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HomeMy WebLinkAbout20210628Application.pdfsmm. An loAcoFp companv LISA D. NORDSTROII Lead Coumd lnoldgtromtDldahopmr.corn LDN:sh Attachments June 25,2021 VIA ELECTRONIC FlLlNG Jan Noriyuki, Secretrary ldaho Public Utilities Commission 11331 West Chinden Blvd., Building 8 Suite 201-A Boise, ldaho 83714 Re: Case No. IPC-E-21-21 ln the Matter of the Application of ldaho Power Company's Application to lnitiate a Multi-Phase Collaborative Process for the Study of Costs, Benefits, and Compensation of Net Excess EnergyAssociated with CustomerOn-Site Generation Dear Ms. Noriyuki: Attached for electronic filing, pursuant to Order No. 35058, is ldaho Power Company'sApplication in the above entitled matter. Also attached is the DirectTestimony of ConnieA.schenbrennerfiled in support of the Application.AVbrd version of thetestimony is also attached brthe reporter. Finally, copies of ldaho Porrer Companfs customer notioe/bill insert and lnstaller newsletter/email are also attached. lf you have any questions about the attached documents, please do not hesitate to contact me. Very truly yours, X*!.(^*+r,-*,, Lisa D. Nordstrom LISA D. NORDSTROM (lSB No. 5733) Idaho Power Company 1221 West ldaho Street (83702) P.O. Box 70 Boise, Idaho 83707 Telephone: (208) 388-61 17 Facsimile: (208) 388-6936 lnordstrom@ idahopower. com Attorney for ldaho Power Company BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF IDAHO POWER COMPANY'S APPLICATION TO INITIATE A MULTI-PHASE COLLABORATIVE PROCESS FOR THE STUDY OF COSTS, BENEFITS, AND COMPENATION OF NET EXCESS ENERGY ASSOCIATED WTH CUSTOMER ON.SITE GENERATION CASE NO. IPC-E-21-21 APPLICATION ldaho Power Company ("ldaho Power" or "Company"), in response to the ldaho Public Utilities Commission's ("Commission") directive in Order No. 34046,1 respectfully requests that the Commission initiate the multi-phase process for a comprehensive study of the costs and benefits of on-site generation. ldaho Power further requests the Commission acknowledge Attachment 1 as an initial draft for Staff, other intervenors, and the public to consider and provide feedback on for the Commission's consideration. Ultimately, the Company requests the Commission to approve a final scoping document, which will conclude the "study design" phase. ln support of this Application, ldaho Power asserts as follows: 1 ln the Matter of the Application of ldaho Power Company for Authority to Establish New Schedules for Residential and Small General Seryice Customers with On-Site Genention, Gase No. IPC-E-17-13, Order No. 34046 at 31 (May 9, 2018). APPLICATION - 1 ) ) ) ) ) ) ) ) ) I. BACKGROUND On-Site Generation 1. Some retail customers choose to install "on-site generation" equipment, most commonly solar panels, to meet some or all of their electric needs. While generating electricity on-site, these customers are also simultaneously connected in parallelto ldaho Power's grid and the vast majority export energy to the grid. Customers who install on- site generation can interconnect an Exporting System under the terms of Schedule 6, Residential Service On-Site Generation ("Schedule 6"), Schedule 8, Small General Service On-Site Generation ("Schedule 8"), Schedule 68, lnterconnections to Customer Distributed Energy Resources ("Schedule 68") and Schedule 84, Customer Energy Production Net Metering Service ("Schedule 84"). Customers who installa Non-Exporting System continue to take service under the retail rate schedule they qualiff for based on the applicability of the Company's retail tariff schedules. All customers with on-site generation are subject to the terms of Schedule 68 governing interconnection. 2. As of May 31 ,2021, there are 7,789 Exporting Systems interconnected and taking service under Schedules 6, 8, and 84 and three (3) Non-Exporting Systems interconnected and taking service under Schedules I and 19. Collectively, these customer systems represent approximately 70 MW of generation, Billino Structure 3, The billing structure currently applicable to these schedules is referred to as "net metering." Under the net metering compensation structure, if electricity supplied by the Company during a Billing Period exceeds the electricity generated by the Customer and delivered to the Company during the Billing Period, the Customer is billed for the net electricity supplied by the Company at the rates contained within the applicable service schedule. lf the electricity generated by the Customer and delivered to the Company during the Billing Period exceeds the electricity supplied by the Company during the APPLICATION - 2 Billing Period, the Excess Net Energy is carried forward as a kilowatt-hour ("k\A/h") credit to offset energy usage in a subsequent Billing Period, These customers could also be referred to as "partial requirements" customers because they are offuetting some or all of their usage with their own generation. 