20210628Aschenbrenner Direct.pdf

BEFORE THE IDAI{O PT'BI,IC UTIIJITIES COMMISSION
IN THE MATTER OF IDAI{O POWER
COMPANY' S APPLICATION TO INITIATE
A MUI,TI-PHASE COLI,ABORATIVE
PROCESS FOR THE STI'DY OF COSTS,
BENEFITS, AIVD COMPENSATION OF NET
EXCESS ENERGY ASSOCIATED WITH
CUSTOMER ON-SITE GENERATION
IDAI{O POWER COMPAI\TY
DIRECT TESTIMOIiTY
CONNIE G. ASCHENBRENNER
CASE NO. TPC-F,-2L-2L
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o.Please state your name, business address, and
present position with Idaho Power Company ("Idaho Power" or
"Company").
A. My name is Connie G. Aschenlcrenner. My
business address is 1-221- West Idaho Street, Boise, Idaho,
83702. f am employed by ldaho Power as the Rate Design
Senior Manager in the Regulatory Affairs Department.
O. Please describe your educational background.
A. In May of 2006, I received a Bachelor of
Business Administration degree in Finance from Boise State
University in Boise, Idaho. In December of 201-L, I earned
a Master of Business Admj-nj-stration degree from Boise State
University. In addition, I have attended the electric
utility ratemaking course The Basics: Practical Regulatory
Training for the Electric Industry, a course offered
through New Mexico State University's Center for Publ-ic
Utilities.
a. Please describe your work experience with
Idaho Power.
A. ln 201-2, I was hired as a Regulatory Analyst
in the Company's Regulatory Affairs Department. My primary
responsibilities included support of the Company's
Commercial- and Industrial customer class's rate design and
general support of tariff rules and regulations. In 2015,
r assumed responsibilities associated with Residential and
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Idaho Power Company
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l- Sma1l General Service rate design, as well as regrrlatory
2 support assoclated with demand-side management (*DSM")
3 activities. In 20L6, I was promoted to a Senior Regulatory
4 Analyst, and my responsibilities expanded to include the
5 development of complex cost-related studies. In 2017, I
5 was promoted to Rate Design Manager for Idaho Power, and in
7 201,9 I was promoted to my current role as Rate Design
8 Senior Manager. I am currently responsible for the
9 management of the rate design strategies of the Company, as
10 well as oversight of all tariff administration. In my
lL current role, I am one of the Company representatives at
12 its Energy Efficiency Advisory Group (*EEAG") meetings.
l-3 O. What is the purpose of your testimony?
L4 A. My testimony describes the Company's proposal
l-5 to initiate a multi-phase collaborative process for a study
16 of the costs and benefits of on-sj-te generation. The
17 proposed process incl-udes a "study designr " "study revJ-ewr "
18 and "implementation" phase.
19 O. What is the Company's primary objective of
20 this multi-phase study process?
21- A. The Company's primary objective of the study
22 process is to establish a sustainable on-site generation
23 offering that limits subsidies by implementing a more
24 eguitable pricing and compensation structure. The multi-
25 phase study process will be accomplished through a
ASCHENBRENNER, DI
Idaho Power Company
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1 transparent and collaboraEive approach with stakeholders
2 and the public. Ultimately, the Company anticipates
3 proposals to implement changes to the on-site generation
4 offering will be informed by the studies and should seek to
5 eliminate or minimize potential cross-subsidies that exist
5 between participants and non-participants of on-site
7 generation through rate design and compensation structures
8 for on-site generatJ-on customers. Further, the Company
9 believes recommendations to modify the existing offering
10 should focus on cost-of-service principles, while
11- identifying the appropriate value of excess net energy to
12 ensure equitable compensation for on-site generators.
13 O. How is your testimony organized?
14 A. The first section of my testimony will discuss
15 pertinent case history related to the Commission's
16 directive for the Company to comprehensively study the
L7 costs and benefits of on-site generation and rate design.
L8 In the second section, I will describe the Company's
19 proposed scope for the "study design" phase. The third
20 section of my testimony will outline the broader proposed
21- timeline for the "study design, " "study reviewr " and
22 "implementation" phases of the study. The concludi-ng
23 section will describe proposed stakeholder engagement and
24 public workshops to solicit input in the "study design"
25 phase.
