20201117Reply Comments.pdf

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LISA D. NORDSTROIi
Lead Gounrel
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November 17,2020
ELECTRONIC FILING
Jan Noriyuki, Secretary
ldaho Public Utilities Commission
11331 W. Chinden Boulevard
Building 8, Suite 201'A
Boise, ldaho 83714
Re Case No. IPC-E-20-26
ln the Matter of ldaho Power Company's Application for Authority to
Modiff Schedule 84's Metering Requirement and to Grandfather Existing
Customers with Two Meters
Dear Ms. Noriyuki:
Attached for electronic filing, pursuant to Order No. 34602, is ldaho Power
Company's Reply Comments.
lf you have any questions about the attached document, please do not hesitate to
contact me.
Very truly yours,
fr;!.fl,,,t +,,.*,
Lisa D. Nordstrom
LDN:slb
Attachment
LISA D. NORDSTROM (tSB No. 5733)
ldaho Power Company
1221 West ldaho Street (Bg7O2l
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: (208) 38S-0936
lnordstrom@ irJahopower. com
Attorney for ldaho Power Company
IN THE MATTER OF IDAHO POIA'ER
COMPANY'S APPLICATION FOR
AUTHORITY TO MODIFY SCHEDULE
84's METERING REQUTREMENT AND TO
GRANDFATHER EXISTI NG CUSTOMERS
WITH TWO METERS.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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GASE NO. !PC-E-20-26
IDAHO POWER COMPANY'S
REPLY COMMENTS
ldaho Power Company ('ldaho Powe/'or the'Company') respects its customers'
desire to self-generate electricity. To better facilitate this, ldaho power proposes to
modiff the interconnection requirement from a two+neter to a single+neter
interconnection requirement to reduce customer costs and administrative complexities
associated with interconnection under Schedule &4, Customer Energy production Net
Metering service ("schedule 84'). wrile the ldaho public utilities commission
("Commission") has directed that grandfathered status be provided to ldaho power
IDAHO POVVER COMPANY'S REPLY COMENTS - 1
Residential & Small General Service ('R&SGS') customergeneratorsl and Roc*y
Mountain Powe/s net metering participants,2 such treatment does not yet exist for ldaho
Power's Commercial, lndustria! & lrrigation ("Cl&1") customergenerators. To that end,
simultaneous with the implementation of a single-meter requirement, the Company
requests that the Commission grandfather existing customers and applicants with two
meters under the cunent one-for-one net metering billing construct provided for in
Schedule 84. Establishing a clear delineation between grandfathered Cl&l net metering
customers and those for which future changes will apply will better position the Company
to engage with interested parties from all customer segments to develop its upcoming
study of the compensation structure and uniform export credit rate.
I. BACKGROUND
The Company filed an Application on June 19, 2020, requesting Commission
authorization to: (1) modify the metering requirement under Schedule &4 from a two-
meter to a single-meter requirement on December 1, 2020, or another date as ordered
by the Commission ("Effective Date') and (2) simultaneous with the implementation of a
single-meter requirement, grandfatherexisting customers and applicants with two meters
under the cunent one-for-one net metering billing construct provided for in Schedule 84,
for a period of no more than ten (10) years. lf the Company's proposal is approved, all
new single-metered systems would not be grandfathered, and therefore would be subject
1 ln the Matter of the Petition of ldaho Power Company to Study the Cosfe Benefits, and Compensation of
Nef Excsss Energy Supplied by Customer On-Srfe Genention, Case No. IPC-E-'l8-15, Order Nos, 34509
(December 20, 2019) and 34546 (February 5,20201. Grandfathered demarcation date December 20,2019,
including customers that made a financial commitment before this date and interconnect within one year.
2 ln the Matter of the Application of Rocky Mountain Power to Close the Net Metering Prognm fo New
Seryioe & lmplement a Net Biiling Prcgrum to Compansate Customer-Genentors for Exported Generation,
Case No. PAC-E-19-08, Adopting Order No. 34798 (October 2,20201. Grandfathered demarcation date
October 2,2020, including customers that interconnect within one year.