4. ldaho Power's current retail rates were designed to align with the load characteristics of full requirements customers. A large portion of the Company's revenue requirement is collected through volumetric energy rates, including costs associated with all components of the electrical system, from investment in generation resources to the meters installed on customers' premises. Consequently, the energy rates for ldaho Power's customers include not only the variable energy-related components of the revenue requirement, but also the fixed operations and maintenance and plant-related costs associated with generation, transmission, distribution, and customer care. 5. Because fixed costs do not vary with changes in the amount of energy consumed from Idaho Power, a volumetric rate does not fully recover fixed costs associated with customers who offset their consumption with on-site generation. The Company's residential and small general service (.R&SGS") customers have the most significant portion of fixed costs - 91 percent2 - collected through those schedules' volumetric charge. The Company's large general service (commercial), industrial, and irrigation customer classes ("Cl&|" customers) have 60, 39, and 70 percent, respectively, of each schedule's fixed costs collected through the volumetric charges. 6. To more accurately assign the appropriate share of fixed costs and unquantified benefits of on-site generation, in Order No. 34046 the Commission directed the Company to (1) "undertake a comprehensive study of fixed costs" and (2) "initiate a docket to comprehensively study the costs and benefits of on-site generation on ldaho 2 Fixed costs collected through volumetric charges proportion is calculated from inputs sourced from the Company's most recent general rate case, Case No. IPC-E-I1-08. APPLICATION .3 Powe/s system, as well as proper rates and rate design, transitional rates, and related issues of compensation for net excess energy provided as a resource to the Company.'3 Case No. IPC-E-18-15 7. ln Order No. 34509 the Commission directed ldaho Power to prepare and file a "credible and fair study" of the costs and benefits of distributed on-site generation where: (1) the study must use the most current data possible and must be readily available to the public, and in the Commission's decision-making record; (2) the Company must design the study in coordination with the parties and the public, and the Commission will determine the final scope of the study; (3) the study must be written, so it is understandable to an average customer, but its analysis must be able to withstand expert scrutiny.a 8. ln its Order, the Commission outlined a "study design" phase and a "study review" phase. During the "study design" phase, Staff and the Company will both "host public workshops to share information and perspectives on net-metering program design with the public and to listen to customer concerns and input."s ln the "study review" phase, the public will have the opportunity to comment on whether the study sufficiently addressed their concerns and their opinions on what the study shows. 9. While the study is intended to inform future implementation of on-site generation compensation and billing structures, the Commission's order established criteria6 to define legacy treatment for systems under Schedule 6 and Schedule 8. The 3 Order No. 34046 at 31 4 ln the Matter of the Application of ldaho Power Company to Study the Costs, Benefits, and Compensationof NetExcess EnergySuppliedbyCustomerOn-Srte Generation, CaseNo. IPC-E-18-15, Order No. 34509 at 9 (December 20, 2019). 