HomeMy WebLinkAbout20211202Williams Direct.pdf
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY’S APPLICATION TO EXPAND
OPTIONAL CUSTOMER CLEAN ENERGY
OFFERINGS THROUGH THE CLEAN
ENERGY YOUR WAY PROGRAM.
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CASE NO. IPC-E-21-40
IDAHO POWER COMPANY
DIRECT TESTIMONY
OF
ALISON WILLIAMS
Williams, DI 1
Idaho Power Company
Q. Please state your name, address, and present 1
occupation. 2
A. My name is Alison Williams. My business 3
address is 1221 West Idaho Street, Boise, Idaho 83702. I 4
am employed by Idaho Power as the Regulatory Policy and 5
Strategy Advisor. 6
Q. Please describe your educational background. 7
A. In June 2003, I received a Bachelor of Arts 8
degree in Political Science from the University of 9
California at Davis. In May 2009, I earned a Master of 10
Public Policy degree with a concentration in energy and 11
natural resource economics from the American University's 12
School of Public Affairs in Washington, DC. In addition, I 13
have attended the electric ratemaking courses “Basics: 14
Practical Regulatory Training for the Electric Industry,” 15
offered through New Mexico State University's Center for 16
Public Utilities and the Edison Electric Institute's 17
(“EEI”) “Electric Rates Advanced Course,” hosted by the 18
University of Wisconsin Madison's Wisconsin Public Utility 19
Institute. 20
Q. Please describe your work experience with 21
Idaho Power Company. 22
A. I joined Idaho Power in December 2019. As 23
the Regulatory Policy and Strategy Advisor, my primary 24
Williams, DI 2
Idaho Power Company
responsibilities include providing regulatory support and 1
strategic guidance to business units on a variety of 2
topics, including clean energy offerings, integrated 3
resource planning, distribution system planning, large 4
customer pricing, and energy and utility policy. 5
Prior to joining Idaho Power, I served as the Senior 6
Director of State Energy and Regulatory Policy at EEI, the 7
trade association for the nation's investor-owned electric 8
utilities. Prior to EEI, I was the Vice President of Energy 9
Services at Garten Rothkopf consulting, where I provided 10
business strategy and economic consulting to electric 11
utilities and companies in energy-intensive industries. 12
Additionally, I previously served as an analyst at 13
the U.S. Department of Energy, conducting energy system 14
modeling to advise on Department policy and budget 15
decisions. Other work experience includes energy market 16
financial analysis for Bloomberg Government, and energy and 17
environmental research at the World Resources Institute and 18
the Wilson Center, both located in Washington, DC. 19
Q. What does the Company request in this case? 20
A. The Company is requesting that the Idaho 21
Public Utilities Commission (“Commission”) authorize the 22
modification of its tariff Schedule 62 – Green Energy 23
Purchase Program Rider (Optional) (“Schedule 62”) and 24
Williams, DI 3
Idaho Power Company
approve a regulatory framework for a future voluntary 1
subscription-based green power service offering. 2
Specifically, the Company seeks approval to: (1) 3
rename the existing Schedule 62 to the Clean Energy Your 4
Way Program, (2) maintain and expand procurement options 5
for the renewable energy certificate1 (“REC”) offering 6
under the name Clean Energy Your Way - Flexible, (3) 7
establish a regulatory framework for a future optional 8
subscription green power service offering named Clean 9
Energy Your Way - Subscription, (4) offer a tailored 10
renewables option to the Company’s largest customers 11
(Special Contract and Schedule 19, Large Power Service) 12
named Clean Energy Your Way – Construction, and (5) 13
procure associated program renewable resources outside of 14
the Commission’s current competitive bidding procurement 15
requirements. 16
The Company respectfully requests the Commission 17
establish a schedule that could lead to approval of the 18
elements proposed in this Application by April 2022. 19
Q. What is the significance of receiving Company 20
approval by April 2022? 21
1 The U.S. Environmental Protection Agency defines a renewable energy
certificate as “a market-based instrument that represents and conveys
the property rights to the environmental, social and other non-power
attributes of renewable electricity generation”.
https://www.epa.gov/sites/default/files/2020-06/documents/3.0b-solar-
claims-and-renewable-energy-certificates.pdf
Williams, DI 4
Idaho Power Company
A. The Commission’s approval to offer the 1
proposed Clean Energy Your Way program is the first step in 2
a multi-step process. New renewable resources will be 3
required for implementation of both the Subscription and 4
Construction offerings, and resource selection and 5
construction will add 18 months or more to the date when 6
customers can begin claiming renewable energy use. 7
Many of Idaho Power’s customers have stated clean 8
energy objectives—some with targets as early as 2025. Given 9
the broad customer and stakeholder support for the 10
offerings as described in my testimony, the Company 11
believes its request for an April 2022 decision is a 12
reasonable date that will keep the proposed offerings on 13
track to deliver clean energy to customers in the desired 14
timeframe. 15
Q. How is your testimony organized? 16
A. My testimony is organized as follows: 17
First, I provide the background on the factors 18
leading to this filing, as well as history related to the 19
Company’s renewable energy activities. Second, I provide an 20
overview of the customer outreach that ultimately informed 21
the proposed new offerings. Third, I discuss the proposed 22
modifications to the existing Schedule 62 offering, Clean 23
Energy Your Way – Flexible. Lastly, I provide a detailed 24
description of the two new proposed program offerings: 25
Williams, DI 5
Idaho Power Company
Clean Energy Your Way – Subscription and Clean Energy Your 1
Way – Construction. 2
Q. Are you sponsoring any exhibits? 3
A. Yes. I am sponsoring the following exhibits: 4
Exhibit No. 1 - Clean Energy Your Way – 5
Subscription Proposed Program Parameters; and 6
Exhibit No. 2 – Customer Bill Mock-up for Clean 7
Energy Your Way – Subscription Participant. 8
I. BACKGROUND 9
Q. What led the Company to consider modifying and 10
expanding the offerings under tariff Schedule 62? 11
A. As of January 2021, customers enrolled in the 12
Company’s existing Green Power Program have purchased 13
355,393,513 kilowatt-hours (“kWh”) of renewable energy 14
through the program — the equivalent of avoiding 254,751 15
tons of carbon dioxide or removing 45,733 cars from the 16
road since the Program’s inception 20 years ago, according 17
to the U.S. Environmental Protection Agency’s Greenhouse 18
Gas Equivalencies Calculator. 19
While the Green Power Program has met many 20
customer’s needs to date, Idaho Power recognizes that 21
customer preferences and desires have shifted in recent 22
years, with a growing number of customers seeking 23
additional clean energy offerings. In response to customer 24
requests and feedback, and in consultation with individual 25
Williams, DI 6
Idaho Power Company
customers, Idaho Power set out to design a “menu” of clean 1
energy offerings that would appeal to customers of all 2
sizes and seeking a variety of clean energy objectives, 3
while also holding non-participants harmless. 4
Q. How long has Idaho Power been working on 5
developing new clean energy offerings for customers? 6
A. The Company has spent more than two years 7
conducting customer and stakeholder outreach, as well as 8
doing industry research, on new clean energy programs for 9
customers. As a result of this research and engagement, 10
Idaho Power has developed a three-pronged offering that 11
builds off the successful foundation of the Green Power 12
Program to include a new subscriber-based option and a 13
tailored renewable energy offering for customers seeking 14
renewable resources to accomplish their sustainability 15
goals. To reflect the Company’s new clean energy 16
opportunities, Idaho Power proposes the name “Clean Energy 17
Your Way” to house the three options: Clean Energy Your 18
Way - Flexible (REC offering), Clean Energy Your Way – 19
Subscription (individual subscriber offering), and Clean 20
Energy Your Way - Construction (large customer offering). 21
Q. What has Idaho Power done to support and 22
provide renewable energy options for its customers? 23
A. Idaho Power has long supported customers’ 24
individual goals and initiatives to achieve clean energy 25
Williams, DI 7
Idaho Power Company
offerings through efforts like the Green Power Program and 1
the Company’s 2017 Community Solar Pilot Program. 2
Additionally, in March 2019, Idaho Power enhanced 3
its commitment to the customers and communities it serves 4
by becoming one of the first investor-owned utilities to 5
proactively establish a 100 percent clean energy goal by 6
2045. Idaho Power’s “Clean Today. Cleaner Tomorrow.®” 7
initiative builds off the Company’s foundation of clean 8
energy—primarily attributable to its vast dispatchable 9
hydropower network.2 Background on these three efforts is 10
offered below to provide additional background and context 11
around Idaho Power’s decision to develop new clean energy 12
opportunities for customers. 13
Green Power Program 14
Q. Please describe the history of the Green Power 15
Program. 16
A. Formally known as the Green Energy Purchase 17
Program and operating under the Company’s Schedule 62 18
tariff, the Green Power Program is an easy, flexible, and 19
voluntary offering that allows customers to purchase 20
renewable energy in the form of RECs. 21
The program was initially designed to stimulate the 22
demand of electricity generated from renewable resources. 23
2 Approximately 41.7 percent of Idaho Power’s generation was comprised
of hydroelectric generation in 2020. https://www.idahopower.com/energy-
environment/energy/energy-sources/
Williams, DI 8
Idaho Power Company
Now, 20 years since the program’s launch, this demand has 1
been realized, with an increasing number of customers 2
seeking ways to meet clean energy objectives. 3
Q. How has the Company modified the Green Power 4
Program since its original offering? 5
A. In an early version of the Green Power 6
Program, customers specified the dollar amount they wished 7
to add to their monthly electric bill to purchase renewable 8
energy. In 2016, the Company modified its offering3 to 9
allow for either purchasing 100 kilowatt-hours (kWh) 10
“blocks” of renewable energy or by purchasing amounts equal 11
to 100 percent of a customer’s monthly energy use. The 12
Company also modified the Program to seek Green-e® Energy 13
certification of RECs—an important certification to verify 14
the attributes and ownership of RECs and marketing 15
accuracy. Additionally, a large-quantity REC option was 16
developed for business customers to purchase a customized 17
REC portfolio supported by local wind, solar, hydro and 18
geothermal projects. 19
Q. Does participation in the Green Power Program 20
support additional renewable initiatives? 21
A. Yes. When customers support the Green Power 22
Program, they also support the Solar 4R Schools education 23
3 In the Matter of Idaho Power Company’s Application to Modify Option
Schedule 62, Green Energy Purchase Program Rider, Case No. IPC-E-16-13,
Order No. 33570 (Aug 29, 2016).
