20211013Initial Comments.pdf

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LISA D. NORDSTROIi
Lead Gounsel
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October 13,2021
VIA ELECTRONIC FILING
Jan Noriyuki, Secretary
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 forthe Study of Costs, Benefits,
and Gompensation of Net Excess Energy Associated with Customer On-
Site Generation
Dear Ms. Noriyuki:
Attached for electronic filing, pursuant to Order No. 35058, is ldaho Power
Company's lnitialComments in the above entitled matter.
lf you have any questions about the attached documents, please do not hesitate
to contact me.
Very truly yours,
Lisa D. Nordstrom
LISA D. NORDSTROM (lSB No. 5733)
ldaho Power Company
1221 West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: (208) 388€936
lnordstrom@ida hopower.com
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION TO INITIATE
A M U LTI.PHASE COLLABORATIVE
PROCESS FOR THE STUDY OF COSTS,
BENEFITS, AND COMPENSATION OF
NET EXCESS ENERGY ASSOCIATED
WTH CUSTOMER ON.SITE
GENERATION
CASE NO. IPC-E-21-21
IDAHO POWER COMPANY'S
!NITIAL COMMENTS
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Pursuant to the Notice of Application and Notice of lnitial Comment Deadline
issued by the ldaho Public Utilities Commission ("Commission") in Order No. 35176,
ldaho Power Company ("ldaho Powe/'or "Company") submits its initialcomments in the
above-referenced case. ln these comments, the Company intends to provide additional
context on its proposed scope, with modifications as appropriate, for consideration.
The Company anticipates the Commission's approvalof a finalscope willconclude
the "study design' phase of the "comprehensive study of the costs and benefits of on-site
IDAHO POWER COMPANY'S INITIAL COMMENTS.l
generation on ldaho Power's system, proper rates and rate design, transitional rates,
alongside the related issues of compensation for net excess energy provided as a
resource to the Company."l The Company looks forward to the opportunity to review
parties initia! comments and hear feedback from its customers at the public workshops
scheduled for October 20,2021, and October 26, 2021, and the public hearing scheduled
for October28,2021.2 This feedbackwill ultimately inform the Company's finalcomments
filed in this case.
I. BACKGROUND
The Company filed its Application in this matter on June 28,2021 ("Application")
in response to the Gommission directives issued in Order Nos. 340463 and 34509.4 The
Application included Attachment 1 as an initial draft for Commission Staff ("Staff'), other
intervenors, and the public to consider and provide feedback for the Commission's
consideration prior to approval of a final scoping document.
On July 27,2021, the Commission issued a Notice of Application and established
an intervention deadline. The Commission directed Staff to informally confer with the
1 ln the Mafter of the Application of ldaho Power Company for Authoity to Estab/ish New Schedules for
Residentialand SmallGenenlService Cusfomers with On-Site Genemtion, Case No. IPC-E-17-13,
Order No. 34046 at 31 (May 9, 2018).
2 Notices of Scheduling, Virtual Public Workshops, and Telephonic Public Hearing, Order No. 35193
(October 7,20211.
3 Order No. 34046 at 31 (the Commission ordered Idaho Power to "initiate a docket to comprehensively
study the costs and benefits of on-site generation on ldaho 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.").
a ln the Matter of the Petition of ldaho Power Company to Study the Costs, Benefits, and Compensation
of Net Excess Eneryy Supplied by Customer On-Sife Genention, Case No. IPC-E-18-15, Order No.
34509 at 9 (December 20, 2019) ("The Company must prepare and file a credible and fair study on the
costs and benefits of distributed on-site generation to the Company's system.')( "...Commission 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.').
IDAHO POWER COMPANY'S INITIAL COMMENTS .2
Company and any intervening parties about how to further process this case and report
back on a proposed schedule.