IDAHO POWER COMPANY'S REPLY COMENTS .2
to any future Commission-approved changes to the billing and cornpensation structure
under Schedule &4 or a sucoessor tariff offering, ordered by the Commission.
Parties of record filed comments, including the Commission Staff ("Staff'), City of
Boise, ldaho Conservation League ("lCL'), ldaho Siena Club joined by ldaho Clean
Energy Association ("Sierra Club"), and Russell Schiermeier, on October 27, 2020.
Pursuant to the Notice of Modified Procedure issued by the Gommission in Order No.
34777, ldaho Power hereby submits its Reply Comments responding to parties' proposals
and addressing why it is appropriate for the Commission to establish grandfathering now
for ldaho Powe/s C!&l customers taking servie under Schedule 84.
II. SCHEDULE 84 IIIETERING CONFIGURATION
Before filing this request, ldaho Powe/s discussions with customers, instalters,
and other stakeholders indicated that modification of Schedule 84 to accommodate a
single-meter configuration could reduce the costs and complexities of an on-site
generation interconnection for Schedule 84 customers. The Company appreciates Staffs
support for the Company's proposalto require new Schedule 84 customergenerators to
be metered through a single meter.3 The Company also notes that while no other party
opposed a modification in the metering requirement to a single-meter installation, several
parties introduced additional proposals for the Commission's onsideration. The
Company addresses each of those below.
3 Staff Comrnents at 2,
IDAHO POWER COMPANY'S REPLY COMENTS - 3
A. Modification to a Single-lteter Requirement Does Not lmpact the Existing
Meter Aggregation Rules for Excess Net Energy.
The Company has evaluated the concerns raised in Russell Schiermeie/s
comments, as well as @noerns raised in public testimony, regarding existing systems
'specifically designed to aggregate to larger load sites.'4 No changes to existing meter
aggregation rules have been discussed or recommended in the Company's Application
or the proposed revisions to Schedule &4, Conditions of Purchase and Sale, Section 2.
To clariff, both existing two-meter and new single-meter Schedule 84 systems would
have the opportunity to aggregate Excess Net Energy credits pursuant to the existing
provisions of Schedule 84. Under the Company's current proposal in this case, existing
and new Schedule &4 customers would see no change in how Excess Net Energy credits
are treated.
B.The Commiesion Should lmplement a Single-illeter lnterconnection for All
New lnstallations and Allow Existing Schedule 84 GustomerGenerators to
Retain the Two{llleter Systems.
\Mrile Staff supports the Gompany's proposal to require new Schedule 84
customer-generators to install a single-meter,S both ICL and the City of Boise suggest
that the Commission should authorize new Schedule 84 customerc to choose between a
single- or two-meter option.6 It is important to note, neither lCL nor the City of Boise
provides evidence to validate the suggestion that "some solar-owners may electto pursue
[a dual meter option] because it would better serve their needs."7 On the contrary, if the
4 Russell Schiermebr Comments at 5.
s Staff Comments at 2.
6 ICL Comments at 2. City of Boise Comments at 3.
7 ICL Commenb at 2.
IDAHO POVI/ER COMPANY'S REPLY COMENTS.4
Commission were to allow customers to choose between a single- or two-meter option, it
would result in "incremental costs and complexities"E for two-meter systems - neither of
which better serves customer needs. Every installation of a second meter, configured as
required under the existing Schedule 84, requires customers to incur additional expense
that would not be neoessary under a single-meter configuration. The Commission initially
approved two-meter interconnections for Cl&l customergenerators under Schedule 84
to allow for the recovery of demand-related charges,e not for customer preference.
Further, these future dual-metered installations would be differently situated from other
single-meter installations. Their billing configurations would be based on different data:
the dual-metered customers would not be able to offset demand, while the single-metered
customers could.