5ld.at9 6 Order No. 34509 at 14-15 and Order No. 34546 at 8-9 and 10-11 APPLICATION - 4 legacy systems would be subject to the rules in place as of the service date of Order No. 34509, December 20,2019. A legacy system is defined as either an on-site generation system interconnected with ldaho Power's system as of the service date of Order No. 34509, or a customer with a binding financial commitment to install an on-site generation system that proceeds to interconnect their system on or before December 20,2020.7 While legacy systems operate under the terms of Schedule 6 or Schedule 8 as those Schedules existed on December 20, 2019, rates and rate structure are subject to change for legacy systems until and after legacy status terminates on December 20, 2M5.8 As of May 31, 2021, there are 5,400 legacy R&SGS systems interconnected to ldaho Powe/s system. Case No. IPC-E-20-26 10. To determine legacy treatment for Cl&l customers, the Company initiated Case No. IPC-E-20-26 for authorization to change Schedule 84's two-meter requirement to a single-meter requirement for new customer-generators and to establish legacy treatment for existing customer-generators under the current rules as of December 1, 2020. The Commission ultimately established criteria similar to Case No. IPC-E-18-15, to provide legacy treatment to Schedule 84 systems under the rules in place as of the service date of Order No. 34854.e 11. The Commission's Order Nos. 34854 and 34892 delineated between legacy systems and new systems subject to future changes informed by a comprehensive study. A legacy system is defined as either an on-site generation system interconnected with ldaho Power's system as of the service date of Order No. 34854, or a customer with a 7 Order No. 34509 at 14 8Id.at9 s ln the Matter of ldaho Power Company's Application to Modify Schedule 84's Metering Requirement and to Grandfather Existing Customers with Two Meters, Case No. IPC-E-20-26, Order No. 34854 at 11 (December 1,2020), APPLICATION - 5 binding financial commitment to instal! an on-site generation system that proceeds to interconnect their system on or before December 1,2021.1o 12. Similar to Case No. IPC-E-18-15, the Commission determined that Schedule 84 systems that qualify for legacy treatment continue to be subject to changes in consumption rates but not to changes in the 1:1 monthly k\A/tr retail rate compensation structure until legacy status terminates on December 1,2045.11 As of May 31 ,202'1, there are 302 legacy Schedule 84 systems interconnected to ldaho Power's system. II. STUDY DESIGN PHASE: IDAHO POWER,S PROPOSED SCOPE 13. The Company's primary objective of the study process is to establish a sustainable on-site generation offering that limits subsidies by implementing a more equitable pricing and compensation structure. The multi-phase study process will be accomplished through a transparent and collaborative approach with stakeholders and the public. Ultimately, the Company anticipates proposals to implement changes to the on-site generation offering will be informed by the studies and should seek to eliminate or minimize potentialcross-subsidies that exist between participants and non-participants of on-site generation through rate design and compensation structures for on-site generation customers. Further, the Company believes recommendations to modify the existing offering should focus on cost-of-service principles, while identifying the appropriate value of excess net energy to ensure equitable compensation for on-site generators. 14. ln compliance with Commission Order No. 34509, the Company has developed a draft scope of an on-site generation study for public review and input. The draft scope is included as Attachment 1. To develop the draft scope of the study design la ln the Matter of ldaho Power Company's Application to Modify Schedule 84's Meteing Requirement and to Grandfather Existing Customers with Two Meters, Case No. IPC-E-z}-2fl Order No. 34892 at 9 (January 14,20211. 11 Order No. 34854 at 11. APPLICATION .6 the Company leveraged information developed in the studies performed in Case No. IPC- E-18-15; considered comments from intervenors in Case Nos. IPC-E-18-16, IPC-E-20- 26, and IPC-E-20-30; and to the extent applicable, considered components of the Commission-approved scope in Order No. 34753121or Rocky Mountain Power. 