20200619Aschenbrenner Direct.pdf

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BEFORE THE IDAI{O PI'BIJIC UTIIJITIES COMMISSION
IN THE MATTER OF IDAI{O POWER
COMPANY' S APPLICATION FOR
AUTHORITY TO MODIFY SCHEDULE 84'S
METERING REQUIREMENT AND TO
GRAIIDFATHER EXISTING CT'STOMERS
WITH TWO METERS
IDAI{O POWER COMPAI\TY
DIRECT TESTIMONY
CONNIE G. ASCHENBRETiINER
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cAsE NO. IPC-E-20-26
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l- O. Please state your name, business address, and
2 present position with Idaho Power Company ("Idaho Power" or
3 "Company").
4 A. My name is Connj-e G. Aschenbrenner. My
5 business address is t22L West Idaho Street, Boise, Idaho
6 83702. I am employed by Idaho Power as the Rate Design
7 Senior Manager in the Regulatory Affairs Department.
8 Q. Please describe your educational background.
9 A. In May of 2005, I received a Bachelor of
10 Business Administration degree in Finance from Boise State
lL University in Boise, Idaho. In December of 20LL, I earned
L2 a Master of Business Administration degree from Boise State
13 University. In addition, I have attended the electric
1-4 utility ratemaking course The Basics; PracEical Regulatory
l-5 Training for the Electric Industry, a course offered
15 through New Mexico State University's Center for Publ-ic
1-7 Utilities.
L8 O. Please describe your work experience with
19 Idaho Power.
20 A. In 201-2, I was hired as a Regulatory Analyst
2L in the Company's Regulatory Affairs Department. My primary
22 responsibilities incl-uded support of the Company's
23 Commercial and Industrial customer class's rate design and
24 general support of tariff rules and regulations. In 20L5,
25 I assumed responsibilities associated with Residential and
ASCHENBRENNER, DI
Idaho Power Company
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1 Sma1l General Service rate design, as well as regrrlatory
2 support associated with demand-side management (*DSM')
3 activities. In 20L6, I was promoted to a Senior Regulatory
4 Analyst, and my responsibilities e>cpanded to include the
5 development of complex cost-related studies. fn 2OL7, I
5 was promoted to Rate Design Manager for Idaho Power, and in
7 2Ol9 f was promoted to my current role as Rate Design
8 Senior Manager. I am currently responsible for the
9 manag'ement of the rate design strategies of the Compdny, as
l-0 well as oversight of all tariff administration. fn my
1l- current role, f am one of the Company representatives at
1-2 its Energy Efficiency Advisory Group (*EEAG") meetings.
13 O. What is the Company's request in this docket?
1,4 A. With this case, the Company requests that the
l-5 Idaho Public Utilities Commission ("Commission") authorize
16 the Company to modify the metering reguirement under
L7 Schedule 84, Customer Energy Production Net Metering
18 Service ("Schedul-e 84') to be effective on December 1,
1-9 2020, ot another date as ordered by the Commission
20 ("Effective Date"). The requested modification would
21, remove the two-meter requirement for new Schedule 84
22 customers that begin taking service under Schedule 84 on or
23 after the Effective Date. The Company further requests
24 that, sj-multaneous with the implementation of the single-
25 meter requirement, the Commission grandfather existing
ASCHENBRENNER, DI
fdaho Power Company
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L customers and applicants with two-meter systems under the
2 ctrrent one-for-one net metering billing construct provided
3 for in Schedule 84, for a period of no more than J-0 years.
4 O. How is your testimony organized?
5 A. The first section of my testj-mony will discuss
6 pertinent history related to Schedule 84 that is currently
7 applicable to Schedule 84 net metering customers. In the
8 second section, I will describe recent and potential future
9 growth in Schedule 84. The third section of my testimony
10 will outline the Company's request for the Commission to
lL modify the metering requirement for new Schedule 84
L2 customers and to grandfather existj-ng Schedule 84
13 customers. The concluding section will describe the
14 Company's efforts related to customer notice.
L5 I. History of ScheduLe 84
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O. Please describe the Company's net metering
service offered under Schedule 84.
