20211116Final Comments.pdf

LISA D. NORDSTROM
Lead Counsel
[e-mail]
November 16, 2021
VIA ELECTRONIC FILING
Jan Noriyuki, Secretary
Idaho Public Utilities Commission
11331 West Chinden Blvd., Building 8
Suite 201-A
Boise, Idaho 83714
Re: Case No. IPC-E-21-21
In the Matter of the Application of Idaho Power Company’s Application to
Initiate a Multi-Phase Collaborative Process for the Study of Costs, Benefits,
and Compensation of Net Excess Energy Associated with Customer On-
Site Generation
Dear Ms. Noriyuki:
Attached for electronic filing, pursuant to Order No. 35058, is Idaho Power
Company’s Final Comments in the above-entitled matter.
If you have any questions about the attached documents, please do not hesitate
to contact me.
Very truly yours,
Lisa D. Nordstrom
LDN:sg
Attachments
RECEIVED
2021 NOV 16 PM 4:37
IDAHO PUBLIC
UTILITIES COMMISSION

IDAHO POWER COMPANY'S FINAL COMMENTS - 1
LISA D. NORDSTROM (ISB No. 5733)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
[e-mail]

Attorney for Idaho 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 COMPENSATION OF
NET EXCESS ENERGY ASSOCIATED
WITH CUSTOMER ON-SITE
GENERATION

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CASE NO. IPC-E-21-21

IDAHO POWER COMPANY'S
FINAL COMMENTS

After considering the feedback received thus far from the Idaho Public Utilities
Commission ("Commission") Staff, intervenors, and the public, Idaho Power Company
("Idaho Power" or "Company") submits its Final Comments pursuant to the Commission’s
Notice of Scheduling in Order No. 35193. Idaho Power has included Attachment 1, Idaho
Power's Revised Study Framework ("Revised Study Framework"), reflecting changes to
Attachment 1 of the Company’s Application (“Initial Study Framework”), to add or revise
areas of study in response to comments and feedback received from the public and

IDAHO POWER COMPANY'S FINAL COMMENTS - 2
intervenors. Idaho Power believes its Revised Study Framework, which incorporates
feedback provided by the public and intervening parties, provides a reasonable basis for
the Company to complete a comprehensive study, as ordered by the Commission.1,2
Idaho Power’s Final Comments summarize Idaho Power’s revisions in its Revised
Study Framework, recommendations from the public and intervenors that the Company
contends are out-of-scope, and procedural considerations. Attachment 2 provides
tracked changes in legislative format, comparing Idaho Power’s Initial Study Framework
and the Revised Study Framework to highlight feedback the Company has incorporated
during the study design phase.
The Revised Study Framework will provide for a comprehensive study of the costs
and benefits of on-site generation, as directed by the Commission in Order Nos. 34046
and 34509. In their Initial Comments, several intervenors have recommended the
Commission limit the scope of the study by suggesting to narrowly focus on evaluating
only an export credit rate.3 While a change to the export credit methodology and valuation
is a key element of the comprehensive study, the Company does not believe it was the
Commission’s intent – nor is it necessary – to limit areas of study to only this one element.

1 In the Matter of the Application of Idaho Power Company for Authority to Establish New Schedules for
Residential and Small General Service Customers with On-Site Generation, Case No. IPC-E-17-13,
Order No. 34046 at 31 (May 9, 2018) (the Commission ordered Idaho Power to “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 Company.”)

2 In the Matter of the Petition of Idaho Power Company to Study the Costs, Benefits, and Compensation
of Net Excess Energy Supplied by Customer On-Site Generation, Case No. IPC-E-18-15, Order No.
34509 at 9 (Dec 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 listen to customer concerns and input.”)

3 CEO Initial Comments at 1-6, ICEA Initial Comments at 2, ICL Initial Comments at 1 (Oct 13, 2021).

IDAHO POWER COMPANY'S FINAL COMMENTS - 3
Idaho Power recommends that the Commission approve the Revised Study Framework
as the final scope to conclude the study design phase so the Company can begin its
comprehensive study of the costs and benefits of on-site generation.
I. PROCEDURAL BACKGROUND
On September 8, 2021, Notice of Parties included the Company, Commission Staff
(“Staff”), Industrial Customers of Idaho Power (“ICIP”), IdaHydro, Idaho Conservation
League (“ICL”), Idaho Clean Energy Association (“ICEA”), Clean Energy Opportunities
for Idaho (“CEO”), Idaho Solar Owners Network (“ISON”), Micron Technology, Inc.
(“Micron”), City of Boise, Kiki Leslie A. Tidwell (“Tidwell”), Richard E. Kluckhohn and
Wesley A. Kluckhohn (“Kluckhohn”), ABC Power Company, LLC (“ABC Power”), and
Idahome Solar, LLC (“Idahome Solar”) (“Intervenors” and collectively, the “Parties”).
On September 22, 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. Initial comments were filed by the Company,4
Staff, ICIP, ICL, ICEA, CEO, ISON, City of Boise, Tidwell, and Kluckhohn.
On October 20, 2021, Idaho Power held a public workshop to provide the public
with an overview of its Application. On October 26, 2021, Staff held a public workshop to
provide the public with an overview of the Company’s Application and Staff’s analysis
regarding its Study Framework (“Staff Study Framework”). At each workshop, the public
had the opportunity to ask questions about the Company’s Application and how
customers may further participate in the proceeding.

