20210930Study Framework.pdf

ERICK SHANER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 5214
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
CASE NO.IPC.E.2I.2I
STUDY FRAMEWORK
FOR PARTY COMMENTS
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Street Address for Express Mail:
1 I331 W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, ID 837I4
Afforney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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STAFF OF the Idaho Public Utilities Commission, by and through its attorney of record,
Erick Shaner, Deputy Attorney General, submits the following.
BACKGROUND
On June 28,202l,ldaho Power Company ("Company") applied to the Commission to
begin a multi-phase process for a comprehensive cost and benefit study of on-site generation as
directed in Order No. 34046.1 The Company requests that a final order be issued in this case by
the end of 2021so that 2021 data can be used for the "study design" phase in the first half of
2022 and the "study review" phase can be begin in June 2022.
On July 27,2021, the Commission issued a Notice of Application and set a deadline for
I In the Matter of the Application of ldaho Power Companyfor Authority to Establish New Schedulesfor Residential
and Small General Seryice Customers with On-Site Generation, Case No. IPC-E-17-13, Order No. 34046 at3l
(May 9,2018).
ISTUDY FRAMEWORK SEPTEMBER 30,2O2I
intervention and deadline for the Company, Commission Staff, and intervening parties to confer
regarding a proposed schedule for this matter. Industrial Customers of Idaho Power, IdaHydro,
Idaho Conservation League, Idaho Clean Energy Association, Clean Energy Opportunities for
Idaho, Idaho Solar Owners Network, Micron Technology, [nc., City of Boise, Kiki Leslie A.
Tidwell,pro se, Idaho Irrigation Pumpers Association, Inc., Richard E. Kluckholtn, pro se and
Wesley A. Kluckhohn,pro se, ABC Power Company, LLC, Comet Energy, LLC, and Idahome
Solar petitioned for and were granted intervention ("Intervenors"; collectively with the Company
and Commission Staff "the Parties").
On August 30,2021, the Parties met and agreed that Staff would file with the
Commission the Initial Framework to Study ("Study Framework") on September 30, 2021. The
Study Framework is based on initial work completed by the Parties and discussed on September
22,2021. The Study Framework does not represent agreement by all parties on what should be
included in the Final Study Framework. Each Party will file Comments with the Commission to
present their formal views and recommendations for the Final Study Framework to be
established by the Commission.
On September 8,2021, the Commission issued aNotice of Parties giving notice of the
parties to this matter that included the Company, Staff, and lntervenors.
On September 22,2021, the Commission issued Order No. 35 176 requiring all Parties and
the public to file initial comments about the appropriate scope of the Study Framework by October
13,2021.
Also on September 22,2021, the Parties met and continued the work started on August 30,
2021, to develop the Study Framework and agreed upon a general schedule for this case.
The Commission has jurisdiction over this matter under Title 6l of the Idaho Code. The
Commission is empowered to investigate rates, charges, rules, regulations, practices, and
contracts of public utilities and to determine whether they are just, reasonable, preferential,
discriminatory, or in violation of any provision of law, and to fix the same by order. Idaho Code
$$ 61-502 and 6l-503; IDAPA 31.01.01 .000 et seq.
2STUDY FRAMEWORK SEPTEMBER 30,2021
Commission
Staff
('Staff'l
Clean Energy
Opportunities of
ldaho
("cEo"l
ldaho
Conservation
League
("tct"l
ldaho Solar Owners
Network
("lsoN")
lndustrial
Customers of
ldaho Power
("tctP")
Micron
Technology, lnc.
("Micron")
City of Boise City
("Boise Citf')
Kiki Leslie A.
Tidwell, pro se
('Tidwell"|
Richard E. Kluckhohn,
pro se
and
Wesley A. Kluckhohn,
pro se
("Kluckhohn")
ldaho Clean
Energy
Association
("tcEA")
Key
STUDY FRAMEWORK
IPC-E-21-21 "Study Desisn" Obiectives
Primary Objective (for this case - "study design phase"):
l. ICL: The Commission identified the following "criteria for a fair and credible study". Order No
34509 at9.
. "IJse the most current data possible and the data must be readily available to the public and
in the Commission's decision-making record."
. The Commission will approve the final scope of the study that the Company o'must design in
coordination with the parties and the public"
. "The study must be written so it is understandable to an average customer, but its analysis
must be able to withstand expert scrutiny"
. The Commission further explained that "Table I to the first Staff Report could serve as the
basis for a scoping recommendation in the next case." Order 34546 at7.
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he'1p de'ferm ine:
- ICL: Such as Energy Policy Institute at Boise State University or Idaho
National Lab. A neutral expert conducting the study is more likely to
build public support for a credible and fair analysis
a. The rates and dollar bill credit to on-site generation who export energy on to the Company's
grid (Export Credit Rate - "ECR").