ICL also incorrectly assumes that "if Schedule 84 mandates that all customer-
owned systems use a single-meter, current solar-owners with dual meters will be out of
compliance when the grandfathering period expires since their system wil! not conform to
the tariff.'10 [ is common practice for a tariffschedule to be modified to close a particular
offering to new customers without inhibiting the service schedule's eligibility for existing
customers. Attachment 1 of the Company's Application illustrates that the Applicability
section defines that the "Two-Meter lnterconnection'would be closed to new applicants
as of the Effective Date, and that the "Single-Meter lnterconnection" would be applicable
to new applicants as of the Effective Date. Therefore, under the Company's proposal,
EAschenbrenner, Dl at 15.
s ln the Matter of the fiplication of ldaho Power Company for Amendments to Schedule 84 - Nat Metering,
Case No. IPC-E-02-04, Order No. 29094 (August 21,2002).
10 IGL Comments at 2.
IDAHO POVVER COMPANY'S REPLY COMENTS - 5
two-meter grandfathered systems would still be in compliance when the grandfathering
period expires.
Implementing a single-meter interconnection for all new Schedule 84 installations
is also consistent with other net metering interconnection requirements in ldaho. The
Company is not aware of other electric utilities in ldaho that allow customers to install on-
site generation under a two-meter configuration. ICL referenoes a Commission order in
their comments, highlighting that "[t]he Commission has consistently tried to align the net
metering programs between ldaho utilities to the extent reasonable,"ll which suggests it
would be more reasonable for the Commission to require all new Schedule &4 customers
to interconnect under a single-meter configuration.
Staff believes the Commission should allow existing Schedule &4 customer-
generators to retain two-meter systems indefinitely.l2 \ ltrile it is not opposed to Staffs
position in principle, the Company believes it is imperative to note whether a dual-meter
would need to convert to a single-meter to accommodate a future billing structure would
depend on the billing structure implemented at that future point in time. The Company
believes this evaluation could be accomplished through a future filing, for the
Commission's consideration, well in advance of the date when the grandfathering period
for Schedule &4 expires to present a recommendation related to how two-metered sites
are transitioned to a successor tariff.
11 ICL CommenE at 8 citing Case No. PAGE-I9-08, Proposed Order No 34752 at 7 (later adopted by Order
No. 34798).
12 Staff Comments, at 3.
IDAHO POWER COMPANY'S REPLY COMENTS - 6
III. GRANDFATHERING
A. As Has Been Done for Other ldaho Power and Rocky Mountain Power
CustomerGenerators, The Gommission Should DetErmine the Grandfather
Status of ldaho Power's Cl&l Customers Wthout Delay.
As it did in Case No. IPC-E-18-15 for R&SGS customers, the Commission should
resolve the issue of grandfathering in this case for Cl&l customers. ln its Application filed
in this case, the Company argued that a differing meter configuration (a two-meter versus
a single-meter requirement) provides a reasonabh distinction for purposes of
grandfathering.B ln developing its initial recommendation, the Company considered the
Commission's position in Case Nos. IPC-E-18-15 and IPC-E-19-15 related to Cl&l
customers.
As noted by several parties, after the Company submitted its Application in Case
No. IPC-E-20-26, the Commission issued an order grandfathering Rocky Mountain
Power's customergenerators.ll The Commission found it'Tair, just, reasonable, non-
discriminatory, and in the public interest to grandfather existing Rocky Mountain Power
customer-generators on the same terms the Commission granted existing ldaho Power
customer-generators in IPC-E-18-15.'15 The Commission also stated that Rocky
Mountain Power customergenerators were similarly siluated 'in their reasonable
expectations of fundamental program stability" and noted, 'the Commission has
consistently tried to align the net metering programs between ldaho utilities to the extent
reasonable."l6
13 Application at 5. Aschenbrenner Dl, at 15.
ta Case No. PAC-E-19-08, Order No. 34798 adopting Proposed Order No. UT52,
15 Order No 34752, at 7.
16ld.