ASCHENBRENNER, DI
Idaho Power Company
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I. Background
On-Site Generation
O. What is on-site generation?
A. The Company uses the term "on-site generation"
to refer to its retail customers who install equipment used
to generate electricity, 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 paral1e1 to ldaho Power's grid
and the vast majority e>rport ener!ry to the grid.
O. V{hat rate schedules are applicable to
L2 customers with on-site generation?
who install on-site
interconnect an Exporting System under
Schedule 6, Residential Service On-Site
generation can
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A Customers
the
Generation
16 ("Schedul-e 6"), Schedule 8, SmalL General- Service On-Site
17 Generation ("Schedu1e 8"), Schedul-e 68, Interconnectj-ons to
l-8 Customer Distributed Energy Resources ("Schedule 68") and
19 Schedule 84, Customer Energ"y Production Net Metering
20 Service ("Schedule 84') .
21- Customers who install a Non-Exporting System
22 continue to take service under the retail rate schedule
23 they qualify for based on the applicability of the
24 Company's retail tariff schedules.
ASCHENBRENNER, DI
Idaho Power Company
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l- A11 customers with on-site generation are subject to
2 the terms of Schedule 58 governing interconnectj.on.
3 Q. How many customers currently have an
4 Exporting- or Non-Exporting System interconnected to fdaho
5 Power's grid?
5 A. As of May 31, 2021-, there are 7,789 Exporting
7 Systems interconnected and taking service under Schedules
8 6, 8, and 84 and three (3) Non-Exporting Systems
9 interconnected and taking service under Schedules 9 and l-9.
10 Collective1y, these customer systems represent
11 approximately 70 MW of generation.
12 O. Please describe the billing and compensation
13 structure currently in place for Schedules 6, 8, and 84.
L4 A. The billing structure currently applicable to
15 these schedules is referred to as "net metering. " Under
15 the net metering compensation structure, if electricity
t7 supplied by the Company during a Billing Period exceeds the
l-8 electricity generated by the Customer and delivered to the
19 Company during the Billing Period, the Customer is biIled
20 for the net electricity supplied by the Company at the
2L rates contaj-ned within the applicable service schedule. If
22 the electricity generated by the Customer and delivered to
23 the Company during the Billing Period exceeds the
24 electricity supplied by the Company during the Billing
25 Period, the Excess Net Energy is carried forward as a
ASCHENBRENNER, DI
Idaho Power Company
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1 kilowatt-hour (*kwh") credit to offset energy usage in a
2 subsequent Billing Period. These customers are often
3 referred to as "partial requirements" customers because
4 they are offsetting some or all of their usage with their
5 own generation.
6 O. Were Idaho Power's retail rates desj-gned in a
7 manner that considered the unique load characteristics of
8 partial reguirements customers?
9 A. No. Idaho Power's current retail rates were
1-0 designed to align with the load characteristics of fuII
1l- reqr:irements customers. Historically, residential electric
12 rate designs bundled all electric services into one k['Ih
l-3 rate, chargj-ng customers for the amount of energy they
1,4 used. Non-Residential- or Smal1 General Service cl-ass's
15 rate design also recover a portion of fixed costs through
L5 Demand and Basic Load Capacity charges. When applied only
1-7 to customers taking fuII service from the utility, this
l-8 structure represented a fair and reasonable mar:ner to
19 collect service costs from customers.
20 A large portion of the Company's revenue requirement
2L is collected through volumetrj-c energy rates, including
22 costs associated with all components of the electrical
23 system, from investment in generation resources to the
24 meters installed on customers' premises. Consequently, the
25 energy rates for Idaho Power's customers include not only
ASCHENBRENNER, DI
Idaho Power Company
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1 the variable energy-related components of the revenue
2 requirement, but fixed operations and maintenance and
3 plant-related costs associated with generation,
4 transmj-ssion, distributi-on, and customer care.
5 Q. Does the net metering billing and compensation
6 structure provide the Company a reasonable opportunity to
7 collect the costs associated with serving an on-site
I generation customer?
9 A. No. A customer who installs on-site
10 generation does so with the intent to offset their usage
11 and reduce or eliminate the volume of energy they consume
1,2 from Idaho Power. Recovering fixed costs through a
L3 volumetric rate does not work well for this segrment of
1,4 customers because fixed costs do not vary with changes in
15 the amount of energy consumed from Idaho Power.