:'Tl:;",ign, ro. rcn
- Kluckhohn: Other PUC models
JSTUDY FRAMEWORK SEPTEMBER 30,2O2I
I
- Kluckhohn: Other "Models" (quantitative/mathematical) for evaluating
rate design
Value of avoided cost of energy
- ICL: See our attachments for recent studies identifying methods to
conduct value of solar studies.
https://wrvw.sciencedirect.corn/science/article/abs/pii/S I 3640321203088
32?via%3Dihub
Value of avoided cost of capacity
Value of cost of avoided transmission and distribution
Value of cost of avoided line losses
Cost to integrate customer-generation exported to the grid
Environmental and Other Benefits
Kluckhohn: Idaho Power cost-of-service by customer class and by measurement
intervals (month, hour, separate channel)
Kluckhohn: Cost of purchase power by provider type (wind, solar, hydro-
generation) by measurement intervals (month, hour, separate channel)
Kluckhohn: Recommendations regarding the timing and threshold number of
customer generators when the PUC should implement a change to the ECR
Kluckhohn: Fair method for evaluation of all customer/classes to ensure the
systemic process remains fair, just, and reasonable for all customers
- How does IPC define fair, just, and reasonable? What factors need to be
considered for each to be fair, just and reasonable?
- What recommendations does IPC have for weighting the factors in the
evaluation of fairness, justness, and reasonableness?
Tidwell: How solar generated power and credits can be equitably shared with
low income or workforce customers. This should include community solar farms
and multi-family buildings.
4STUDY FRAMEWORK SEPTEMBER 30,2021
What level of onsite generation total dollar value actually materially
impacts rates for all customers; are small net-metering customers bearing
undue financial burdens and filings in contrast to their overall percentage
of Idaho Power's last rate application reported $2,355,906,412ldaho
retail rate base?
Idaho Power has the obligation to provide information in this case as to
when a levelof such on-site generation actually substantively impacts its
operations to become a material factor to all ratepayers' costs.
b. The proper ECR measurement interval (month, hour, separate channel).
By identif,ing, characterizing, and/or quantifuing implementation issues of potential
ECR solutions and rate designs using the different measurement intervals.
Sub-objectives of Study:
l. Identifu, characterize and/or quantiff issues that potential ECR alternative solutions will
create that will impact the Company's ability to recover costs from self-generating customers.
The evaluation should include issues across the ECR solution space using the different ECR
measurement intervals (month, hour, separate channel) and ECR rate designs.
Kluckhohn: "Identifu, characterize and/or quantift issues that potential ECR
alternative solutions will create that will impact the Company's ability to recover
costs from self-generating customers. The evaluation should include issues across
the ECR solution space and Non-ECR solution space using the different ECR
measurement intervals (month, hour, separate channel) and ECR rate designs."
2. Identiff, characterize and/or quantiff issues to both participating and non-participating self-
generating customers (e.g., bill impacts, subsidies) relative to potential ECR solutions. The
evaluation should include issues across the ECR solution space using the different ECR
measurement intervals (month, hour, separate channel) and ECR rate designs.
ICL: We recommend reordering these sub-objectives to more appropriately balance
the study and build public confidence in the process.
ICL: We recommend the study address impacts to participants in the customer-
generation program separately from impacts to non-participating customers because
these are fundamentally distinct issues
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I
5STUDY FRAMEWORK SEPTEMBER 30,2021
3. Evaluate alternatives (including the process definition, frequency of updates, timing,
customers affected, etc.) for updating the ECR to ensure it remains fair, just, and reasonable
for all customers.
. Kluekhohn: "Evaluate alternatives (including the process definition, frequency of
updates, timing, customers affected, magnitude of customer impacted relative to total
system, etc.) for updating the ECR to ensure it remains fair, just, and reasonable for
all customers.
4. Provide precise definition of terms used in the study.
ICL: We recommend the parties in this process verif,, the terms used are clear to the
public.
Company's Objectives from Application and Testimony
L Initiate a multi-phase collaborative process for a study of the costs and benefits of on-site
generation.
o The Company's primary objective of the study process is to establish a sustainable on-site
generation offering that limit subsidies by implementing a more equitable pricing and
"":*':K',';'::;:robjective
#l contains a biased premise that assumes current
pricing is not equitable. We suggest the statement be worded as such: " 1. The
Company's primary objective of the study process is to establish a sustainable
on-site generation offering that fairly prices the compensation structure."
o Recommendations to modifu the existing offering shouldfocus on cost-of-service
principles, while identifuing the appropriate value of excess net energl to ensure
equitable compensation for on-site generators.
2. To prepare andfile a "credible andfair study" of the costs and benefits of distributed on-site
generation using the most curuent data
. Kluckhohn: What factors determine "credible and fairness to the PUC"
. Kluckhohn: How might the PUC Staffweight these factors?
6STUDY FRAMEWORK SEPTEMBER 30,2O2I
IPC-E-2I -21 Study Framework
From All Parties
Measurement Interval
1. Calculate the class revenue requirement if each of the existing customer-generators net their
energy exports:
cEo: "calculate the quantity of kwh exported rather than class revenue
requirement if each of the existing customer generators net their energy exports."
Stafr: By netting energy exports from consumption by the various measurement
intervals, identifu, characterize and/or quantifu issues that could impact the
determination of the revenue requirement for customer generators.
ICEA: Revenue requirement is something that can only be logically considered
after we have determined the value of the ECR based on the timing of each kWh
excess generation.
a. Monthly
b. Hourlyc'-i':1"'
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"Instantaneous Net Energy Measurement" is suggested for all locations
throughout the document.