Parties who intervened and/or were listed on the September 8,2021, Notice of
Parties included the Company, Staff, lndustrial Customers of Idaho Power ("lClP"),
ldaHydro, ldaho Conservation League ('lCL"), ldaho CIean Energy Association ("!CEA"),
Clean Energy Opportunities for ldaho ("CEO'), ldaho Solar Owners Network ('ISON"),
Micron Technology, lnc. ("Micron"), City of Boise, Kiki Leslie A. Tidwell("Tidwell"), Richard
E. Kluckhohn and Wesley A. Kluckhohn (.Kluckhohn's'), ABC Power Company, LLC
("ABC Powe/'), and ldahome Solar, LLC ("ldahome Sola/') (collectively the "Parties").
Staff held meetings with Parties on August 30 and September 22,2021, to develop
a general framework to study the costs, benefits and compensation of net excess energy
associated with customer on-site generation ("Study Framework") and discuss a general
schedule for this case. ln the first meeting, the Company reviewed Attachment 1 from its
Application and responded to Parties'questions regarding the proposed scope outline.
Parties provided informal comments in advance of the second meeting, where parties
had an opportunity to discuss initialfeedback and additional items they recommended be
included within the scope of a study. On September 30, 2021, Staff filed its Study
Framework summarizing the Parties' informal comments on the proposed scope.
On September22,2021, the Commission issued Order No.35176 inviting Parties
and any persons desiring to state a position to file initial comments about the appropriate
scope of the Study by October 13,2021.
IDAHO POWER COMPANY'S INITIAL COMMENTS - 3
II. MEASUREMENT INTERVAL
A. ldaho Power Proposes to Study Three teasurement lntervals and Two
Billing Structures.
ln its draft study design scope included as Attachment 1 to the Application, the
Company proposed to study three measurement intervals: (1) monthly, (2) hourly, and (3)
separate channel. ln response to feedback from Parties, the Company proposes to
replace the term "separate channe!' with 'instantaneous" or 'real-time" net energy
measurement. This terminology more appropriately describes the proposed
measurement interval -'separate channel' is a method to measure the energy for net
billing under either an hourly or instantaneous/real-time net energy measurement interval.
Table 1 provides an overview of the measurement intervals and associated billing
structures that are described in more detail in the following two sections.
Table 1
Monthly (Billing Cycle)Hourly or
! nstantaneous/Real-Ti me
1)Net consumption over the
billing cycle
Net excess k\Mt credits to
be banked
2)
Accrued net excess generation
kWh credits
Retail rate for self-
consumption and exported
generation
1) Hourly or instantaneous net
consumption throughout the
billing cycle2) Hourly or instantaneous net
exports throughout the
billing cycle
Net hourly or instantaneous DER
exports
. Retail rate for self-
consumption. ECR for hourly or
instantaneous net DER
exports
a
Yes
ECR Applicability
Net Energy Metering (NEM)Net Billing (NB)
Value of DG to
Customer
Quantities
Measured and
Billed
Netting
Frequency
lntra-Billing Cycle
Banking of kWh's
IDAHO POWER COMPANY'S INITIAL COMMENTS -4
No
1. Net Energy Metering - Monthly Measurement lnterval
Net energy metering ("NEM'), often referred to as net metering, allows a distributed
energy resource ('DER") system owner who is generating more electricity than they are
consuming to export that excess energy to the utility grid, receiving a credit in kilowaft-
hours (.kwh"). The credit can be applied to offset electricity consumption (also measured
in kWh) within the current billing cycle or future billing cycles. The DER owner is billed
for net energy consumption during a billing cycle (i.e., what the system owner consumed
during the billing cycle, less what the DER system generates during the same period).
NEM requires a single bidirectional meter that provides one net reading at the end of the
billing cycle.
NEM is the Company's existing offering for on-site generation customers and is
what the Company intends to study for the "monthly" measurement interval. Under NEM,
a DER system owner can "bank' kwh credits within a billing cycle, as the meter only
reports net consumption at the end of the billing cycle. A DER system owne/s produced
electricity may exceed electricity consumed from the grid during a billing cycle, and DER
system owners can also bank those credits between billing cycles. Figure 1 shows an
illustrative diagram of NEM configuration, and the gray box illustrates usage, metering,
and billing.