Williams, DI 9
Idaho Power Company
program. Solar 4R Schools is a grant program that awards 1
schools (K-12) in Idaho Power’s service area with a small 2
solar array and energy education kits that can be 3
incorporated into the school’s curriculum. Grant 4
recipients are chosen in part because they have 5
demonstrated a commitment to energy education, energy 6
efficiency, a broader dedication to sustainability, and the 7
ability to involve their district and community. To date, 8
the Solar 4R Schools component of the Green Power Program 9
has awarded grants to 23 schools across 10 counties in 10
Idaho with the following achievements: 11
More than 7,700 Idaho students reached; 12
More than 50 kilowatts (“kW”) of solar 13
panels installed at schools; 14
760 hours of training completed; and 15
152 teachers trained. 16
Q. Is the Company proposing any modifications to 17
Solar 4R Schools? 18
A. Not at this time. Idaho Power’s REC program 19
will continue to support renewable demonstration projects 20
at schools. Such renewable demonstration projects will 21
remain exclusive to the Company’s REC purchase offering. 22
23
Williams, DI 10
Idaho Power Company
Community Solar Pilot Program 1
Q. Please provide an overview of the Company’s 2
Community Solar Pilot Program (“Pilot Program” or “Pilot”). 3
A. On June 22, 2016, in response to increasing 4
customer interest in the Company developing a community 5
solar program, Idaho Power filed an application with the 6
Commission requesting approval of a new tariff Schedule 63, 7
Community Solar Pilot Program. The Company proposed to 8
build a 500 kW single-axis tracking community solar array 9
in southeast Boise, to which Idaho Power customers could 10
voluntarily subscribe to the generation output. 11
Parties to the case agreed to a settlement, which 12
was ultimately approved by the Commission on October 31, 13
2016. In Order No. 33638 approving the Settlement 14
Stipulation, the Commission stated: 15
“The record demonstrates that 16
there is great interest and enthusiasm 17
for the Company's proposed Community 18
Solar Pilot Program. The issues raised by 19
the parties were valid concerns that 20
touch on the viability of the project 21
itself. We find that the resolutions 22
reached in the Settlement Stipulation 23
represent fair and reasonable 24
compromises intended to help the proposed 25
pilot program succeed. We further find 26
that pilot programs such as that proposed 27
here, on a small-scale, are valuable for 28
learning what works and what does not, to 29
inform future projects with similar 30
offerings… finding that it is just, fair 31
Williams, DI 11
Idaho Power Company
and reasonable, and in the public 1
interest.”4 2
3
Q. Was the Pilot Program successful? 4
A. The Pilot was valuable as a learning 5
experience for Idaho Power. Although the Company marketed 6
it widely — including awareness marketing reaching all 7
customers and highly targeted approaches reaching customers 8
most likely to subscribe — the Pilot never achieved greater 9
than 15.3 percent enrollment. On February 1, 2019, the 10
Company requested to suspend the Pilot Program, citing 11
insufficient enrollment.5 12
Q. What did the Company learn about customer 13
preferences as a result of the Pilot? 14
A. In March 2017, six months after the Pilot 15
launched, Idaho Power surveyed customers6 to solicit 16
feedback on the Pilot. Survey responders interested in 17
community solar listed the two main barriers to subscribing 18
as (1) the overall cost of the subscription and (2) concern 19
4 In the Matter of Idaho Power Company’s Application to Approve New
Tariff Schedule 63, A Community Solar Pilot Program, Case No. IPC-E-16-
14, Order No. 33638 at 10 (Oct 31, 2016).
5 Idaho Power Company’s 2019 Community Solar Annual Report, Case No.
IPC-E-16-14 (Feb 1, 2019); Advice No. 19-02, Suspension of Schedule 63,
Community Solar Pilot Program (Optional), (approved and effective Apr
26, 2019).
6 In addition to contacting individual customers, Idaho Power surveyed
its Empowered Community of customers and received a 65 percent response
rate. The Empowered Community is an online panel of nearly 3,000 Idaho
Power residential customers who have agreed to participate in periodic
online surveys and provide feedback to the Company.
Williams, DI 12
Idaho Power Company
that they may not recover the initial investment. 1
Similarly, survey responders not interested in community 2
solar listed the same two barriers as the main reasons they 3
were not considering subscribing. 4
Additionally, the Company’s Energy Advisors undertook 5
a large effort to contact business customers about the 6
potential to participate in the Pilot. They completed more 7
than 300 one-on-one interactions, but only 1 percent of 8
these customers said they were interested in the Pilot; the 9
main reasons cited were Pilot costs. 10
Overall, the survey and business customer feedback 11
revealed that the common concerns about the Pilot were the 12
cost to participate and the return on investment. These 13
financial considerations informed development of the 14
proposed new clean energy offerings. 15
Idaho Power’s Clean Energy Goal 16
Q. What is the Company’s clean energy goal? 17
A. Idaho Power’s “Clean Today. Cleaner 18
Tomorrow.®” goal sets a target of 100 percent clean energy 19
by 2045. This goal mirrors sentiments from Idaho Power’s 20
customers and communities that a cost-effective glide path 21
toward clean energy is vital to reduce carbon emissions and 22
a logical corporate approach given industry advancements 23
Williams, DI 13
Idaho Power Company
that make many renewable energy technologies more 1
affordable. 2
Q. Is Idaho Power’s clean energy goal consistent 3
with least-cost, least-risk planning? 4
A. Yes. Idaho Power believes its 2045 goal is 5
achievable without compromising the critical attributes of 6
cost and reliable service the Company has delivered 7
consistently throughout its 105-year history. Recent and 8
planned milestones7 toward achieving the 2045 goal while 9
focusing on maintaining reliability and affordable prices 10
for customers include: 11
Exits from one coal-fired generating unit at Valmy 12
in 2019 and the Boardman coal-fired power plant in 13
2020, and strategic plans to move away from 14
remaining coal-fired generation by 2030; 15
Planned investments in solar, wind, and battery 16
resources; and 17
Expansion of clean energy pipelines such as the 18
planned Boardman to Hemingway transmission line, 19
which will facilitate the movement of clean energy 20
resources throughout the Pacific Northwest. 21
7 Idaho Power Company’s Second Amended 2019 Integrated Resource Plan,
Case No. IPC-E-19-19 (Oct 2020).
