20220719Comments.pdf

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An DACOf,PCompilY
.r. -l ,;r::- i t Fil tr: llrMegan Goicoechea A!!en
Corporate Counsel
[e-mail]
MGA:sg
Attachment
July 19,2022
VIA ELECTRONIC FILING
Jan Noriyuki, Secretary
ldaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg 8,
Suite 201-A (83714)
PO Box 83720
Boise, ldaho 83720-0074
Re Case No. IPC-E-22-12
In the Matter of Clean Energy Opportunities for ldaho's Petition for an Order
to Modiff the Schedule 84 100kW Cap & To Establish a Transition Guideline
for Changes to Schedule 84 Export Credit Compensation Values
Dear Ms. Noriyuki
Attached for electronic filing is ldaho Power Company's Comments in the above-
referenced matter.
lf you have any questions about the documents referenced above, please do not
hesitate to contact me.
Very truly yours,
Wloi0dw^00l0,n.,
Megan Goicoechea Allen
LISA D. NORDSTROM (lSB No. 5733)
MEGAN GOICOECHEA ALLEN (!SB No. 7623)
1221 West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
lnordstrom@idahopower. com
mooicoecheaa !len@ida hopower.com
Attorneys for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF CLEAN ENERGY
OPPORTUNITIES FOR IDAHO'S
PETITION FOR AN ORDER TO MODIFY
THE SCHEDULE 84 IOOKW CAP & TO
ESTABLISH A TRANSITION GU!DELINE
FOR CHANGES TO SCHEDULE 84
EXPORT CREDIT COMPENSATION
VALUES
Case No. IPC-E-22-12
IDAHO POWER COMPANY'S
COMMENTS
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ldaho Power Company ("ldaho Powe/' or "Company") respectfully submits the
following Comments in opposition to Clean Energy Opportunities for ldaho's ('CEO")
Petition ("Petition") and in support of the Company's Motion to Dismiss in the above-
entitled case pursuant to Rule 203 of the Rules of Procedure of the ldaho Public Utilities
Commission ("Commission") and the Notice of Modified Procedure, Order No. 35453,
issued by the Commission on June 28,2022.
The Company appreciates the opportunity to offer Comments in this case to
discuss the problems with addressing the issues raised in CEO's Petition separately
through this docket as opposed to considering them within the context of the Commission-
IDAHO POWER COMPANY'S COMMENTS - 1
directed process that is already well underway.l As set forth herein, such a disjointed
approach would be inefficient and confusing with an end result that is, at best, duplicative,
and at worst, contradictory. Moreover, CEO's mischaracterization of the Schedule 84
project eligibility cap as solely a "system design paramete/' and its request to bifurcate
the issue has already been made, considered, and rejected, and a new docket is not the
proper forum for CEO to dispute the Commission's prior decisions.
I. IDAHO POWER SUPPORTS ON.SITE GENERATION.
1. ldaho Power firmly believes that every customer should have access to
reliable, affordable, clean energy - and the ability to generate their own electricity if they
want. lts efforts to modernize its outdated net metering offerings to better align with the
bidirectional relationship of on-site generation have resulted in a series of customer self-
generation related dockets culminating in the recent filing of the comprehensive study it
conducted, at the Commission's behest, of the costs and benefits of on-site generation to
help inform future changes to the on-site generation service offerings in Case No. IPC-E-
22-22 (hereinafter referred to as "Study").2
2. The Company is committed to establishing a customer generation service
offering that reduces structural uncertainty going forward while continuing to give
customers the flexibility to generate their own energy at their home or business. While it
is supportive of customer choice, the Company is not able to rely on non-firm, non-
dispatchable resources to meet near-term capacity deficiencies, and so contrary to CEO's
1 See ln the Mafter of ldaho Power Company's Application to Complete the Study Review Phase of the
Comprehensive Study of Costs and Benefits of On-Site Customer Generation & For Authority to
lmplement Changes to Schedules 6, 8, and 84 for Non-Legacy Systems, Case No.IPC-E-22-22
(referenced infra as the'Study Review and lmplementation Docket").
2 Case No. IPC-E-22-22, Application (Jun. 30,2022).
IDAHO POWER COMPANY'S COMMENTS - 2
assertion,3 capacity from an on-site generation facility will not adequately address
identified 2023 deficiencies.
3. As the administrative history demonstrates, there are a number of complex
and interrelated issues surrounding the topic of on-site generation, and the regulatory
process has been supported by numerous engaged and passionate individuals and
groups working to find a viable solution.
4. Agribusinesses, the subject of CEO's Petition, are only one class of
stakeholders interested in the ultimate resolution. Currently, customers that generate their
own electricity and interconnect with exporting systems are billed under different rate
schedules as follows: Schedule 6, Residential Service On-Site Generation ("Schedule 6"),
Schedule 8, SmallGeneral Service On-Site Generation ("Schedule 8"), and Schedule 84,
Customer Energy Production/Net Metering Service ("Schedule 84"), which is the schedule
that commercial, industrial, and irrigation ("CI&1") customers (including agribusinesses)
take net metering service under.