A. Schedule 84 is an optional service offered by
the Company for customers j-ntending to operate their own
generation facilities with a capacity up to 100 kilowatts
("kW") to offset a portion or all their energ'y usage. Net
metering customers may transfer excess electricity to the
Company from customer-owned generation facj-Iities.
ASCHENBRENNER, DI
Idaho Power Company
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1- O. When was Idaho Power's Schedule 84 initially
2 made available to commercial, industrial, and irrigation
3 customers?
4 A. By way of compliance with Commission Order No.
5 28951-, the Company filed an application in Case No. IPC-E-
6 02-04 presenting a net metering proposal for the Company's
7 commercial, industrial, and irrigation ("Cf&I") customers.
8 The Company reguested approval of amendments to its
9 existing Schedule 84 that: (1-) allowed customers receiving
L0 retail service under schedules other than Schedule 1 or
11 Schedule 7 to connect a generating resource they own or
L2 operate to the Company's system to offset all or part of
L3 their electric consumption by means of a financial credit
14 on their bi11ing, (2) allowed the Company t,o continue to
15 charge the CI&I net metering customer with a demand
1,6 component in its retail rates for the electrical demand
17 their load places on Idaho Power's system, (3) did not
L8 impose any monthly charges other than those provided for in
1,9 the Company's standard service schedu1e appJ-icable to the
20 net metering customer, (4) credited all energy provided in
2l excess of the customer's consumption at a price that does
22 not result in a subsidy from other customers, (5) permitted
23 generating projects with a capacity up to 100 kW to
24 intercor:nect to the Company's system in a safe and reliable
ASCHENBRENNER, DT
Idaho Power Company
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manner, and (5) provided for broad-based access to
customers to participate in net metering.
O. What differences related to interconnection
and metering requirements were proposed in Case No. IPC-E-
02-04 for CI&I net metering customers compared to
residential and sma1I general service net metering
customers?
A. Residential and smal1 general service
(*R&SGS") net metering customers utilized a single utility
meter to net both consumption and excess generation. In
the development of the Company's proposed CI&I net metering
service, the CI&I net metering customer would continue to
use a standard utility meter that measured the customer's
demand and energ'y, and a second meter installed to measure
the energy provided by the customer's generating facility.
This metering configuration provided the customer with the
ability to offset any energy charges with the production
from their on-site generation system. Additionally, it
enabled the collection of demand and basic load capacity
charges based on the customer's gross demand, measured
independent of the on-site generation.
O. Was there support for the Company's original
two-meter proposal for CI&I net metering?
A. Yes, the Commission Staff ("Staff") supported
the Company's proposal, incl-udj-ng the requirement that
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Idaho Power Company
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1 customers pay the cost of installing a new meter base and
2 second meter. fn that case, Staff contended that demand
3 charges al1ow the utility to recover its cost of
4 maintaining the capacity and necessary infrastructure to
5 serve a particular customer and should not be offset.t
5 O. Did the Commission approve the Company's
7 request to implement net metering for CI&I customers?
8 A. Yes. The Commission approved the Company's
9 request as filed in Order No. 29094.
10 O. Have there been any changes to the Schedule 84
Ll- metering requirements since 2OO2?
1,2 A. Yes. In 2016, the Commission approved a
L3 modification to allow for the second met,er to be installed,
14 at the Company's discretion, either adjacent to or on the
L5 customer's side of the point of delivery. The Company
15 proposed this change in Advice No. 16-05 to reduce the
1-7 barriers to participation for primary service-Ievel
LB customers who desire to install on-site generation. The
19 existing requirement, was unnecessarily limiting because, in
20 some cases, the Company understood compliance with the
2L existing two-meter requirement was cost-prohibitive.