IDAHO POVI/ER COMPANY'S REPLY COMENTS - 7
The Commission grandfathered existing ldaho Power R&SGS customer-
generators and all Rocky Mountain Power customer-generators on the basis that it was
no longer reasonable for a customer to assume the net metering program fundamentals
will remain the same over the expected payback period of their investment.lT As noted
in parties' comments and the public testimony on the record in Case No. IPC-E-20-26,
ldaho Power Cl&l customer{enerators are similarly situated, as they have generally
testified to making investments with the expectation that existing program fundamentals
would remain.
B. The Gommission's Determination on Gmndfathering Now is Gritical to Notify
Potsntial Customers That it is No Longer Reasonable to Assume the Net-
iietering Fundamentals Will Remain the Same Over the Expected Payback
Period.
The Comments of Staff and the City of Boise suggest that the Commission should
defer a decision on grandfathering existing Schedule 84 customers - Staff argues
defening until a sucoessor program is proposed, and City of Boise argues until a
comprehensive study of on-site generation has been completed.lo ICL and Sierra Glub
indicate that the Commission should make a grandfather status determination now but
align the grandfathering date with establishing a successor tiariff.le However, these
positions are counter to what the Commission found in Case Nos. IPC-E-18-15 and PAC-
E-19-08, and would create an unnecessary difference in the treatment of ldaho Powe/s
Cl&l customer-generators as compared to similarly situated ldaho Power and Rocky
Mountain Power customer-generators. ln Case No. IPC-E-I8-15, Order No. 34546, the
17 Order Nos. 34509 at 10 and 34752 al7.
18 SEff Comments at 4, Ci$ of Boise Comments at 4
le ICL Comments at 3, Siern Club Comments at 1.
IDAHO POWER COMPANY'S REPLY COMENTS. S
Commission stated the following regarding the timing at which customers are eligible for
grandfathered status:
We decided to grandfather customers based on our
acknowledgment that, until that point, customers reasonably could
have believed that the fundamentals of the net metering program
would not change...it would contravene our rationale to extend the
date at which customers are elisible for qrandfather status. and we
therefore decline to do so.20 (emphasis added)
The Commission has made the decision to grandfather existing net-metering customers
without a successor schedule or a study. Staffs comments restate the Commission
finding in Case No. IPC-E-18-15: "customers who have made significant investments in
on-site generation systems reasonably differ from customers who have not yet made
significant investments in on-site generation systems, and this difference justifies
separate treatment.'2l The suggestion to defer a decision on grandfathering, in this case,
would not only result in preferentialtreatment for similarly situated customer{enerators
but relies on contradictory policy and, as a result, will create confusion for customers.
Both ICL and Sierra Club suggest that grandfathering existing customers now
without a successor tariff is not fair, just, or reasonable. ICL states that such a decision
will result in 'leaving customers with no option but to purchase from...ldaho Power,"22 and
Sierra Club statesthat"[alfairand assessable opportunityto self-generate is vitalto many
customerc."Z3 As previously mentioned, the Commission has already made similar
decisions in Case Nos. IPC-E-18-15 and PAC-E-19-08. These arguments also incorrectly
m Order No. 34546 at 10.