5. ldaho Power has appreciated the input from CEO and others acting on behalf
of customers during the course of on-site generation proceedings. The Company will
continue to be informed and guided by feedback as it develops its ultimate
recommendation for potential modifications to the on-site generation service offerings for
Commission consideration as part of the study review and implementation phase initiated
by Case No. IPC-E-22-22 ("Study Review and lmplementation Docket").
6. The Company disputes CEO's characterization of the eligibility cap as a
veiled attempt to discourage customer-owned generation. ldaho Power supports
3 CEO's Response to ldaho Power Company's Answer and Motion to Dismiss CCEO Response") at 7
(Jun.1,2022).
IDAHO POWER COMPANY'S COMMENTS - 3
customer choice in solar and other clean energy choices in earnest and has a proven
track record of working to improve the customer experience. CEO claims that, in seeking
to dismiss the Petition, ldaho Power disregards the fundamental premises of its Petition:
the fairness of allowing ldaho businesses the timely opportunity to access technology
needed to manage costs and compete in commodity markets.a ldaho Power is committed
to supporting local businesses; the Company is not seeking dismissal of CEO's Petition
to marginalize the concerns of agribusinesses but to ensure they are addressed in the
most appropriate and efficient manner. The issues raised in the Petition are important
and worthy of thoughtfu!, reasoned consideration, as are other components of the on-site
generation service offering not identified in the Petition but subject to review in the Study
Review and lmplementation Docket.
7. ln the meantime, in the event there are Cl&l customers looking for
immediate opportunities to utilize technology to generate some of their own electricity,
options currently exist that would enable them to do so. For example, any customer can
choose to interconnect their non-exporting system per the Commission-approved tariff
requirements so that they consume all the energy generated on-site.s Cl&l customers
also may choose to sell their renewable energy as a Qualified Facility to ldaho Power
under Schedule 86, Cogeneration and Small Power Production Non-Firm Energy.6
8. ldaho Power's efforts are not intended to hinder customer-owned
generation but to achieve a long-term solution through thoughtful, careful planning. The
Company has devoted significant time and resources to ensure that customers with on-
4 CEO Response at 4.
5 See ldaho Power Company's Answer and Motion to Dismiss at 3 (May 18,2022)
6 See id. at 18.
IDAHO POWER COMPANY'S COMMENTS -4
site generation will have a service offering available to them that is scalable, sustainable
into the future, and fair to all customers.
II. CEO'S CONCERNS ARE WITHIN THE SCOPE OF THE STUDY REVIEW AND
IMPLEMENTATION DOCKET.
9. The Study submitted by ldaho Power in Case No. IPC-E-22-22 is now
available for public review and input. The Study analyzes the benefits and cost of on-site
generation within the Company's service area, which involves consideration of a number
of interconnected and interdependent matters, including those that CEO seeks to have
addressed in the instant case docket as more fully set forth below.
10. The Study provides information that the Commission, ldaho Power, and
other stakeholders will use to determine whether and what changes should be made to
ldaho Power's existing customer generation service offering for all customer classes
(Schedules 6, Schedule 8, and Schedule 84). Allowing one class of customers to address
certain components within a parallel proceeding would be inefficient and inexpedient.
Proiect Elioibilitv Cap
11. CEO's first request is for the Commission to modiff the project eligibility cap
for Schedule 84 customers to 100o/o of a customer's maximum demand. Pursuant to the
Study FrameworkT as authorized by the Commission, this issue is addressed in Section
9 of the Study.
12. ln pursuing this issue in a parallel proceeding to the Study Review and
lmplementation Docket, CEO has attempted to distinguish the project eligibility cap from
the "compensation mafters" driving the Study by asserting the cap is merely a "system
7 ln the Matter of ldaho Power Company's Application to lnitiate a Multi-Phase Collaborative Process for
the Study of Costs, Benefits, and Compensation of Net Excess Energy Associated with Customer On-Site
Generation, Case No. IPC-E-21-21, Order No. 35284 at 25 (Dec. 30,202'l).
IDAHO POWER COMPANY'S COMMENTS - 5
design paramete/'.8 Semantics aside, the Commission recognized that analysis of the
project eligibility cap, which was put in place, in part, to mitigate cost-shifting concerns,
should not be conducted in a vacuum but considered as part of the larger effort to
comprehensively review the Company's on-site generation service offering.e The
Commission also noted that analysis of the project eligibility cap should include evaluation
of concerns previously raised by the Commission regarding "safety, service quality, and
grid reliability,"to
13. Likewise, CEO's contention that this separate proceeding is necessary to
protect the lnterests of Cl&l customers is based on a mistaken premise, to wit, that Cl&!
customers are not within the scope of the Study Review and lmplementation Docket; "an
Order in [a residential and small genera! service] docket to consider customer concerns
is poor reason to dismiss a proposa! to address Cl&l concerns not represented in that
docket."11 !n support of its assertion that Cl&! customer concerns will not be addressed
within the Study Review and lmplementation Docket, CEO cites to a scheduling order
from Case No. IPC-E-19-15, which indicates that Cl&l concerns were not within the scope
of the docket establishing the study review phase.12
14. This reference, however, is taken out of context, mischaracterizes the
Commission's order, and disregards subsequent rulings; the Commission made clear it
expected consistent application of principles across dockets and noted that there would
8 CEO Response at 5-6.
s Case No. IPC-E-21-21, Order No. 35284 at 25.
