20220602Reply Comments.pdf

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P.O. Box70 (t3707)
t2ilt W. ldaho 3t.
Boisc, lD 811702
JULIA A. HILTON
Depu$ General Counsel and
Dircctor of Legal
[e-mail]
June 2,2022
Jan Noriyuki, Secretary
ldaho Public Utilities Commission
1 1331 W. Chinden Boulevard
Building 8, Suite 201-A
Boise, ldaho 83714
Case No. !PC-E-2140
Application to Expand Optional Customer Clean Energy Offerings Through
the Clean Energy Your Way Program
Dear Ms. Noriyuki:
Aftached for electronic filing is ldaho Power Company's Reply Comments in the
above-entitled matter.
lf you have any questions about the attached document, please do not hesitate to
contact me.
Re
Sincerely,
d-i44(r-
Julia A. Hilton
JAH:sg
Enclosure
LISA D. NORDSTROM (lSB No. 5733)
ldaho Power Company
1221 West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
lnordstrom@ida hopower.com
Attorney for ldaho Power Company
BEFORE THE lDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION TO EXPAND
OPTIONAL CUSTOMER GLEAN ENERGY
OFFERINGS THROUGH THE CLEAN
ENERGY YOUR WAY PROGRAM.
)) CASE NO. !PC-E-2140
)) IDAHO POWER COMPANY',S
) REPLY COMMENTS
)
ldaho Power Company ("ldaho Powed'or "Company') hereby respectfully submits
the following Reply Comments in response to Comments filed by Staff ("Staff') of the
ldaho Public Utilities Commission ("Commission'), the City of Boise ('Boise City), Clean
Energy Opportunities for ldaho ('CEO"), ldaho Conservation League ("!CL'), Walmart lnc.
("Walmart"), and the public in the matter of the Company's application to expand optional
customer clean energy offerings through the new Clean Energy Your Way ('CEYW')
program. ldaho Power submits these Reply Comments pursuant to the Notice of Modified
Procedure, Order No. 35338, issued by the Commission on March 9,2022.
The Company is grateful for the opportunity to offer Reply Comments in this case
and is especially thankful for the broad engagement by stakeholders and the public. The
IDAHO POWER COMPANY'S REPLY COMMENTS - 1
level of interest in this case speaks to the importance of expanding clean energy options
for customers.
Development of the Company's proposed CEYW program began in response to
customer requests in 2019. At that time, ldaho Power set out to build off its successful
Green Power Prograrn-now in its 20th year-and design an expanded 'menu" of clean
energy offerings that would appeal to customers of all sizes in their pursuit of clean energy
objectives.
After more than two years of customer and stakeholder engagement, as wel! as
industry research, ldaho Power designed a three-pronged offering to include 1)
broadened Renewable Energy Certificate ("REC) purchase options under CEYW -
Flexible, 2) a new subscription option for customers under CEYW - Subscription, and 3)
a large customer clean energy option under CEYW - Construction.
Staff and intervenors in this case are generally supportive of ldaho Power's
proposed CEYW offerings. ln its Gomments, Staff recommends the Commission approve
the Company's proposed programs in conjunction with additional reporting and public
outreach requirements. lntervenors in this case also broadly recommend approval,
although some request additional study, program modifications, and alternative
considerations. Staffs ten (10) specific recommendations,l as well as intervenor and
public suggestions, are addressed in detail in the sections below.
Notably, the comments all express a sense of urgency about developing more
renewable energy and expanding ldaho Power customers' access to that energy. The
comments also recognize that the Company's proposal is an important step toward
1 Commission Staff Comments, pg. 2-3.
IDAHO POWER COMPANY'S REPLY COMMENTS - 2
advancing clean energy in ldaho and in furthering the clean energy objectives of ldaho
Power's customers. Stakeholders commend the Company for proposing programs
informed by customer feedback and consultation, and for seeking broad customer access
to clean energy through a range of CEYW program options.
CEO noted in its Comments that "overall [it] congratulates ldaho Power for acting
upon the broad range of their customers' interests in clean energy and undertaking a
comprehensive approach to addressing those concerns as reflected in the CEYW
program.'2 Similarly, Boise City stated in its Comments: "Boise City commends the
Company on its responsiveness to customer clean energy needs, identiffing
opportunities for all customers to participate in the clean energy transition, and
collaboration with interested customers while developing potential offerings."3
Since ldaho Power filed its Application for the CEYW program in December of
2021, the Company has continued to receive customer inquiries and growing interest in
the new proposed clean energy program. Evidence of this customer demand for clean
energy options can be found in the two CEYW - Construction agreements that have
already been filed with the Commission for Brisbie, LLC (Case No. !PC-E-21-42) and
Micron Technology, lnc. (Case No. IPC-E-22-06).
Considering the supportive Comments from Staff and intervenors, as well as the
high level of customer interest, the Company respectfully requests that the Commission
approve the CEYW program as proposed, with acceptance of certain Staff and
stakeholder recommendations, as detailed below.
2 Clean Energy Opportunities for ldaho CCEO') Comments, pg. 2.
3 City of Boise (.Boise City') Comments, pg. 2.
IDAHO POWER COMPANY'S REPLY COMMENTS - 3
I. BACKGROUND
On December 2,2021, ldaho Power filed its Application with the Commission for
authority to expand optional clean energy offerings for customers under the new CEYW
program. ln its Application, the Company specifically asked for authority to: 1) name a
new suite of offerings under the title Clean Energy Your Way, 2) expand procurement
options for RECs under the new name Clean Energy Your Way - Flexible, 3) establish
a regulatory framework for a future voluntary subscription green tariff named CEYW
- Subscription, 4) offer a tailored renewables offering to the Company's largest
customers (Special Contract and Schedule 19) called CEYW - Construction, and 5)
procure CEYW-associated resources outside the Commission's current competitive
procurement req uirements.
