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.