15 The Company's residential and smal-l- general servj-ce
17 (*R&SGS") customers have the most significant portion of
18 fixed costs 91 percentl - collected through those
19 schedules' volumetric charge. The Company's large general
20 service (commercial), industrial, and irri-gation customer
21, classes have 50, 39, and 70 percent, respectively, of each
22 schedul-e's fixed costs collected through the volumetric
1 Fixed costs co1lected through volumetri-c charges proportion is
cal-cul-ated from inputs sourced from the Company's most recent generalrate case, Case No. IPC-E-11--08.
ASCHENBRENNER, DI
Idaho Power Company
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charges. These customers are collectively referred to as
"Cf&I" customers.
O. Has the Commission acknowledged the
limitations of retail rate net metering?
A. Yes. Most recently, in Order No. 34046, the
Commission found:
Our analysis of the history of the
Company's on-site generation program reveals
an unfairness i-n how current and future on-
site generation customers avoid fixed costs.
The ability these customers have to "net out"
or net to zero their electricity use causes
them to underpay their share of the Company's
fixed costs to serve customers, and this
ineguity will only increase as more customers
choose on-site generation.z
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17 The Commission also found that "the present netting of
18 energy not only a11ows these customers to avoid paying
19 their fair share of fixed costs, but also prevents them
20 from realizing presently unguantified benefits to the
2l grid. "i
22 O. What steps did the Commlssion order the
23 Company take to address the issues related to rate design
24 and guantifying the costs and benefits of on-site
25 generation on Idaho Power's system?
2 In the Matter of the AppTication of ldaho Power Company for Authority
to Estabfish New Scheduies for Residential- and Sma77 General Serwice
Customers with on-site Generation, Case No. IPC-E-17-!3, Order No 34045
at 15 (May 9, 2018).
ASCHENBRENNER, DI
Idaho Power Company
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A In Order No. 34046, the Commission ordered 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 Idaho
Power'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 Compdtty.'t+
IPC-E-18-15 and IPC-E-18-16
O. Did the Company initiate a docket to
comprehensively study the costs and benefj.ts of on-site
generation on Idaho Power's system?
A. Yes. The Company filed a petition to initiate
Case No. IPC-E-18-l-5 on October l-9, 201-8.
O. Did the Company perform any studies related to
customers with on-site generatJ-on in that case?
A. Yes. In advance of petitioning the Commission
to initiate Case No. IPC-E-18-l-5, the Company conducted an
initial study evaluating costs and benefits of on-site
generati-on on Idaho Power's system. That initial- study
evaluated cost-of-service, rate desj.gn, billing and
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2A compensation structures, and
and served as the foundation
parties.
("Staff"),
the value of excess net
for analysis and input
Staff
energy
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23 Ultimately, the Compdny, Commission
and numerous intervening parties with diverse
ASCHENBRENNER, DI
fdaho Power Company
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1 interestsu reached a settlement on an agreed-upon
2 compensation structure for excess g'eneration and a value
3 for the excess g'eneration, as well as several other aspects
4 of the Company's on-site generatj-on service. The
5 Settlement Agreement was the product of several studies
5 resulting from a year-Iong collaborative process that
7 included eight half or all-day settlement meetings and
8 hours of collaborative analysis and deliberation.
9 O. Did the Company seek to implement changes as a
l-0 result of these studies in Case No. IPC-E-18-I-5?
11 A. Yes. On October 11, 2019, Idaho Power and
12 Staff jointly submitted a Motion to Approve Settlement.
l-3 Agreement. The Settlement Agreement requested the
L4 Commission approve changes to Idaho Power's net metering
15 program, supported by the underlying information studied by
1-6 the Company and parties and representing a settlement of
L7 several other key issues.
18 O. Did the Commission approve the Settlement
19 Agreement?
20 A. No. In Order No. 34509 issued on December 20,
2L 20L9, the Commission rejected the Settlement Agreement,
22 stating:
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We thus find it appropriate to reject
the Settlement Agreement and prescribe
procedures to be followed to develop an
s While all 13 parties participated in the settslement process, nine of
those parties ultimately signed the Settslement Agreement.