21 Staff Comments at B citing Oder No. 34509 at 12.
22 ICL Comments at 3.
23 Sierra Club Comments at 3.
IDAHO POWER COMPANY'S REPLY COMENTS - 9
assume that existing customers have no applicable net metering tariff schedule to install
on-site generation. Prospective Cl&l customers would continue to have the ability to
install on-site generation to offset all or a portion of their energy under Schedule 84 single-
meter option after the Effective Date or to install a non-exporting system without similar
limitations on installed system capacity.2a
Siena Club also argues that the Commission's decision to grandfather R&SGS
customers in Case No. IPC-E-18-15 resulted in a greater than 40 percent reduction in
solar installation capacity.2s This provocative overstatement ignores the impact of the
decrease in the solar investrnent tax credit, which also occurred in December 2019, and
the economic impact of the COVID-l9 pandemic that began to affect ldaho Power
customers early in 2020. The reduction claimed by Sierra Club compares the capacity
installed in a single month (December 2019) to the capacity installed in a different month
(August zlz}),which is arbitrary and ignores the impact of seasonality. Figure 1 provides
a more accurate representation of the change in installed solar capacity for R&SGS
customers for the months following the Commission's decision in Case No. IPC-E-18-15.
Fioure 1
SolarCapacity lnstalled (ldaho Schedules 6 & 8l
Tlne Period tW lnstalled
December 20'18 - At4ust 2019 10.4
9.3December2019 -2020
2a On July 20, 2A20, the Company filed an applicaton seeking to implement a non-export option and
requested no size limitations for customers taking service under Schedules 9, 19, ot 24 (GI&l customerc).
See, ln the Matter of ldaho Power Company's Application for Authorfi to Establish Tariff Schedule 68,
lntarconnections to Customer Distributed Eneryy Resources, Case No. IPC-E-20-30.
2s Siena Club Comments at 3,
IDAHO POWER COMPANY'S REPLY COMENTS - 1O
Figure 1 compares the year-over-year change for the months December through
August for the data provided as Attachment 1 in response to Sierra Club's Discovery
Request No. 4. lnstalled solar capacity for R&SGS customers for the months December
2019 through August 2020 decreased from 10.4 MW to 9.3 MW or 1 1 percent year,over-
year. However, to suggest that any reduction in installed capacity is isolated to the
Commission's decision to grandfather - in light of other macroeconomic conditions - is
speculative and misguided.
Now is the appropriate time for the Commission to determine the grandfather
status for Schedule 84 customer-generators. The following rationale all support the
conclusion that existing two-meter systems should be grandfathered as of the Effective
Date of a Schedule 84 single-meter requirement: (1) the modification to a single-meter
requirement physically and functionally differentiates existing customergenerators from
new customer-generators, (2) the requested delineation provides formal notice from the
Commission that it is no longer reasonable for Cl&l customers to expect the net-metering
fundamentials to remain the same, and (3) the proposed grandfathering treatment
provides reasonable accommodation for customers who have made a significant
investment in on-site generation prior to notice from the Commission. Therefore, the
Company requests that the Commission grandfather existing two-meter Schedule 84
customers simultaneous with a change to a single-meter requirement as of the Effective
Date.
IDAHO PO\'l'ER COMPANY'S REPLY COMENTS - 11
C. A l0-Year Grandfathering Period is Reasonable for the Business and
Regulatory Sawy CI&l Customer Segment; However, the Gompany
Recognizes Thers Are Reasons for Which the Commission May Consider a
25-Year G randfathering Period.
ln the Company's Application, ldaho Power proposed a 1O-year grandfathering
period for existing Schedule 84 customers. ln Case No. IPC-E-19-15, the Commission
declined to suspend Schedule 84, stiating, "Cl&l customers are well-verced in both
regulatory proceedings and this Commission's authori$ and responsibilities.'zG The
Company contends that it is reasonable for the Gommission to approve a 10-year
grandfathering period for Schedule &4 systems due to the reasonable expectation that
Cl&l customers, to a greater extent than R&SGS customerc, underctood the
fundamentals associated with the net metering service offering would be subject to
change. The Company disagrees with ICL's misrepresentation that the Companfs
rationale for a 1O-year grandfathering period in its Application was "a mere 'belief in the
ability of some customerc to have a better understianding than other customers.'27
However, the Company also understands the rationale and merit for the positions
presented by Staffand Russell Schiermeier's filed Comments. Staffstates that the'public
testimony in this case demonstrates that Schedule 84 customers have been making
investment decisions under many of the same assumptions that Schedule 6 and
Schedule 8 customers made their decisions."2E Russell Schiermeier stiates that "flust like
the residentia! customers were addressed in IPC-E-18-15, the irrigation customers were
n h the Mafter of ldaho Powefs Application to Evaluate Schedule 84 - Net Meteing,IPC-E-19-15, Order
No. 34335 at 2.