L In the MaEter of the AppTication of Idaho Power Companyfor Amendments to Schedule 84 - Net Metering, Case No. IPC-
E-02-04, Staff Comments aL 4.
ASCHENBRENNER, DI
Idaho Power Company
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1- O. Please summarize the Company's request in Case
2 No IPC-E-19-L5.
3 A. The Company became aware that CI&I customers
4 were relying on an expectation of the continued net monthly
5 compensation structure to calculate their potential return
5 on investment. In consideration of ongoing R&SGS
7 discussions at that time in Case No. IPC-E-I-8-15 to
I comprehensively study the costs and benefits of on-site
9 generatJ-on on Idaho Power's systemr ds well as proper rates
10 and rate design, transitional rates, and related issues of
LL compensation for net. excess energy as provided as a
12 resource to the Company, the Company was concerned that
13 certain CI&I customers may be pursuing the installation of
14 on-site generation systems that may not prove to be
L5 economical under a dj-fferent compensation structure.
l-6 Further, the growth of installed and pending capacity in
:-'7 these customer segments, most notably within the irrigation
18 segment, had become of a magnitude that the Company felt it
19 was necessary to bring to the Commission's attention.
20 O. What was the proposed scope of Case No. IPC-E-
2L 19-15?
22 A. In its application filed in April 20L9, the
23 Company recommended addressing the measurement interval and
24 compensatj-on structure for CI&I net metering customers in
25 the newly filed case (Case No. IPC-E-19-15) due to the
ASCHENBRENNER, DI
Idaho Power Company
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L different int,erconnection and metering reguirements for
2 CI&I customers. The Company proposed that the value of
3 Excess Net Energy for CI&I customers be evaluated in Case
4 No. IPC-E-l-8-L5, in which the compensation structure and
5 value for Excess Net Energ-y was being studied for R&SGS net
5 metering customer classes.
7 Q. How did the Commission ultimately process Case
8 No. IPC-E-19-15?
9 A. In Order No. 34335, the Commission determined
L0 that the scope of IPC-E-L8-1-5 should not be broadened to
l-l- include the interests of CI&I customers under Schedule 84.
1-2 The Commission concluded that merging IPC-E-18-l-5 and IPC-
L3 E-l-9-L5 would result in a disadvant,age to CI&I customers by
1-4 not having the benefit of fu1I participation in the IPC-E-
15 l-8-15 docket that had already beg-un. Additionally, the
1-6 Commission stated that it e>cpected consistent application
1-7 of the principles across the dockets.2
18 O. What was the result of Case No. IPC-E-L8-Ls?
L9 A. Parties met on ilanuary 9, 2019, for a
20 prehearing conference and subsequently held eight
2L settlement conferences that resulted in settlement of
22 issues related to the Company's Application. The
2 In the Matter of ldaho Power's AppTication to Eval-uate
Schedule 84 - Net Metering, Case No. IPC-E-19-L5, Order No.
34335 at 1.
ASCHENBRENNER, DI
Idaho Power Company
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L Commission ultimately rejected the proposed Settlement
2 Agreement and ordered (1) Idaho Power t.o submit a
3 comprehensive net metering cost/benefit study informed by
4 public workshops and public input prior to proposing
5 changes to the net metering structure, and (2) existing
5 R&SGS net met.ering customers grandfathered into Schedules 5
7 or 8 under the rules in place as of the service date of
8 Order No. 34509, December 20, 20]-9.
9 O. What grandfathering parameters were put into
10 place by the Commission for R&SGS customers in Case No.
r-r- rPc-E- l_8 - L5?