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Idaho Power Company
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adequate record and address our ongoingconcerns. More specifically, we find the
public was not adequately notified this
docket might result in a significant changeto the Companyrs net-metering program
structure. Further, filing the Settlement
Agreement in the absence of a comprehensive
sEudy does not comply with our directive toparties in Order No. 34046.6
L0 Ultimately, the Commission found an insufficient record to
l-1 support that the Settlement Agreement was reasonable, in
12 the public j-nterest, or otherwise in accordance with 1aw or
13 regulatory poIicy.,
L4 O. What did the Commission determine necessary
l-5 before it could decide on modifications to the Company's
1,5 net metering design?
1-7 A. In Order No. 34509, the Commission directed
18 Idaho Power to prepare and fil-e a "credibl-e and fair study"
19 of the costs and benefits of distributed on-si-te
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generation.
a.
what would
A
What grridance did the Commission provide about
constj-tute an acceptable study?
The Commission identified the following
the study must24 criteria for a credible and fair study: (1)
25 use the most current data possible and must be readily
6 In the Matter of the Application of ldaho Power Company to Study the
Costs, Benefits, and Compensation of Net Excess Energy SuppTied by
Customer On-Site Generation, Case No. IPC-E-18-15, Order No. 34509, at5 (December 20, 20!9) .
ASCHENBRENNER, DI
Idaho Power Company
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l- available to the public, and in the Commission's decision-
2 making record; (2) the Company must design the study in
3 coordination with the parties and the pr:bIic, and the
4 Commission will determine the final scope of the study; (3)
5 the study must be written, so it is understandable to an
6 average customer, but its analysis must be able to
7 withstand e>cpert scrutiny.e
8 Q. What other criteria did the Commissj-on
9 establish for a study?
L0 A. The Commission outlined a "study design" phase
l-l- and a "study review" phase. Durj-ng the "study design"
L2 phase, Staff and the Company will both "host pr:bIic
13 workshops to share information and perspectives on net-
L4 metering program design with the public and to listen to
l-5 customer concerns and input.us In the "sEudy review" phase,
L6 the public will have the opportunity to comment on whether
L7 the study sufficiently addressed their concerns and their
L8 opinions on what the study shows.
L9 0. Did the Commission issue any other directives
20 in Case No. IPC-E-18-15?
I Id. at 9.
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Idaho Power Company
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A. Yes. The Commission established criteriaro to
define legacy treatment for systems under Schedule 5 and
Schedule 8. The legacy systems would be subject to the
rules in place as of the service date of Order No. 34509,
December 20, 201-9. Additionally, the Commission stated
that the more clearly worded disclosure in the recently
enacted Residential Solar Energ'y System Disclosure Act, and
its more complete description in Order No. 34509 of what ,a
tariff can changerr means provides a reasonable difference
between legacy and new systems.
O. what criteria did the Commission outline for
legacy treatment?
A. A legacy system is defined as either an on-
site generation system interconnected with Idaho 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, 2O2O.Lt Legacy
systems sha11 operate under the terms of Schedule 5 or
Schedule 8 as those Schedules exist on December 20, 20L9.
Legacy status terminates December 20, 2045.12
a. Are the rates and rate structure subject to
LO Id.
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at 8-9 and 10-L1.
at 14.
at 9.
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Idaho Power Company
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change for legacy systems?
A. Yes. Schedule 6 and Schedule 8 state, 'tThe
following rate
upon Commission
structure and
approval" and
charges are subject to change
lists the current rate
structure comprised of the monthly service charge and the
monthly energy charges. The Commission also stated the
following regarding legacy treatment
These rates and rate structure are
sti11 subject to change. We make thisdistinction based on our finding that
customers who installed on-site generation
understood that rates for consumption could
change, and recognized that the value of the
1:L monthly kWh offset would change in value
along with the rates for consumption. We
e>cpect proposals for changes to consumption
rates and rate structures to be made only ina general rate case in which rates and rate
structure for all customer classes are under
review. See also Order No. 32845 at L2-l-3. We
recognize that an increase to the monthly
service charge could impact the f inanc j-a1
payback period on a customer's on-site
generation system, but rates for consumption
are not frozer:- in time, and we find that such
a change has always been within the realm of
customer expectatj-ons . r:
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O. How many
have legacy systems?