27lCL Gomments at 8,
20 Staff Comments at 7.
IDAHO POWER COMPANY'S REPLY COMENTS - 12
under the same understanding.'ze The positions of Staff and Russell Schiermeier support
the position that Schedule 84 customergenerators are similarly situated to those
customer-generatorc in Case No. IPC-E-18-15.
ln further support of a 2}-year grandfathering period, Staff and ICL's comments
both reference PAC-E-19-08 and Order No. 34752, where the Commission found:
...it is fair, iust, reasonable, nondiscriminatory, and in the public
interest to grandfather existing Rocky Mountain Power customer
generators on the same terms the Commission granted existing
ldaho Power customer-generators in IPC-E-18-15. There has been
no showing of how Rocky Mountain Power customer-generators are
differently situated than ldaho Power customers in their reasonable
expectations of fundamentalprogram stability. The Commission has
consistentlv tried to alion the net meterino proorams between ldahg
utilities to the extent oossible. See Order No. 29260 at 6.30
(emphasis added)
The Company's Application in Case No. IPC-E-20-26 was filed before Order No.
U752was issued by the Commission. The Company did not have the same information
when the 10-year grandfathering period was proposed as parties had in advance of filing
their respective comments on Oc'tober 27,2020.
The Company acknorledges Staffs argument that if the Commission issues a
determination on grandfathering in this case, that a 2S-year period is reasonable based
on the premise that CI&l customers may .look at the treatment that Schedule 6 and
Schedule 8 customers received, and reasonably conclude that the Commission would
grant them grandfathering treatment on the same or similar terms."3l Staff also stated
that "[e]xisting Schedule 84 customers have made the same, if not more substantial types
r Russell Schiermeier Comments, at 6.
s Order No 34752, at 7.
sr Staff Comments al 7.
IDAHO POWER COMPANY'S REPLY COMENTS - 13
of investments as Schedule 6 and Schedule 8 customers, based on many of the same
principles."3z ln light of the Commission's position in IPC-E-18-15, PAC-E-19-08, and
comments from Staff, other parties, and public testimony in Case No. IPC-E-20-26, the
Gompany recognizes it is reasonable for the Commission to assess the merits of a
grandfather period of 25 years for existing Schedule 84 systems.
IV. SCHEDULE 84 IOO.KT'U CAP
A review of the 100-kW nameplate capacity cap is outside the scope of this case
and is appropriately considered only after program fundamentials, including pricing for
exports, have been addressed. The 100-kW cap contained in Schedule 84 was initially
established by the Gommission in Case No. IPC-E-02-04, Order No. 29094. The rationale
for a cap for individual installations of 25-kW (for R&SGS customers) and 100-kW (for
Cl&l customers) was to limitthe amountthat other customers subsidize some of the costs
of serving net metering customers.33 As highlighted in Staffs comments in Case No. IPC-
E-Ol-39, "ffior the Commission to accept a net metering tariff where customer generation
is credited at full retail rates, it must be willing to accept the fact that ldaho Power may
not recover its full costs of providing service from net metering customers."s Additionally,
in implementing the cap, the Commlssion noted a reasonable limit for Cl&l customers
should align with the Federal Energy Regulatory Commission minimum qualifying facility
size of 100 kW.35
32 Staff Comments at 8.
s Order No. 29094 at 3, citing Order No. 28951 at 11.