1-2 A. The Commission defined grandfathered systems
13 as existing Schedule 5 and Schedule 8 customers under the
14 rules in place as of the service date of Order No. 34509,
15 December 20, 20]-9. The Commission further ordered four
16 criteria that would apply for grandfathering by system: (1)
1-7 a customer who moves into a property with a grandfathered
18 on-site generation system will "inherit" the grandfathered
19 status of the system, (2) if a system is offline for longer
20 than six months, or is moved to another site, the
2l grandfathered system is forfeited, (3) to allow for the
22 replacement of degraded or broken panels, the customer may
23 increase the capacity of the grandfathered system by no
24 more than 10 percent of the originally installed nameplate
ASCHENBRENNER, DI
Idaho Power Company
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1 capacity or l- kw, whichever is greater, and (4)
2 grandfathered status terminates December 20, 2045.3
3 Q. Did the decision on grandfathering in Case No.
4 fPC-E-18-L5 appfy to the Company's CI&f customers?
5 A. No. In Order No. 34546, the Commission stated
5 that the decision to grandfather existing customers was
7 based on the facts of that case. The Commission further
8 not,ed if CI&I customers in Schedule 84 are to be
9 grandfathered as of a specific date, that decision must be
L0 made based on the facts presented in a separate case.
1l- O. What was t,he outcome of Case No. IPC-E-l-9-l-5?
12 A. In Iight, of the orders issued in Case No. IPC-
L3 E-L8-15, the Company filed to withdraw its petition on
L4 March 17, 2020. The Company stated that the matters
L5 related to compensation structure and export credit rate
1-5 for Schedule 84 customers would be addressed in a new
1-7 future docket applying the process the Commission laid out
18 in Order Nos. 34509 and 34546.
1,9 II. Schedule 84 Growth
20 O. What is the current 1eve1 of participation in
2l Schedule 84?
3 In the Matter of the Petition of ldaho Power Company to
Study the Costs, Benefits, and Compensation of Net Excess
Energy Supplied by Customer On-Site Generation, Case No.
IPC-E-L8-J.5, Order Nos. 34509 (December 20, 2019) and 34546
(February 4, 2020).
ASCHENBRENNER, DI
Idaho Power Company
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1 A. As shown in Figure L, the participation in
2 Schedule 84 as of May 31, 2020, included 155 service poj-nts
3 with 6.96 MW of installed generation capacity and 175
4 service points with 14.85 MW of pending generation
5 capacity, for a total potential for 340 service points with
6 2L.82 MW of Schedule 84 generation capacity.
7 Figure 1
Idaho Schedule 84 - Total Participation
(As of May 31, 2O2O)
Number of Participants (Count by Service Point)
Commercial
(r0e )
Industrial
(r1e )
Irrigation
(r24l TotaI
Installed
Pending
Total
L27
26
2 36
]-49
155
1-7 5
153 2 18s 340
Nameplate Generation (M$I)
Commercial
(r0e )
Industrial
(r19 )
IrrigaEion
(T241 TotaI
Installed
Pending
3.83
L.52
0.07 3.05
13 .33
6.96
t_4 .85
8
9
10
TotaI 5.35 0 .07 16 .40 2L.82
O. What defines a pending net metering customer?
A. Pending net metering customers are customers
who have sent in their completed application and paid a
$100 application fee. Sj-nce 2003, 86 percent of CI&I
customers that have applied for net metering service have
completed the j-nterconnection process and take service
under Schedule 84.
ASCHENBRENNER, DI
Idaho Power Company
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L O. What level of growth has the Company observed
2 in Schedule 84 over the last five years?
3 A. The Company has e>cperienced increasing growth
4 in Schedule 84, as shown in Figure 2. From 2015 t,hrough
5 20L9, Schedule 84 has exlgerienced a 49 percent, compound
6 annual growth rate ('CAGR") in installed generation
7 capacity. From year-end 20L9 through the end of May 2020,
8 there has been a 257 percent increase in active and pending
9 Schedule 84 generation capacity.
10 Fiqure No. 2
25 MW
Idaho Schedu]e 84
Total- Nameplate Capacity
2OL5 - May 31, 2020
20 MW
15 MW
10 MW CAGR49t
5MW 3.95 M$I
MW ry*ifigH
20L5 20L5 20L7 2018 20L9
lCumulative Capacity rPending Capacity
May 2020
YTD
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Recent Schedule 84 growth continues to be primarily
driven by the irrigation class, Ers shown in Figur€ 3, which
has e>cperienced a L27 percent CAGR in installed generation
capacity from 20L5 through 20L9, with most of that growth
occurring in the last two years. In just the five months
between year-end 20L9 and the end of May 2020, installed
ASCHENBREIiINER, DI
Idaho Power Company
6.11 MW
14.85 MW
6. 96 MW
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l- and pending generatj.on capacity in the irrigation class has
2 grown 554 percent, from 2.47 MW to 1-6.40 MW.