4 The Company’s Initial Comments (Oct 13, 2021) contain a more detailed procedural background prior to
the issuance of Order No. 35176.

IDAHO POWER COMPANY'S FINAL COMMENTS - 4
At the Commission Public Hearing on October 28, 2021, six (6) individuals from
the public provided verbal testimony. As of November 15, 2021, 130 written comments
were submitted in this docket. The majority of the written comments received express
support for completion of a study that will result in a fair valuation for on-site generation.
II. IDAHO POWER’S REVISED STUDY FRAMEWORK
After considering the questions and comments from Parties and the public on the
Initial Study Framework, Idaho Power makes the following revisions and clarifications
incorporated in the Revised Study Framework:
A. Measurement Interval (#1-3)
The Company has proposed to evaluate the length of time between meter reads
(measurement intervals) to measure the energy delivered and the energy received by the
following: (1) monthly, (2) hourly, and (3) instantaneous/real-time. Under each of the
proposed measurement intervals, the Company modified its Initial Study Framework5 to
suggest studying the following:
(1) Calculate the quantity of kWh consumed and billed for utility service
(2) Calculate the quantity of kWh exported and credited
(3) Analyze bill impacts to customer-generators
The Company’s proposed measurement intervals are similar to the Netting Periods in the
Scope of Rocky Mountain Power’s On-Site Generation Study set forth in Attachment A in
Final Order No. 34753.6

5 Revised Study Framework (Attachment 1) at 1.

6 In the Matter of the Application of Rocky Mountain Power to Close the Net Metering Program to New
Service & Implement a Net Billing Program to Compensate Customer-Generators for Exported
Generation, Case No. PAC-E-19-08, Order No. 34753, Attachment A at 1 (Aug 26, 2020).

IDAHO POWER COMPANY'S FINAL COMMENTS - 5
B. Export Credit Rate (#4-16)
Avoided Energy (#4-7)
The Company proposed the following areas of study for an avoided energy value
in its Application: (1) methods for calculating the avoided energy value of exported
energy; and (2) whether exported energy should be discounted to reflect its non-firm
nature. The Company's proposed areas of study are similar to the Avoided Energy Value
of the Export Credit Rate in the Scope of Rocky Mountain Power’s On-Site Generation
Study.7
The Company’s Revised Study Framework includes additional detail and areas of
study related to the avoided energy value of exported energy to incorporate feedback
received.8 First, in response to feedback from the public, CEO,9 and Staff,10 the Company
has included an evaluation of exported energy that could vary with time and/or location
of exported energy. The Company acknowledges that an export credit rate that accounts
for the time and/or location of exported energy may result in a credit value that reflects a
more accurate avoided cost.
The Company agrees with Staff that it is essential to consider the firmness of
energy exported from customer-generators to ensure that the export credit rate reflects
the cost of energy avoided.11 In response to Staff’s comments, the Company has included
two (2) additional aspects in the Revised Study Framework: (1) evaluate firmness of

7 Id. at 1-2.

8 Revised Study Framework (Attachment 1) at 1-2.

9 CEO Initial Comments at 3.

10 Staff Comments at 4-5 (Oct 13, 2021).

11 Id. at 6.

IDAHO POWER COMPANY'S FINAL COMMENTS - 6
energy for individual customers compared to as a combined class; and (2) evaluate
firmness of energy for customers with energy storage devices compared to those without
energy storage devices.12
Avoided Capacity Value (#8-9)
Staff recommends that the Company include methods that consider the valuation
of avoided capacity cost based on the timing of the Company's first capacity deficiency
and how it can be incorporated into the development of the export credit rate.13 Idaho
Power has added this consideration to its Revised Study Framework.14
Staff also suggests the time periods when avoided costs are realized be studied.
The three issues that Staff recommends be addressed in the study include (1)
identification and evaluation of methods for identifying system coincident peak hours (i.e.,
the Company’s net peak hours – the hours that drive the need for capacity resource or
capacity-equivalent resource additions); (2) an identification and an evaluation of different
export credit rate designs to ensure customer-generators are correctly compensated for
the amount of capacity they contribute during system peak and for the amount of capacity
they avoid; (3) an evaluation of differences between customer-generators who have
energy storage versus those that do not.15 Idaho Power has reflected these
recommendations in its Revised Study Framework.16