Y ln the Maftar of the Apptication of ldaho Power Company for Apprcval of a New Schedule 84 - Net
M eterin g T aritr, lP C-E-0 1 -39, Staff Comments at 3.
gs ln the Matter of the Apptication of ldaho Power Company for Approval of a New Scfiedule 84 - Net
Metering Tarttr, IPC-E-01-39, Order No. 28951, at 1 1.
IDAHO POVT,ER COMPANY,S REPLY COMENTS - 14
ldaho Power disagrees with Sierra Club's suggestion that the 100-kW cap should
be evaluated in this case. An evaluation of the 100-kW cap is most appropriately
considered after the net metering underlying fundamentals are addressed, such as
measurement interval and excess net energy compensation. The request in this filing is
appropriately limited in scope, and only seeks to streamline the interconnection process
by modiffing to a single-meter requirement and implement grandfathering for existing
Schedule &4 customers.
Moreover, discussion of this unrelated issue has not been noticed to properly elicit
comments from interested persons that could provide the Commission with a reasonable
evidentiary basis to evaluate changes to the 100-kW cap. Because no party to this case
has presented any changes to Schedule 84 that would address cost-shifting concerns the
100-kW cap was intended to mitigate, it would be inappropriate to evaluate or modiff the
cap in this case. A review of the 100-kW cap is only appropriately considered after
program fundamentals, including pricing for exports, have been addressed.
V. STUDY COSTS AND BENEFITS OF DISTRIBUTED ON.SITE GENERATION
ldaho Power appreciates the comments from parties requesting that ldaho Power
initiate a filing to study the compensation structure and export credit rate following the
process the Commission laid out in Order Nos. 34509 and 34546. The Company looks
forward to the opportunity to collaborate with interested stakeholders and appreciates the
thoughtful analysis conducted by Sierra Club and reflected in its comments.
ldaho Power's intent regarding all net metering issues is to address pricing
equitably. Additionally, as stated in filed testimony in this case, resolving grandhthering
for ldaho Power's remaining customer classes wil!: "enable the Company and interested
IDAHO POWER COMPANY'S REPLY COMENTS. 15
stakeholders to address a study of the costs and benefits of distributed on-site generation
to the Company's system."36 ICL claims that "ldaho Power stiates in regards to all net
metering issues, a primary goal for the utility is to slow the growth of customer-owned
solar.,'37 ldaho Power takes exception to this allegation; it is not only a
mischaracterization of the Company's intent but contrary to ldaho Power's explicit
statements made on its website and customer communication documents'38,3e Moreover,
through its actions, the Company has sought Commission approvalto eliminate the two-
meter requirement in Case No. IPC-E-2}-26 and, in Case No. IPC-E-20-30, institute a
non-export option to further remove barriers to entry that existfor all customerc who wish
to install on-site generation. The Company intends to submit a filing to formally initiate a
comprehensive study of the costs and benefits of distributed on-site generation upon
completion of Case Nos. IPC-E-20-26 and IPC-E-20-30.
vl. coNclusloN
The Company's proposal in this case to modify the interconnection requirement
from a two-meter to a single-meter configuration will reduce barriers for customers and
reduce complexities associated with Schedule 84 interconnection. ln response to other
proposals suggested by parties'comments, ldaho Power reiterates its position that (1)
modification to a single-meter requirement does not impact the existing meter aggregation
s Aschenbrenner, Dl at 25.
* tn the Matter ot tctaho Power Company's Applicatbn for Authoity to Modify S$"a{9 &4's Metering
aeqiiremeit and to Gnnctfather Eiistiig criitomers with Two Meters, case No' lPc-E-20-26' lcL
Comments at 3.