15. Regarding billing structure, the Company proposes to evaluate the following measurement intervals: (1) monthly, (2) hourly, and (3) separate channel, which is sometimes referred to as "instantaneous." Under each of the three measurement intervals, the Company would evaluate the class revenue requirement and consider revenue collection for existing customergenerators under each proposed measurement interval. Additionally, the Company would conduct a bill impact analysis to compare how each measurement interval may impact existing and future customers with on-site generation. 16. The Company proposes to include several value components of the Export Credit Rate ("ECR") such as an avoided cost of energy and study the firm versus non- firm nature of exported energy from customer{enerators. Additionally, ldaho Power proposes to evaluate avoided generation capacity, avoided transmission and distribution capacity, avoided line losses, and integration costs as part of the value components of the ECR study. The Company also recommends studying how the expenditures associated with the ECR should be recovered. 17. ln addition to billing structure and the ECR applicable to customers with on- site generation, ldaho Power also proposes to include a review of the project eligibility cap in coordination with program fundamentals, including rate design and the pricing for exports. The Company has also included various implementation issues such as credit expiration and the frequency of updating the ECR. 12 ln the Matter of the Applicatbn of Rocky Mountain Power to Close tha Net Metering Prqram to New Serube & lmplemenf a Net Billing Program to Compensate Customer-Generators for Exported Generation, Case No. PAC-E-19-08, Order No. 34753 (August 26,2020). APPLICATION . 7 18. lt is the Company's desire that Staff, other intervenors, and the public provide feedback to develop a record for the Commission to approve the completion of scope for the "study design" phase. III. PROPOSED STUDY DESIGN SCHEDULE 19. ln evaluating the "two-phase" approach that the Commission has laid out for the study, the direct testimony of Company witness Connie Aschenbrenner proposes a broader schedule to provide transparency to parties and the public as it relates to the "study design" and "study review" phases, and to the eventua! implementation as informed by a Commission-approved study. 20. The Company believes the following timeframe forthe "study design" phase will provide the public, stakeholders, and the Commission time to adequately consider these issues: o a notice of public workshops to be held in August or early September 2021 . party comments to be filed in early October 2021 r Company reply comments due late October or early November 2021. 21. This proposed procedural schedule would position the Commission to issue an order establishing the scope of the study before the end of 2021. Because the Company plans to use the most recent data available to complete its study (and was directed to do so in Order No. 34046), receiving an order establishing the scope by the end of 2021 wtll allow the Company to use 2021 data to complete the study in the first half of 2022. The Company could then initiate the "study review" phase by June 2022. 22. Absent the Commission establishing a different process, the Company anticipates making a request to implement any potential changes to the net metering rate design, compensation structure, or ECR after the Commission acknowledges a study. APPLICATION - 8 IV. STAKEHOLER & CUSTOMER NOTIFICATION 23. ldaho Power will notiff its customers of this application to initiate the study with a bill insert that will be sent to all customers in their next billing cycle. lncluded as Attachment 2, this bill insert will be sent to existing customer-generators, regardless of legacy treatment, and all other customers that might choose to pursue on-site generation in the future. 24. The bill insert will provide notice to all customers of the Company's application to initiate the study. Additionally, the bill insert addresses the following: (1) a brief summary ol on-site generation; (2) why Idaho Power is making the filing to initiate the study, (3) the key tenants of the study as directed by the Commission, (4) an estimated timeline to complete both the study design and study review phases, and (5) how customers can participate and provide feedback in the study design and study review process. 25. ldaho Power will notiff the on-site generation system installer community through an email to the distribution list for its periodic publication, the Customer Generation Newsletter. Attachment 3 to the Application includes a copy of the notification that will be sent to installers following the filing. 