Schedule 5 and Schedule 8 customers
there are 5,400 legacy
interconnected to Idaho
ASCHENBRENNER, DI
Idaho Power Company
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L O. Did the decision in Case No. IPC-E-L8-15 to
2 define legacy systems apply to the Company's CI&I
3 customers?
4 A. No. In Order No. 34546, the Commission stated
5 that the decision was based on the facts of that case. The
5 Commission further noted that if CI&I customers in Schedule
7 84 are to receive legacy treatment as of a specific date,
8 that decision must be based on the facts presented in a
9 separate case.l4
l-0 a. Did the Company undertake a comprehensive
1l- study of fixed costs?
12 A. Yes. On October 19, 2018, the Company filed a
13 petition to open Case No. IPC-E-18-1-5 related to studying
14 fixed costs of providing electric service to customers.
15 Several parties intervened in the docket, and the Company
1,5 participated in multiple workshops in advance of filing a
1,7 Fixed Cost Report on September 30, 20L9. On March 31,
18 2020, the Commission issued Order No. 34508, recognizing
19 the Company filed a Fixed Cost Report, in compliance with
20 Order No. 34046.
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74 In Ehe Matter of the AppTication of ldaho Power Company to Study theCosts, Benefits, and Compensation of Net Excess Enerry SuppTied by
Customer On-Site Generation, Case No. IPC-E-18-l-5, Order No. 34546 at12 (February 5, 2020).
ASCHENBRENNER, Df
Idaho Power Company
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TP0-E-20 -26 and IPC-E-2O-30
O. Oid the Company initiate a separate case to
determine if existing CI&I customer systems would receive
Iegacy treatment before initiating the "study design"
phase?
A. Yes. In the same way that the Commission
provided Schedule 5 and Schedule 8 customers a more
complete description of what "a tariff can change" means,
fdaho Power t.hought it was essential for the same
communication and determination on legacy treatment for
CI&I customers under Schedule 84. The Company initiated
Case No. IPC-E-20-26, where it applied for authorization to
change the two-meter requirement in Schedule 84 to a
single-meter requirement for new customer-generators and to
grant legacy treatment to existing customer-gienerators
under the current rules as of December 1 , 2020.
O. What was the outcome of Case No. IPC-E-20-25?
A. The Commission issued Order Nos. 34854 and
34892 on December 1 , 2020, and ,January L4, 202L,
respectively. As a result, the Commission estalrlished
criteria similar to Case No. IPC-E-l-8-15, to provide legacy
treatment to Schedule 84 systems under the rules in place
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Idaho Power Company
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as of the service date of Order No. 34854.1s The decisi-on
delineated between legacy systems and new systems subject
to future changes informed by a comprehensive study.
O. what criteria did the Commission outline for
legacy treatment for Schedule 84?
A. A legacy system is defined as either an on-
site generation system interconnected with Idaho Power's
system as of the service date of Order No. 34854, or a
customer with a binding financial commitment to install an
on-site generation system t,hat proceeds to interconnect
their system on or before December 1, 2021-.t6 Legacy status
terminates December l- , 2045.t1
O. Did the Commission add additional clarity to
the term "Iegacy treatment" in its Order No. 34892?
A. Yes. The Commission delineated between
existing customer-generators who are eligible for legacy
treatment and new customer-generators who are not eligible
for legacy treatment and explained that the term
"grandfather" or "legacy treatment" in this specific
Ls In the l,b.tter of ldaho Power Company's AppTication to lbdity Schedufe
84's lbtering Requirement and to Grandfather Existing Customers with
Two I'Ieters, Case No. IPC-E-20-25, Order No. 34854 at 11 (December 1,
2020) .
16 In the yktter of Idaho Power Conpany's AppTication to lbdify ScheduJ-e84's lbtering Requirement and to Grandfather Existing Customers with
Two Meters, Case No. IPC-E-20-26, Order No. 34892 aL 9 (.fanuary 1-4,
202L) .
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ASCHENBRENNER, DI
Idaho Power Company
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L context means that customer-generators are entitled to
2 continue to take service according to the terms of the
3 existing schedules in place as of the service date of the
4 Commission order for a period of 25 years.re Similar to
5 Case No. IPC-E-18-l_51s, Schedule 84 systems that gualify for
6 legacy treatment continue to be subject to changes in
7 consumption rates. However, they would not be subject to
I changes in the L:1 monthly kl{h retail rate compensation
9 structure until the legacy treatment terminates.20
L0 a. How many Schedule 84 customers have legacy
LL systems?