Williams, DI 14
Idaho Power Company
Q. Does the Company’s Clean Energy Goal align 1
with customer views? 2
A. Idaho Power’s clean energy objectives are 3
shared by a growing number of customers and communities in 4
Idaho. These customers have been vocal about their own 5
climate- and clean energy-related goals, and the desire to 6
work with Idaho Power to meet their clean energy 7
objectives. In particular, commercial, industrial, and 8
municipal customers are increasingly pursuing or exploring 9
sustainability targets, such as powering their operations 10
on 100 percent renewable energy by the end of the decade—if 11
not sooner. 12
Q. Do Idaho Power customers’ clean energy goals 13
align with national clean energy trends? 14
A. Yes. Idaho Power customers are not alone in 15
pursuing clean energy goals. Across the United States, 60 16
percent of Fortune 500 companies and 76 percent of Fortune 17
100 companies have established climate or energy-use 18
targets to decrease their carbon footprint.8 Entities such 19
as the RE100,9 Renewable Energy Buyer’s Alliance,10 and the 20
U.S. Department of Energy’s Clean Cities Coalition Network11 21
8 https://www.worldwildlife.org/stories/fortune-500-companies-are-
acting-on-the-climate-crisis-but-is-it-enough
9 https://www.there100.org/
10 https://rebuyers.org/
11 https://cleancities.energy.gov/coalitions/
Williams, DI 15
Idaho Power Company
provide a visible, public platform for companies and 1
communities to hold themselves accountable in achieving 2
aggressive targets on behalf of their customers, 3
shareholders, key stakeholders, and constituents. Pursuing 4
renewable energy or climate targets has become a widely 5
expected corporate social responsibility pillar for many 6
companies—both large and small. 7
Q. Are federal and state mandates driving Idaho 8
Power’s customers to adopt clean energy targets? 9
A. No. Despite the lack of a federal or state 10
climate or renewables policies, Idaho businesses and 11
municipalities are not immune from customer or constituent 12
pressure or may simply have the desire to adopt 13
sustainability goals. With this reality in mind, Idaho 14
Power has worked with customers to leverage the tools at 15
its disposal—namely, the existing Green Power Program. 16
Several Idaho Power customers, including the Boise Co-op,12 17
Bogus Basin,13 POWER Engineers,14 and Bigelow Tea,15 have 18
12 https://www.boise.coop/blog-recipes-1/boise-co-op-goes-100-renewable-
686aw#:~:text=We%20are%20so%20excited%20to,here%20in%20the%20beautiful%
20northwest.
13 https://www.ktvb.com/article/news/local/bogus-basin-to-switch-to-100-
percent-renewable-energy-in-2020/277-dd58d2c4-e401-4377-a4c8-
0750b9a35f2c
14 https://www.powereng.com/library/powers-idaho-offices-go-renewable
15 https://bigelowteablog.com/2020/01/17/100-renewable-energy-100-
bigelow-tea/
Williams, DI 16
Idaho Power Company
publicly announced partnerships with Idaho Power to achieve 1
their respective renewable energy targets. 2
Q. Do Idaho Power’s customers need additional 3
offerings to meet their clean energy targets beyond what 4
the current Green Power REC purchase option provides? 5
A. Yes. The purchase of RECs is an acceptable 6
strategy for many Idaho Power customers, but RECs do not 7
meet the needs of all customers due to limited 8
availability, lack of long-term commitment, and—critically—9
the inability of RECs to help customers achieve a “net new” 10
resource to meet their renewable energy goals (i.e., so-11
called “additionality” of a new wind or solar resource that 12
does not currently exist on Idaho Power’s system). 13
Based on this feedback from customers and lessons 14
learned from the Pilot Program, Idaho Power explored new 15
clean energy offerings. In the section below, the Company 16
details its customer and stakeholder outreach efforts, as 17
well as the lessons learned, that informed the offerings 18
proposed in this filing. 19
II. CUSTOMER OUTREACH TO INFORM CLEAN ENERGY OFFERINGS 20
Q. What prompted the Company to further 21
investigate potential new clean energy offerings after 22
suspension of the Pilot Program? 23
Williams, DI 17
Idaho Power Company
A. During the past two years, Idaho Power focused 1
efforts to better understand the needs of its customers 2
interested in clean or renewable energy. The Company 3
strategically sought input from three segments of 4
customers: (1) customers who expressed interest in the 5
Pilot Program; (2) existing Green Power Program customers, 6
as well as customers who inquired but ultimately determined 7
that RECs did not meet their needs; and (3) customers with 8
established clean energy goals, renewable energy targets, 9
and/or carbon reduction goals. 10
Q. What was the result of the various customer 11
outreach efforts? 12
A. As a result of customer conversations, Idaho 13
Power determined that customers are generally seeking the 14
following attributes in expanded clean energy programs: 15
broader availability of offerings that work for small and 16
large businesses alike; longer and shorter-term renewable 17
energy opportunities; and access to new renewable resources 18
that they can count toward specified renewable or 19
sustainability objectives. 20
More specifically, the key themes from Idaho Power’s 21
customer conversations can be summarized as follows: 22
Accessibility: Customers of all sizes—from 23
residential to large industrial—should be able to 24
access expanded clean energy offerings. 25
Williams, DI 18
Idaho Power Company
Additionality: Expanded clean energy offerings 1
should focus on new resources to Idaho Power’s 2
system. 3
Affordability: Clean energy offerings must be 4
available at an affordable cost. 5
Flexibility: Customers would like to tailor clean 6
energy offerings to fit their needs, including the 7
possibility of leveraging multiple programs to 8
achieve corporate clean energy goals. 9
Q. Were there additional considerations for 10
expanded program offerings? 11
A. Yes. Timing is also an important 12
consideration, as several Idaho Power customers have 13
established 100 percent clean or renewable energy goals 14
that they hope to achieve in the 2023-2024 timeframe. One 15
specific example is a public goal stated by the City of 16
Boise, which outlined a strategy in the Boise’s Energy 17
Future16 plan to achieve 100 percent clean energy for city-18
owned facilities by 2030, and 100 percent clean energy for 19
all residents of the City of Boise by 2035. In both cases, 20
the City of Boise is seeking solutions—including from Idaho 21
Power—to accelerate those timelines. Another Idaho Power 22
16 https://www.cityofboise.org/departments/public-works/boises-energy-
future/
Williams, DI 19
Idaho Power Company
customer, Micron Technology, Inc., has established a goal 1
for 100 percent renewable energy across its U.S. 2
manufacturing operations by 2025.17 3
Q. Did Idaho Power conduct any industry research 4
on clean energy programs offered by other utilities? 5
A. Yes. The Company conducted an extensive review 6
of existing clean energy offerings by utilities across the 7
country, including successful customer programs in 8
Washington, Oregon, Utah, Colorado, Virginia, Kentucky, 9
Florida, and Georgia. 10
The Company also consulted with EEI and their State 11
Regulatory Affairs and National Customer Accounts 12
departments to better understand the electric industry 13
landscape for customer clean energy programs. 14
Q. How did the Company use customer feedback and 15
industry research to inform its proposed offerings? 16
A. Using general and specific suggestions from 17
customers, Idaho Power drafted two new options: a 18
subscription-style green tariff and a more detailed option 19
for large customers looking for new renewable resources. 20
The design of both new offerings was informed by 21
successful programs in other jurisdictions, notably Puget 22
17 https://www.globenewswire.com/en/news-
release/2021/04/22/2215178/14450/en/Micron-s-Sixth-Annual-
Sustainability-Report-Highlights-Progress-on-Goals-and-Unwavering-
Commitment-to-Innovation-and-Advancing-Society.html
Williams, DI 20
Idaho Power Company
Sound Energy’s Green Direct,18 Xcel Colorado’s 1
Solar*Connect,19 and Kentucky Utilities(“KU”)/Louisville Gas 2
& Electric’s (“LG&E”) joint Renewable Power Agreement.20 3
These utility customer programs all qualify as green 4
tariffs but have important programmatic distinctions. Idaho 5
Power leveraged these successful examples and “mix-and-6
matched” elements to design a comprehensive set of 7
offerings that will serve the needs of Idaho Power’s 8
customers. 9
For example, Xcel Colorado’s subscription-based 10
program allows residential participation, while Puget 11
Sound’s program does not. Based on customer feedback and to 12
appeal to Pilot Program participants, Idaho Power allows 13
residential participation in its proposed subscription 14
offering (detailed in the Application and below in the 15
Subscription section of this testimony). 16
KU/LG&E’s program is not a subscription-based 17
offering but a tailored renewables solution for their large 18
utility customers to purchase energy from a renewable 19
resource that delivers energy through the utilities’ 20
transmission and distribution system. Idaho Power looked 21
18 Puget Sound Energy’s (“PSE”) Green Direct program (docket UE-160977)
was approved by the Washington Utilities and Transportation Commission
in September 2016. PSE’s Schedule No. 139 governs the program.
19 Xcel Colorado’s Solar*Connect program (docket 16-A0055E) was approved
by the Colorado Public Utilities Commission in November 2019. Xcel’s
Schedule RC tariff governs the program.