3 Based on this growth, the Company betieves it is in
4 the best interest of customers, both existing and future,
5 to know to what extent they may be impacted by the outcome
6 of a future docket that results in a change to the
7 measurement interval or compensation structure applied to
8 Schedule 84. The Commission issuing a determination on
g grandfathering in this case will provide essential
LO information for customers that have or are evaluating on-
l-L site generation investments.
L2 Figure No. 3
Idaho Schedule 84 (Irrigation Only)
Total Nameplate CapacitY
201,5 - May 31, 2020
MW
MW
MW
MW
MW
MW
CAGR
0.09
20
1_5
10
5
96
0.l_3 MW
2 015 20L6 201-7
tCumulative Capacity
2-47 MW1.09 MW
--
201,8 20]-9
rPending Capacity
L21t^
May 2020
YTD
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ASCHENBRENNER, DI
Idaho Power Company
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3 .06 MW
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IfI. Modifications to Meterinq Recnrirement and
Grandfathering Request
O. What specifically is the Company requesting in
this case?
A. The Company requests that the Commission
authorize the Company to modify the metering requirement
under Schedule 84 from a two-meter to single-meter
requirement and issue an order to grandfather existing
Schedule 84 customers with two-meter interconnections for a
period of no more than 1-0 years pursuant to the current
metering and billing provisions contained in Schedule 84 as
of the Effective Date. Under this proposal, all new
single-metered systems would not be grandfathered, and
therefore would be subject to any future changes to the
billing and compensation structure provided under Schedule
84 or a successor tariff offering, ordered by the
Commission.
A. How does the Company propose to change the
metering requirement applicable to Schedule 84 customers?
A. The Company is requesting to implement a
single-meter interconnection requirement for all new
Schedule 84 customers. The proposed modification would
remove the two-meter requirement for the retail electric
service that is measured separately from a customer's on-
site generation. The Company has provided a revised
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Idaho Power Company
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l- Schedule 84 tariff with the Application as Attachment No. 1
2 and requests that the Commission issue an order approving
3 it as of the Effective Date.
4 O. Why is the Company requesting to modify the
5 metering requirement as part of this case?
5 A. In discussions with customers, installers, and
? other stakeholders, the Company is aware of concerns
8 associated with the j-ncremental costs and complexities that
9 exist as a result of this metering requirement. Further,
10 modification of the metering requirement and transition to
1L a single-meter requirement, simultaneous with a Commission
L2 decision on grandfathering, would enable the Company to
l-3 holistically study the value of excess energy for all on-
1-4 sj-te generation in both the R&SGS and CI&I customer
15 classes. Fina11y, the Company believes the modification in
15 the metering requirement provides a reasonable distinction
L7 for the Commission to rely on as a basis for
L8 grandfathering.
L9 O. How will- modification of the metering
20 requirement impact future study of appropriate interval and
2L value of excess net energy?
22 A. The change in the metering requirement will
23 more closely align the characteristics that exist for R&SGS
24 on-site generation systems and new CI&I on-site generation
25 systems. As a result, all new on-sj-te generation sysEems
ASCHENBRENNER, DI
Idaho Power Company
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L wou1d be similarly situated for a future study of the
2 appropriate interval and value of excess net energy for a
3 comprehensive study with public input as directed by the
4 Commission in Case No. IPC-E-L8-l-5.
5 0. Will the modification to a single-meter
5 interconnection requirement j-mpact the Company's ability to
7 recover its fixed cost of service from Schedule 84
8 customers?