12 Revised Study Framework (Attachment 1) at 1-2.

13 Staff Comments at 8.

14 Revised Study Framework (Attachment 1) at 2.

15 Staff Comments at 9.

16 Revised Study Framework (Attachment 1) at 2.

IDAHO POWER COMPANY'S FINAL COMMENTS - 7
Staff also recommends the Company evaluate two different rate designs for
avoided capacity values. The first method would credit the avoided cost of capacity for
every kilowatt-hour (“kWh”) of energy exported to the Company’s system, irrespective of
the time.17 The second would credit an avoided capacity cost only for exports that occur
during system coincident peak hours.18 These recommendations have been incorporated
into the Revised Study Framework.19
Avoided Distribution and Transmission Costs (#10-11)
Staff and ICL suggest to “separately” study avoided distribution and avoided
transmission costs.20 Idaho Power has incorporated this recommendation into the
Revised Study Framework.21
Avoided Line Losses (#12)
The Company has proposed to quantify the avoided line losses associated with
avoided energy and avoided capacity. CEO suggests the study should address the
avoided marginal line losses.22 Staff recommends that the Company consider line loss at
distribution-level voltages versus at transmission-level voltages in connection with the

17 Staff Comments at 9-10.

18 Id. at 10.

19 Revised Study Framework (Attachment 1) at 2.

20 Staff Comments at 11-12 and ICL Initial Comments at 12.

21 Revised Study Framework (Attachment 1) at 2.

22 Staff Study Framework at 11 (Sept 20, 2021).

IDAHO POWER COMPANY'S FINAL COMMENTS - 8
type of avoided cost being avoided.23 The Revised Study Framework reflects these
additions to the avoided line losses section.24
Integration Costs (#13)
The Company proposes to study whether the export credit rate should be reduced
to account for integrations costs. The Revised Study Framework reflects the following
proposed additions as recommended by Staff:25 (1) evaluate if integration costs apply
differently for customers with and without energy storage devices; (2) explore methods
for evaluating how different penetration levels impact the level of integration cost by
customer; and (3) explore methods for evaluating how integration costs can change over
time to suggest how frequently the ECR should be updated.26
Avoided Risk (#14-15)
City of Boise proposed to include an “avoided risks” section in the Study
Framework filed by Staff on September 30. The Company included both components of
this section in its Revised Study Framework.27
Avoided Environmental Costs and Other Benefits (#16)
Staff states that “avoided environmental costs should be quantifiable, measurable,
and only include avoided costs that affect rates.”28 The Revised Study Framework reflects

23 Staff Comments at 12.

24 Revised Study Framework (Attachment 1) at 3.

25 Staff Comments at 12.

26 Revised Study Framework (Attachment 1) at 3.

27 Id.

28 Staff Comments at 14.

IDAHO POWER COMPANY'S FINAL COMMENTS - 9
this scope of avoidable environmental and other benefits. The Company also heard from
public comments and several Intervenors a desire to see more detail in this section. The
Company appreciates the feedback and has proposed to include the same areas of study
as the Avoided Environmental Costs and Other Benefits in the Scope of Rocky Mountain
Power’s On-Site Generation Study set forth in Attachment A in Final Order No. 34753.29
ICL and other stakeholders also suggested that this section be included as a sub-
section of the Export Credit Rate section rather than a stand-alone section.30 The
Company has reflected this modification in its Revised Study Framework.31
C. Recovering Export Credit Rate Expenditures (#17-18)
The Company proposes to study methods to recover export credit rate
expenditures and quantify the annual costs under varying export credit rate values.
Additionally, the Company intends to analyze how these costs would be allocated and
recovered by rate class. Staff recommends that the Company provide methods to record
bill credit costs, the amount of these costs, and how these costs would change depending
on a range of possible export credit rate values.32 Staff also suggests that the Company
should then analyze how these costs have been allocated and recovered between rate
classes historically and how they would be allocated and recovered in the future. The
Company has reflected the suggested additions in the Revised Study Framework.33

29 Order No. 34753, Attachment A at 3.

30 ICL Initial Comments at 12.

31 Revised Study Framework (Attachment 1) at 3.

32 Staff Comments at 13.

33 Revised Study Framework (Attachment 1) at 4.

IDAHO POWER COMPANY'S FINAL COMMENTS - 10
D. Cost-of-Service & Rate Design (#19)
Staff supports the Company's position that cost-of-service and rate design is within
the scope of a study, pursuant to the Commission's Final Order No. 34046 in Case No.
IPC-E-17-13. Staff agrees that the Company should show the impact to customer-
generators using the currently approved cost-of-service methodology.34 However, Staff
also recommends that the Company include an analysis of both potential cost-of-service
methodologies and/or rate designs that Idaho Power could implement in the Company's
next general rate case by providing the impact to all customer classes, including
customer-generators.35 The Company has added the suggested modifications to the
Revised Scope Framework to reflect Staff's recommendation.36
E. Project Eligibility Cap (#20)
The Company has proposed evaluating the pros and cons of setting a customer’s
project eligibility cap according to a customer’s demand instead of the predetermined cap
of 25 and 100 kilowatts (“kW”). Staff proposed that the Company’s analysis should
evaluate previous concerns from when these caps were initially established by the
Commission, such as “safety, service quality, and grid reliability concerns.”37 Staff also
recommends that during the review of the project eligibility cap, Idaho Power should