20 https://lge-ku.com/renewable-power-agreement
Williams, DI 21
Idaho Power Company
closely at this model to inform its own large-customer 1
offering (detailed in the Application and below in the 2
Construction section of this testimony). 3
After developing straw program proposals, Idaho 4
Power sought input and feedback from Commission Staff 5
(“Staff”) and other stakeholders. 6
Commission Staff Meeting 7
Q. When did the Company meet with Staff and what 8
was the result of that conversation? 9
A. Idaho Power met with Staff on June 2, 2021, to 10
present the conceptual framework of the expanded clean 11
energy offering. In this conversation, Staff asked several 12
important questions that enabled Idaho Power to further 13
refine the program details. With respect to the 14
Subscription option, Staff was interested in how Idaho 15
Power would determine the size and cost of the new 16
renewable resource to meet the level of customer interest 17
and if the Subscription option would be self-supporting 18
(i.e., not shift costs to non-participating customers). 19
These details are addressed below in the Subscription 20
section of my testimony. 21
With respect to the large customer option, Staff was 22
primarily interested in understanding the mechanics of the 23
pricing structure. Additionally, Staff wanted to understand 24
how Idaho Power perceived the benefits the new resource(s) 25
Williams, DI 22
Idaho Power Company
would bring to Idaho Power’s system as a whole and is 1
addressed in the Construction section below. 2
Stakeholder Workshop 3
Q. How did Idaho Power seek feedback on the draft 4
clean energy offerings from other stakeholders? 5
A. On July 7, 2021, Idaho Power held a virtual 6
workshop with many of the Company’s key stakeholders to 7
present the conceptual framework of the expanded clean 8
energy offerings. Participants in the workshop included 9
Staff, Idaho Conservation League, Sierra Club, Clean Energy 10
Opportunities of Idaho, Northwest Energy Coalition, 11
Industrial Customers of Idaho Power, City of Boise, City of 12
Hailey, and Boise State University. 13
Q. What feedback did the Company receive from the 14
stakeholder meeting? 15
A. Stakeholders offered widespread support and 16
reemphasized the need for affordable clean energy programs 17
that could be accessed by all customer classes—from 18
residential to large industrial. Specific questions were 19
asked about ensuring equitable access to program offerings, 20
potential carve-outs for certain customers, and the 21
potential for low-income support. Additionally, 22
participants asked details about the Subscription option’s 23
potential resource (e.g., type, size) and asked when 24
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Idaho Power Company
detailed pricing would be available. These questions are 1
addressed in the Subscription section below. 2
III. NEW PROGRAM NAME: CLEAN ENERGY YOUR WAY 3
Q. Why is the Company requesting to re-name the 4
Green Power Program? 5
A. While the Green Power Program name is 6
established and known, it is typically associated with RECs 7
and does not convey the broader sustainability goals of 8
Idaho Power’s customers. To correct for these limitations, 9
Idaho Power seeks to rebrand its current offering with a 10
new, broader program name: Clean Energy Your Way. 11
The umbrella term of Clean Energy Your Way is 12
intended to communicate Idaho Power’s existing and proposed 13
new offerings. Additionally, the name change better aligns 14
with Idaho Power’s “Clean Today. Cleaner Tomorrow.®” goal. 15
Consistent naming and terminology will allow customers and 16
stakeholders to clearly connect the Company’s clean energy 17
goal and its associated programmatic activities and connect 18
it to their own clean energy objectives. 19
Q. Is the Company requesting additional changes 20
beyond the rebrand of the current program? 21
A. Yes. Specifically, Idaho Power is asking for 22
approval to change the following: (1) rename Schedule 62 23
Green Energy Purchase Program Rider (Optional) to Schedule 24
62 Clean Energy Your Way (Optional), (2) rename the Green 25
Williams, DI 24
Idaho Power Company
Power Program to Clean Energy Your Way – Flexible, and (3) 1
add the Clean Energy Your Way – Construction offering to 2
Schedule 62. These proposed tariff changes are included as 3
Attachment 1 to the Application. 4
As described more fully below, the Company also 5
seeks to establish a regulatory framework for a future 6
Clean Energy Your Way – Subscription option. While many 7
elements of this offering cannot be determined before a 8
program resource is identified, the Company seeks to 9
establish a general regulatory framework for the offering. 10
This framework includes the transaction structure for 11
participating customers and the parameters under which 12
Idaho Power would offer the program to customers. As such, 13
Idaho Power does not propose any Subscription option tariff 14
language at this stage. Rather, the Company offers a 15
description of program elements in Exhibit No. 1. 16
Q. Does the Company’s request align with the 17
feedback from Staff and Stakeholders and address the demand 18
for expanded program options? 19
A. Yes. The Company is confident that this new 20
“menu” of options under the Clean Energy Your Way banner 21
meets the needs of customers with clean energy goals and 22
will offer at least one option for every interested 23
customer. 24
Williams, DI 25
Idaho Power Company
Q. Will Idaho Power’s customers be allowed to 1
select multiple options to meet their energy objectives? 2
A. Yes. Idaho Power envisions that customers on 3
multiple service schedules and/or with more than one 4
account would be allowed to combine participation in these 5
programs to accomplish their clean energy objectives. 6
Customers most likely to seek participation in multiple 7
Clean Energy Your Way offerings are Idaho Power’s larger 8
customers—for example, a municipality with multiple 9
Schedule 19 accounts and smaller commercial accounts, and 10
potentially many residential accounts. A customer such as 11
this could assign different accounts to different programs: 12
participate in Clean Energy Your Way – Flexible for RECs 13
for some accounts, subscribe other accounts to Clean Energy 14
Your Way – Subscription, and work with Idaho Power to 15
develop a new renewable resource under Clean Energy Your 16
Way – Construction for Schedule 19 accounts. 17
IV. CLEAN ENERGY YOUR WAY - FLEXIBLE 18
Q. What is the Clean Energy Your Way – Flexible 19
offering? 20
A. As proposed by Idaho Power, Clean Energy Your 21
Way – Flexible will entirely replace the current Green 22
Power Program. Importantly, however, the only significant 23
change is the program name. From the customer’s 24
perspective, the program will continue to operate as it 25
Williams, DI 26
Idaho Power Company
has, and current participants will remain enrolled without 1
any modifications. 2
Q. If approved, will Idaho Power alert customers 3
to these program changes? 4
A. Yes. Upon Commission approval, Idaho Power 5
will update all marketing and program materials, replacing 6
all references to the Green Power Program with Clean Energy 7
Your Way – Flexible. The Company will then inform and 8
educate existing and prospective customers of the change. 9
Q. Is the Company requesting any additional 10
changes to this offering? 11
A. Yes. In addition to the name change, Idaho 12
Power requests additional authority to purchase RECs to 13
keep up with demand and to satisfy customers with near-term 14
clean energy goals that can be met with small amounts of 15
RECs. 16
Q. Why does Idaho Power require additional 17
authority to purchase RECs for customers beyond the RECs 18
generated from resources connected to Idaho Power’s system? 19
A. Idaho Power anticipates limited availability 20
of its RECs in the near future, based on demand. Rather 21
than turn away interested customers, Idaho Power requests 22
the authority to purchase RECs on customers’ behalf or 23
purchase RECs that may become available with attractive 24
pricing. 25
Williams, DI 27
Idaho Power Company
Idaho Power’s REC transactions are governed by a 1
plan that is filed with the Commission. The Company’s 2
current REC request offers the opportunity to clarify REC 3
transactions in the context of optional customer renewable 4
energy offerings and their associated accounting treatment. 5
REC Management Plan History 6
Q. Please provide a brief history of the 7
Company’s REC Management Plan. 8
A. On June 11, 2010, the Commission issued Order 9
No. 32002 approving Idaho Power’s REC Management Plan 10
(“Management Plan”), which governs the sale and proceeds of 11
Idaho Power-owned RECs.21 Then, on June 6, 2011, the Company 12
filed a letter advising the Commission of a change in 13
market conditions that required the Company to commit to 14
selling a portion of its available RECs for up to a five-15
year period. Prior to the letter, the Company had limited 16
its REC transactions to agreements with a maximum term of 17
two years. 18
Since 2011, Idaho Power has executed REC 19
transactions according to the Management Plan, under which 20
the Company sells RECs in the near-term and returns the 21
customers’ share of the proceeds through the power cost 22
adjustment (“PCA”) mechanism. 23
21 In the Matter of the Application of Idaho Power Company for Authority
to Retire Its Green Tags, Case No. IPC-E-08-24, Order No. 32002 (Jun
11, 2010).