2. Calculate the export credit payments if each of the existing customer-generators net their energy
exports:
a. Monthly
b. Hourly
c. Separate channel
. ICL: We recommend the term "Instantaneous Net Energy Measurement".. ICEA: There has not been a determination if the future compensation will be
monetarily based or credit based, therefore Idaho Power should study the
difference between the two and show, in their study, how each option is affected
by the time intervals suggested.
, CEO: Recommends deleting "Monthly", "Hourly", and "Separate Channel"
7STUDY FRAMEWORK SEPTEMBER 30,2O2T
CEO: 'oln order to compare the difference across alternatives, calculate the value
of export compensation if each of the existing customer-generators were
compensated for their net energy exports under the following 4 scenarios:"
3. Analyze bill impacts to existing customer-generators, stratified by usage, if energy exports are
netted:
. ICEA: A fair study would also evaluate and analyze the impacts of distributed
energy program design to customers who have a right to meet their own needs
through on-site generation.
. ISON: Please analyze "bill impacts" to future customer-generators
a. Monthly
b. Hourly
c. Separate Channel
. CEO: Recommends deleting "Separate Channel"
, ICL: We recommend the term "lnstantaneous Net Energy Measurement".
Exoort Credit Rate ("ECR")
Avoided Energt Value
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factors when determining the avoided energy cost of the ECR:
a. Different methods to value the avoided energy cost (surrogate, market,
proxy, etc.)
b. Value of the avoided energy cost during different times of the day, week,
month, and or year (e.g., l2-month x 24 hour enerry export profiles)
8
Export Value
Current Proposed
Netting
Period
Monthly
NO CHANGE:
a. Monthly netting, 1:1 kWh credit
CHANGE EXPORT VALUE:
c. Monthly netting, proposed ECR
Hourly
CHANGE NETTING:
b. Hourly netting, 1:1 kWh credit
CHANGE BOTH:
d. Hourly netting, proposed ECR
STUDY FRAMEWORK SEPTEMBER 30,2O2I
c. Different configurations of customer generators including non-exporting
customers and customers with storage
. ICEA: The study must recognize that excess generation produced at the
distribution grid level is fundamentally different than generation from utility scale
projects.
. ICL: This section needs a time horizon for analysis.
a. Energy price assumptions in the Company's most recently acknowledged Integrated
Resource Plan ("lRP")
. CEO: "Energy price projections of future year and time period energy marginal
values that represent season, day of the week/holiday and time of day as
proposed assumptions in the Company's 2021 Integrated Resource Plan ("lRP")"
t Staff: Please provide the assumptions currently being used from the IRP.
. ICL: This section needs a time horizon for analysis.
b. Market index price assumptions
. CEO: "Avoided risks, including avoided costs based on reduced risk and
exposure to the volatile fuel prices ofconventional generation resources."
r Staff: Please provide all market index price assumptions evaluated.
t Staff: Please provide market index price analysis on annually, monthly, daily,
and hourly basis.
r Staff: Please provide analysis for translating market index price assumptions into
an ECR.
r ICL: This section needs a time horizon for analysis.
5. Provide the calculations and documentation showing if the avoided cost of exported energy
produced by customer-generators should be discounted to reflect the non-firm nature of the
exported energy.
. ISON: "Provide the calculations and documentation showing if the avoided cost of
exported energy produced by customer-generators should be discounted or increased, to
reflect the non-firm nature of the exported energy."
. Staff: Please explain how the IRP values non-firm energy in its pricing if it does at all. If
it doesn't, please explain why it does not.
o The value of exported energy should be evaluated on the predictability that a
specific amount of energy will be exported when expected (firm versus non-firm)
9STUDY FRAMEWORK SEPTEMBER 30,2O2I
Avoided Capacity Value
6. Analyze the capacity value of exported energy provided by customer-generators. Provide the
calculations and documentation for evaluating the capacity resource value and the contribution to
peak.
. CEO: "Analyze the generation capacity value of exported energy provided by customer-
generators. Provide the calculations and documentation for evaluating the capacity
resource value and the contribution to total system ELCC."
. Staff: Please provide reasoning for the calculations used and explain why that calculation
is the most appropriate compared to alternative calculations.
. Staff: The study should consider the need for and the impact of the following factors
when determining the avoided capacity cost of the ECR:
a) Different methods to value the avoided capacity cost (surrogate, market, proxy,
etc.)
b) Identification of the Company resource investment being avoided (generation,
transmission, distribution, etc.)
c) Value of avoided capacity cost based on when the Company's system or local
distribution area first becomes capacity deficient.
d) Peak hours that the exported energy will avoid incremental capacity investment
(ELCC, capacity contribution at peak).
e) Potential rate designs that include paying avoided capacity costs for all export
using capacity contribution at peak, or by only paying during coincident peak
hours (i.e., time of generation)
0 Different configurations of customer generators including non-exporting
customers and customers with storage.
. ICEA: It is important to value export generation at the time it is exported and not
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an d wi nter d irrerence)
. ICL: This section needs a time horizon for analysis.
Avoided Transmission and Distribution Costs
7. Quantifu the value of transmission and distribution costs that could be avoided by energy
exported to the grid by customer-generators.
. ICEA: Study both the benefits and cost of avoided energy exported to the grid on peak
load.