9 A. Yes, but Iike1y to only a limited extent in
L0 the near-term. The proposed modification to a single-meter
Ll- requirement for new Schedule 84 customers results in a
L2 reduced ability for the Company to continue to collect a
l-3 portion of its fixed costs from on-site generation
14 customers through reduced demand charge revenue. The
l-5 impact on the collection of fixed costs, albeit relatively
16 small in the near-term, will be directly attributed to a
L7 CI&I customer's ability to offset a portion of their
1-8 demand-related charges with a single-meter.
L9 a. Did the Company consider the impact of the
20 lost fixed cost recovery t,hat results from the single-meter
2l proposal?
22 A. Yes. However, as highlighted in Figrures 1-3,
23 much of the growth in the Schedule 84 service is contained
24 within the irrigation customer class and is primarily solar
25 generation. Due to the nature of their usage, EIr
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Idaho Power Company
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L irrigation customer has limited ability to offset their
2 demand with on-site solar generation. However, the
3 continued application of retail rate net metering, with
4 either a single or dual meter, provides the ability for
5 those customers to avoid contributions to fixed cost
6 recovery collected through the energ:y component of their
7 rates. Modification of the metering reguirement in
8 conjunction with establishing the Eerms of grandfathering
9 will position the Company, stakeholders, and the Commission
10 to address any intra-cIass subsidy concerns caused by
l-1 retail rate net metering holistically for all customer
1,2 classes in a future case.
l-3 O. Does the Company support implementing the
14 single-meter interconnection requirement absent the
15 Commission establishing grandfathering in this case?
L6 A. Yes, but only under specific conditions
1-7 regarding grandfathering. The two-meter requirement was
18 initially established, in part, to minimize subsidies
1,9 inherent with retail rate net metering. While the Company
20 is agreeable to pursuing this modification, it is only
2l reguestj-ng a change in conjunction with establishing clear
22 terms for grandfathering. However, in the event the
23 Commission ultimately determines that all CI&f customers,
24 regardless of metering configuration or date of
25 int.erconnection, will be subject to future changes in
ASCHENBRENNER, DI
Idaho Power Company
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1 compensation structure, the Company would continue to
2 support modifying the metering requirements to a single-
3 meter configruration.
4 O. Do the other investor-owned electric utilities
5 in Idaho require a two-meter requirement for Cf&I on-site
6 generation?
7 A. No. Rocky Mountain Power and Avista only
8 require a single meter for their Cf&I on-site generation
9 offering.
L0 O. On what basis does the Company propose the
l-1 Commission grandfather existing Schedule 84 customers?
12 A. The proposed change to a single-meter
L3 intercor:nection requirement reasonably differentiates
14 customers who paid for additional metering infrastructure
l-5 from customers who will not. In consideration of the
L5 Commission's grandfather findings in Order Nos. 34509 and
1-7 34546, it is not reasonable for a CI&I customer to assume
18 the net metering service fundamentals will remain the same
19 over the e>cpecEed payback period of their investment.
20 Therefore, the Company requests the Commission issue an
2l order to grandfat,her existing Schedule 84 customers as of
22 the Effective Date.
23 O. Why do you believe now is the appropriate time
24 for the Commissi-on to issue a determination on
ASCHENBRENNER, DI
Idaho Power Company
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1- grandfathering existing Schedule 84 customers and
2 applicants with two-meter systems?
3 A. In a future docket, the Company will study
4 the compensation structure and e>ryort credit rate following
5 the process the Commission laid out in Order Nos. 34509 and
6 34546. This future study may result in changes to the
7 measurement interval and compensation structure applicable
8 to Schedule 6, 8, and 84 customers. Making a determination
9 on the terms of grandfathering for Schedule 84 customers in
10 this case establishes who would and would not be subject to
11 potential changes in the compensation structure and the
L2 export credit rate.