Williams, DI 28
Idaho Power Company
Q. What type of expanded REC procurement is Idaho 1
Power proposing? 2
A. Over the past year, the Company has identified 3
two ways in which Idaho Power could better serve customers 4
seeking RECs. These two customer-focused opportunities 5
included a limited bulk purchase of RECs and individual 6
procurement of RECs on behalf of customers. Both of these 7
purchase options are detailed below, with discussion of 8
their relationship to the Management Plan. 9
Limited Bulk Purchase Option 10
Q. What is the Limited Bulk Purchase option? 11
A. Under this proposal, the Company would 12
purchase a limited quantity of RECs in advance of a 13
customer request with the intent to sell the RECs to 14
interested customers at a later date under individual 15
customer-specific REC sale agreements. 16
Purchasing RECs in advance (in small bulk 17
quantities, rather than in individual quantities with each 18
new customer request) will result in a more efficient and 19
cost-effective process for Idaho Power and customers. 20
Q. Who will pay for any advanced-purchased RECs? 21
A. The Company will purchase the RECs and sell them 22
to customers at cost, plus any transaction fees, meaning 23
there will be no net proceeds to pass through to the PCA. 24
Williams, DI 29
Idaho Power Company
In the event the Company cannot find a willing 1
purchaser for some or all of the RECs, Idaho Power will 2
record the unsold amounts as a charge to the Company’s 3
Operations & Maintenance expense. 4
Q. Does the Company intend to limit these type of 5
REC purchases? 6
A. Yes. The Company would limit advanced bulk REC 7
purchases to $5,000 at any given time and not execute a new 8
bulk purchase until the prior batch was fully sold. Idaho 9
Power is confident that demand exists to sell this amount 10
of RECs to interested parties. 11
REC ”Sleeve” Option 12
Q. What is the REC “sleeve” option? 13
A. In addition to the request above, Idaho Power 14
seeks the authority to serve as a “sleeve” for REC 15
transactions with customers—that is, connect customers to 16
non-Idaho Power REC purchase options. The Company would 17
like the ability to continue working holistically with 18
customers on their clean energy goals, rather than refer 19
them to another party or outside energy advisor. 20
Q. Why would Idaho Power need to serve as a 21
“sleeve” for REC transactions? 22
A. While the Company will prioritize the sale of 23
its own RECs, there are some circumstances in which Idaho 24
Power’s RECs do not meet the needs of customers. Such 25
Williams, DI 30
Idaho Power Company
instances include, but are not limited to, a customer 1
needing Green-e® certification for RECs or desiring a 2
certain price or type of REC that Idaho Power cannot 3
provide with its own supply. 4
Q. How will Idaho Power facilitate these 5
transactions? 6
A. As Idaho Power envisions this arrangement, the 7
transactions would work exactly in the manner described 8
above—the Company would purchase RECs and sell them at cost 9
to an individual customer, thereby creating no proceeds to 10
pass through the PCA. Unlike the bulk option describe 11
above, there would be no unsold RECs as the Company would 12
only procure the amount of RECs the customer would 13
purchase. 14
Q. Do the requested changes impact the REC 15
Management Plan? 16
A. No, they do not. These intended REC 17
transactions fall outside of the provisions of both the 18
Company’s REC Management Plan and existing Schedule 62, the 19
Company seeks Commission approval for this new practice but 20
does not propose any other modifications or changes to the 21
existing program or governing documents. 22
Williams, DI 31
Idaho Power Company
V. FRAMEWORK FOR A FUTURE CLEAN ENERGY YOUR WAY – 1
SUBSCRIPTION OPTION 2
Q. Why is the Company proposing to offer a 3
subscription-based option? 4
A. Through customer conversations, Idaho Power 5
identified that a subscription-style green tariff offering 6
would be a desirable option. Many customers specifically 7
asked for a program that would provide additionality (that 8
is, a new renewable resource) in an easy, streamlined, and 9
accessible manner. 10
Q. Are subscription green tariff offerings common 11
in the utility industry? 12
A. Yes. Subscription green tariff offerings have 13
been successfully designed, implemented, and operated by 14
electric utilities across the United States. As noted 15
earlier, Idaho Power focused its subscription-based green 16
tariff research on two nearby success stories: Xcel 17
Colorado’s Solar*Connect22 and Puget Sound Energy’s Green 18
Direct.23 These programs, both fully subscribed upon 19
implementation, demonstrate that subscription-based clean 20
energy programs are effective offerings for customers. 21
22 Xcel Colorado’s Solar*Connect program (docket 16-A0055E) was approved
by the Colorado Public Utilities Commission in November 2019. Xcel’s
Schedule RC tariff governs the program.
23 Puget Sound Energy’s (“PSE”) Green Direct program (docket UE-160977)
was approved by the Washington Utilities and Transportation Commission
in September 2016. PSE’s Schedule No. 139 governs the program.
Williams, DI 32
Idaho Power Company
Q. Did Idaho Power review existing green tariff 1
offerings and select elements most suited to its customers’ 2
needs? 3
A. Yes. Recognizing that Idaho Power’s service 4
area is distinct from both Washington and Colorado, the 5
Company closely examined the elements of these two 6
utilities’ programs and selected components that would be 7
most appropriate for Idaho Power and consistent with the 8
objectives of its customers. 9
Q. Why is the Company only proposing a framework 10
and not a fully fleshed-out program for the Subscription 11
offering? 12
A. The Clean Energy Your Way – Subscription 13
offering will require a new renewable resource or resources 14
to serve participants. Idaho Power did not wish to seek a 15
resource before receiving Commission approval to offer such 16
a program. 17
Instead, the Company proposes a two-phase process 18
for the Subscription offering — an initial phase (the 19
current request) to offer a voluntary subscription-based 20
program, and secondary phase that will launch upon approval 21
of the first. Under this two-phase approach, the 22
Subscription would not be available to participants until 23
the conclusion of a separate and subsequent proceeding 24
addressing the resource procurement, resource cost, cost 25
Williams, DI 33
Idaho Power Company
allocation, and any other required regulatory accounting 1
and necessary cost recovery mechanisms. 2
Two-Phase Commission Approval Process 3
Q. Why is the Company proposing a two-phase 4
approval process for the Subscription option? 5
A. In a subscription green tariff construct, 6
customers “subscribe” to a portion of output from a new 7
renewable resource on a utility’s system. But to offer such 8
a program, a utility needs to have a resource selected and 9
pricing determined. Idaho Power believes the sequence of 10
activities is important for the Subscription and, 11
consistent with the processes in other jurisdictions, 12
supports a two-phase process to guide the offering from 13
proposal to Commission approval of the program pricing. 14
Q. What is the Company’s request in each approval 15
phase? 16
A. In Phase I, Idaho Power seeks authority to 17
offer a voluntary subscription option. Included for 18
approval are the foundational concepts of program structure 19
and design, described below and in Exhibit No. 1. 20
In Phase II, and upon Commission approval to offer 21
Clean Energy Your Way – Subscription, Idaho Power would 22
seek a Subscription-dedicated resource. Resource selection 23
would involve determining the resource type, size, and 24
location. Once a resource is identified, Idaho Power would 25
Williams, DI 34
Idaho Power Company
propose specific subscription pricing under the structure 1
approved in Phase I and return to the Commission for 2
approval of those program elements and associated tariff 3
changes. 4
Q. How does the Company propose procuring a 5
resource for the Subscription offering? 6
A. Upon Commission approval to offer the 7
Subscription, the Company intends to work with developers 8
to identify a resource that would best meet the specific 9
needs of the Subscription program. Idaho Power would like 10
to identify a resource expeditiously and, therefore, 11
requests the ability to waive competitive resource 12
procurement requirements. 13
Q. What are the current Commission requirements 14
regarding competitive resource procurement? 15
A. In 2010, the Commission initiated a case24 16
seeking to establish competitive bidding guidelines for the 17
procurement process used to acquire supply-side resources 18
by Idaho Power. In 2013, the Commission closed this case 19
without establishing Idaho-specific resource procurement 20
guidelines, but rather directed Idaho Power to follow the 21
Request for Proposals (“RFP”) guidelines applicable in its 22
Oregon service area. The Oregon RFP guidelines to which 23
24 In the Matter of the Development of Request for Proposal (RFP)
Guidelines for the Procurement of Supply-Side Resources by Idaho Power,
Case No. IPC-E-10-03, Order No. 32745 (Feb 12, 2013).