At the Commission's March 8, 2022, Decision Meeting, the public comment
deadline in this case was set for May 12, 2022. The Company received comments from
four intervenors in the case: CEO, the City of Boise, lCL, and Walmart. The Company
also received numerous public comments, including from the ldaho Organization of
Resource Councils, and the Blaine County Clean Energy Coalition, which represents the
City of Bellevue, the City of Hailey, and the City of Ketchum (collectively, the "Blaine
County Parties"). The lndustrial Customers of ldaho Power intervened in the case but did
not file comments.
II. NEW CEYW PROGRAM
The Company's existing Green Power Program is established and operational, but
the program is limited to RECs, which do not fully support the broader sustainability goals
of some of ldaho Power's customers. To address these Iimitations, ldaho Power sought
IDAHO POWER COMPANY'S REPLY COMMENTS -4
to rebrand its current offering with a new, broader program name: CEYW. The umbrella
CEYW name is intended to communicate ldaho Power's existing and proposed new
offerings. Not only does the name change better align with ldaho Power's "Clean Today.
Cleaner Tomorrow.@" goal, but consistent branding wil! allow customers and
stakeholders to clearly connect the Company's clean energy goal and its associated
programmatic activities to their own clean energy objectives.
ln its Application, the Company asked for authority to rename Schedule 62 Green
Energy Purchase Program Rider (Optional) to Schedule 62 CIean Energy Your Way
Program (Optional). Staff recommends approval of this change in its first
recommendation.a
III. CEYW. FLEXIBLE
The Company also proposed renaming its REC program from the Green Power
Program to CEYW - Flexible. From the customer's perspective, the Flexible option will
operate in the same manner as its predecessor; the only substantive change is the name.
ldaho Power also requested approvalto expand its REC purchase options-to include a
limited bulk purchase option and a REC "sleeve" option-to keep up with demand and to
have greater flexibility to satisff customers' near-term clean energy goals with RECs.
ln its second recommendation, Staff supports approval of the maintenance and
expansion of REC procurement under the name CEYW - Flexible.s ldaho Power
appreciates Staffs review and recommendation to allow procurement of third-pafi RECs.
ln the northwest United States, RECs are often in high demand and, when Company-
owned RECs sell out or the price is outside of a customer's financial means, purchasing
4 Staff Comments, pg. 2.
5 ld.
IDAHO POWER COMPANY'S REPLY COMMENTS - 5
RECs from an outside pafi can become complicated and intimidating to customers that
are not wellversed in the process. By allowing ldaho Power to procure third-party RECs
on their behalf, these customers can benefit from Idaho Power's experience with REC
contracts to source third-party RECs.
Staffs third recommendation is to require the Company to file an annual CEYW -
Flexible report prior to the Company's annual Power Cost Adjustment ('PCA') filing.o Staff
also recommends four new report components: 1) information on advanced procurement
of RECs under the limited bulk purchase arrangement and if any of those purchases will
carry over into the next year; 2) information on all tailored agreements for third-party REC
procurement (amount, price, monthly revenue and expenses, and proof of separate
accounting treatment); 3) report any balance of uncommitted/excess funds from REC
sales to be carried over into the next year; and 4) provide the monthly balance of the rider
for Schedule 62.7
ldaho Power appreciates Staffs perspective that changes to REC procurement
should be accompanied by additional reporting requirements, and the Company can
commit to report the additional information requested. However, with respect to report
timing, the Company does not believe Staffs proposal adequately considers the existing
timing of the Green Power Program report or the timing of the annual PCA filing.
Therefore, the Company does not support an annualfiling requirement that comes earlier
in the year.
Beginning in 2018, the Company began submifting biennial reports for Schedule
62. Later, in 2020, reporting grew to include the Large Renewable Energy Purchase
6 ld.
7 ld., p9.16.
IDAHO POWER COMPANY'S REPLY COMMENTS - 6
Option. These reports are submitted no later than August 29 every other year. Staffs
recommendation to change the timing and frequency of Schedule 62 reporting to occur
annually and before/with the annual PCA filing (due April 15) poses two significant
challenges.
First, the timing of annua! REC retirements does not align with the PCA filing due
date. RECs are created by a tracking authority, such as WREGIS, 90 days after the end
of the generation period. This means December REC generation will not be confirmed
until early April in the following year. Once RECs are confirmed, the REC seller then
needs time to perform the REC transfers or retirements and prepare confirmation reports
or letters for the REC buyers. Company-owned REC sales revenue flows to the PCA
when the REC is retired. PCA sales allocation for a given month is determined within the
first couple of weeks in the following month. For RECs retired in March, the PCA sharing
amountwill not be known untilearly to mid-April. This means the data for CEYW reporting
will be incomplete if the reporting deadline is moved to April 15 or earlier.
Second, the first quarter of every year is labor intensive due to the required tasks
associated with REC program management. These time-sensitive tasks, such as
contractual documentation and reporting and annual audit requirements, are paramount
to the successful execution of prudent program and REC management. To maintain
efficient use of resouroes, the Company proposes to continue the current timeline of
reporting, with a delivery date of no later than August 29.8
Because of the significant amount of work required to prepare the reports and the
time savings realized for combining years, ldaho Power recommends preserving the
8 Order No. 33570, issued August 29,20'16 approved the biennial reporting requirement for the Green
Power Program.