STUDY FRAMEWORK 10 SEPTEMBER 30, 2O2I
CEO: The value of transmission costs that could be avoided by exported energy should
be based on total system peak loads
CEO (ICEA): The value of distribution costs that could be avoided by exported energy
should be based on the impacts to the distribution system at the location of the export.
Any proposed analysis of distribution capacity cost avoidance based on average exports
across the Company's entire system (that is, an analysis of an export's location-based
value that ignores the location where the export occurs) is inappropriate. Rather, we
should establish a placeholder for Locational System Relief Value (LSRV) in the current
value stack for the ECR and make recommendations for further evaluation
ICL: This section should address the distribution and transmission systems separately as
they are distinct issues. We recommend separating the study of avoided distribution and
transm ission infrastructure.
Avoided Line Losses
8. Quantif, the avoided line loss associated with the avoided energy value and avoided capacity
value.
. CEO: "Quantif, the avoided marginal line loss associated with the avoided energy value
and avoided capacity value."
. Staff: Please provide the constraints in place to avoid duplicate counting of avoided
distribution costs and avoided line losses at the distribution level.
' Staff: Please provide the most recent line loss study and explain how this line loss study
was validated.
. ICL: This section should address losses, or more accurately the avoidance of losses, on
the distribution and transmission systems separately as they are distinct issues.
Integration Costs
9. Study methods for determining the integration costs of customer-generators. Provide the
calculations and assumptions showing if the ECR should be reduced to account for integrating the
customer-generator resource.
. CEO: "Utilize recent study of QF grid level integration cost 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."
STUDY FRAMEWORK ll SEPTEMBER 30,2021
. ISON: "Study methods for determining the integration costs of customer-generators.
Provide the calculations and assumptions showing an ECR that accounts for integrating
the customer-generator resource."
, ISON: Study the inherent value of distributed storage integration being potentially
accessed and purchased by the Company must be provided as a solution to offset
integration costs of customer-generators.
, Staff: Please provide allmethods studied for integration costs of customer-generators.
. Staff: The study should consider the need for and the impact of the following factors
when determining the cost to integrate customer generation exported to the grid:
a) Cost of reserves needed to balance the variability of customer generation
exported on to the grid
b) Different methods for determining cost of reserves (i.e., EIM, dispatchable
capacity, etc.)
c) Different configurations of customer generators including non-exporting
customers and customers with storage
. ICL: The Study should explore the level of distributed resource aggregation that would
impact the Company's net loads and resources. We recommend the study first address
whether integrating customer-exports that remain on individual distribution circuits are
meaningfully different from the normal variability in customer loads on these circuits.
The study should also answer the question of what level of aggregated distributed energy
exports is necessary before there is any meaningful impact on the net loads and
variability the company must address through integration. Once aggregated distributed
energy exports rise to the level of influence the Company's need to address net loads and
generation, the study should examine whether customer-exports reduce or increase
overall system integration costs.
. ICEA: Integration cost should not be accounted for by reducing the value of an ECR.
The study should begin by examining if the "integration" of excess generation has any
meaningful difference than meeting the inherent variability of customer demands on each
distribution circuit. Any assessment of integration costs must recognize that on-site
customer generation is spread across a variety of distribution circuits, and each system
has a unique relationship to customer loads and this circuit. If the idea is to make this
process more fair and equitable for the Company and each of its customers, then it is
reasonable that the Company evaluates each of its customers integration cost on an
individual basis. Parameters for these costs should be studies.
STUDY FRAMEWORK 12 SEPTEMBER 3O,2O2I
Boise City: Avoided Risk
10. Boise City: Quantiff and analyze the fuel price guarantee value provided by customer generators
at each penetration level (current levels, 10x, and 25x).
r Boise City: Quantiff the avoided uncertainty in fuel price fluctuations from the displaced
marginal resource across the planning period.
Recovering Export Credit Rate Exnenditures
. CEO: 'oRecoverins Administrative Costs of Export Credit Rate Prosram"
11. Quanti! the annual costs under varying assumed ECR values.
, CEO: "Quantiff the annual costs necessary to administer the ECR program"
. Staff: Please explain how this differs from items I and 2 above.
12. Analyze how these costs would be allocated and recovered by rate class.
. Staff: If the Power Cost Adjustment ("PCA") is the correct mechanism for recovering the
ECR expenditures, please analyze and identifr how the PCA would need to be modified
to recover ECR expenditures.
. ICEA: Study to determine costs relevant to ECR rather than costs to the Company to
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and veriry that doubre counting does not occur.
Cost-of-Service & Rate Desien
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13. Evaluate cost-of-service methodology and potential rate designs for customer-generators.
. CEO: "Evaluate potential rate designs and transitional rates for crediting customers for
providing net excess energy as a resource to the Company."
. CEO: The study of rates and rate design for consumption are outside the scope of this
study.
. CEO: Revenue requirement analysis is outside the scope of this study. If the scope of
this study process is interpreted to include revenue requirement surpluses/deficiencies,
we would ask that revenue requirement surplus/deficiencies across all classes be
evaluated and presented in absolute dollars.
. Staff: Please explain how different rate designs for customer-generators might drive
different customer behavior on energy consumption and influence energy exports from
customer-generators.
' Staff: Cost-of-service changes should be implemented in a general rate case
STUDY FRAMEWORK 13 SEPTEMBER 30,2O2I
. Staff: From a cost recovery perspective, please provide the impacts of raising the
customer charge.