26. The Company has, concurrent with this filing, updated its website to notiff potential customers of the proposal; the Company will maintain a list of Frequently Asked Questions ("FAQs") that will remain accessible to customers, as well as installers. ldaho Power has also served its Application and testimony on the parties of record in Case Nos. IPC-E-1 8-1 5 and IPC-E-20-26. V. MODIFIED PROCEDURE 27. ldaho Power believes that a hearing is not necessary to considerthe issues presented herein, and respectfully requests that this Application be processed under APPLICATION - 9 Modified Procedure; i.e., by written submissions ratherthan by hearing. RP 201, ef seg. lf, however, the Commission determines that a technical hearing is required, the Gompany stands ready to present testimony in support of its Application. VI. COiIIMUNICATIONS AND SERVICE OF PROCEEDINGS 28. Service of pleadings, exhibits, orders, and other documents relating to this proceeding should be served on the following: Lisa D. Nordstrom ldaho Power Company 1221 West ldaho Street (83702) P.O. Box 70 Boise, ldaho 83707 lnordstrom@ida hopower. com dockets@ ida hooower. com Connie Aschenbrenner ldaho Power Gompany 1221 West ldaho Street (83702) P.O. Box 70 Boise, ldaho 83707 caschen brenner@ida hopower. com VII. REQUEST TO INITIATE STUDY PROCESS 29. The Company requests that the Commission initiate the multi-phase prooess for a comprehensive study of the costs and benefits of on-site generation. ldaho Power further requests the Commission acknowledge Attachment 1 as an initial draft on which Staff, other intervenors, and the public may provide bedback for the Commission to approve the completion of scope for the 'study design" phase. lf this order is issued by year-end 2021, the Company will use 2021 data to complete the study in the first half of 2022 before initiating the "study revieu/' phase by June 2022. DATED at Boise, ldaho, this 25th day of June 2021. X*!.("1.t..*, LISA D. NORDSTROM Attorney for ldaho Power Company APPLICATION . 10 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 25h day of June 2021 I served a true and conect copy of IDAHO POI ,ER COMPANY'S APPLICATION TO INITIATE A MULTI-PHASE COLLABORATIVE PROCESS FOR THE STUDY OF COSTS, BENEFITS, AND COMPENATION OF NET EXCESS ENERGY ASSOCIATED WTH CUSTOMER ON.SITE GENERATION upon the following named parties by the method indicated below, and addressed to the following: ldaHydro C. Tom Arkoosh ARKOOSH LAW OFFICES 802 West Bannock Street, Suite LP 103 P.O. Box 2900 Boise, ldaho 83701 ldaho Consewation League and NW Energy Coalition Benjamin J. Otto ldaho Conservation League 710 North 6th Street Boise, ldaho 83702 NW Energy Coalition F. Diego Rivas NW Energy Coalition 1101 8th Avenue Helena, Montana 59601 ldaho lrrigation Pumperc Association, lnc. Eric L. Olsen ECHO HAWK & OLSEN, PLLC 505 Pershing Avenue, Suite 100 P.O. Box 61 19 Pocatello, ldaho 83205 Anthony Yankel 12700 Lake Avenue, Unit 2505 Lakewood, Ohio 44107 _Hand Delivered U.S. Mail _Overnight Mail _FA)(_FTP SiteX Email tom.arkoosh@arkoosh.com tavlor. pestel!@ a rkoosh. com _Hand Delivered U.S. Mail _Overnight Mail _F$(_FTP SiteX Email botto@idahoconservation.orq _Hand Delivered U.S. Mail _Overnight Mail _FA)(_FTP SiteX Email dieqo@nwenerov.oro _Hand Delivered U.S. Mail _Overnight Mail _FA)(_FTP SiteX Email elo@echohawk.com _Hand Delivered U.S. Mail _Overnight Mail _FA)(_FTP SiteX Email tony@vankel.net APPLICATION . 11 Vote Solar Briana Kobor Vote Solar 358 South 700 East, Suite 8206 Salt Lake City, Utah 84102 David Bender Earthjustice 3916 Nakoma Road Madison, lMsconsin 537 11 Al Luna Nick Thorpe 1625 Massachusetts Avenue, NW, Suite 702 Washington, DC 20036 Clty of Bolse Mary R. Grant Deputy City Attomey Boise City Attorney's Office 150 North Capitol Boulevard P.O. Box 500 Boise, ldaho 83701-0500 ldaho Clean Energy Association Preston N. Garter GIVENS PURSLEY LLP 601 West Bannock Street Boise, ldaho 83702 ldaho Sierra Club Kelsey Jae Nunez KELSEY JAE NUNEZ LLC 920 North Clover Drive Boise, ldaho 83703 _Hand Delivered U.S. Mail Overnight Mail _FN(_FTP SiteX Email briana@votesolar.orq _Hand Delivered U.S. Mail _Ovemight Mail _FA)(_FTP SiteX Email dbender@earthiustice.org _Hand Delivered U.S. Mail Ovemight Mail _FAX_FTP SiteX Email aluna@earthiustice.oro nthoroe@earthi ustice. oro _Hand Delivered U.S. Mail _Ovemight Mail _FAX_FTP SiteX Email boisecityattronev@cityofboise.orq _Hand Delivered U.S. Mail _Ovemight Mail _FN(_FTP SiteX Email prestoncarter@givensnurslev.com _Hand Delivered U.S. Mail Overnight Mail _FA)(_FTP SiteX Email kelsey@kelseviaenunez.com APPLICATION . 