IDAHO POWER COMPANY'S REPLY COMMENTS - 7
biennial reporting cycle, which the Company believes has proven effective and sufficient.
lf, however, the Commission deems the shift to annual reporting necessary, the Company
would respectfully request that the annual reporting deadline stay consistent with the
existing August deadline, for the reasons noted above.
IV. CEYW - SUBSCRIPTION
ln its Application, the Company proposed a green tariff-style subscription option
(CEYW - Subscription), the design and development of which would proceed in two
phases: a first phase seeking authority to establish the foundational concepts of the
program structure and design (represented by ldaho Power's Application in this matter),
and a second phase<ccurring after Commission approval of the first phase-to select
a program resource, establish program costs and credits, and determine program
accounting, among other program details.
lntervenor comments are generally supportive of the Subscription offering, with
several parties recommending specific modifications or alternatives, In its fourth
recommendation, Staff proposes allowing the Company to "proceed" with the general
framework and concept for the Subscription (recommendation four), '\rvith parameters
subject to change pending Commission approval when the Company files the second
phase."e The Company supports Staffs recommendation and finds it consistent with the
Company's initial request.
ldaho Power understands the concerns voiced by Staff and intervenors that not
enough detail was provided about the Subscription to fully assess the offering or
determine any customer impact. The Company finds these concerns valid but reiterates
eStaff Comments, pg. 2.
IDAHO POWER COMPANY'S REPLY COMMENTS - 8
that the Company's Application represents only the first phase of the Subscription, while
the second phase will be dedicated to vetting the details and impact of the CEYW -
Subscription.
Considering that a resource will need to be procured to support the Subscription,
the Company's proposed two-phase process is intended to ensure it first has necessary
approval to offer a subscription-style program before moving to the time- and resource-
intensive secondary step of resource procurement. Further, the two-phase approach is
consistent with the order in which other utility subscription-style programs have been
introduced, vefted, and approved by regulators.
ln addition to concerns regarding lack of detail with respect to the Subscription,
several key themes emerged in Comments. The Company addresses these themes in
turn below but again notes that many of these issues will be fully vetted in the second
phase fi!ing.
A. Proqram Gosts and Proposed Charqe and Credit
Staff, Boise City, lCL, Walmart, and the Blaine County Parties all raise issues
related to Subscription program costs, as well as the proposed program charge and
credit. Staff is rightly concerned about ensuring that the Subscription program does not
harm non-participating customers. ldaho Power agrees that this is a primary objective of
the Subscription and, as such, intends to provide analysis in the second phase filing to
demonstrate that the Subscription will not adversely impact non-participating customers.
Staff also recommends that the Company work with Staff in advance of the second
phase filing to "discuss potential methods that can be used to calculate a reasonable
IDAHO POWER COMPANY'S REPLY COMMENTS - 9
avoided cost that benefits potential participants and will not harm non-participants."l0The
Company supports this approach and looks forward to working with Staff to address
appropriate avoided cost methods with respect to the Subscription resource.
ICL and Walmart share concerns that the Subscription program credit will never
exceed the program charge.11 While specific program costs and credits have yet to be
determined, the Company reaffirms that the Subscription is intended as a voluntary
customer program. As such, participation will come at a cost to customers. Stated
differently: The Company will not pay customers to participate, which is what would occur
if the program credit were to exceed the program charge. Paying customers to participate
would result in shifting of costs to non-participants-an outcome the Company has stated
it views is unacceptable for a voluntary offering.
Boise City, lCL, Walmart, and the Blaine County Parties each note that cost and
credit elements-including proposed administrative and marketing expenses-should be
thoroughly assessed.l2 The Company agrees. The second phase filing will offer a full
opportunity to discuss proposed program charges and credits, as well as administrative
and marketing expenses.
B. Subscriotion Amounts and Terms
Several intervenors propose specific modifications to the Subscription program
parameters. Walmart proposes allowing customers to subscribe at any percentage up to
100 percent of their average historic annual energy use, as opposed to the 50 and 100
loStaff Comments, pg. 7.
11 ldaho Conservation League CICL) Comments, pg. 4; Direct Testimony and Exhibits of Steve W. Chriss
on behalf of Walmart lnc., pg. 16.
12 Boise City Comments, pg. 2; ICL Comments, pg. 4; Chriss Direct Testimony, pg. 15; Blaine County
Parties Comments, pg. 3.
IDAHO PO\A'ER COMPANY'S REPLY COMMENTS - 10
percent proposed by the Company.l3 Similarly, the Blaine County Parties suggest adding
25 and 75 percent subscriber options to facilitate greater customer access to the
Subscription.la
The Company appreciates these suggestions and supports adding 25 and 75
percent subscriber levels, thereby creating a total of four subscriber possibilities-2S, 50,
75, and 100 percent of a customer's average historic annual energy use. The Company
does not, however, support Walmart's proposalto allow any subscriber percentage up to
100 percent of their average prior year use. The Subscription amounts are intended as
reasonable approximations of a customer's energy use, and the Company believes that
the majority of eligible customers will fit within at least one of the four subscription size
categories described above. Creating an unlimited number of subscriber levels, as
Walmart suggests, wi!! result in unnecessary administrative burden.
Walmart also proposes an additional term Iength of 15 years to accompany the
proposed month-to-month, 5-, 10-, and 2}-year term lengths.ls The Company supports
this expansion of term lengths and agrees thatthe span between 10 and 20 years is large.
A 1S-year term may a!!ow access to customers that are prevented from or reluctant to
commit to a 2O-year term. ln adding this subscriber term length, the Company would
propose to also apply a Term Adjustment Charge, albeit small, to participants with 15-
year terms.