IDAHO POWER COMPANY'S INITIAL COMMENTS.5
Fisure I
2. Net Billing - Hourly & lnstantaneous/Real-Time Measurement lntervals
NEM was implemented in 1983 when residential rate designs were limited by
meters that could only track inflow and outflow, and DERs were an expensive and nascent
technology. The circumstances that existed when NEM policies and practices were
originally established have changed dramatically. First, ldaho Power has deployed
Advanced Metering lnfrastructure ("AMl') in its service area, enabling the Company to
achieve more precise measurement intervals. Second, the cost of DERs has continued
to decline resulting in increased adoption.
Electric utilities and regulators nationally are considering significant net metering
reforms. The predominant successor tariff structure is net billing fNB"). NB is where a
DER system owner can consume electricity generated by their DER system in real-time
and export any generation in excess of on-site consumption to the utility grid. ln this way,
NB is akin to NEM. However, banking of k\lVh within a billing cycle to offset future
NET ENERGY METERING
Udllty GrldMebrtSystem
t
il*P*v-
Bidircctional
IGrossDERPmduction INeIDERExports IGridElectricity I
flrlrb
Meednt Bllllng
Bill
'"-
-rl
rMeasures net consumptlon mr ore billing cycle.
Setrconflm€d
DfR Producdon
Load
N€t DG Eeorts
tlettlng Frcquency
1 Billing Cycle
UraSe
IE-
IDAHO POWER COMPANY'S INITIAL COMMENTS -6
consumption does not occur under NB. lnstead, the DER owner is typically billed for net
energy consumption under either (1) hourly net billing or (2) instantaneous/real-time net
billing. NB allows for a more precise measurement of both grid consumption and net DER
exports. A billing structure that allows for a more precise measurement and
compensation for both grid consumption and net DER exports is more equitable to the
DER system owner and the utility's other customers.
Instead of banking k\A/h credits, all net energy exports are metered and measured
as they are injected into the grid under NB. lf at any point the customer is generating
more electricity than they are using on-site, then the customer is nef exporting - injecting
electricity into the grid. Similarly, if at any point the customer is using more electricity than
they are producing, then the customer is nef consuming - drawing electricity from the
grid. A DER system owner's meter separately records the following: (1) real-time nef grid
electricity consumption and (2) rea!-time net DER exports. Both are measured and
aggregated separately by the meter. Figure 2 shows an illustrative diagram of NB
configuration, and the gray box illustrates usage, metering and billing.
IDAHO POWER COMPANY'S INITIAL COMMENTS. T
Fiqure 2
Hourlv Net Billinq
A customer is billed under hourly NB for net energy consumption during every hour
of the billing cycle (i.e., what the system owner net consumed from the grid during the
hour, less what the DER system net expofted during the hour). If the customer is
generating more electrici$ than they are using on-site in any hour, they will be credited
at a predetermined export credit rate ("ECR"). lf the customer consumes more electricity
than they are generating on-site in any hour, the customer will pay the applicable retail
rate.
lnstantaneous/Real-Time Net Billi nq
Under instantaneous/real-time NB all net exports will be measured separately, and
all k\Mr would receive the predetermined ECR. Similarly, the meter will measure all net
consumption separately, and all k\Mr would be charged the applicable retail rate.
lnstantaneous/real-time net energy measurement removes the need to "net' in the billing
NET BITLING
Separate Channel Meterl Utillty Grld
j
System
t EGrossDERProduction IINetDERExports IGridElectricity I
rMea{ret instantareous net electrkity consumption and instantarees net D€R spons
Time
Frequency
lnstantaneous/RealG
Usage Metering Bllling
-rJj:Etlet DG kports
separate ch.nnel
Netting
Hourly or
Bill
Cm+
Prod -
E
Elport
Credit
Rate
Self-Consumed
DER Production
IDAHO POWER COMPANY'S INITIAL COMMENTS. S
system (i.e., subtract what the system owner net consumed and what the DER system
net exported every hour). lnstead, the DER system owner simply receives the ECR for
all DER net exports and allconsumption from the grid is charged the applicable retail rate.