L3 O. How does the Company propose the Commission
L4 define existing Schedule 84 customers with two-meter
L5 systems for purposes of grandfathering?
16 A. The Company proposes defining an existing
L7 customer as a person or business who either has an approved
18 two-meter on-site generation system interconnected with
19 Idaho Power's system before the Effective Date or who has
20 su-bmitted an application to install a two-meter on-site
2L generation system as of the Effective Date ordered by the
22 Commission. A customer that has applied for the Company's
23 net metering service before the Commission's ordered
24 Effective Date would be reguired to proceed to interconnect
ASCHENBRENNER, DI
Idaho Power Company
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L their system within one year of their date of application.a
2 Further, any customer that submitted an application after
3 the service date of this Application would be rtequi-rea to
4 provide proof to the Company that a financial investment in
5 a two-meter system was made before the Commission's ordered
6 Effective Date.
7 Any person or business who submits an application
8 after the Effective Date would be required to interconnect
9 under the rules in place at that time. As more fu11y
L0 explained beIow, all potential customers and known
11 installers operating in the Company's service area will
12 have received reasonable notice of the Company's request to
13 modify the meter interconnection requirements and the
L4 reqr:ested date of j-mplementation of the new requirements.
15 O. What other criteria does the Company propose
LG to apply to the grandfathered customers?
t7 A. The following criteria would apply to
LB grandfathered systems: (1) a customer who moves into a
L9 property with a grandfathered on-site generation system
20 will "inherit" the grandfathered status of the system, (2)
21- if a system is offline for longer than six months, or is
22 moved to another site, the grandfathered system is
a Schedule 12 provides that "app1i-catj-ons
complet.ed within one year of the initial
are considered expired." (Page 9)
that are notFeasibility Review
ASCHENBRENNER, DI
Idaho Power Company
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l- forfeited, (3) to allow for the replacement of degraded or
2 broken panels, for applications received before May 1,
3 2O2Os, the customer may increase the capacity of the
4 grandfathered system by no more than 10 percent of the
5 originally installed nameplate capacity or 1 kW, whichever
6 is greater, (4) grandfathered status termj-nates 10 years
7 from the Commission Order date, and (5) a customer who
8 modifies their system from a two-meter intercor:nection to a
9 single-meter interconnection will forfeit their
10 grandfathering status.
11 The Company also proposes that any Schedule 8
12 customer who was grandfathered by the Commission in Order
L3 Nos. 34509 and 34546 would maintain grandfathering status
14 as prescribed by the Commission j-n those orders if they
l-5 later exceed the energy reguirements of Schedule 8 and are
15 moved to Schedule 9 and take service under Schedule 84.
17 O. How does the Company propose to process
1-8 requests for system expansions?
L9 A. The customer would have two choices: (1) the
20 existing grandfathered system would remain behind the
2L second customer generation meter, and the new system would
5 As of May 1 , 2020, solar on-site generation capacity has
been evaluated in terms of the inverter size (AC), not the
panel size (DC), for the Feasibility review. Therefore,
changes to panel size do not direct.ly impact the nameplate
capaci-ty of the inverter for systems evaluated on or after
May 1, 2020.
ASCHENBRENNER, DI
Idaho Power Company
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be placed behind the load meter, or (2) the existing and
new systems could be combined, following the customer
generation rules in place at the time, and placed behind a
single meter with the 1oad.
O. Please explain why the Company believes a 10-
year grandfathering period is appropriate in this case.
A.In its application in IPC-E-19-15, the Company
sought to suspend service under Schedule 84, primarily due
to concerns that customers were making decisions to install
10 on-site generation based on the assumption that retail rate
LL net metering would continue over the life of the system.