Additionally, Walmart suggests pro-rating customer subscriptions to match
available program capacity.lo The Company considers pro-rating a good idea to keep the
13 Chriss Direct Testimony, pg. 7.
1a Blaine County Parties Comments, pg. 3.15Chriss Direct Testimony, pg. 17.
1a ld., pg. 14.
IDAHO PO\A'ER COMPANY'S REPLY COMMENTS - 11
program fully subscribed and believes that it can do so effectively in the majority of cases
with the four subscriber amounts proposed above. Should the historic average energy
use of a customer in the Subscription queue exceed Subscription resource availability,
the customer may subscribe at one of the Iesser amounts. For example, if 100 percent of
a customer's historic prior year annual energy use exceeded available capaci$ in the
program, the customer could subscribe at a lower level. The Company believes that these
circumstances will be Iimited and exist only at the margin of filling the program to capacity.
The Company may consider addressing these situations on a case-by-case basis to
ensure that the next customer in line may participate, rather than skipping over them due
to size constraints.
Lastly, Walmart suggests that the individual customer cap of 15 percent of program
capacity may be limiting for customers of certain sizes.17 The Company acknowledges
this could be a barrier to participation by some customers and is open to discussing a
larger cap on subscription limits within the second phase of this docket.
C. Subscriotion Resource Procurement
ln ldaho Powe/s Application, the Company requested authority to waive the
Commission's competitive resource procurement requirements for Subscription
resource(s). Staffs tenth and final recommendation is to approve the Company's request
with respect to waiving the Commission's competitive bidding requirements.ls Staff goes
on to note that the Company should "perform a thorough procurement process for the
renewable resource(s), which Staff will analyze in Phase ll."1e
17 Chriss Direct Testimony, pg. 20-21
18 Staff Comments, pg. 3.
1s ld.
IDAHO POWER COMPANY'S REPLY COMMENTS - 12
Additionally, Boise City supports a limited exemption of the Commission's
competitive bidding requirements for the purpose of expediting the Subscription and
Construction options.2o Boise City at 3, Walmart does not offer a position on competitive
bidding requirements, but, like Boise City, notes that'speed to market for the program"
and 'competitive pricing" are both "critical" and that the Company should strive to procure
the "lowest possible cost resources brought to the offering.'2l Walmart at 6.
The Company appreciates recognition that the existing competitive bidding
requirements may delay CEYW program implementation. The Company will take great
care to identiff and secure the best possible resource(s) for the CEYW program
regardless of any limited waiver of competitive bidding requirements. ldaho Power fully
intends to conduct a thorough procurement process, as it has done through its recent
resource Requests for Proposals.
D. Low-lncome Customer Particioation
Severalstakeholders, including Boise City, !CL, and the Blaine County Parties, as
well as public commenters, express a desire to have the CEYW program serve low-
income customers. ICL asserts that the proposed Subscription program "does not provide
a comprehensive Iow-income customer program that will improve access to clean energy
for all customers."22
Boise City suggests that the Company propose a "mechanism" to make
Subscription participation "feasible for customers with low incomes" as part of the second
phase filing.23 However, ICL argues that, even with a low-income carveout or mechanism
20 Boise City Comments, pg. 3.
21 Chriss Direct Testimony, pg. 6-7
22 ICL Comments, pg. 6.
23 Boise City Comments, pg. 3.
IDAHO POWER COMPANY'S REPLY COMMENTS - 13
in the Subscription, the proposed program pricing-that is, an added Term Adjustment
Charge for participants on lesser terms-'presents yet another barrier to low-income
participation."2a
ldaho Power recognizes that equitable program access, and specifically low-
income access, is a priority for many stakeholders. \A/hile ldaho Power maintains that
CEYW is a voluntary premium program, the Company also acknowledges that there may
be successful mechanisms to facilitate participation by low-income customers. The
Company suggests that this topic be addressed in a future stakeholder workshop, in
which participants can present and discuss ideas for such a mechanism and how it might
be used in a way that would ensure no impact to non-participating customers.
V. CEYW - CONSTRUCTION
In its Application, ldaho Power identified the need for a tailored renewable option
for its largest customers-specifically, Schedule 19 and SpecialContract customers. The
Company developed and proposed the CEYW - Construction option to help meet the
clean energy objectives of these large customers. The Company requested Commission
approval of the CEYW - Construction framework and the proposed modifications to
Schedule 62 that outline Construction arrangements and allow for Schedule 19
participation.
A. Staff Recommendations
Staffs sixth recommendation is to approve the CEYW- Construction as proposed,
with additiona! requirements to: 1) veriff the cost-of-service rates used to recover costs
from each Construction customer;2) evaluate the effect of increased energy priced at
2a tCL Comments, pg. 7
IDAHO PO\A/ER COMPANY'S REPLY COMMENTS - 14
avoided cost in the Company's overall net power costs and evaluate alternative methods
of determining avoided cost of energy; and 3) submit every Renewable Construction
Agreement and associated Power Purchase Agreement (.PPA") to the Commission for
review and authorization.2s
The Company supports the first two proposed requirements. Cost-of-service-
based rates are a cornerstone of utility ratemaking and are equally important in the
context of a CEYW - Construction arrangement. The Company agrees with Staff that
these customers should pay rates that reflect the costs to serve them. The Company also
supports an evaluation of avoided costs and finds this recommendation consistent with
Staffs other recommendation, addressed in Section lV of these Reply Comments, to
discuss and evaluate appropriate avoided cost pricing associated with the Subscription
option.