34 Staff Comments at 13.

35 Id.

36 Revised Study Framework (Attachment 1) at 4.

37 Staff Comments at 14, citing Case No. IPC-E-01-39, Order No. 28951 at 11 (Feb 13, 2002).

IDAHO POWER COMPANY'S FINAL COMMENTS - 11
provide an analysis for 100% and 125% of customers' demand.38 Idaho Power has
included these specific analyses recommendations in the Revised Study Framework.39
CEO and ICL suggest in their Initial Comments that this issue should be addressed
in a separate docket before a comprehensive study.40 Staff stated in its comments that it
“does not believe that a separate docket is necessary to study these items and believes
the Company has the necessary data and expertise to provide a thorough and fair
evaluation of the 100 kW predetermined cap through this study.”41 In Order No. 34854,
the Commission stated there would be opportunities to address issues related to the
project eligibility cap during or after the forthcoming comprehensive study.42
Pursuant to the Commission’s Order, Idaho Power has retained this section in the
Revised Study Framework.43
F. Implementation Issues (#21-25)
Billing Structure (#21-22)
The Company proposes to evaluate and explain how potential customer-
generators will access accurate and adequate data and information to make informed
choices about the economics of on-site generation systems. Staff recommends that the

38 Id.

39 Revised Study Framework (Attachment 1) at 4.

40 CEO Initial Comments at 6 and ICL Initial Comments at 15.

41 Staff Comments at 14.

42 In the Matter of Idaho Power Company’s Application for Authority to Modify Schedule 84’s Metering
Requirement and to Grandfather Existing Customers with Two Meters, Case No. IPC-E-20-26 at 12 (Dec
1, 2020)(emphasis added).

43 Revised Study Framework (Attachment 1) at 4.

IDAHO POWER COMPANY'S FINAL COMMENTS - 12
study also identify when, how, and where customers will be able to access this
information.44 Idaho Power has reflected this in the Revised Scope Framework.45
ICL also suggests that the Billing Structure section of the study should evaluate
options for providing export credits to customers. Options suggested include which bill
components the credits can offset, whether customer-generators can use credits to offset
other accounts held by the same customer, and the ability of customers to donate credits
to other customers.46 Idaho Power has included these recommended areas of study in
the Revised Study Framework.47
Export Credit Expiration (#23-24)
The Company recommends evaluating if unused credits should expire or remain
available indefinitely. Parties’ comments address concerns with credits expiring, the
mechanics necessary to do so, and ensuring proper recovery. The Company emphasizes
that it has not taken a position on any particular matter with this topic and all areas of
the proposed scope. Instead, it has made recommendations of what should be included
in the scope of a study. Export Credit Expiration was included in the Scope of Rocky
Mountain Power’s On-Site Generation Study set forth in Attachment A in Final Order No.
34743 in Case No. PAC-E-19-08 and Idaho Power has proposed its study include a
similar evaluation.48

44 Staff Comments at 15.

45 Revised Study Framework (Attachment 1) at 4.

46 ICL Initial Comments at 13.

47 Revised Study Framework (Attachment 1) at 4.

48 Id.

IDAHO POWER COMPANY'S FINAL COMMENTS - 13
Frequency of Export Credit Rate Updates (#25)
The Company has proposed to quantify the impact of annual and biennial updates
to the export credit rate; however, ICL incorrectly suggests that the Company
presupposes the frequency of an update.49 The Company offered examples that it could
study based on what was approved in in the Scope of Rocky Mountain Power’s On-Site
Generation Study set forth in Attachment A of Order No. 34753. The Company has
modified this section to study the impacts of different update frequencies more broadly in
the Revised Study Framework to alleviate concerns of limited scope.50 The Company
again emphasizes that nothing in the Revised Study Framework is in any way intended
to be limiting.
Staff believes the Company should also identify the processes, cases, or
mechanisms for identifying updates.51 Idaho Power has added this recommendation to
the Revised Study Framework.52
III. ITEMS OUT-OF-SCOPE TO STUDY
A. Off-Site Generation
ICIP suggests that the scope of a study should include “Off-Site Non-Exporting
DER.”53 Staff states its belief that this is outside the scope of this case.54 The Company

49 ICL Initial Comments at 14.

50 Revised Study Framework (Attachment 1) at 5.

51 Staff Comments at 16.

52 Revised Study Framework (Attachment 1) at 5.

53 ICIP Comments at 1-4 (Sep 15, 2021).

54 Staff Comments at 16.

IDAHO POWER COMPANY'S FINAL COMMENTS - 14
agrees with Staff that ICIP’s proposal is outside the scope of "studying the costs and
benefits of on-site generation."55
B. Tidwell Proposal
Ms. Tidwell has recommended the Company include the benefits of microgrids and
their potential impact on low-income housing in the study.56 While the Company is not
opposed to further exploring the benefits of microgrids, it believes that this evaluation is
outside of the scope of the study ordered by the Commission.
IV. PROCEDURAL CONSIDERATIONS
A. Idaho Power to Conduct the Study
ICL proposed to have a neutral third-party conduct the study in Staff’s Study
Framework and its initial comments filed on October 13, 2021.57 Subsequently ISON,58
ICEA,59 and some members of the public have echoed this recommendation. The
Company believes that the Commission was clear in its directive for preparing a study:
“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.”60 The Company has prepared
and filed general rate cases to evaluate the total system revenue requirement and

55 Order No. 34046 at 31 (emphasis added)(directing the Company to “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 Company.”)