B. The Company lntends to Study lmpacts of Different Measurement lntervats.
The'Measurement lnterval'section of Attachment 1 to the Company's Application
includes the three proposed primary areas of focus for studying and evaluating each
measurement interval proposed under a range of potential ECR values: (1) calculate the
revenue requirement, (2) calculate the total credit value for exported energy, and (3)
analyze bill impacts.
The Company intended to create consistencies, to the extent reasonable, between
the proposed scope in Attachment 1 with what was approved by the Commission in Case
No. PAC-E-19-08.5 The'Measurement lnterval'section (ltem Nos. 1 - 3) in Attachment
1 is essentially identicalto what the Commission approved in Order No. 34753, issued in
Case No. PAC-E-19-08. The purpose of this section is to provide a comparative analysis
between the proposed measurement intervals and billing structures. ltem No. 1 is
intended to evaluate revenue collected for net consumption under each of the
measurement intervals studied. Based on initia! discussions with Parties, ldaho Power
believes there is potential to state ltem No. 1 more clearly by modifoing "revenue
requirement" to "revenue collection." ltem No. 2 is intended to quantiff the total amount
credited to customers at a predetermined ECR (or range of ECRs) to evaluate potential
recovery mechanisms. Last, with ltem No. 3, the Company plans to include a bill impact
5 ln the Matterof the Application of Rocky Mountain Powerto Close the Net Metering Program to New
Service & lmplement a Net Billing Progrum to Compensate Customer-Genentors for Expofted
Generation, Case No. PAC-E-19-08, Order No. 34753, Attachment A (August 26,2020).
IDAHO POWER COMPANY'S ]NITIAL COMMENTS.9
analysis under each measurement interval. lt is common practice for the Company to
evaluate the impact to customer bills when considering any potential change.
III. EXPORT CREDIT RATE
The Company has proposed to study severalcomponents for potential inclusion in
the study and valuation of an ECR to be applied to net exports (ltem Nos. 4 - 9, 13).
These components include an avoided energy value (ltems Nos.4 - 5), avoided capacity
value (ltem No. 6), avoided transmission and distribution costs (ltem No. 7), avoided line
Iosses (ltem No. 8), integration costs (ltem No. 9), environmentaland other benefits (ltem
No. 14). Each of these components is similarly addressed in the scope the Commission
approved in Case No. PAC-E-19-08.
The Company proposes evaluating the avoided cost of energy component of the
ECR using (1) energy price assumptions from the most recently acknowledged Integrated
Resource Plan ("lRP") and (2) market index price assumptions. The Company is not
presupposing that one method is more favorable - only that it is reasonable to evaluate
alternative valuation methodologies and provide the calculations and documentation for
all methodologies evaluated.
IV. RECOVERY OF EXPORT CREDIT RATE EXPENDITURES
ln Case No. PAC-E-19-08, Rocky Mountain Power filed for authority to recover the
exported energy credits from the NB program through its annual Energy Cost Adjustment
Mechanism ("ECAM'). Commission Order No. 34753 approved several areas to be
included in the Rocky Mountain Power scope of a study regarding the recovery of export
credit rates. ldaho Power proposes evaluating a similar recovery mechanism in
Attachment 1 of its Application (ltem Nos. 10 - 11). The Company proposes quantiffing
IDAHO POWER COMPANY'S INITIAL COMMENTS - 1O
the annua! costs under varying assumed ECR values and analyzing how these costs
would be allocated and recovered by rate class.