. Staff: From a cost recovery perspective, please provide the impacts of implementing a
demand charge.
i. Demand Charge by the peak hours ofthe month?
ii. Demand at peak moment?
iii. Average of demands?
. ICEA: When evaluating cost-of-service and potentialrate designs for self-generation
customers we need to include transitional rate structures, gradual rate structures, and
issues associated with all potential changes in direct relation to net excess energy. We
also believe that each customer group in each class should be looked at individually.
14. Micron: Evaluate how various cost of service methodologies and potential rate designs impact
non-customer-generators in each rate class (including Special Contract customers) including the
potential for cross-subsidies between customer-generators and non-customer-generators.
15. Kluckhohn: Evaluate revenue-otservice methodology and potential rate designs for customer-
generators and non-customer generation class of IPC customers
Proiect Elisibilitv Cao
16. Analyze pros and cons of setting a customer's project eligibility cap according to a customer's
demand as opposed to predetermined caps of 25 kW and 100 kW.
' CEO: "Analyze pros and cons of setting a customer's project eligibility cap according to
a customer's peak electric load as opposed to predetermined caps of 25 kW and 100 kW."
. Staff: Please provide analysis at 100%o and 125Yo of a customer's demand.
. Staff: This study should determine whether the size of the cap needs to consider impacts
to safety and reliability of the system.
. CEO: For residentialcustomers, who are rarely impacted by the 25kW cap, include
analysis of the pros and cons of maintaining the 25kW cap while also allowing customers
an option to apply for a feasibility review for systems larger than 25kW yet constrained
by a cap according to a customer's peak load. Estimate the costs associated with such
residential feasibility reviews to inform any potential decisions on an appropriate fee.
. CEO: We propose a filing, as soon as possible after an order issues on this study design
proposal, of an application proposing changes to the CI&l cap. The separate CI&l cap
docket should review a cap no less than a customer's peak electric load. The pros and
STUDY FRAMEWORK t4 SEPTEMBER 3O,2O2I
cons of such a change and modifications to the proposal can then be studied in the
context of that docket, enabling an informed order by the Commission.
ISON: Definition of "customer's project eligibility cap" should be provided so that the
average customer understands this item. The context surrounding the current cap, and
how advancement has changed their application should also be included to prevent the
same issue in the future due to inevitable load increases.
ICEA: This study needs to look at this in a few different ways. For example, the system
size cap in relation to peak demand, transformer size, and the on-site customer's right to
meet their own needs with their own system. We believe that customers should be
allowed to install systems that meet their own needs before considering any excess
generation.
ICL: The Study should consider system sizes that are related to a customer's
consumption.
Environmental and Other Benefits
17. Evaluation of the quantifiable environmental and other system benefits provided by customer-
generators.
. Staff: Please provide the criteria the Company plans to use to quantiff the environmental
and other systems benefits provided by customer-generators.
. Staff: Please include the dollar impacts to customers of these environmental impacts.
Please include dates that those costs would be incurred.
. Staff: This study should consider the need for and the impact of different methods to
value environmental benefits for energy exported to the grid such as the market value of
Renewable Energy Credits ("REC"), cost of carbon, avoided investment cost of
environmental controls, or other avoided financial costs.
. Staff: Quantiff the possible net value of REC sales produced by net metering exported
energy and determine how the REC sales by net metering exported energy could be
allocated back to customer generators.
. ICEA: This section should be broken down in more detail prior to the study so we can
see exactly what factors are being considered. There are many factors that fall into the
environmental and other benefit bucket, and we should have an opportunity to know what
the current factors are and the ability to suggest additional factors if necessary.
. CEO: Ensure that the process to quantifu potentially transferable environmental
characteristics to customers who value such matters does not presume a need to incur the
I
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STUDY FRAMEWORK l5 SEPTEMBER 30,2O2I
I
I
I
expense of acquiring formal Renewable Energy Certification by a third party. Idaho
Power billing records should provide sufficient accuracy and detail.
ISON: Environmental impact must include land use costs and economic impact costs
related to utility scale generation versus customer-generators, specifically rooftop
applications. The current and future cost of occupying land for 25+ years needs to be
added to the study to accurately provide value to kWh's generated by using existing roof
space.
ISON: "Other benefits" must include the inherent value of increased reliability of a
distributed generation system, including the potentialvalue of power provided locally
through customer-generators with storage might provide sufficient power to operate
micro-grids in various locations during emergencies which would otherwise result in
extended blackouts LE. Texas in February of202l.
ISON: "Other benefits" must include the potential value customer-owned generators
could potentially provide to compliment hydro generation during a drought. During
drought the value of solar power increases, which should be included as a benefit
provided as a rate option during low hydro production if created by customers.
Boise City: Quantifu the value of grid stability, resiliency, and cybersecurity protection
provided by customer generators at each penetration level (current levels, l0x, and 25x).
Boise City: Quantif the value to local public health and safety from reduced local
impacts of global warming such as extreme temperatures, reduced snowpack variation,
reduced wildfire risk, reduced hydroelectric generation, degraded air quality, and other
impacts that can have direct impacts on Idaho Power customers at each penetration level
(current levels, l0x, and 25x).