56 Tidwell Comments at 9 (Sep 7, 2021).

57 ICL Initial Comments at 4-6.

58 ISON Initial Comments at 4 (Oct 13, 2021).

59 ICEA Initial Comments at 1.

60 Order No. 34509 at 9.

IDAHO POWER COMPANY'S FINAL COMMENTS - 15
recommend base rates for all customers. It can assuredly conduct a credible and fair
study on the costs and benefits of distributed on-site generation. As the Commission
stated, “the study will be one critical component of Commission review but will not
preclude Parties from introducing and the Commission considering other relevant pieces
of information when it's time to address proposals for new program implementation.”61
B. An Additional Round of Comments on a Commission-Issued Scope is
Unnecessary
The Commission has provided Parties and public stakeholders the opportunity to
comment during the study design phase and has stated62 its intent to do the same in the
study review phase. During the Commission Public Hearing on October 28, 2021, four (4)
members of the public provided verbal testimony requesting the Commission issue a draft
scope for stakeholders to comment on before issuing a final ordered scope.
Although it is for the Commission to determine if this additional round of comments
on a Commission-issued scope would assist in developing the evidentiary record in a way
that the three (3) rounds of comments scheduled in Order Nos. 35176 and 35193 will not,
the Company believes it would create a superfluous step in the study design process and
functionally duplicate Commission’s reconsideration process.63
V. CONCLUSION
The Company provides these Final Comments to describe what changes have
been made to the Company’s Initial Study Framework based on feedback received in this
docket and provide support for suggestions that the Company believes the Commission

61 Order No. 34753 at 9.

62 Order No. 34509 at 9-10.

63 IDAPA 31.01.01.331 et seq.

IDAHO POWER COMPANY'S FINAL COMMENTS - 16
should not include in the scope of a study. Idaho Power appreciates the input received in
the study design phase during the public workshops, the Commission’s public hearing,
and written comments. The Company provides the Revised Study Framework
(Attachment 1) for the Commission's consideration and respectfully requests that the
Commission issue an order with a final approved scope and direct the Company to begin
the comprehensive study of the costs and benefits of on-site generation.
DATED at Boise, Idaho, this 16th day of November 2021.

________________________________
LISA D. NORDSTROM
Attorney for Idaho Power Company

IDAHO POWER COMPANY'S FINAL COMMENTS - 17
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the 16th day of November 2021, I served a true and
correct copy of IDAHO POWER COMPANY’S FINAL COMMENTS upon the following
named parties by the method indicated below, and addressed to the following:

Commission Staff
Erick Shaner
Deputy Attorney General
Idaho Public Utilities Commission
472 West Washington Street (83702)
P.O. Box 83720
Boise, Idaho 83720-0074

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IdaHydro
C. Tom Arkoosh
ARKOOSH LAW OFFICES
913 W. River Street, Suite 450
P.O. Box 2900
Boise, Idaho 83701

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Idaho Conservation League
Benjamin J. Otto
Idaho Conservation League
710 North 6th Street
Boise, Idaho 83702

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Idaho Irrigation Pumpers Association, Inc.
Eric L. Olsen
ECHO HAWK & OLSEN, PLLC
505 Pershing Avenue, Suite 100
P.O. Box 6119
Pocatello, Idaho 83205

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IDAHO POWER COMPANY'S FINAL COMMENTS - 18
City of Boise
Ed Jewell
Deputy City Attorney
Boise City Attorney’s Office
150 North Capitol Boulevard
P.O. Box 500
Boise, Idaho 83701-0500
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Idaho Clean Energy Association
Kevin King
P.O. Box 2264
Boise, ID 83702
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Industrial Customers of Idaho Power
Peter J. Richardson
RICHARDSON ADAMS, PLLC
515 North 27th Street (83702)
P.O. Box 7218
Boise, Idaho 83707
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Dr. Don Reading
6070 Hill Road
Boise, Idaho 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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Jim Swier
Micron Technology, Inc.
8000 South Federal Way
Boise, Idaho 83707
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IDAHO POWER COMPANY'S FINAL COMMENTS - 19
[e-mail]
Clean Energy Opportunities for Idaho
Kelsey Jae
Law for Conscious Leadership
920 N. Clover Dr.
Boise, Idaho 83703
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Michael Heckler
Courtney White
Clean Energy Opportunities for Idaho
3778 Plantation River Drive, Suite 102
Boise, Idaho 83703