V. COST.OF.SERVICE & RATE DESIGN
The Company has proposed to include an evaluation of cost-of-service
methodology and potential rate designs for customer-generators within the scope of a
study. Each of the studied measurement intervals will impact a cost-of-service study
differently and the Company believes it is essential to provide a comparative analysis of
the impact that each of the studied measurement intervals would have on cost-of-service.
The Commission articulated in Order No. 34046 what it desired this docketto study
and expressly included proper rates and rate design for on-site generation:
"We find it reasonable to direct the Company, Commission
Staff, and all interested parties to initiate an ldaho Power
specific docket on @ to study the costs and
benefits of net metering on ldaho Power's system, proper
rates and rate desiqn, alongside the related issues of
compensation for net excess energy provided as a resource
to the utility."6
Therefore, the Company contends that cost-of-service and rate design must be included
within the scope of a study. The study will be one critical component of Commission
review but will not preclude Parties or the public from introducing, and the Commission
considering, other relevant pieces of information when it is time to address proposals for
implementation.
VI. PROJECT ELIGIBILITY CAP
The Company has proposed analyzing the pros and cons of setting a custome/s
project eligibility cap according to a custome/s demand instead of the existing caps of 25
6 Order No. 34046 at 22. (emphasis added)
IDAHO POWER COMPANY'S INITIAL COMMENTS - 11
kW and 100 kW.7 ln Order No. 34854, the Commission supported including an evaluation
of the existing caps in the study:
"...we acknowledge the comments submitted regarding the
100 kW cap and meter aggregation rules but decline to
address them in this docket. There will be opportunities to
address these issues
comprehensive studv.
durinq or after the forthcomins,8
VII. Ii'IPLEMENTATION ISSUES
The final area the Company has proposed to include within the scope of a study
addresses implementation issues (ltem Nos. 15-18). Any measurement interval or
billing structure studied must allow potential DER system owners to have accurate and
adequate data and information to make informed choices about the economics of on-site
generation (ltem No. 15). ldaho Power also recommends evaluating if unused credits
should expire or remain available indefinitely (!tem No. 17). Last, the Company intends
to assess and provide recommendations on the frequency of ECR updates (ltem No. 18).
vilt. coNcLUstoN
ldaho Power filed its Application in compliance with the Commission's direction to
"study the costs and benefits of net metering on Idaho Power's system, proper rates and
rate design, alongside the related issues of compensation for net excess energy provided
as a resource to the utility.'e The Company provided a draft scope of a study as
7 Schedule 6, ResidentialService On-Site Generation and Schedule 8, SmallGeneralService On-Site
Generation limit applicability for exporting systems to a total nameplate capacity rating of 25 kW.
Schedule &4, Customer Energy Production Net Metering Service limits applicability under Schedule 9, 19,
and24 to 100 kW.
8 ln the Matter of ldaho Power Company's Application for Authoity to Modify Schedule 84's Metering
Requircment and to Gmndfather Existing Cusforners with Two Meterc, Case No. IPC-E-20-26, Order No.
348t4 at 12 (December 1,2020). (emphasis added)
e Order No. 34046 at 22.
IDAHO POWER COMPANY'S INITIAL COMMENTS.l2
Attachment 1 to its Application, which leveraged information developed in the studies
performed in Case No. IPC-E-18-15, and considered comments from intervenors in Case
Nos. IPC-E-18-16, IPC-E-20-26, and IPC-E-20-30. The Company also considered
components of the Commission-approved scope in Order No. 34753 for Rocky Mountain
Power, recognizing that "the Commission has consistently tried to align the net metering
programs between ldaho utilities to the extent reasonable."l0
The Company appreciates the opportunity to provide these lnitial Comments to
provide additionalbackground and supporting rationale for using Attachment 1 to develop
a basis of an approved scope of study. ldaho Power is encouraged by the discussions
to date with the Parties and looks forward to input received from the public through the
public workshops and the Commission's public hearing, and the continued contributions
from Parties to develop a complete record for the Commission to approve a final scope
and complete the "study design" phase.