Boise City: Quantifi the reduced risk from end-of-life disposal concerns for the
Company compared to fossil-fueled resources at each penetration level (current levels,
l0x, and 25x).
Boise City:Quantifu lodaleconomic benefits, including local job creation and increaied
economic activity in the immediate service territory at each penetration level (current
levels, l0x, and 25x).
a)Recommend Idaho Power incorporate the IMPLAN model analysis as completed
in Maryland's 2018 Cost and Benefits of Solar study completed by Daymark.
Methodology detailed at I 7 I - I 80. lrff ps://rvww. psc. state. rn d. us/rvp-
content/uploads/M D-Costs-and-Benefits-of-Solar-Draft-for-stakeholder-
review.pdf
STUDY FRAMEWORK 16 SEPTEMBER 30,2021
. ICL: This section should be in the Export Credit rate and not placed here as a side issue
. ICL: This section needs far more detail. Customer-exports that displace fossil fuels
reduce utility compliance costs imposed by the Clean Air Act regarding Sulfur-Dioxide,
Nitrous-Oxides, Mercury, and particulates. For years Idaho power has included carbon
costs in their resource planning to address the likelihood and impact of future carbon
limits, so the study must also examine the ability of customer-exports to reduce carbon
risks. Because these benefits are tied directly to the electric system and can increase as
the amount of clean energy added increases, the study should explore how growth in
customer-exports can increase this benefit over time.
18. Boise City - Additional Environmental and Other Areas to Study:
A. Quantifr the total avoided carbon emissions from on-site generators and the benefit
of avoided costs of compliance with carbon emissions regulation at each penetration
level (current levels, l0x, and 25x) and incorporating the following carbon costs:
i. 2021IRP Planning Case Carbon Cost.
ii. $5 I per metric ton of CO2 - 2020 social cost of carbon at 3oZ discount rate
from Interagency Working Group on Social Cost of Greenhouse Gases.
(htt ps://rvr,r rv.lvh itehouse. gov/r,i,p-
content/uploads/202 l/02/TechnicalSupportDocunrent_SocialCostofCarbonM
ethaneN itrousOxide.pdf at 5)
iii. $93 per metric ton of CO2- to achieve Net zero emissions by 2040 as
identified in Kaufman, N., Barron, A.R., Krawczyk, W. et al. A near-term to
net zero altemative to the socialcost of carbon for setting carbon prices.
(https://n rvw.nature.com/artic les/s4 I 5 5 8-020-0880-3 #citeas)
B. Quantifu the benefits from the following avoided environmental impacts of
distributed PV at each penetration level (current levels, l0x, and 25x):
i. Methane: Quantifu the avoided methane leakage from the displaced marginal
nafural gas resource, incorporating natural gas production, transmission rates
and intra-plant leakage/loss throughout. The Gas Index 2020 "Where Leaks
Occur" report identified 338 grams methane per Mcf natural gas through the
production and distribution systems to Boise. Utilizing the identified total
methane leakage avoided from distributed PV, quantiff the avoided social
cost of methane utilizing the February 202l lnteragency Working Group on
Social Cost of Greenhouse Gases reported $ 1 5 00 in 2020 dollars per metric
ton of CH4. (tttps:llwww.wnit
contenVuploads/202 I /02/Techn ical SupportDocument_Soc ialCostofCarbonM
ethaneN itrousOxide.pdf at 5)
ii. Water: Quantifr the avoided acre feet and cost of water from decreased water
use required for electric generation as Crossborder Energy quantified in
STUDY FRAMEWORK t7 SEPTEMBER 30,2021
Arizona Public Service costs and benefits of distributed generation study
(https://rvwrv.seia.org/sites/defaul t/fi les/resources/AZ-Di stributed-
Generation.pdf at 12).
iii. Land: Quantiff the land use required per MW of utility scale solar generation
in an acre/I4W calculation. Utilizing 2021 IRP preferred portfolio, quantiff
potential for avoided land costs and acres preserved by distributed PV
compared to planned utility scale solar deployment.
C. Utilizing the 2021 IRP Climate Change scenario with increased hydro variability year
over year, high gas price, and high load groMh, quantifu the avoided costs at each
penetration level (current levels, l0x, and 25x) ofdistributed energy resources.
Imnlementation Issues
Billing Structure
19. Explain how potential eustomer-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.
' Staff: In the study, please provide plans the Company intends to take in order to display
this information for potential customer generators and on-site generation system
installers.
' Tidwell: An automatic application of credits to production should occur monthly without
an on-site generator being tasked to manually request such application. Idaho Power has
the billing software capabilities to apply these credits in an automated way.
. ICEA: Residential Solar Energy System Disclosure Act I 182 - This was a law passed in
2019, supported by Idaho Power, that requires solar companies to meet certain
requirements when selling solar systems. There needs to be an evaluation on any
suggested changes to the ECR and net metering process to ensure that solar installers are
capable of meeting the requirements of this Law. The ability to inform potential
customers of the true value of on-site generation and the ECR's associate with it, both
ethically and accurately, is imperative.
. ICEA: The information and data provided by the Company cannot be so complicated that
the consumers or installers can't make sense of the information or process.
' ICEA: Who gets to determine what the expected life of a system is? It needs to be clear if
the expected life ofthe system is based on the solar panels, inverters, or any other
necessary component of the system.