Williams, DI 35
Idaho Power Company
the Commission referred were later codified into the 1
administrative rules of the OPUC. OAR 860-089-0010 et. 2
seq. (“OPUC Resource Procurement Rules”). 3
The OPUC Resource Procurement Rules impose 4
competitive bidding requirements upon an electric utility 5
for the “acquisition of a resource or a contract for more 6
than an aggregate of 80 megawatts and five years in 7
length,” among other requirements. OAR 860-089-0100(1)(a). 8
Q. Does the Company believe the Commission should 9
require Idaho Power to follow the OPUC Resource Procurement 10
Rules for renewable resources procured for the purpose of 11
serving customers under the Subscription option? 12
A. No. The resource, or resources, procured for 13
this program will be acquired for the sole purpose of 14
implementing this optional service offering. This is not to 15
suggest that Idaho Power would not apply a competitive 16
procurement process in this instance. Rather, the Company 17
envisions a competitive process would be applied – just not 18
the specific process required under OPUC Resource 19
Procurement Rules. It is Idaho Power’s expectation that the 20
Commission would review the associated procurement process 21
as part of Phase II, as described above. 22
Q. If the Commission were to grant Idaho Power’s 23
request for relief from the OPUC Resource Procurement Rules 24
in this instance, what assurance would non-participating 25
Williams, DI 36
Idaho Power Company
customers have that such a resource, or resources, will not 1
inappropriately shift costs to them? 2
A. As part of Phase II, Idaho Power expects that 3
it would not only make a showing to the Commission that the 4
program resource was competitively procured, but also that 5
the cost of such a resource will not negatively impact the 6
rates of non-participating customers. 7
Q. Will the Commission and other interested 8
stakeholders have an opportunity to weigh in on program 9
resources and pricing? 10
A. Yes. Under the two-phase approach, all 11
resource and other costs, financial analysis, program 12
accounting treatment, and customer pricing would be 13
determined in the second filing, as these details are not 14
possible to establish absent a known resource. Stakeholders 15
would have ample opportunity to provide input on program 16
pricing and accounting during the second phase. 17
Subscription Option Terms and Conditions 18
Q. What are the basic program design components 19
of the Subscription? 20
A. The basic design elements of the Subscription 21
offering address subscriber eligibility, subscription size, 22
subscription term length, treatment of associated RECs, 23
customer agreement, and program pricing elements 24
(categories rather than specific pricing values). 25
Williams, DI 37
Idaho Power Company
Q. Who is eligible for the Subscription program? 1
A. The Clean Energy Your Way – Subscription 2
offering would be a voluntary subscription-based program 3
open to all of Idaho Power’s customer classes, from 4
residential to Special Contracts. However, given the size 5
of Idaho Power’s largest customers relative to the 6
generation output of a likely renewable resource, Idaho 7
Power proposes an individual customer cap of 15 percent of 8
program capacity. This eligibility cap is to preserve 9
equitable access to the program by ensuring that no one 10
customer can absorb more than 15 percent of program 11
availability. 12
Q. How would subscription sizes be determined? 13
A. Idaho Power proposes basing individual 14
subscription size on a customer’s average prior year energy 15
use in kWh. Customers without a complete year of history 16
with Idaho Power would be subscribed to an amount informed 17
by their usage history at the point of program sign up. New 18
customers with no billing history would be assigned a 19
subscription size based on their expected energy use. 20
For additional flexibility, customers would be able 21
to sign up for the subscription at 50 or 100 percent of 22
their average prior year energy use. 23
Q. What are the proposed term lengths for 24
participation? 25
Williams, DI 38
Idaho Power Company
A. Idaho Power proposes multiple term lengths. 1
Residential customers would be offered a month-to-month 2
subscriber option. Residential and all other classes of 3
customers could also subscribe to terms of 5 years, 10 4
years, or 20 years. 5
Q. How will RECs generated from the Subscription 6
resource be treated? 7
A. To reflect the renewable attributes of 8
Subscription participation, Idaho Power will retain and 9
retire subscription resource RECs. Different REC treatment 10
would be considered on a case-by-case basis at the request 11
of individual customers. 12
Q. Will customers be required to sign a 13
commitment as part of the Subscription program? 14
A. Yes. All participating customers will be 15
required to sign a participant agreement, which will detail 16
terms, conditions, and obligations of the customer. The 17
customer agreement will provide details with respect to 18
subscription transfer, roll-over, and early termination. A 19
proposed customer agreement will be included in the phase 20
II filing. 21
Q. How does Idaho Power propose pricing the 22
Subscription program for participants? 23
A. As noted earlier, Idaho Power will not propose 24
actual resource pricing for the Subscription offering until 25
Williams, DI 39
Idaho Power Company
the program is approved by the Commission and a resource is 1
identified. However, the Company does propose the following 2
program price elements: 3
Program Charge: A subscriber’s charge would be 4
made up of four elements -- (1) cost of the 5
resource ($/kWh); (2) integration charges 6
associated with the resource; (3) 7
administration and marketing costs to advertise 8
and maintain the offering; and (4) a term 9
adjustment charge applied in tiers to shorter-10
term (month-to-month, 5-year, and 10-year) 11
subscribers. As anchor tenants of the program, 12
full-term (20-year) subscribers would not pay a 13
term adjustment charge. 14
Program Credit: For the value that the specific 15
resource would bring to Idaho Power’s system, 16
subscribers would receive a credit for both 17
energy and capacity of the program resource. 18
Q. What is the purpose of the term adjustment 19
charge referenced above? 20
A. In considering relative program costs and 21
risks, Idaho Power identified that shorter-term subscribers 22
add a small amount of risk to the program’s long-term 23
viability. Month-to-month, 5- or 10-year subscribers may 24
exit the program before the envisioned program end date. To 25
Williams, DI 40
Idaho Power Company
correct for this subscriber risk, the Company proposes a 1
term adjustment charge that would be applied in tiers 2
relative to subscriber level—from largest for month-to-3
month to smallest for 10-year terms. This charge would be 4
used in part to cover any unexpected under-collection of 5
program costs due to early customer exit from the 6
Subscription and also used to fund ongoing advertising and 7
marketing to keep the program fully subscribed over time. 8
In contrast, subscribers to the full 20-year term 9
would not pay any additional charge. These customers pose 10
no additional risk, as their anchor tenancy provides full 11
program stability. 12
Q. How will a customer’s monthly bill change by 13
participating in the Subscription Option? 14
A. Customers of the Subscription offering would 15
continue to pay all standard rates and charges associated 16
with their rate schedule(s). The Subscription would be an 17
add-on to the customer bill, with five new line items, as 18
illustrated in the bill mock-up attached to this 19
Application as Exhibit No. 2: (1) Program name; (2) 20
Subscriber amount (in kWh), (3) Subscriber charge amount; 21
(4) Subscriber credit amount, and (5) total (or net) charge 22
(subscriber charge less subscriber credit). 23
Williams, DI 41
Idaho Power Company
Q. What level of enrollment is necessary for the 1
Subscription option to move forward with resource 2
procurement? 3
A. Based on expressed customer interest, Idaho 4
Power believes it can fully subscribe the offering as 5
described above with a resource of 50-100 megawatts. If 6
customer demand exceeds what the first Subscription 7
resource can provide, Idaho Power would consider seeking 8
approval for a second Subscription offering. 9
However, in the unexpected event that the Company 10
cannot fully subscribe the program, Idaho Power proposes to 11
dispatch any unsubscribed renewable generation to its 12
system with the costs included in broader customer rates 13
and/or the PCA mechanism. Idaho Power intends to make a 14
showing in Phase II that any unsubscribed energy cost 15
resulting from the Subscription would be assigned to non-16
participating customer as a cost at, or below, reasonable 17
avoided cost. The Company considers inability to fully 18
subscribe the program a low probability outcome, but one 19
that would not harm the broader customer base. Considering 20
Idaho Power’s capacity deficit25 occurs before 2028, any 21
25 In the Matter of Idaho Power Company’s Application for a
Determination Acknowledging Its North Valmy Power Plan Exit Date, Case
No. IPC-E-21-12, Ellsworth DI at p. 26, l. 21 – p. 27, l. 16 (Apr 30,
2021); In the Matter of Idaho Power Company’s 2019 Integrated Resource
Plan, LC 74, Valmy Unit 2 Exit Analysis at 11 (Aug 4, 2021).