12 Lisa Young Mike Heckler ldaho Sierra Club 503 West Franklin Street Boise, ldaho 83702 PacifiCorp d/bla Rocky Mountain Power Yvonne R. Hogle Rocky Mountain Power 1407 West North Temple, Suite 320 Salt Lake City, Utah 84116 Ted Weston Rocky Mountain Power '1407 West North Temple, Suite 330 Salt Lake Gity, Utah 84116 lnduetrial Gustomerc of ldaho Power Peter J. Richardson RICHARDSON ADAMS, PLLC 515 North 27th Street (83702) P.O. Box 7218 Boise, ldaho 83707 Dr. Don Reading 6070 Hill Road Boise, ldaho 83703 I5icron Technology, lnc. Austin Rueschhoff Thorvald A. Nelson Holland & Hart, LLP 555 Seventeenth Street, Suite 3200 Denver, Colorado 80202 _Hand Delivered U.S. Mail _Overnight Mail _FA)(_FTP SiteX Email lisa.vounq@sierraclub.oro michael.p. heckler@omail.com _Hand Delivered U.S. Mail Overnight Mail _FA)(_FTP SiteX Email yvonne.hoole@oacificorp.com _Hand Delivered U.S. Mail _Overnight Mail _FA)(_FTP SiteX Email ted.weston@pacificorp.com _Hand Delivered _U.S. Mail Overnight Mail _FN(_ FTP SiteX Email reter@richardsonadams.com _Hand Delivered _U.S. Mail _Overnight Mail_FA)(_ FTP SiteX Emai! dreadino@mindsprino.com Hand Delivered U.S. Mail Overnight Mail _ FN(_ FTP SiteX Emai! darueschhoff@hollandhart.com tnelson@hollandhart. com aclee@holland hart.com o loa roano-amari@holland hart. com APPLICATION - 13 Jim Suvier Micron Technology, hs. 8000 South Federal ll\hy Boiee, ldaho 83701 lndlvldua! Russell Schiermeier 29303 Davis Road Bruneeu, ldaho 83604 Hand Delivered U.S. Mail Ovemight Mail_ FN(_ FTP SiteX Email iawier@r*qpn.oom Hand D,elivercd U.S. Mail Orcm[ht Mail_ FA)(_ FTP SibX Emai! buvhav@omail.conr fu)rrQ Sandra D. Hdmes Legal Admin ietnative AssHant APPLICATION. 14 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC.EA|-21 IDAHO POWER GOMPANY ATTACHMENT NO. 1 DRAFT Attachment I: Idaho Power-Proposed Scope of On-Site Generation Study Measurement Interval l. Calculate the class nevenue requirement if each of the existing customer-generators net their energy exPorts: a. Monthly b. Hourly c. Separate channel 2. Calculate the export credit payments if each of the existing customer-generators net their energy exports: a. Monthly b. HourlY c. Separate channel 3. Analyze bill impacts to existing customer-generators, stratified by usage, if energy exports are netted: a. Monthly b. Hourly c. Separate channel Exnort Credit Rate (*ECR''| Avoided Energt Yalue 4. Provide the calculations and documentation for the avoided cost of exported energy using: a. Energy price assumptions in the Company's most recently acknowledged Integrated Resource Plan ("lRP") b. Market index price assumptions 5. Provide the calculations and documentation showing if the avoided cost of exported energy produced by customer-generators should be discounted to reflect the non-firm nature of the exported energy. Avoided Capacity Value 6. Analyze the capacity value of exported energy provided by customer-generators. Provide the calculations and documentation for evaluating the capacity resource value and the contribution to peak. Avoided Transmission and Dislribulion Costs 7. Quantifr the value of transmission and distribution costs that could be avoided by energy exported to the grid by customer-generators. Avoided Line Losses ATTACHMENT I DRAFT Attachment l: Idaho Power-Proposed Scope of On-Site Generation Study 8. Quantifo the avoided line loss associated with the avoided energy value and avoided capacity value. Integration Costs 9. Study methods for determining the integration costs of customer-generators. Provide the calculations and assumptions showing if the ECR should be reduced to account for integrating the customer-generator resource. Recoverins f,xnort Crcdit Rate Exnenditures 10. Quantifu the annual costs under varying assumed ECR values. I l. Analyze how these costs would be allocated and recovered by rate class. Cost-of-Service & Rate Desien 12. Evaluate cost-of-service methodology and potentialrate designs for customer-generators. Proiect Elieibilitv Cao 13. Analyze pros and cons of setting a customer's project eligibility cap according to a customer's demand as opposed to predetermined caps of 25 kW and 100 kW. Environmental and Other Benefits 14. Evaluation of the quantifiable environmental and other system benefits provided by customer- generators. lmolementation Issues Billing Structure 15. Explain how potentialcustomer-generators and on-site generation system installers will have accurate and adequate data and information to make informed choices about the economics of on- site generation systems over the expected life of the system. Export Credit Expiration 16. Quantifu the magnitude, duration, and value of accumulated export credits. 