12 A. As of May 31, 2021,, there are 302 legacy
L3 Schedule 84 systems interconnected to Idaho Power's system.
14 O. What other docket related to customer
15 generation has the Company initiated since the issuance of
16 Order Nos. 34509 and 34545?
L7 A. On .fu1y 20, 202A, in compliance with Order
l-8 Nos. 34045 and 34147 in Case No. IPC-E-L7-L3, Idaho Power
t9 filed an application to initiate Case No. IPC-E-20-30 to
20 establish smart inverter requirements. This case also
2L addressed other interconnection reguirements for
18 Id. at LL.
1e Order No. 34509, at 1-4-15
20 Order No. 34854 at l-l-.
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Idaho Power Company
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interconnections to customer distributed energy resources
("DERs").
O What was the Company's request in Case No.
rPc-E-20-30?
A. The Company
Inverter standard for all
establish interconnection
Systems. zz
O. What was the
sought to establish a Smart
new DER interconnectionszl and
requirements for Non-Drporting
outcome of Case No. IPC-E-20-30?
A The Commission approved the Company's10
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application in Case No.
March 9, 2021-.
IPC-E-20-30 and Schedule 68 on
13 Rocky ldouataia Power's On-Site Geaeration Study Desiga
1-4 Phase
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O. What did Rocky Mountain Power reguest in its
application in Case No. PAC-E-19-08?
A. On June 14, 2019, Rocky Mountain Power (*RMP")
applied to the Commission for an order closing net metering
service and opening a net billing service to new customers.
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21 In Order No. 34046, Ehe Commission directed the Company to submit afiling within 60 days of the final adoption of IEEE standards l-547 and
1_547 .L.
22 On page l-6 of Order No. 34147 issued in Case No. IPC-E-17-13, the
Commission stated it was "open to the possibility of allowing the
customer opportunity to remove himsel-f from the company's net metering
schedul-es" if that "customer can reasonably and safefy eliminate the
export of energy to the Company's grid." The Commission further found
that "a non-export option should be studied for feasibil-ity and vettedfor safety and operational concerns by the Company and interested
stakeholders in the forthcomi-ng docket. "
ASCHENBRENNER, DI
Idaho Power Company
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The proposed modifications would have modified the
compensation structure and the value of excess net energy
for RMP's on-site generation customers.
o.
impacted by
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A.
How was Case No. PAC-E-19-08 procedurally
the Commission's decision in Case No. IPC-E-18-
After the Commission issued a final order in
Case No. IPC-E-I-8-15 directing Idaho Power to complete
additional studies, RMP submitted a Supplemental
Application on April 23, 2020, with updated inputs to the
proposed export credit rate and an updated proposal
regarding legacy treatment for existing customers. RMP and
Staf f held public workshops on .Tune LG and ,June 18, 2O2O ,
respectively. Staff's Revised Comments submitted on July
2, 2020, included Attachment A with study design
recommendations. RMP f iled Reply Comments on iluly 1-6,
2020, responding to many of the issues raised by Staff and
other parties.
O. What was the outcome of PAC-E-L9-08?
A. On August 26, 2020, the Commission issued
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21, Order No. 34753 and found it reasonable to use Staff's
22 Attachment A as the basis of the ordered scope of the
23 study. The Commission modified Staff's Attachment A to
24 reflect the proposed order on legacy treatment issued
25 concurrently with recommendations from other parties and
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Idaho Power Company
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responses from RMP. The Commission indicated that this
order completed the "study design" phase and determined the
scope of the study Rocky Mountain Power is to undertake.
II. On-Site Generation Study Desiga Phase: Idaho Power's
Proposed Scope
O. Has the Company developed a recommended scope
for Idaho Power's on-site generation study?
A. Yes. In 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 the application
filed in this case.
O. How did the Company determine what elements
should be included in the scope of the study?
A. The Company leveraged the studies performed in
Case No. IPC-E-18-15, to the extent applicable, considered
components of the Commj-ssion-approved scope in Order No.