1-2 In Order No. 34335, the Commission ultimately declined to
L3 suspend Schedule 84, stating in part:
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The likelihood of a change in rates or
rate structure is not a unique situation thatjustifies suspending a program. Cf&I
customers are well versed in both regulatory
proceedings and this Commission's authorityand responsibilities. Indeed, the Idaho
Irrigation Pumpers Association has already
intervened. As long as solar installers and
other sellers of net metering systems are not
misrepresenting how utility rates and rate
structures operate, customers should have
suf f icient underst,anding that a change in
rates and/or rate structures will impact the
payback period for a net metering system.
The Company believes it is reasonable to e)ryect CI&I
customers, to a greater extent than R&SGS customers,
understood that fundamentals associated with the net
metering service offering would be subject to change.
ASCHENBRENNER, DI
Idaho Power Company
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IV. Customer Comrnunication
O. How will the Company notify customers of the
Company's proposal in this case?
A. The Company will notify all CI&I customers,
regardless of whether they have on-site generation
installed, of the proposed change. The Company will notify
existing and pending Schedule 84 customers by sending a
direct mail letter informj-ng them of the proposed metering
change as well as the proposal to grandfather. Attachment
No. 2 Lo the Application contains a draft of the letter
t,hat will be sent to existing and pending customers.
The Company also will send bill inserts to all CI&I
customers to make them aware of the Company's proposal and
the opportunlty for public review. Attachment No. 3 to the
Application includes a copy of the bill j-nsert that will be
sent to customers with their bi11s.
O. How will the Company notify installers of the
proposed changes?
A. The Company will notify the installer
community through an email to the distribution list for its
periodic publj-cation, the Customer Generation Newsletter.
Attachment No. 4 to the Application includes a copy of the
not,ification that will be sent to installers following the
filing.
ASCHENBRENNER, DI
Idaho Power Company
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l- O. What other means will the Company use to
2 communicate with customers and installers regarding the
3 proposed change?
4 A. The Company has, concurrent with this filing,
5 updated its website to notify potential customers of the
5 proposal; Ehe Company will maj-ntain a list of Freguently
7 Asked Questions ("FAQs") that will remain accessible to
8 existing and potential customers, as well as installers.
9 The Company will also notify applicants and their
L0 designated installer of the proposed changes when the
lL Company sends the application confirmation emai1.
1,2 V. ConcLuEion
1_3 O. Please summarize the Company's request in this
14 case.
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A. The Company requests that the Commj-ssion
authorize the Company to modify the metering reguj-rement
under Schedule 84 from a two-meter to a single meter
reguirement that can be implemented by December 1, 2020 (or
another date as ordered by the Commission). The Company
further reguests that, simultaneous with the implementation
of the single-meter requirement, the Commission grandfather
existing customers and applicants with two-meter systems
under the current one-for-one net metering billing
construct provided for in Schedule 84 for a period of no
more than 10 years.
ASCHENBRENNER, DI
Idaho Power Company
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Approval of the Company's request will enable the
Company and interested stakeholders to address a study of
the costs and benefits of distributed on-site generation to
the Company's system, according to Order Nos. 34509 and
34546, that would apply t,o aII new Schedule 6, Schedule 8,
and Schedule 84 customers.
O. Does this conclude your testimony?
A. Yes.
ASCHH{BRENNER, DI
Idatro Power Comparry
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DECI.ARATION OF CONNIE G. ASCHEIIBRENNER
I, Connie G. Aschenbrenner, declare under penalty of
perjury under the laws of the state of Idaho:
L. My name is Connie G. Aschenbrenner. I am
employed by Idaho Power Company as the Senior Manager of
Rate Design in the Regulatory Affairs Department.
2. On behalf of fdaho Power, I present this
pre-filed direct testimony in this matter.
3. To the best of my knowledge, my pre-fiIed
direct testimony is true and accurate.
I hereby declare that the above statement is true to
the best of my knowledge and belief, and that I understand
it is made for use as evidence before the ldaho Public
Utilities Commission and is subject to penalty for perjury.
SIGNED this 1-9th day of ,June 2020, 3t Boise, Idaho.
/s/
Connie G. Aschenlcrenner
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ASCHENBRENNER, DI
Idaho Power Company
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