17. Explain the need for the credits to expire. a. Show how the Company does or does not benefit from the expiration of customer export credits. b. Show how non customer-generators are harmed or benefited from the expiration of customer export credits. i. Quantif, the impact to non customer-generators of aZ-year,S-year, and 10-year expiration period. Frequency of Export Credit Rate Updates 18. Quantifu the impact of biennial updates as compared to annual updates of the ECR. zATTACHMENT I BEFORE THE IDAHO PUBLIC UTILITIES GOMMISSION cAsE,NO. IPG-EA1-21 IDAHO POI'VER GOMPANY ATTAEHMENT NO.2 elmlp An IOACORP Ccnlodny ! Idaho Porrrcr Begins Gllaborati\re Process for On-Site Generation Study ldaho Power has initiated the process for a comprehensive study of the costs and benefits of on-site generation. This request is outlined in a recent filing with the ldaho Public Utilities Commission (IPUC). lt kicks off a multi- phase process whereby ldaho Power will work with the commission, the public and other stakeholders to (1) review the scope for a study, (2)complete and review the study and (3) implement potential changes to ldaho Power's on-site generation offerings. What is on-site generation? On-site generation is a service offering available to ldaho Power customers who install electricity generating equipment - most commonly solar panels - at their home or business to meet some of their energy needs while remaining connected to ldaho Power's grid. This offering, also known as customer generation or net metering, is available to the following customers: . ldaho residential (Schedule 6) o ldaho small general service (Schedule 8) e ldaho and Oregon commercial, industrial, and irrigation as well as Oregon residential and small general service (Schedule 84) Why is ldaho Power making this filing? The IPUC dirested ldaho Power and interested stakeholders to collaborate on a comprehensive study of the costs and benefits associated with on-site generation. This filing will allow participating parties to recommend a final scope of what should be considered and included in the study for IPUC approval. What will the study include? The study will use current, publicly available data; be available for public input; and be clearly written but also able to withstand expert scrutiny. Factors considered during the scoping phase will include compensation structure, excess energy credit rate, rate design, system size el ig ibi I ity, and envi ron mental and other system benef its. Who would future changes apply to? The IPUC previously ordered that existing on-site generation customers be grandfathered ior 25 years to receive credits in the form of kilorruatt-hours for excess energy produced, Customers who install on-site generation after the dates of those orders (December 20,2019 for Schedule 6 and 8; December 1,2020 for Schedule 84) are subject to future changes to compensation structure, including how much they are compensated for excess energy. All on-site generation customers, regardless of grandfathered status, are subject to changes in rates (energy prices), billing components, and billing structure. What is the timeline? ldaho Power has requested that the IPUC consider a schedule that would provide for the scoping phase to be completed by the end of 2021. The study would then be completed and made available for public input before the IPUC issues an order. lmplementation of changes to the on-site generation offering would follow, with proposals informed by the findings of the study. How can customenr participate? ldaho Power is requesting a series of public workshops to gather feedback on the scope of the study. Customers with interest in participating should visit puc.idaho.gov and reference case ,PC-E-21-21 for workshop schedules and other updates. Copies