With respect to the third proposed requirement pertaining to each individual
Renewable Construction agreement, the Company has already stated affirmatively that
each arrangement will be filed with the Commission. However, some of these
arrangements may necessitate more than one resource. As a result, the Company
respectfully disagrees with Staff and does not believe that each PPA associated with a
Construction arrangement should be individually authorized by the Commission.
As the Company has already stated in the case of Brisbie, LLC, the selection, size,
and other details of a Construction customer's supporting resources are not necessary
for the Commission to review so long as the customer pays in full for those resources26-
which is precisely what each Construction arrangement will require.
25Staff Comments, pg. 3.
26 Case No. IPC-E-2142, ldaho Power Company's Reply Comments, pg.1 5-16 (May 6, 2022|
IDAHO PO\A'ER COMPANY'S REPLY COMMENTS - 15
Staff also proposes another set of conditions with respect to CEYW - Construction
program approval.2T These conditions include: a) ensuring that all Construction-related
renewable resource costs are passed through to the CEYW - Construction customer; b)
hourly netting of the Construction customer's energy consumption against the renewable
resource(s) generation; c) net consumption (or energy supplied by the Company) based
on cost-of-service rates; and d) net production exported to the Company's system should
be valued based on avoided cost.
The Company agrees and supports the first three conditions (a, b, and c, above).
These conditions are consistent with the Company's description of CEYW - Construction
program mechanics, as wel! as the two Construction agreements currently before the
Commission.2s However, the Company disagrees with Staff that net production (that is,
renewable energy in excess of a customeds load in a given hour) should always be priced
at avoided cost. lnstead, the Company recommends that the Commission preserve the
flexibility initially proposed in its Application and allow the credit for excess renewable
resource generation to be negotiated as part of each Construction arrangement. Each
arrangement willstill be put before the Commission for review and authorization, allowing
this particular crediting element a full opportunity for review in each unique arrangement.
B. lntervenor Recommendations
While Boise City recommends Commission approval off CEYW - Construction as
proposed, CEO and Walmart offer their support with additional recommendations or
modifications.
CEO argues that excess renewable energy generation should not be priced based
27 Staff Comments, pg. 9.
28 Case No. IPC-E-21,42, ldaho Power Company's Reply Comments, p9.15-16 (May 6,2022)
IDAHO POWER COMPANY'S REPLY COMMENTS - 16
on an IRP-generated market forecast but should be based on actua! hourly market prices
and cites the Energy lmbalance Market ("ElM") as a reasonable price option.2e CEO at 7.
The Company appreciates CEO's argument and finds its points logica!. Actual market
prices are surely the best way to compensate Construction customers for a market sale
of their excess renewable energy generation. But the Company cannot state with certainty
whether any excess renewable energy generation in a given hour will result in system
use or a market sale. As a result, the Company finds a market forecast from the IRP to
be the most reasonable price stream. However, the Company reaffirms its comment
above and recommends that the Commission preserve the flexibility in Construction
arrangements to individually determine the appropriate compensation mechanism for
excess renewable energy generation, should it exist.
Walmart asserts that the Construction option should be available to "commercial
and industrial customers who can aggregate more than 5 MW of load across accounts in
ldaho Power's service territory regardless of service schedule."30 The Company strongly
disagrees with this suggestion for two reasons. First, customer aggregation violates the
conditions of ldaho Powe/s Rule C.31 Second, the Company designed the CEYW -
Construction option for its largest customers. The development of Renewable
Construction Agreements is intensive and time consuming-for the customer, the
Company, and the Commission-and ldaho Power does not believe it is feasible or
practical to extend the option to its smaller customer classes. For example, Schedule 9,
the customer class most likely to apply to individua! Walmart facilities, contains
2eCEO Comments, p9.7.
30 Chriss Direct Testimony, pg. 21.
31 |.P.U.C. No. 29, Tariff No. 101, Rule C
IDAHO POWER COMPANY'S REPLY COMMENTS - 17
approximately 37,000 customers. Even if only 1 percent of those customers pursued the
Construction option, the Company would still need to negotiate hundreds of agreements.
As an alternative to the tailored Construction option, the Subscription option was designed
to give customers in smaller rate classes access to clean energy options. The Company
is not insensitive to Walmart's corporate objectives, though, and believes that direct
consultation between the Company and the customer may be valuable for determining
how Walmart can best meet its corporate objectives for its facilities in ldaho.
C. Construction Resource Procurement
Like its request in the Subscription option, the Company asked the Commission
for authority to procure Construction-specific renewable resources without undertaking
the Commission's competitive bidding requirements. Staff and Boise City support the
Company's request, as discussed in Section lV of these Reply Comments.
VI. WORKSHOPS AND CEYW REPORTING
Staff and stakeholders propose several workshops to facilitate education,
transparency, and community collaboration around clean energy options. Additionally,
Staff proposes new CEYW reporting requirements in the PCA filing. The Company
add resses these recommendations below.
A. Workshops
Staffs seventh recommendation is to require the Company to host a workshop to
evaluate the PCA treatment of CEYW offerings, including how system-generated RECs
are passed on to CEYW customers in the PCA, prior to the Company's next general rate
case ("GRC"1.sz The Company would be happy to host a workshop before the Company's
32 Staff Comments, pg. 3.
IDAHO POWER COMPANY'S REPLY COMMENTS - 18
next GRC to discuss the PCA treatment of CEYW offerings.