Williams, DI 42
Idaho Power Company
unsubscribed portions of energy from the Subscription 1
resource could be a helpful contribution to meeting Idaho 2
Power’s capacity needs. 3
Additionally, Idaho Power proposes that the RECs 4
associated with any unsubscribed portions of the 5
Subscription resource would be treated in a manner 6
consistent with the REC Management Plan – that is, sold to 7
interested parties with sale proceeds passing through the 8
PCA to benefit all customers. 9
VI. CLEAN ENERGY YOUR WAY - CONSTRUCTION 10
Q. How did the Company decide to offer a large-11
customer renewable option? 12
A. In addition to the Flexible and Subscription 13
offerings, Idaho Power identified the need for a tailored 14
renewable option for its largest customers—specifically, 15
Schedule 19 and Special Contracts. While Idaho Power 16
believes it can work with its existing or future Special 17
Contract customers to integrate a renewable offering into 18
their service agreements with the Company, it does not 19
currently have the ability to extend these kinds of 20
agreements to Schedule 19 customers. As a result, Idaho 21
Power’s request of the Commission is to allow equal 22
opportunity to the Construction option for Special Contract 23
and Schedule 19 customers alike. 24
Williams, DI 43
Idaho Power Company
Q. How is the Construction offering different 1
than the Subscription option? 2
A. In simple terms, Clean Energy Your Way – 3
Construction offers large customers a tailored way to cover 4
100 percent of their energy use with a new renewable 5
resource(s). Logistically, the Construction option works 6
by reconciling a customer’s energy use against the 7
generation of a renewable resource (or resources) on an 8
hourly basis. 9
As detailed in the modified Schedule 62, the Company 10
requests approval from the Commission to offer the 11
Construction arrangement to both Schedule 19 and Special 12
Contract customers under a broad framework with consistent 13
mechanics and pricing structure. 14
Q. What are the basic program design components 15
of the Construction Option? 16
A. Under the proposed Construction arrangement, 17
eligible customers would have the ability to work with 18
Idaho Power to select a renewable resource(s), including 19
providing input on the type, size, and location. 20
Construction resources must connect to Idaho Power as 21
system resources, and customers may claim the renewable 22
attributes. RECs will be retained and retired by Idaho 23
Power, unless the customer has specific REC accounting 24
requirements. The Company would work with customers on a 25
Williams, DI 44
Idaho Power Company
case-by-case basis if alternative REC accounting were 1
requested. 2
Q. Why does the resource need to be connected to 3
Idaho Power as a system resource? 4
A. The resource must connect to Idaho Power’s 5
system to allow for accurate metering to measure the new 6
cost and benefit streams envisioned for the Construction 7
offering. 8
Q. How will the monthly billing work under the 9
Construction offering? 10
A. Unlike the Subscription, the Construction 11
offering would impact a customer’s existing rate structure 12
by creating new cost and benefit streams resulting from the 13
renewable resource(s). 14
Q. Please elaborate on the functional dynamics of 15
the Construction offering. 16
A. The Company proposes the following consistent 17
dynamics in each Construction arrangement: 18
When the renewable resource is not generating (for 19
example, a solar resource does not generate 20
electricity at nighttime), the customer continues 21
to take service from Idaho Power at their standard 22
rates. (This amount is defined as Net Consumption 23
in Attachment 1 to the Application (“Attachment 24
1”).) 25
Williams, DI 45
Idaho Power Company
When the resource is generating, the customer pays 1
for all the generation output at an agreed-upon 2
price. (Renewable Energy Facilities (“REF”) Cost in 3
Attachment 1.) 4
For the value the resource brings to Idaho Power’s 5
system, the Company credits the customer at an 6
agreed-upon, Commission-approved value. (REF 7
Credit in Attachment 1.) 8
In any given hour, if the renewable generation 9
exceeds the customer’s energy use, Idaho Power 10
credits the customer for that excess at a 11
negotiated value. (Excess Generation in Attachment 12
1.) 13
The customer continues to pay all fixed costs in 14
their energy rate (REF On-Site Usage in Attachment 15
1), as well as standard rates, charges, and fees 16
(e.g., franchise fees) for fully bundled service 17
provided by Idaho Power. 18
Q. What does the REF On-Site Usage capture? 19
A. The REF On-Site Usage quantifies the amount of 20
energy generated by the renewable resource that, for billing 21
purposes, will offset the amount of energy subject to the 22
Customer’s standard service rates. 23
Williams, DI 46
Idaho Power Company
Q. What is the significance of the REF On-Site 1
Usage? 2
A. Historically, customers have relied on Idaho 3
Power to provide for all their energy needs. The volumetric 4
rates charged for energy have reflected this arrangement and 5
have been “bundled” to include the variable costs associated 6
with producing energy (variable costs) and some of the costs 7
associated with the Company’s obligation to maintain an 8
interconnected network of power plants, transmission 9
poles/wires, substations, and distribution poles/wires 10
necessary to balance the supply of and demand for electricity 11
in its service area (fixed costs). 12
Under a Construction arrangement, the principles of 13
fully bundled service are altered to accommodate a new 14
renewable resource, the pricing of which is determined 15
independent of Idaho Power’s costs to serve customers. If the 16
standard service cost of energy paid by the customer is 17
“traded” in the Construction option for the cost of the 18
renewable resource’s energy, then the customer avoids payment 19
for the fixed costs within their volumetric energy rate. 20
The REF On-Site Usage captures the amount of energy 21
consumed by the customer for which fixed costs are not being 22
collected. 23
Williams, DI 47
Idaho Power Company
Q. For Construction arrangements, how does the 1
Company propose to structure billing to ensure adequate 2
customer payment for cost of service, including fixed costs? 3
A. A customer with Construction arrangement will 4
be billed as follows: (1) the customer’s metered usage will 5
be assessed the Service, Billing Demand, On-Peak Billing 6
Demand, and Basic Load Capacity charges from their applicable 7
service schedule, (2) the customer’s Net Consumption will be 8
assessed the energy rates from their applicable service 9
schedule, and (3) the REF On-Site Usage will be assessed the 10
charge outlined in Schedule 62 associated with their 11
applicable service schedule. 12
Q. How is the charge for the REF On-Site Usage 13
calculated? 14
A. The methodology for determining the rate to be 15
applied to the REF On-Site Usage is based on reducing the 16
volumetric rates by the Company’s embedded energy-related 17
costs. These embedded energy-related costs were determined by 18
the cost-of-service methodology most recently reviewed by the 19
Commission26 and have been adjusted to reflect revenue 20
requirement changes that impact the authorized level of 21
energy-related cost recovery. The fixed costs in the energy 22
26 In the Matter of the Application of Idaho Power Company for Authority
to Increase its Rates and Charges for Electric Service in Idaho, Case
No. IPC-E-11-08, Order No. 32426 (Dec 30, 2011).
Williams, DI 48
Idaho Power Company
rate were calculated by removing the embedded energy-related 1
costs from the fully bundled energy charges. 2
Q. Why is it appropriate to assess the fixed cost 3
charge against the REF On-Site Usage? 4
A. The charge is necessary to ensure that 5
customers continue to pay their costs of service. If fixed 6
costs were not accounted for in Construction arrangements, 7
the Construction customer(s) would underpay for their 8
service, which may ultimately shift those costs to non-9
participants. Idaho Power has designed the Construction 10
offering to ensure that non-participants are held harmless, 11
making the fixed cost charge for REF On-Site Usage a critical 12
component for inclusion in all Construction agreements. 13
Q. Does the Company envision identical contracts 14
for customers who opt for the Construction Option? 15
A. No. Idaho Power envisions that the rates 16
resulting from each Construction arrangement would be 17
approved by the Commission on a case-by-case basis. The 18
Company’s largest customers have vastly different 19
businesses, energy use patterns, demand for energy, and 20
clean energy objectives. As such, the Construction option 21
must be broad enough to allow for tailored customer 22
solutions. 23
Williams, DI 49
Idaho Power Company
Q. Does the Company contemplate possible 1
alternate Construction arrangements beyond one customer and 2
one resource? 3
A. Yes. One such alternate arrangement might 4
involve multiple customers joining together under one 5
Construction agreement to achieve resource economies of 6
scale. Another tailored arrangement could involve Idaho 7
Power working with a customer to develop more than one 8
resource (e.g., two solar facilities, or both a solar and 9
wind facility). Several customers have already expressed a 10
desire to work with Idaho Power on tailored Construction 11
solutions with other customers and/or multiple resources. 12
Q. Is Idaho Power also requesting relief from the 13
OPUC Resource Procurement Rules for renewable resources 14
procured for the sole purpose of supporting each 15
Construction agreement? 16
A. Yes. As with the Subscription offering, the 17
resource, or resources, procured for the Construction 18
offering will be acquired for the sole purpose of serving 19
the customer or customers under a Construction arrangement. 20
It is Idaho Power’s expectation that the Commission would 21
review the procurement process and associated resource cost 22
assignment as part of each Construction arrangement prior 23
to approval. 24
Williams, DI 50
Idaho Power Company
Q. If the contracts are not identical, how will 1
the Company ensure non-participants are held harmless? 2
A. Each Construction arrangement will include a 3
no-harm revenue requirement analysis to ensure that non-4
participants are held harmless from the arrangement. 5
Additionally, individual Commission approval ensures that 6
each arrangement is evaluated and approved on its own 7
merits. 8
V. CONCLUSION 9
Q. Please summarize your testimony. 10
A. Although the Green Power Program has met many 11
customer’s needs to date, a growing number of Idaho Power’s 12
customers are seeking additional clean energy options. In 13
consultation with individual customers, and based on 14
industry research, Idaho Power has designed a “menu” of 15
clean energy options to appeal to customers of all sizes 16
and different clean energy objectives. 17
Idaho Power has developed a three-pronged offering 18
that builds off the successful foundation of the Green 19
Power Program to include a new subscriber-based option and 20
a tailored renewable energy offering for customers seeking 21
new renewable resources to accomplish their sustainability 22
goals. To reflect the Company’s new clean energy 23
opportunities, Idaho Power proposes the program name 24
“Clean Energy Your Way” to house the three options: Clean 25
Williams, DI 51
Idaho Power Company
Energy Your Way - Flexible (REC option), Clean Energy Your 1
Way – Subscription (individual subscriber option), and 2
Clean Energy Your Way - Construction (large customer 3
option). These offerings are voluntary, designed to meet 4
the needs of customers with clean energy goals, and 5
developed with precautions that hold non-participants 6
harmless. 7
Specifically, the Company is requesting approval to 8
(1) rename and expand the existing Schedule 62 to the 9
Clean Energy Your Way Program, (2) maintain and expand 10
procurement options for the REC program under the name 11
Clean Energy Your Way - Flexible, (3) establish a 12
regulatory framework for a future voluntary subscription 13
green power service offering named Clean Energy Your Way - 14
Subscription, 4) offer a tailored renewables offering to 15
the Company’s largest customers (Special Contract and 16
Schedule 19) named Clean Energy Your Way – Construction, 17
and 5) procure associated program renewable resources 18
outside of the Commission’s current competitive 19
procurement requirements. 20
Idaho Power’s proposed offerings and target 21
timeframes were developed to be responsive to customers’ 22
sustainability goals, some of which are as early as 2025. 23
With customer needs in mind, the Company respectfully 24
Williams, DI 52
Idaho Power Company
requests the Commission establish a schedule that could 1
lead to approval of the elements proposed by April 2022. 2
Q. Does this complete your testimony? 3
A. Yes, it does. 4
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-21-40
IDAHO POWER COMPANY
WILLIAMS, DI
TESTIMONY
EXHIBIT 1
EXHIBIT 1
Clean Energy Your Way – Subscription: Proposed Program Parameters
Idaho Power’s Clean Energy Your Way - Subscription will allow customers of any size to participate and
receive both the energy and Renewable Energy Certificates (“RECs”) from a new and dedicated
renewable resource on Idaho Power’s system. Participation in this program is voluntary and is in
addition to a customer’s existing electric service schedule. While the specific values for the various
billing components will be determined in a subsequent filing made with the Idaho Public Utilities
Commission (“Commission”), the general program design and a summary of the charges and credits is
provided below.