3475323 for RMP and considered comments from intervenors in
19 Case Nos.IPC-E-18-l-6, IPC-E-20-26, and IPC-E-20-30.
How does the Company's recommended scope
what the Commission approved for Rocky Mountain
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23 In the lulatter of the application of Rocky Mountain Power to CTose the
Net Metering Program to New Sertrice & Implement a Net BiTTing Programto Compensate Customer-Generators for Exported Generation, Case No.
PAC-E-19-08, Order No. 34753 (August 26, 2020') .
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Power?
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Idaho Power Company
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L A. One primary difference is that the Company's
2 recommended scope includes evaluating the cost to serve
3 grid consumption of on-site generators consistent with
4 discussions in Case No. IPC-E- 18 - l-5 . 24 Because f daho Power
5 has separate rate classes for R&SGS on-site generation
5 customers, it is appropriate to study cost-of-service and
7 alternative rate designs within the scope of a
8 comprehensive study. Additionally, Idaho Power does not
9 propose to study a Smart Inverter reguirement as it
10 recently received Commission approval to require Smart
1l- Inverters for all new DER interconnections.
12 O. What does the Company propose to study
13 regarding billing structure?
!4 A. The Company proposes to evaluate the following
15 measurement interwals: (1) monthly, (2) hourly, and (3)
16 separate channel, often referred to as "instantaneous."
1-7 Under each of the three measurement intervals, the Company
18 would evaluate the class revenue reguirement and consider
19 revenue collection for existing customer-generators under
20 each proposed measurement interwal. Additionally, the
2l Company would conduct a bill impact analysis to compare how
22 each measurement interval may impact existing and future
23 customers with on-site generation.
ASCHENBRENNER, DI
Idaho Power Company
2a Order No. 34546 aL 7
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l- O. What does the Company recommend including in
2 scope for the study as it relates to the Export Credit Rate
3 (*ECR") ?
4 A. The Company proposes to include several value
5 components. The Company suggests including an avoj-ded cost
6 of energy and studying the firm versus non-firm nature of
7 exported energy from customer-g'enerators. Additionally,
8 Idaho Power proposes to evaluate avoided generation
9 capacity, avoided transmission and distribution capacity,
10 avoided line losses, and integration costs as part of the
l-1 value components of the ECR study.
L2 The Company also recommends studying how the
L3 expenditures associated with the ECR should be recovered.
14 O. Why has the Company included evaluating the
15 project eligibility cap in its proposed scope?
15 A. Parties initially raised questions regarding
L7 the project eligibility cap through discussions in Case No.
18 IPC-E-18-l-5. Most recently, in Case No. IPC-E-20-25, the
L9 Company and Staff addressed questions regarding the project
20 eligibility cap for CI&I customers during the public
2l workshop held on September 28, 2020. In their comments
22 filed in the case, the City of Boise and Idaho ConservaLion
23 League both suggested that the Company evaluate the system
24 size limit in its comprehensive study and the Idaho Sierra
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Idaho Power Company
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Club requested the Commission modify the size limit based
on the total load of the customer.
The rationale for a cap for individual installations
of 25-kw and 100-kW was to limit the costs that non-net
metering customers sr:bsidize to serve net metering
customers.zs Additionally, in implementing the cap for
Schedule 84, the Commission noted a reasonable limit for
CI&I customers should align with the Federal Energy
Regulatory Commissj-on minimum gualifying facility size of
100 kW.26 Therefore, a review of the project eligibility
cap is appropriately considered when changes to other
program fundamentals, including rate design and the pricing
for e>cports are evaluated.
O. Does the Company propose to include any other
areas of focus in the scope of the study?
A. Yes. The Company has included various
implementation issues such as credit expiration and the
frequency of updating the ECR. Idaho Power provides
Attachment 1 as an initial draft for Staff, other
intervenors, and the public to provide feedback and
2s In the Matter of the Application of ldaho Power Company for
Anendments to Schedul-e 84 - Net l@tering, IPC-E-02-04, Order No. 29094
at 3, ciuing Order No. 2895]- at 11 (August 1, 2002).
26 In the l"Iatter of the aFplication of Idaho Power Company for \pproval
of a New Schedufe 84 - Net Wtering Tariff, IPC-E-01-39, Order No.
2895L, at l-l- (February 13, 2002).
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Idaho Power Company
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adequately build a record for the Commission to approve the
completion of scope for the "study design" phase.
III. Proposed Study Design Schedule
O. Does the Company have a proposed schedule as
it rel-ates to accomplishing the Commission's desire for a
"two-phase" study process?