As the Company noted in IPC-E-2142,33 the Company disagrees with Staffs
inference that CEYW participants should not receive the benefit of system-generated
REC sales that pass through the PCA. Under the Company's REC Management Plan, all
Company-owned RECs (including RECs from PURPA projects) are sold, with proceeds
passing through the PCA. That is, the proceeds from REC sales result in a reduction of
power supply costs. CEYW participants will not be different from other customers-they
will continue to pay for energy service from ldaho Power. These customers should have
the same right to a PCA reduction as every other customer. The choice to participate in
a CEYW program should not penalize this subset of customers from experiencing the
same reduction of power costs enjoyed by all customers for energy services they take
from ldaho Power. \Mile ldaho Power would be happy to address REC-related
transactions and PCA impacts of "system-generated RECs," the Company does not
believe there is anything to evaluate on this topic. Reduced power supply costs from ldaho
Power REC sales should be enjoyed and shared by all customers.
Staff also recommends, as its eighth recommendation, that the Company hold a
workshop to discuss accounting treatment of costs, benefits, and loads for all CEYW
offerings prior to the next GRC.34 The Company can certainly hold a workshop on these
topics, recognizing that different CEYW offerings will commence at different times in the
future. As a result, the Company can, at a minimum, hold a workshop before the next
GRC that addresses the CEYW offerings that are active at that point in time.
lntervenors also suggested workshops/workgroups to continue collaboration
33Case No. IPC-E-2142,ldaho Power Company's Reply Comments, pg. 14-15.il Staff Comments, pg. 3.
IDAHO POWER COMPANY'S REPLY COMMENTS - 19
between the Company, customers, and stakeholders. Specifically, Boise City
recommends working "collaboratively with stakeholders throughout the development and
filing of Phase 11 of the Clean Energy Your Way - Subscription offering...'35 CEO
suggests that "Staff establish and facilitate Workgroup meetings" to address the broad
issues encompassed in the CEYW docket, including the development of the Subscription
in the second phase, alternatives for REC certification, and the Company's near-term
capacity deficiency, among other issues).36
ldaho Power agrees that workshops leading into the second phase of the
Subscription will be valuable to discuss and build consensus around program details in
advance of the filing. The Company also sees a natural place within those conversations
for some of the broader topics identified by CEO. However, the Company notes that
working groups are typically Company-led (as opposed to facilitated by Staff). Given that
ldaho Power needs to develop the program that will be presented in a future filing, the
Company thinks the workshop organization and facilitation should remain with the
Company, as it does with other advisory groups, such as the IRP Advisory Council and
the Energy Efficiency Advisory Group.
B. CEYW Reportinq
Staffs ninth recommendation is to have the Company include supplemental
material with each PCA filing. Specifically, Staff recommends five additional reporting
requirements: 1) cost information that flows through the PCA; 2) the consumption and
generation of renewable resources serving CEYW - Construction arrangements; 3)
annual CEYW - Construction customer load forecasts compared to these customers'
35 Boise City Comments, p9.4.
30 CEO Comments, pg. 7-8.
IDAHO POWER COMPANY'S REPLY COMMENTS - 20
annual generation forecast on a monthly basis; 4) annual CEYW - Subscription
enrollment; and 5) forecasted Subscription enrollments and load.37
ldaho Power considers these additional reporting requirements reasonable.
However, the Company believes that, with the exception of the first item (cost information
flowing through the PCA), allthe requested information is better placed inside the future
CEYW reporting requirement-the current Green Power Program biennia! report that will
be built out to include comprehensive CEYW information. Items two through five have
little bearing on the PCA itself and, as a result, could unnecessarily complicate and
expand an already complex filing that is processed in an expedited fashion. The
Company, therefore, recommends that the Commission approve these reporting
requirements but move them to the future CEYW report.
VII. PROPOSED PROGRAM MODIFICATIONS AND ALTERNATIVES
Many stakeholder comments offer suggestions for program modifications and/or
program alternatives. These suggestions are addressed in turn below.
A. Communitv Solar
Several intervenors, as well as the public, have called on ldaho Power to re-
examine community solar as part of the CEYW program. Specifically, ICL asks the
Commission to require ldaho Power to begin development of a customer-owned
community solar program.3s
With respect to a community solar concept, the Company developed the CEYW
offerings with the goa! of addressing the key limitations of the now-defunct Community
Solar Pilot Program, such as the upfront investment component. The Company considers
37 Staff Comments, pg. 3s ICL Comments, pg. 11
IDAHO POWER COMPANY'S REPLY COMMENTS - 21
the resulting CEYW program options sound, reasonable, and based on successful
models from other utilities. A community-owned solar development is simply beyond the
scope of the Company's specific CEYW requests before the Commission.
However, the Company recognizes that community-owned projects are of interest
to various stakeholders and, therefore, can commit to hosting a workshop with interested
parties to examine and better understand how stakeholders conceive of such an
arrangement.
B. CEWI and OnSite Generation
Several stakeholders, primarily CEO and lCL, identiff a connection between
CEYW and customer on-site generation. CEO suggests that on-site generation
resources could be interpreted as "community" resources, which the Company could
aggregate and use as resources for the Subscription or Construction options.3e Similarly,
ICL suggests that the Company should explore how the CEVW can help facilitate
distributed generation.40 ICL also requests that, if the Subscription leverages a solar
resource, that the Company use the forthcoming Value of Distributed Energy Resources
study that will specifically address the costs and value of customer on-site generation.al
Additionally, the BIaine County Parties discuss the importance of distributed energy
resources to meeting "local, national, and global efforts to mitigate climate change
impacts" and encourage the Company to find means of working with municipalities to
accomplish their specific energy goals, including through the development of community-
owned resources.a2
3eCEO Comments, p9.5.{ ICL Comments, pg. 11.