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Richard E. Kluckhohn
Wesley A. Kluckhohn
2564 W. Parkstone Dr.
Meridian, ID 83646
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Kiki Leslie A. Tidwell
704 N. River Street #1
Hailey, Idaho 83333
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ABC Power Co. LLC
Ryan Bushland
184 W. Chrisfield Dr.
Meridian, ID 83646
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Idahome Solar, LLC
Tyler Grange
2484 N. Stokesberry Pl. #100
Meridian, ID 83646
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IDAHO POWER COMPANY'S FINAL COMMENTS - 20
Comet Energy LLC
George Stanton
13601 W. McMillan Rd. Ste 102
PMB 166
Boise, ID 83713
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Idaho Solar Owners Network
Joshua Hill
1625 S. Latah
P.O. Box 8224
Boise, ID 83707
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Stacy Gust, Regulatory Administrative
Assistant

BEFORE THE

IDAHO PUBLIC UTILITIES COMMISSION

CASE NO. IPC-E-21-21

IDAHO POWER COMPANY

ATTACHMENT 1

REVISED STUDY FRAMEWORK
(CLEAN)
Attachment 1
Idaho Power Company
Revised Study Framework

ATTACHMENT 1 1
Measurement Interval
1. Calculate the quantity of kWh consumed and amount billed for utility service if each of the
existing customer-generators net their energy exports:
a. Monthly
b. Hourly
c. Instantaneous/Real-Time
2. Calculate the quantity of kWh exported and amount credited if each of the existing customer-
generators net their energy exports:
a. Monthly
b. Hourly
c. Instantaneous/Real-Time
3. Analyze bill impacts to existing customer-generators, stratified by usage, if energy exports are
netted:
a. Monthly
b. Hourly
c. Instantaneous/Real-Time
Export Credit Rate (“ECR”)
Avoided Energy Value
4. Provide the calculations and documentation for the avoided cost of exported energy using:
a. Energy price calculations from the Company’s most recently acknowledged Integrated
Resource Plan (“IRP”)
b. Market index price assumptions
c. Other methods to determine an avoided energy value (e.g., surrogate resource)
5. Evaluate an avoided energy value that could vary with time and/or location of exported energy.
If a method is not available for location of exports, evaluate a placeholder for calculating
locational derived value.
6. Provide calculations and documentation evaluating if the avoided cost of exported energy
produced by customer-generators should be discounted to reflect the non-firm nature of the
exported energy.
a. Evaluate firmness of energy for individual customers compared to as a combined class.
b. Evaluate firmness of energy for customers with energy storage devices compared to those
without energy storage devices.
Attachment 1
Idaho Power Company
Revised Study Framework

ATTACHMENT 1 2
7. Consider any impact of the ECR on non-generating customers to ensure other customer classes
are held neutral to avoid inter-class subsidies.
Avoided Capacity Value
8. 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
reducing the Company’s system coincident peak (i.e., the Company’s net peak – the hour(s) that
drive the need for capacity or capacity-equivalent resource additions) as a component of the
Company’s broad resource portfolio.
a. Consider valuation of avoided capacity based on the timing of the Company’s first
capacity deficiency and how it can be incorporated into the development of the ECR.
b. Identify and evaluate methods for identifying system coincident peak hours.
c. Identify and evaluate different ECR rate designs to ensure customer generators are
correctly compensated for the amount of capacity they contribute during system
coincident peak hours and for the amount of capacity avoided.
d. Evaluate potential differences between customer generators who have energy storage
devices and those that do not have energy storage devices.
9. Evaluate rate designs for avoided capacity values:
a. Credit the avoided cost of capacity for every kilowatt-hour of energy exported to the
Company’s system regardless of the time period.
b. Credit an avoided cost of capacity only for exports that occur during system coincident
peak hours.
Avoided Distribution Costs
10. Quantify the value of distribution costs that could be avoided by energy exported to the grid by
customer-generators.
a. Evaluate the range of avoided capacity between individual customer generators and
avoided capacity cost at a class level.
Avoided Transmission Costs
11. Quantify the value of transmission costs that could be avoided by energy exported to the grid by
customer-generators.
a. Evaluate the range of avoided capacity between individual customer generators and
avoided capacity cost at a class level.

Attachment 1
Idaho Power Company
Revised Study Framework

ATTACHMENT 1 3
Avoided Line Losses
12. Quantify the avoided marginal line loss associated with the avoided energy value and avoided
capacity value.
a. Consider line loss at distribution-level voltages and transmission-level voltages in
connection with the type of avoided cost.
Integration Costs
13. 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.
a. Evaluate if integration costs apply differently for customers with and without energy
storage devices.
b. Explore methods for evaluating how different penetration levels impact the level of
integration costs by customer.
c. Explore methods for evaluating how integration costs can change over time to suggest
how frequently ECR should be updated.
Avoided Risk
14. Quantify and analyze the fuel price guarantee value provided by customer generators.
15. Quantify the avoided uncertainty in fuel price fluctuations from the displaced marginal resource
across the planning period.
Avoided Environmental Costs and Other Benefits
16. Evaluate environmental and other costs that are quantifiable, measurable, and only include
avoided costs that affect rates.
a. Quantify the potential value of grid stability, resiliency, and cybersecurity protection
provided by on-site generators as a class and different penetration levels.
b. Quantify the value to local public health and safety from reduced local impacts of climate
change such as reduced extreme temperatures, reduced snowpack variation, reduced
wildfire risk, and other impacts that can have direct impacts on Idaho Power customers.
c. Quantify local economic benefits, including local job creation and increased economic
activity in the immediate service territory.
d. Quantify the possible net value of Renewable Energy Credit sales produced by net
metering exported energy.
e. Quantify the reduced risk from end-of-life disposal concerns for the Company compared
to fossil fuel resources.