36 https:/ r^^fvr,.idahopower.com/energv-environmenuoreen-choicedsolar-oovver-options'customer-
ggneration/
3e httos://u,u
^,.idahopower.cotn/e[€roy-environmenuoreen-choices/so]ar-Dower-ootions€ustomer-qe neration/freq uentlY'asked'ouestiony
IDAHO POWER COMPANY'S REPLY COMENTS - 16
rules; (2) it is reasonable forthe Commission to implement a single-meter interconnection
for all new Schedule &4 installations and allow existing Schedule 84 customer4enerators
to retain the two-meter systems; and (3) a review of the 1OO-kW cap is out of scope for
this case and only appropriately considered after program fundamentats, including the
pricing for exports, have been addressed.
Simultaneous with the implementation of a singte-meter requirement, the
Company requests that the Commission grandfather existing customerc and appticants
with two meters under the current one-for-one net metering bilting construct provided for
in Schedule 84, for a period of no more than ten (10) years. As described above, there
are no distinguishing factors that would suggest that ldaho Powe/s Cl&t customers
should not be grandfathered. The Company believes it is prudent to decide on
grandfathering now to notiff potential customers that it is no longer reasonable to assume
the net-metering fundamentals will remain the same over the expected payback period.
ldaho Power contends that a 1O-year grandfathering period is reasonable; however, the
Company recognizes there may be reasons for the Commission to consider a 2s-year
grandfathering period. Modiffing the metering requirement and grandfathering existing
and pending Schedule 84 systems willeliminatethe uncertainty regarding the applicability
of grandfathering and future changes to the compensation structure and valuation of the
export credit rate. A decision to grandfather will create clarity as to the applicability of
future changes in response to a study of the compensation structure and export credit
rate.
IDAHO POWER COMPANY'S REPLY COMENTS. 17
DATED at Boiee, ldaho, thb 17t'day of Norcnrber 2020,
X*!-ff^*t"*,
LISA D. NORDSTROM
Attomey br ldaho Porpr Company
IDAHO POTTT'ER COMPA]{Ys REPLY COMENTS.ls
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 17th day of November,2020l served a true and
correct copy of the within and foregoing IDAHO POWER COMPANY'S REPLY
COMMENTS upon the following named parties by the method indicated below, and
addressed to the following:
Commission Staff
Edward Jewell
Deputy Aftorney General
ldaho Public Utilities Commission
11331 West Chinden Blvd., Building 8
Suite 201-A (83714)
P.O. Box 83720
Boise, ldaho 8372A-OO7 4
ldaho Irrigation Pumpers Assoclatlon, lnc.
Eric L. Olsen
ECHO HAWK & OLSEN, PLLC
505 Perching Avenue, Suite 100
P.O. Box 6119
Pocatello, ldaho 83205
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Anthony Yankel
12700 Lake Avenue, Unit 2505
Lakewood, Ohio 44107
ldaho Gonservation League
Benjamin J. Otto
ldaho Conservation League
710 North 6th Street
Boise, ldaho 83702
City of Boise Glty
Abigail R. Germaine
Deputy City Attorney
Boise City Attorney's Office
105 North Capitol Boulevard
P.O. Box 500
Boise, ldaho 83701-05000
IDAHO POWER COMPANY'S REPLY COMENTS - 19
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Micron Technology, lnc.
Austin Rueschhoff
Thorvald A. Nelson
Holland & Hart, LLP
555 17h Street, Suite 3200
Denver, Colorado 80202
Jim Swier
Micron Technology, lnc.
8000 South FederalWay
Boise, ldaho 83747
ldaho Sierra Club
Kelsey Jae
Law for Conscious Leadership
920 North Clover Drive
Boise, ldaho 83703
Lisa Young
Mike Heckler
ldaho Sierra Club
503 West Franklin Street
Boise, ldaho 83702
lndividual
Russell Schiermeier
29393 Davis Road
Bruneau, ldaho 83604
IOAHO POWER COMPANY'S REPLY COMENTS.20
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tnelson @ h ol land ha rt. com
[e-mail]
o loarqanoamari@holland hart. com
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michael. p. heckler@omai!.com
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Stephanie L. Buckner,
Executive Assistant