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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. ) ) ) ) ) ) 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 Williams, DI 23 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