of ldaho Power's application are available to the public at IPUC offices (11331 W. Chinden Blvd. Building 8, Suite 201-A, Boise, lD 83714), ldaho Power offices, or at idahopower.com or puc.idaho.gov. Customers also may subscribe to the IPUC's RSS feed to receive updates via email about the case. As always, written comments regarding ldaho Power's proposal may be filed with the IPUC. Thank you for rcading this notice. We value Wur business. SIIMIOFqlUH @ Printed on recyrled paper 02021 ldaho Porer 31 180-t-0142An IDACORP Company BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION GASE NO. IPC.E.21A1 IDAHO POWER COMPANY ATTACHMENT NO.3 3stoppFoi,H !o ICAL(\\rr (, :'tr\.,'it il -. E Customer Generation! ldaho Power Begins Collaborative Process for On-site Generation Study ldaho Power has initiated the process for a comprehensive study of the costs and benefits of on-site generation. This request is outlined in a recent filing with the ldaho Public Utilities Commission (IPUC). !t kicks off a multi-phase process whereby ldaho Power will work with the commission, the public and other stakeholders to (1) design the scope for a study, (2) complete and review the study and (3) implement potential changes to ldaho Powe/s on-site generation offerings. What is on-site generation? On-site generation is a service ofiering available to ldaho Power customers who install electricity generating equipment - most commonly solar panels - at their home or business to meet some of their energy needs while remaining connected to ldaho Powe/s grid. This ofiering, also known as customer generation or net metering, is available to the following customers:. ldaho residential (Schedule 6). ldaho smallgeneralservice (Schedule 8). ldaho and Oregon commercial, industrial, and inigation as wellas Oregon residential and small genera! service (Schedule &4) Why is ldaho Power making this filing? The IPUC directed ldaho Power and interested stakeholders to collaborate on a comprehensive study of the cosb and benefits associated with on-site generation. This filing will allow participating parties to recommend a finalscope of what should be considered and included in the study for IPUC approval. What will the study include? The study will use current, publicly available data; be available for public input; and be clearly written but also able to withstand expert scrutiny. Factors considered during the scoping phase will include compensation structure, excess energy credit rate, rate design, system size eligibility, and environmental and other system benefits. Who would future changes apply to? The IPUC previously ordered that existing on-site generation customers be grandfathered for 25 years to receive credits in the form of kilowatt-hours for exoess energy produced. Customers who install on-site generation after the dates of those orders (December 20, 2019 for Schedule 6 and 8; December 1,2020 for Schedule 84) are subject to future changes to compensation a ttlrtltrrtI' structure, including how much they are compensated for excess energy. Al! on-site generation customers, regardless of grandfathered status, are subject to changes in rates (energy prices), billing components, and billing structure. What is the timeline? ldaho Power has requested that the IPUC consider a schedule that would provide for the scoping phase to be completed by the end of 2A21. The study would then be completed and made available for public input before the IPUC issues an order. lmplementation of changes to the on-site generation offering would follow, with proposals informed by the findings of the study. How can customers participate? ldaho Power is requesting a series of public workshops to gather feedback on the scope of the study. Customers with interest in participating should visit puc.idaho.gov and reference case IPG-E-21-21for workshop schedules and other updates. Copies of ldaho Powe/s application are available to the public at IPUC offices (11331 W Chinden Blvd. Building 8, Suite 201-A, Boise, lD 83714), ldaho Power offi@s, or at idahopqrer.com or puc.idaho.oov. Customers also may subscribe to the IPUC's RSS feed to receive updates via email about the case. As always, written comments regarding ldaho Power's proposal may be filed with the tPuc. Questions about customer generation? Contact us at 208-388-2559 or cg@idahopower.com or visit www. idahopower. com/customeryeneration.