A. Yes. In evaluating the "two-phase" approach
that the Commission has laid out, for the study, the Company
intends to propose a broader schedule to provide
transparency to parties and the public as it relates to the
"study design" and "study revj-ew" phases and the eventual
implementation as j.nformed by a Commission-approved study.
The Company believes the following timeframe for the "study
design" phase provides the public, stakeholders, and the
Commission tj-me to adequately consider the issues before
the Commission.
The Company requests that the Commission consider
the issuance of a notice of public workshops to be held in
August or early September 2021- and party comments to be
filed in early October 2021- with Company reply due late
October or early November 2021-. This schedule would a11ow
for robust, public involvement as parties finalize scoping
recommendations to be considered by the Commission. The
Company believes this proposed procedural schedule would
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Idaho Power Company
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1 position the Commission to issue an order establishing the
2 scope of the study before the end of 202L.
3 Q. Is there significance to completing the "study
4 design" phase before the end of 2027?
5 A. Yes. Pursuant to the Commission's direction in
6 Order No. 34046, the Company plans to use the most recent
7 data available to complete its study. Receiving an order
8 establishing the scope by the end of 202L will a11ow the
9 Company to use 2O2L data Eo complete the study in the first
10 half of 2022. The Company would then plan to initiate the
11 "study review" phase by June 2022.
!2 A. Does the Company intend to request changes to
L3 the net metering service in either the "study design" or
74 the "study review" phase that is expected to occur
l-5 throughout 2O2L and 2022?
L6 A. No. In both the "study design" and the "study
L7 review" phase, the Company only intends to meet the
Lg Commission's directive for a comprehensive study to be
L9 completed. Absent the Commission establishing a different
20 process, the Company anticipates requesting to implement
2L any potential changes to t,he net metering rate design,
22 compensation structure, or ECR after the Commission
23 acknowledges a study.
ASCHEI{IBRMiINER, DI
Idaho Power Company
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IV. Stakeholder and Customer Notification
O. will the Company notify its cusEomers of its
Application in this matter?
A. Yes. Attachment 2 is a bill insert that will
be sent to all customers in the next billing cycIe. 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 j-n the
future.
O. Please summarize the key components of the
customer notice.
A. 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 of 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.
O. Does the Company intend to provide any other
notice to stakeholders?
A. Yes. Idaho Power will notify the on-site
generation system installer community through an email to
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Idaho Power Company
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the distribution list for its periodic publication, the
Customer Generation NewsletEer. Attachment 3 to the
Application includes a copy of the notification that will
be sent to installers following the filing.
a. What other means will the Company use to
communicate with customers and installers regarding the
proposed change?
A. The Company has, concurrent with this filing,
updated its website to notify 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. Idaho Power has also
served its Application and testimony on the parties of
record in Case Nos. IPC-E-L8-15 and IPC-E-2O-26.
V. Conclusion
0 Please summarize the Company's request in this
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A. The Company requests that the Commission
initiate the multi-phase process for a comprehensj-ve study
of Ehe costs and benefits of on-site generation. Idaho
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 consi-deration.
Ultimately, the Company requests the Commission to approve
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Idaho Power Company
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a final scoping document, which will conclude the "study
des j-gn" phase.
A. Does this conclude your testimony?
A. Yes.
ASCHEI{BRMiINER, DI
Idaho Power Comparry
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DECIJARATION OF CONNIE G. ASCHENBRENNER
l, Connie G. Aschenlcrenner, declare under penalty of
perjury r:nder the laws of the state of Idaho:
1. My name is Connie G. Aschenbrenner. I am
employed by Idaho Power Company as the Senior Manager of
Rate Design in the Regrulatory Affairs Department.
2. On behalf of Idaho Power, I present this
pre-fi1ed direct testimony in this matter.
3. To the best of my knowledge, my pre-fiIed
direct testimony is true and accurate.
I hereby declare that the above statement is true to
the best of my knowledge and belief and that I understand
it is made for use as evidence before the ldaho Public
Utilities Commission and is subject to penalty for perjury.
SIGNED this 25th day of ilune 202L, 4t Boise, Idaho.
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L8 Connie G. Aschenbrenner
ASCHMIBRENNER, DI
Idaho Power Comparry
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