boise,ID 83702-5983
Electronic Mail:
Idaho Power
Lisa D. Nordstrom
Tim Tatum
Connie Aschenbrenner
Idaho Power Company
P.O. Box 70
Boise,Idaho 83701
lnordstrom@idahopower. com
ttatum@idahopower. c om
[e-mail]
[e-mail]
Idaho PUC Staff
Sean Costello
Deputy Attorneys General
Idaho Public Utilities Commission
472 W. Washington
Boise ID 83702
sean.costello@puc. idaho. gov
Idahohydro
C Tom Arkoosh
Arkoosh Law Offrces
802 W Bannock St., Suite 900
PO Box 2900
Boise, ID 83701
tom. arkoosh@arkoosh. com
erin. [e-mail]
Idaho lrrigation Pumper s Assoc iat ion
Eric L. Olsen
Echo Hawk & Olsen PLLC
505 Pershing Ave., Suite 100
PO Box. 6119
Pocatello,ID 83205
[e-mail]
Anthony Yankel
29814 Lake Road
Bay Village, Ohio 44140
Fax: [phone]
[e-mail]
Auric LLC
Elias Bishop
Auric Solar, LLC
2310 s 1300 w.
West Valley City, UT 84119
[e-mail]
Preston N. Carter
Deborah E. Nelson
Givens Pursley LLC
601 WBannockSt.
Boise,lD 83702
prestoncarter@givenspursley. com
[e-mail]
Sierra Club
Kelsey Jae Nunez, LLC
Sierra Club
920 N. Clover Drive
Hand delivery:
Boise,ID 83703
kelsey@kelseyj aenunez. com
Zack Waterman
Idaho Sierra Club
503 W. Franklin St.
Boise, ID 83702
zack.waterman@sierraclub. org
[e-mail]
City of Boise
Abigail R. Germaine
Deputy City Attorney
Boise City Attorney's Office
105 N. Capitol Blvd.
PO Box 500
Boise,ID 83701
agermaine@cityofboise. org
Idaho Clean Energt Association
C Tom Arkoosh
Arkoosh Law Offices
802 W Bannock St., Suite 900
PO Box 2900
Boise, tD 83701
tom.arkoosh@arkoosh. com
erin.cecil@arkoosh. com
David H. Arkoosh
Law Office of David Arkoosh
PO Box 2817
Boise,ID 83701
[e-mail]
Vote Solar
David Bender
Earthjustice
3916 Nakoma Road
Madison, WI 53711
dbender@earthj ustice. com
Briana Kober
Vote Solar
360 22nd Street, Suite 730
Oakland, CA946l2
[e-mail]
J. Kahle Becker
223 N. 6th St., Suite 325
Boise, lD 83702
kahle@kahlebeckerlaw. com
Snake River Alliance and NW Energt
Coalition
John R. Hammond, Jr.
Fischer Pusch, LLP
101 S. Capitol Blvd., Suite 701
PO Box 1308
Boise,ID 83701
[e-mail]
Wendy Wilson
Executive Director, Snake River
Alliance
[e-mail]
Diego Rivas
Policy Associate, NW Energy Coalition
[e-mail]
Intermountain Wind and Solar, LLC
Ryan B. Frazier
Brian W. Burnett
Kirton McConkie
50 East Temple, Suite 400
PO Box 45120
Salt Lake City, UT 8411
[e-mail]
[e-mail]
Intermountain Wind and Solar, LLC'
1952 West 2425 South
Woods Cross, UT 84087
[e-mail]
[e-mail]
Benjamin J. Otto