11 ld.
a2 Blaine County Parties Comments, pg. 3.
IDAHO PO\A/ER COMPANY'S REPLY COMMENTS - 22
The Company appreciates these stakeholder suggestions. On-site generation is
clearly a priority for some stakeholders. Recognizing this fact, the Company specifically
designed the CEYW offerings to accommodate customers with on-site generation.
CEYW offerings can be considered additive for customers who either do not have a
facility that can accommodate on-site solar or who require renewable energy beyond
what an on-site generation project can accommodate.
The selection of the Subscription resource has not occurred yet. As such, the
Company cannot rule out the possibility that the resource could be distributed-that is,
not transmission connected. ln selecting a Subscription resource, the Company will
consider multiple options and, ultimately, seek the most cost-effective resource that will
allow the most customers to subscribe.
ldaho Power is unclear, though, how customer on-site generation can serve as
potential CEYW resources. The Company, by definition, does not own or control on-site
generation resources and therefore cannot assign other customers the costs, credits, or
RECs associated with those resources.
However, the Company recognizes there may be creative ways to work with select
groups of existing or future on-site generation customers-such as irrigators-to develop
CEYW resources. The Company proposes that stakeholders could present alternative
program ideas and concepts in a workshop to determine how such alternative
arrangements might work under the CEYW umbrella.
C. RECs
Walmart and CEO provided additional REC-related recommendations or
considerations. While it does not oppose the Company's proposed REC treatment for the
IDAHO PO\A'ER COMPANY'S REPLY COMMENTS - 23
CEYW - Subscription option, Walmart notes that the Company should be required to
"make attestations available on an annual basis to participating customer who choose to
have the Company retain and retire the RECs.'43 The Company believes it has accounted
for these sorts of special requests in its proposed Subscription program parameters, in
which the Company states: 'Different REC treatment would be considered on a case-by-
case basis at the request of individual customers.'4
CEO, meanwhile, takes a broader view of RECs, arguing that REC certification
may not be "essential" for all CEYW participants.as ldaho Power agrees, which is why the
Company's Subscription proposal involves retaining and retiring RECs on behalf of
customers as the default, as opposed to transferring all RECs to individual customers
through an established REC tracking system such as WREGIS.
CEO's REC recommendations, though, seem to suggest alternatives to WREGIS
as a way to maneuver around established systems of buying, selling, and tracking
ownership of RECs. CEO states: "CEO believes CEYW programs should consider both
the RECs as wel! as exports from customers with renewable self-generation as sources
of clean energy to meet CEYW customer needs.'a6
As discussed above, the Company does not own or operate on-site generation
resources and, as such, has no ownership claims over those resources or their
environmental attributes. The Company is not aware of any on-site generation or net
metering arrangements in which a customer's export of energy back to the utility involves
€Chriss Direct Testimony, pg. 7{Application, Exhibit 1.
15CEO Comments, p9.4.
46ld.
IDAHO POWER COMPANY'S REPLY COMMENTS.24
the transfer of the RECs or environmental attributes of those exports. ln bundled REC
transactions, including on-site generation, the customer that pays for the resource retains
the RECs or environmental attributes associated with those resources. While the
Company appreciates CEO's creativity with respect to RECs, the Company cannot
support its position.
vilr. coNcLUsloN
ldaho Power again would like to thank Staff, stakeholders, and the public for their
engagement in the Company's effort to expand optional clean energy programs for
customers. The Company supports Staffs broad recommendation to approve the CEYW
program as proposed. Additionally, ldaho Power supports several of Staffs and
stakeholders' recommendations, but respectfully disagrees with a few recommendations
and proposals. The Company's positions are summarized below by topic.
CEYW General
. Staff Recommendation 1: The Company supports Staffs recommendation
to establish the CEYW program name.
CEYW - Flexible
. Staff Recommendation 2: The Company supports Staffs general
recommendation to authorize the Flexible program name, as well as the
Company's ability to expand REC procurement.
. Staff Recommendation 3: The Company agrees to Staffs additional REC
reporting requirements but respectfully disagrees with its recommendation
to require REC reporting in advance of the annualPCAfiling. The Company
instead requests that the Commission approve the additional reporting
IDAHO POWER COMPANY'S REPLY COMMENTS - 25
elements but preserve biennial reporting and the existing August 29 report
deadline.
CEYW - Subscriotion
o Staff Recommendation 4: The Company supports Staffs recommendation
to allow the Company to proceed with the general framework of the
Subscription.
o Staff Recommendation 5: The Company agrees to work with Staff to
discuss potentia! avoided cost methods with respect to the Subscription.
o Stakeholder-Proposed Modifications and Considerations: Recognizing
that ldaho Power did not ask the Commission for approval of specific
Subscription program design, but rather the authority to proceed with the
concept into a second phase filing, the Company nevertheless supports the
Blaine County Parties'suggestion to allow additionalsubscriber amounts of
25 and 75 percent of a custome/s historic average annualenergy use. The
Company also supports Walmart's recommendation to add a 1S-year
subscriber term. Finally, the Company proposes collaborating with
stakeholders in a workshop to discuss options for facilitating low-income
access to the Subscription.