Subscription Offering Design
Resource and Project Size. It is anticipated that the initial project under the Subscription option will be
50-100 MW, depending on initial participation interest. Following Commission approval to offer the
Subscription program, Idaho Power will seek a resource to serve the program.
Participation and Eligibility. The Subscription program is open to Residential, Small General Service,
Large General Service, Large Power Service, Agricultural Irrigation Service, and Special Contract
customers receiving service under Idaho Rate Schedules: 01, 05, 07, 09, 19, 24, 26, 29, and 30.
Participation is optional and will result in additional charges.
Customer Subscriptions. Program participants may elect to subscribe to an expected annual production
of 50 or 100 percent of their usage based on the prior 12 months of average energy usage (on a kWh
basis). Customers with less than 12-months’ history as an Idaho Power customer will be assessed on the
average of their prior months of energy use or an approximated amount based on the customer’s rate
class. Customers without a complete year of history with Idaho Power would be subscribed to an amount
informed by their usage history at the point of program sign up. New customers with no billing history
would be assigned a subscription size based on their expected energy use.
RECs. Idaho Power will retain and retire RECs and all other environmental attributes including but not
limited to carbon emission reduction credits. Different REC treatment would be considered on a case-
by-case basis at the request of individual customers.
Enrollment. Following Commission approval to offer the voluntary program and approval of a resource
with specific pricing, Idaho Power will market the Subscription offering and announce a sign-up schedule.
Residential customers will be allowed a six-week early sign-up period, during which other customer classes
will not be allowed to subscribe. Following the residential sign-up window, Subscription sign-up will be
opened to all other customers in blocks based on the resource size. Once one “block” is subscribed, Idaho
Power will open the next block, giving customers notice in advance of each new subscriber block option.
Term Length. Month-to-month (for Residential only), 5-year, 10-year, and 20-year.
Customer Agreement. Customers will be required to sign a binding agreement to enroll in the Subscription
program. The agreement will address the terms and conditions of the customer’s subscription
commitment and specify customer obligations in the event of early exit from the program relative to the
customer’s term length.
Customer Billing. The Schedule 62 – Subscription rates are in addition to all charges under the Customer’s
existing Electric Service Schedule. A participant’s electric bill will include five new line items: (1) the name
of the program (Clean Energy Your Way – Subscription); (2) subscriber amount (in kWh), (3) subscriber
charge amount, (4) subscriber credit amount, and (5) net cost (subscriber charge less subscriber credit).
Program Charge and Credit
Specific program pricing will be proposed based on resource identification and finalized upon approval by
the IPUC. Program charge and credit components will be based on:
Resource Cost ($/kWh)
Resource-specific Integration Charges
Program Administration and Marketing
Short-Term Adjustment Charge – A small risk-based fee added to customers on month-
to-month, 5-year, and 10-year terms. The adjustment charge would be highest for month-
to-month customers, less for 5-year subscribers, and less still for 10-year subscribers.
Credits
Energy Credit
Capacity Credit
The program credit is not to exceed the program charge.
Unsubscribed Energy
In the event that Idaho Power could not fully enroll the Subscription offering, any unsubscribed energy
from the renewable resource would be dispatched to Idaho Power’s system with the cost of the resource
included in broader customer rates and/or the PCA mechanism. The RECs associated with any
unsubscribed energy would be treated in a manner consistent with the Company’s REC Management Plan
with the proceeds from REC sales passing through the PCA to benefit all customers.
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-21-40
IDAHO POWER COMPANY
WILLIAMS, DI
TESTIMONY
EXHIBIT 2
Amount DueDue Date07/30/2021
$389.4608/16/202107/31/2021PAGE 1 OF 2
Billing Date
Print Date
Name
Write your account number on your check or money order made payable to
Idaho Power. Mail payment to address below. Returned checks may be
resubmitted electronically, and remaining unpaid items will be charged $20.
P L E A S E D E T A C H A N D R E T U R N B O T T O M P O R T I O N W I T H Y O U R P A Y M E N T
Address/Phone Correction
Due Dateand/or Project Share Pledge
noted on reverse side
Amount Enclosed $208-388-2323
CLEAN ENERGY 12115 W STILL DR
BOISE ID 83713-6648
2222222222
Amount Due
PROCESSING CENTERP.O. BOX 5381
CAROL STREAM IL 60197-5381
FTFDDDFFFTAFFTADDDDADFFDDFDFADADADTDAAFFTDATDFTAADDDDFFDDDFDDDTAA
2206090000038746 000000000 000038746 0730 3
P.O. BOX 70, BOISE, ID 83707
Account Number
08/16/2021 $389.46
CLEAN ENERGY
Account Number:2222222222
Previous Balance $219.90
Payments Received - Thank You - $219.90
Balance Forward $0.00
Current Charges $389.46
$389.46Account Balance
NOTE:Any unpaid balance may be assessed a monthly charge of 1 percent.
Sign up for My Account!
Access your account 24/7 to pay your bill,
track your use and learn to save. Visit
idahopower.com/myaccount to get started.
Name
Av
e
r
a
g
e
k
W
h
P
e
r
D
a
y
Average Daily Energy Use for 12115 W STILL DR / BOISE,ID
Name
Questions? Contact your Customer Care team:
M-F: 7:30 a.m.-6:30 p.m.208-388-2323
Boise, ID 83707P.O. Box 70
Hablamos español.
For more information and/or self-help options,
idahopower.com.visitPAGE 2 OF 2
• •
•
Contact your Customer Care team at least two business daysMoving?
before you want to end service.
FOR ACCOUNT NUMBERNEW CONTACT INFORMATION
Has your address, phone number or email changed? Provide changes below.
Name
Apt./SuiteStreet
StateCity Zip
Telephone
Email
2222222222
0032833333
12115 W STILL DR / BOISE,ID
06/26/21 - 07/28/21 (33 days)
08/27/2021
NA
Service Period
Next Read Date
Service Agreement Number
Description
Service Address
Meter Number Energy Used (kWh)Reading TypePrevious Reading Current Reading
66566666 10775 13936 3,161 Regular
SERVICE DETAILS (Residential Standard Plan Schedule 01)
$5.00Service Charge
$68.00Summer Energy Charge 800 kWh @ $0.085005 per kWh
$122.66Summer Energy Charge 1,200 kWh @ $0.102214 per kWh
$140.97Summer Energy Charge 1,161 kWh @ $0.121424 per kWh
$23.93Power Cost Adjustment
$22.15Fixed Cost Adjustment
$5.74Franchise Fee 1.50% Paid to Your City
$10.44Energy Efficiency Services
- $11.43Federal Columbia River Benefits Supplied by BPA
$389.46Current Charges - Electric Service
NOTE: For an explanation of these charges, go to idahopower.com/billglossary.
kWh = Kilowatt-hour
$A.AA
$B.BB
Subscriber amount Participant Program Charge (Subscriber amount kWh x Program Charge/kWh)
Participant Program Credit (Subscriber amount kWh x Program
Credit/kWh)
Total Participant Charge ($A.AA-$B.BB)$C.CC
Clean Energy Your Way-Subscription
XXX kWh