Attachment 1
Idaho Power Company
Revised Study Framework

ATTACHMENT 1 4
Recovering Export Credit Rate Expenditures
17. Quantify the annual costs of export credits under varying assumed ECR values.
18. Analyze methods for how these costs would be allocated and recovered by rate class.
a. Identify the customer classes responsible and the potential impact to other customer
classes.
Cost-of-Service & Rate Design
19. Evaluate cost-of-service methodologies and potential rate designs for customer-generators that
could be implemented in the Company’s next general rate case.
a. Provide the impact to all customer classes, including customer generators.
Project Eligibility Cap
20. Analyze pros and cons of setting a customer’s project eligibility cap according to a customer’s
demand (peak electric load) as opposed to predetermined caps of 25 kW and 100 kW.
a. Analyze at 100% of customer’s demand.
b. Analyze at 125% of customer’s demand.
Implementation Issues
Billing Structure
21. Explain when, how, and where potential customer-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.
22. Examine the options for providing credits for exports to customers.
a. Evaluate which bill components the credits can offset.
b. Assess whether credits can be used to offset other accounts held by the same customer,
and the ability of customers to donate credits to other customers.
Export Credit Expiration
23. Quantify the magnitude, duration, and value of accumulated export credits.
24. Evaluate if there is a need for credits to expire.
c. Show how the Company does or does not benefit from the expiration of customer export
credits.
d. Show how non-customer-generators are harmed or benefited from the expiration of
customer export credits.
i. Quantify the impact to non-customer-generators of a 2-year, 5-year, and 10-year
expiration period.
Frequency of Export Credit Rate Updates
Attachment 1
Idaho Power Company
Revised Study Framework

ATTACHMENT 1 5
25. Quantify the impact of biennial, annual, or other frequency of updates of the ECR by evaluating
how each component can change over time.
a. Consider impact of timing of updates.
b. Evaluate objective criteria such as changes to the costs Idaho Power avoids by receiving
exports from customer-generators.
26. Identify potential process, case, or mechanism for identifying updates to the export credit rate.

BEFORE THE

IDAHO PUBLIC UTILITIES COMMISSION

CASE NO. IPC-E-21-21

IDAHO POWER COMPANY

ATTACHMENT 2

REVISED STUDY FRAMEWORK
(LEGISLATIVE)
Attachment 1:
Idaho Power-Proposed Scope of On-Site Generation Company
Revised Study Framework

ATTACHMENT 1 1
Measurement Interval
1. Calculate the class revenue requirementquantity of kWh consumed and amount billed for utility
service if each of the existing customer-generators net their energy exports:
a. Monthly
b. Hourly
c. Separate channel
c. Instantaneous/Real-Time
2. Calculate the export credit paymentsquantity of kWh exported and amount credited if each of the
existing customer-generators net their energy exports:
a. Monthly
b. Hourly
c. Separate channel
c. Instantaneous/Real-Time
3. Analyze bill impacts to existing customer-generators, stratified by usage, if energy exports are
netted:
a. Monthly
b. Hourly
c. Separate channel
c. Instantaneous/Real-Time
Export Credit Rate (“ECR”)
Avoided Energy Value
4. Provide the calculations and documentation for the avoided cost of exported energy using:
a. Energy price assumptions incalculations from the Company’s most recently
acknowledged Integrated Resource Plan (“IRP”)
b. Market index price assumptions
c. Other methods to determine an avoided energy value (e.g., surrogate resource)
5. Evaluate an avoided energy value that could vary with time and/or location of exported energy.
If a method is not available for location of exports, evaluate a placeholder for calculating
locational derived value.
5.6. Provide the calculations and documentation showingevaluating if the avoided cost of exported
energy produced by customer-generators should be discounted to reflect the non-firm nature of
the exported energy.
Attachment 1:
Idaho Power-Proposed Scope of On-Site Generation Company
Revised Study Framework