CEYW - Construction
. Staffs Recommendation 6: The Company supports Staffs high-level
recommendation to approve the proposed CEYW- Construction framework
and modifications to Schedule 62.
o Staff Recommendation 6(a): The Company also agrees to the
IDAHO PO\A/ER COMPANY'S REPLY COMMENTS - 26
additional requirements to veriff the use of cost-of-service based
rates for ldaho Power-supplied energy in each Construction
arrangement.
o Staff Recommendation 6(b): The Company also agrees to take a
closer look at avoided costs before more CEYW program customer
arrangements are developed.
o Staff Recommendation 6(c): The Company agrees with Staff that
each Renewable Construction Agreement should be submitted to the
Commission for review and approval, as was proposed by the
Company. However, ldaho Power disagrees with Staffs belief that
Construction arrangements with multiple resources must require
each individual PPA to be approved by the Commission.
Additional Staff Conditions: Staff proposes four additional conditions as
part of recommending approval of the CEYW - Construction option: a)
ensuring that all Construction-related renewable resource costs are passed
through to the CEYW - Construction customer; b) hourly netting of the
Construction custome/s energy consumption against the renewable
resource(s) generation; c) net consumption (or energy supplied by the
Company) based on cost-of-service rates; and d) net production exported
to the Company's system should be valued based on avoided cost. The
Company agrees to Staffs conditions (a), (b), and (c), but respectfully
disagrees with condition (d). The Company recommends that the
Commission preserve the flexibility for excess renewable energy generation
a
IDAHO POWER COMPANY'S REPLY COMMENTS.2T
compensation to be negotiated within each individual Renewable
Construction Agreement, each of which will be filed with the Commission
for review and approval.
. Stakeholder-Proposed Construction Recommendations: The Company
respectfully disagrees with CEO's recommendation to always use EIM as
the basis for any excess renewable energy generation crediting. The
Company also disagrees with Walmart's recommendation to allow
aggregation of customer load sites to allow access to the Construction
option.
Workshops and Reportinq
o Staff Recommendations 7 and 8: The Company agrees to hold a
workshop on the PCA treatment of CEYW offerings and a workshop in
advance of the next GRC on the accounting treatment of costs, benefits,
and loads for all CEYW offerings. ln Section Vl, the Company explains why
it disagrees with Staffs thinking on the evaluation of system-generated
RECs and their application to CEYW participants. Nevertheless, the
Company agrees to hold a workshop and present on the topic.
o Staff Recommendation 9: The Company agrees to provide supplemental
information (Staffs list a through e) on the CEYW program. However, Staff
recommends that all information be reported in the PCA filing. The
Company disagrees and, instead, recommends that only CEYW cost
information flowing through the PCA (item a) be incorporated into the PCA
filing. The remaining reporting requirements (b-e) are all better captured in
IDAHO POWER COMPANY'S REPLY COMMENTS - 28
the biennial CEYW report, as these elements do not have a direct
relationship to the PCA.
Addition al CEYW Recommendations and Altem atives
o Stakeholder-Proposed Recommendations: Several stakeholders and
members of the public request that the Company look at community-owned
solar as an option for the CEYW program. While this suggestion falls
outside the scope of ldaho Power's requests before the Commission, the
Company agrees to include the issue in a future stakeholder workshop.
Similarly, the Company agrees to facilitate a discussion of any synergies
between on-site generation and CEYW in a future workshop.
Resource Procurement
o Staff Recommendation 10: Finally, the Company supports Staffs
recommendation to allow Idaho Power to procure CEYW resources outside
the Commission current competitive bidding requirements.
Considering the Reply Comments herein, Idaho Power respectfully requests that
the Commission approve the proposed CEYW program along with the additional
considerations supported by the Company and listed in this conclusion.
Respectfully submitted this 2nd day of June 2022
rl (:,-){(*
for
LISA D. NORDSTROM
Attorney for ldaho Power Company
IDAHO PO\A'ER COMPANY'S REPLY COMMENTS - 29
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 2nd day of June 2022, I served a true and correct
copy of ldaho Power Company's Reply Comments upon the following named parties by
the method indicated below, and addressed to the following:
Gommission Staff
Dayn Hardie
Deputy Attorney General
ldaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg No.8,
Suite 201-A (83714)
PO Box 83720
Boise, lD 83720-0074
lndustrial Customers of ldaho Power
Peter J. Richardson
Richardson Adams, PLLC
515 N. 27th Street
P.O. Box 7218
Boise, lD 83702
Dr. Don Reading
6070 Hill Road
Boise, ldaho 83703
ldaho Conservation League
Benjamin J. Otto
Emma E. Sperry
ldaho Conservation League
710 N. 6th Street
Boise, lD 83702
Walmart, lnc.
Norman M. Semanko
Parsons Behle & Latimer
800 W. Main Street, Suite 1300
Boise, lD 83702
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IDAHO PO\A'ER COMPANY'S REPLY COMMENTS - 30
Walmart, lnc.
Vicki M. Baldwin
Parsons Behle & Latimer
201 South Main Street, Suite 1800
Salt Lake City, UT 84111
Steve W. Chriss
Director, Energy Services
Walmart, lnc.
City of Boise
Ed Jewell
Deputy City Attorney's Office
150 N. Capitol Blvd.
P.O. Box 500
Boise, lD 83701-0500
\MlGehl
Energy Program Manager
Boise City Department of Public Works
150 N. Capitol Blvd.
P.O. Box 500
Boise, lD 83701-0500
Clean Energy Opportunities for ldaho
Kelsey Jae
Law for Conscious Leadership
920 N. Clover Dr.
Boise, lD 83703
Courtney \Mite
Mike Heckler
Clean Energy Opportunities for ldaho
3778 Plantation River Drive, Suite 102
Boise, ID 83703
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IDAHO POWER COMPANY'S REPLY COMMENTS - 31
&r"J-
Stacy Gust, Regulatory Administrative
Assistant
IDAHO POWER COMPANY'S REPLY COMMENTS.32