STUDY FRAMEWORK l8 SEPTEMBER 30,2021
20. Boise City: Explain how seasonal and time-of-delivery price diflerences will be used to help
align customer generated exported energy with the Company's system needs at each penetration
level (current levels, l0x, and 25x).
Export Credit Expiration
21. Quantif the magnitude, duration, and value of accumulated export credits.
. Staff: If the Company should change the base actual data in any way, (i.e., normalizing
the data) please provide the analysis on both before and after the data was altered.
22. Explain the need for the credits to expire.
. Staff: In the study, please explain how export credits willbe properly tracked if
export credits expire.
. Staff: The study should determine how credits based on kWh vs. a dollar value
based on avoided cost will affect the need for policies regarding credit expiration.
. Staff: Please explain how excess credits will be handled at end of the expiration
period.
. ISON: Credits do not need to expire, the study should determine if the profit
recovered from the initial sale receives more benefit, interest and subsidies in
favor of the company. We suggest changing to "Explain if there is or is not a
need for the credits to expire." Further, there is a potential cost to the customer
for generating power which cannot be exchanged for direct compensation. Profits
from a public utility should be provided directly to the customer-generator
instead of only being carried as credit for future use.
. ICEA: Any examination of whether to expire credits must examine whether this
policy choice has an unfair impact on the majority of system owners due to the
circumstances of a few system owners.
. ICEA: If credits expire this would encourage customers to use more energy to
consume the accumulated credits prior to expiration. The study should examine
this impact. By allowing the credits to expire there would be no incentive for
consumers to design systems for future purchase, such as electric cars, which is
contradictory to other state initiatives such as the electrification of transportation.
a) Show how the Company does or does not benefit from the expiration of customer export
credits.
STUDY FRAMEWORK l9 SEPTEMBER 30,2O2I
. Staff: If the Company collects money from the customer base for the credits
awarded and those credits expire before the Company has to pay them, please
explain how this may or may not constitute a taking.
. Staff: Please explain how the Company will handle expired credits that have
been recovered from customers.
. ICEA: The study should also show how the customer does or does not benefit
from the expiration of export credits. Credits represent value provided to the
company, a kwh, the company then sold to a neighbor at the retail rate. The
study should examine the impacts of having these credits expire without
compensating the customer for the value of the credit. It should not be up to the
Company to determine if this value has an expiration date, that value belongs to
the customer and it is up to their discretion on when, how or if they use the value
they are owed for their net excess energy.
b) Show how non customer-generators are harmed or benefited from the expiration of
customer export credits.
i. Quantifr, the impact to non customer-generators of aZ-year,S-year, and l0-year
expiration period.
. Staff: Please show how credits that have been billed for are returned to
customers.
. ICEA: This study is to determine the value of an ECR not to determine
the duration on which the export has value.
Frequency ofExport Credil Rate Updates
23. Quantifu the impact of biennial updates as compared to annual updates of the ECR.
. Stalf: Please explain the process, case, or mechanism (e.g., IRP, separate case, etc.) that
ECR updates will be determined. Please identifu and examine if updates will be based
off a regular schedule or if there are specific triggers that could be identified signaling the
need for a change in the ECR.
. ICL: The Study should consider whether establishing a timeline for updates in this one
area is fair, just and reasonable when there is no similar timeline for updating the
Company's overall electric rates. The Study should consider how the timing of updates
impacts the ability of customers to make informed decisions about a product that lasts for
20 years or more. The Study should consider how the timing of updates impacts
STUDY FRAMEWORK 20 SEPTEMBER 30,2021
customer-owned system providers to provide rigorous information and informed
forecasts to their potential customers.
ICEA: If the ECR is updated too frequently, there would be no way for companies to
provide an assumed future value of the export credit rate. If it is believed that a frequent
update is necessary, then the Company should be required to provide projections for such
update to offer providers of on-site generation with usable data to comply with the law.
We believe that these updates, at a bare minimum, need to be connected to the IRP
process.
ICIP: Off-site Non-Exnof
24. ICIPz Analyze Feasibility of off-site Non-Exporting net metering facilities (Please see Comments
from ICIP for additional comments on the case).
a) Analyze how DER energy could be credited to the physical site of the DER's actual load
i. Determine if credited DER energy would be used to offset customer's load in
real time or over a predetermined time period (e.g., month , laa;r, or billing
period)
b) Analyze whether customers with multiple accounts/meters/locations would be able to
amalgamate its disparate load locations for purposes of consuming the load from a single
or multiple off-site DERs
c) For use of the Company's transmission and distribution system:
ii. Determine how the Company would be Compensated for its use
iii. Determine impacts of customers using transmission and distribution system for
off-site DER
d) Analyze physical (e.g., engineering) or legal limitations of off-site DERs
25. Boise City - Additional Areas to Study:
A. Utilize consistent and reasonable penetration levels of on-site generation throughout
study. Current levels, l0x, and 25x would be appropriate.
B. Quantifi, and evaluate the customer generator capacity resource value for customer
generators with 4 hours of available on-site energy storage at the penetration levels
indicated above according to the method agreed to for calculating capacity payments
in the IPC-E-18-15 settlement agreement and according to ELCC value.