DATED at Boise, ldaho, this 13th day of October 2021
X* !.7(^t t,-*,
LISA D. NORDSTROM
Attorney for ldaho Power Company
r0 Case No. PAC-E-I9-08, Proposed Order No. 34752 at 7 (August 26,2020}
IDAHO POWER COMPANY'S INITIAL COMMENTS - 13
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 13h day of October 2021,lserved a true and
correct copy of IDAHO POWER COMPANY'S lNlTlAL COMMENTS upon the following
named parties by the method indicated below, and addressed to the following:
Commission Staff
Erick Shaner
Deputy Aftorney General
ldaho Public Utilities Commission
472 West Washington Street (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
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ldaHydro
C. Tom Arkoosh
ARKOOSH LAW OFFICES
802 West Bannock Street, Suite LP 103
P.O. Box 2900
Boise, ldaho 83701
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erin.cecil@a rkoosh.com
ldaho Conservation League
Benjamin J. Otto
ldaho Conservation League
710 North 6h Street
Boise, ldaho 83702
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ldaho lrrigation Pumpers Association, lnc.
Eric L. Olsen
ECHO HAWK & OLSEN, PLLC
505 Pershing Avenue, Suite 100
P.O. Box 6119
Pocatello, ldaho 83205
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City of Boise
Ed Jewell
Deputy City Attorney
Boise City Attorney's Office
150 North Capitol Boulevard
P.O. Box 500
Boise, ldaho 83701-0500
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bo isecitvattro nev@citvofboise. o rq
IDAHO POWER GOMPANY'S INITIAL COMENTS.14
ldaho Glean Energy Association
Kevin King
Board President
P.O. Box2264
Boise, lD 83702
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lndustrial Gustomerc of Idaho Power
Peter J. Richardson
RICHARDSON ADAMS, PLLC
515 North 27h Street (83702)
P.O. Box 7218
Boise, ldaho 83707
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Dr. Don Reading
6070 Hill Road
Boise, ldaho 83703
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Micron Technology, Inc.
Austin Rueschhoff
Thorvald A. Nelson
Austin W. Jensen
Holland & Hart, LLP
555 Seventeenth Street, Suite 3200
Denver, Colorado 80202
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tnelson@ hollandha rt.com
q lo a rqan o-a ma ri@ h olla nd ha rt. co m
Jim Swier
Micron Technology, lnc.
8000 South FederalWay
Boise, ldaho 83707
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Clean Energy Opportunities for ldaho
Kelsey Jae
Law for Conscious Leadership
920 N. Clover Dr.
Boise, ldaho 83703
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IDAHO POWER COMPANY'S INITIAL COMENTS - 15
Michael Heckler
Courtney White
ldaho Sierra Club
503 West Franklin Street
Boise, ldaho 83702
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cou rtnev@cleanenerqvopportu nities.com
mike@clea nenerqvopportu n ities.com
Richard E. Kluckhohn
Wesley A. Kluckhohn
2564 W. Parkstone Dr.
Meridian, lD 83646
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Kiki Leslie A. Tidwell
704 N. River Street #1
Hailey, ldaho 83333
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ABC Power Co. LLC
Ryan Bushland
184 W. Chrisfield Dr.
Meridian, lD 83646
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ldahome Solar, LLC
Tyler Grange
2484 N. Stokesberry Pl. #100
Meridian, lD 83646
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Comet Energy LLC
George Stanton
13601 W. McMillan Rd. Ste
102 PMB 166
Boise, lD 83713
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IDAHO POWER COMPANY'S INITIAL COMENTS.16
ldaho Solar Ovynerc Network
Joshua Hill
1625 S. Latah
P.O. Box 8224
Boise, lD 83707
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[e-mail]
\t"""&r"J=
Stacy Gust, Regulatory Administrative
Assistant
IDAHO POI/VER COMPANY'S INITIAL COMENTS.lT