ATTACHMENT 1 2
a. Evaluate firmness of energy for individual customers compared to as a combined class.
b. Evaluate firmness of energy for customers with energy storage devices compared to those
without energy storage devices.
7. Consider any impact of the ECR on non-generating customers to ensure other customer classes
are held neutral to avoid inter-class subsidies.
Avoided Capacity Value
6.8. 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
peakreducing the Company’s system coincident peak (i.e., the Company’s net peak – the hour(s)
that drive the need for capacity or capacity-equivalent resource additions) as a component of the
Company’s broad resource portfolio.
a. Consider valuation of avoided capacity based on the timing of the Company’s first
capacity deficiency and how it can be incorporated into the development of the ECR.
b. Identify and evaluate methods for identifying system coincident peak hours.
c. Identify and evaluate different ECR rate designs to ensure customer generators are
correctly compensated for the amount of capacity they contribute during system
coincident peak hours and for the amount of capacity avoided.
d. Evaluate potential differences between customer generators who have energy storage
devices and those that do not have energy storage devices.
9. Evaluate rate designs for avoided capacity values:
a. Credit the avoided cost of capacity for every kilowatt-hour of energy exported to the
Company’s system regardless of the time period.
b. Credit an avoided cost of capacity only for exports that occur during system coincident
peak hours.
Avoided Transmission and Distribution Costs
7.10. Quantify the value of transmission and distribution costs that could be avoided by energy
exported to the grid by customer-generators.
a. Evaluate the range of avoided capacity between individual customer generators and
avoided capacity cost at a class level.
Avoided Transmission Costs
11. Quantify the value of transmission costs that could be avoided by energy exported to the grid by
customer-generators.
a. Evaluate the range of avoided capacity between individual customer generators and
avoided capacity cost at a class level.

Attachment 1:
Idaho Power-Proposed Scope of On-Site Generation Company
Revised Study Framework

ATTACHMENT 1 3
Avoided Line Losses
8.12. Quantify the avoided marginal line loss associated with the avoided energy value and
avoided capacity value.
a. Consider line loss at distribution-level voltages and transmission-level voltages in
connection with the type of avoided cost.
Integration Costs
9.13. 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.
a. Evaluate if integration costs apply differently for customers with and without energy
storage devices.
b. Explore methods for evaluating how different penetration levels impact the level of
integration costs by customer.
c. Explore methods for evaluating how integration costs can change over time to suggest
how frequently ECR should be updated.
Avoided Risk
14. Quantify and analyze the fuel price guarantee value provided by customer generators.
15. Quantify the avoided uncertainty in fuel price fluctuations from the displaced marginal resource
across the planning period.
Avoided Environmental Costs and Other Benefits
16. Evaluate environmental and other costs that are quantifiable, measurable, and only include
avoided costs that affect rates.
a. Quantify the potential value of grid stability, resiliency, and cybersecurity protection
provided by on-site generators as a class and different penetration levels.
b. Quantify the value to local public health and safety from reduced local impacts of climate
change such as reduced extreme temperatures, reduced snowpack variation, reduced
wildfire risk, and other impacts that can have direct impacts on Idaho Power customers.
c. Quantify local economic benefits, including local job creation and increased economic
activity in the immediate service territory.
d. Quantify the possible net value of Renewable Energy Credit sales produced by net
metering exported energy.
e. Quantify the reduced risk from end-of-life disposal concerns for the Company compared
to fossil fuel resources.

Attachment 1:
Idaho Power-Proposed Scope of On-Site Generation Company
Revised Study Framework

ATTACHMENT 1 4
Recovering Export Credit Rate Expenditures
10.17. Quantify the annual costs of export credits under varying assumed ECR values.
11.18. Analyze methods for how these costs would be allocated and recovered by rate class.
a. Identify the customer classes responsible and the potential impact to other customer
classes.
Cost-of-Service & Rate Design
19. Evaluate cost-of-service methodologymethodologies and potential rate designs for customer-
generators that could be implemented in the Company’s next general rate case.
a. Provide the impact to all customer classes, including customer generators.
Project Eligibility Cap
12.20. Analyze pros and cons of setting a customer’s project eligibility cap according to a
customer’s demand (peak electric load) as opposed to predetermined caps of 25 kW and 100 kW.
a. Analyze at 100% of customer’s demand.
a.b. Analyze at 125% of customer’s demand.
Environmental and Other Benefits
13. Evaluation of the quantifiable environmental and other system benefits provided by customer-
generators.
Implementation Issues
Billing Structure
14.21. Explain when, how, and where potential customer-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.
22. Examine the options for providing credits for exports to customers.
a. Evaluate which bill components the credits can offset.
b. Assess whether credits can be used to offset other accounts held by the same customer,
and the ability of customers to donate credits to other customers.
Export Credit Expiration
15.23. Quantify the magnitude, duration, and value of accumulated export credits.
16.24. Explain theEvaluate if there is a 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.
Attachment 1:
Idaho Power-Proposed Scope of On-Site Generation Company
Revised Study Framework

ATTACHMENT 1 5
i. Quantify the impact to non -customer-generators of a 2-year, 5-year, and 10-year
expiration period.
Frequency of Export Credit Rate Updates
25. Quantify the impact of biennial updates as compared to , annual, or other frequency of updates of
the ECR by evaluating how each component can change over time.
a. Consider impact of timing of updates.
b. Evaluate objective criteria such as changes to the costs Idaho Power avoids by receiving
exports from customer-generators.
17.26. Identify potential process, case, or mechanism for identifying updates to the export credit
rate.