C. Quantiff and evaluate the customer generator capacity resource value for solar PV
customer generators at the penetration levels and according to the method agreed to
STUDY FRAMEWORK 2t SEPTEMBER 30,2021
for calculating capacity payments in the IPC-E- I 8- I 5 settlement agreement and
according to ELCC value.
D. Using the method to calculate the avoided cost of energy agreed to in the IPC-E- l8-
l5 settlement agreement, compare the avoided cost of energy rates a customer-
generator would have received given a typical rooftop solar PV output profile in
southern Idaho, with the cost of the Company's actual marginal resource for each
hour ofthe year in 2018,2019, and2020.
26. Tldwell - Comments:
a) Please see Comments from Kiki Tidwell for additional comments on the case.
b) Provide studies on the benefits to the grid and to all ratepayers when onsite generation
and micro-grids can reduce load at peak power demands.
c) This study should be designed to focus on how to encourage more distributed generation,
more sharing of electrons and credits with workforce or low-income customers, and more
benefit to all Idaho ratepayers through microgrids which would alleviate the need for
expensive and under-utilized peaker plants.
d) Study the physical constraints of existing rules for on-site generators in multifamily
buildings.
e) Please provide updated facts and data about total on-site generation information.
Respecttully submitted this 3O-+^tof Septemb er 2021
Erick Shaner
Deputy Attomey General
Technical Staff: Taylor Thomas
i:uimisc:comments/ipce2 1.21 estt framework
STUDY FRAMEWORK 22 SEPTEMBER 30,2021
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 30th DAY OF SEPTEMBER 2021,
SERVED THE FOREGOING STUDY FRAMEWORK FOR PARTY COMMENTS, IN
CASE NO. IPC-E-21-21, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
LISA NORDSTROM
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: [e-mail]
[e-mail]
PETER J RICHARDSON
RICHARDSON ADAMS PLLC
515 N 27TH STREET
BOISE TD 83702
E-MAIL : [e-mail]
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
7IO N 6TH ST
BOISE ID 83702
E-MAIL: [e-mail]
RICHARD E. KLUCKHOHN
WESLEYA. KLUCKHOHN
2564W. PARKSTONE DR.
MERIDIAN ID 83646
E-MAIL : [e-mail]
KELSEY JAE
LAW FOR CONSCIOUS LEADERSHIP
920 N CLOVER DR
BOISE ID 83703
CONNIE ASCHENBRENNER
IDAHO POWER COMPANY
PO BOX 70
BOrSE ID 83707-0070
E-MAIL: [e-mail]
DR DON READING
6070 HILL ROAD
BOISE ID 83703
E-MAIL: [e-mail]
ED JEWELL
DEPUTY CITY ATTORNEY
BOISE CITY ATTORNEYS OFF
PO BOX 500
BOrSE rD 83701-0500
E-MAIL: [e-mail]
eiewel fboise.ors
MICHAEL HECKLER
COURTNEY WHTTE
CLEAN ENERGY OPPORTUNITIES FOR
IDAHO
3778 PLANTATION DR, SUITE 102
BOISE ID 83703
E-MAIL:
nl com
courtney @cl eanenersyopportunities.corn
JIM SWIER
MICRON TECHNOLOGY INC
8OO SOUTH FEDERAL WAY
BOISE ID 83707
E-MAIL: [e-mail]-MAIL: kelsey ae.com
CERTIFICATE OF SERVICE
AUSTIN RUESCHHOFF
THORVALD A NELSON
AUSTIN W JENSEN
HOLLAND & HART LLP
555 17TH ST STE 32OO
DENVER CO 80202
E-MAIL: [e-mail]
tne I son @ho I I anclhart. co m
awi ensen@)ho I I andhart. com
[e-mail]
sl llandhart.com
KEVIN KING
P .O.8OX2264
BOISE rD.83702
E-MAIL: staff@[e-mail]
KIKI LESLIE A. TIDWELL
704 N. RIVER ST. #I
HAILEY ID 83333
E-MAIL: ktinsr,@cox.net
GEORGE STANTON COMET ENERGY
LLC
13601 W. MCMILLAN RD.
STE IO2 PMB 166
BOISE ID 837I3
E-MAIL: [e-mail]
TYLER GRANGE IDAHOME SOLAR
2484 N. STOKESBERRY PL. #1OO
MERIDIAN ID 83646
E-MAIL : [e-mail]
C. TOM ARKOOSH
ARKOOSH LAW OFFICES
9I3 W RIVER STREET SUITE 450
PO BOX 2900
BOISE ID 83701
E-MAIL [e-mail]
[e-mail]
JOSHUA HILL
IDAHO SOLAR OWNERS NETWORK
1625 S. LATAH
BOISE,ID 83705
P.O. BOX 8224
BOISE ID 83707
E-MAIL [e-mail]
tottens @,amsid aho. com
ERIC L. OLSEN
ECHO HAWK & OLSEN, PLLC
505 PERSHING AVE., STE. IOO
PO BOX 6l 19
POCATELLO ID 83205
E-MAIL: elo@,echohawk.com
RYAN BUSHLAND
ABC POWER CO. LLC
184 W. CHRISFTELD DR.
MERIDIAN ID 83646
E-MAIL : [e-mail]
J",/D-,"Y/-SECRETAR
CERTIFICATE OF SERVICE