10 ld.
11 CEO Response at 22.
12 ln the Matter of ldaho Power Company's Application for Authority to Study the Measurement lnterval,
Compensation Structure, and Value of Net Excess Energy for On-Site Generation Under Schedule 84
and to Temporarily Suspend Schedule 84 Net Metering Service to New ldaho Applicants, Case No. IPC-
E-19-15, Order No. 34335 at 1 (May 15, 2019).
IDAHO POWER COMPANY'S COMMENTS -6
be opportunities to address issues related to the project eligibility cap for C!&l customers
relative to the "forthcoming comprehensive study."1s
15. The Study, in fact, incorporates data for residential, smal! general,
commercial, industrial, and irrigation customers with exporting systems and includes: an
evaluation of the existing cap for each customer type; an evaluation of technological
improvements and standardization relative to safety, service quality, and grid reliability
concerns; consideration of the merits of a project eligibility cap set relative to a customer's
demand; and evaluation of the impact of a modified cap on interconnection requirements
and distribution system operations and other implementation considerations.la
16. In addition to mischaracterizing the issue of the project eligibility cap for Cl&l
customers as outside the purview of the Study (despite its explicit inclusion in the Study
Framework and corresponding coverage in the Study), CEO contends that it is most
practical to address potential cost-shifting, which project eligibility caps are in part
intended to regulate, through rate design changes rather than an arbitrary cap.1s ldaho
Power agrees, and in fact, this is precisely why the cap should be considered in
conjunction with the changes to the compensation structure in the Study Review and
lmplementation Docket. Some of the concerns related to cost shifting will indeed be
mitigated as a result of modifying the compensation structure, but the actua! impact, which
should be an important consideration in modifying the cap, will not be known until the on-
site generation service offering fundamentals are decided upon.
13 ln the Matter of ldaho Power Company's Application for Authority to Modify Schedule 84's Metering
Requirement and to Grandfather Existing Customers with Two Meters, Case No. IPC-E-20-26, Order No
34854 at 12 (Dec. 1,2020).
1a Case No. IPC-E-22-22,Value of Distributed Energy Resources (VODER) Study at 97-102 (Jun.2022)
15 CEO Response at 9.
IDAHO POWER COMPANY'S COMMENTS - 7
17. CEO's argument that the cap should be modified posthaste to enable Cl&!
customers to make better-informed investment decisions is unavailing considering the
Commission's previous remarks relative to potential investors' risk assessment vis-i-vis
the variable nature of tarifts.16 In addressing the impact of uncertainty surrounding the net
metering service offering on investment in solar generation the Commission stated:
While it may be difficult for potential customer-generators to
determine their likely return on investment without knowing the
details of the successor program, we find this consideration is
outweighed by the public interest in clarity that the tariff is likely to
change. We find that the claimed chilling effect on new customer
participation in Schedule 84 during the interim is unpersuasive.
Customer-generator decisions are based on many factors and when
making future decisions it is important to acknowledge that any tariff
may change.17
18. This same reasoning applies to CEO's request to implement a change to
the Schedule 84 cap "before the Fall 2022 deadline for investment decisions by
agribusinesses."l8 Agribusinesses' desire to make more informed investment decisions
and/or take advantage of tax credits and funding is simply not an adequate justification
for implementing a change to the project eligibility cap for one class of customers on an
expedited basis and without regard to other components of the on-site generation service
offering in the Study Review and lmplementation Docket. To reiterate, these customers
are not left without an option to install renewable generation and claim the associated tax
credits; they have the option to installa Qualifying Facility of up to 10 MW underthe terms
of Schedule 86.
16 See, e.9., ln the Matter of the Application of ldaho Power Company to Study the Costs, Benefits, and
Compensation of Net Excess Energy Supplied by Customer On-Site Generation, Case No. IPC-E-18-15,
Order No. 34509 at 12-13 (Dec. 20, 2019); Case No. IPC-E-20-26, Order No. 34854 at 10-1 1 ; Case No.
IPC-E-21-21, Order No. 35284 at 10.
17 Case No. IPC-E-20-26, Order No. 34854 at 10-1 1.
18 CEO Petition at 4 (Apr. 28,2022).
IDAHO POWER COMPANY'S COMMENTS - 8
Transition Guideline
19. CEO's second request is for the Commission to establish a Transition
Guideline that improves predictability and stability of rates by setting a limit to the pace at
which compensation for excess energy may change for Schedule 84 customers if and
when an Export Credit Rate ("ECR") is implemented. This issue is addressed in Section
11 of the Study.
20. CEO has requested a Transition Guideline to provide Cl&l customers
"better ability to model a range of risks associated with future export credit rates yet allows
latitude for different transition plans."1e Specifically, CEO proposes establishing a
Transition Period Guideline that borrows concepts from the transition plan included in the
rejected Settlement Agreement in Case No. IPC-E-18-15 ("settlement Agreement')2o
including: a glide path to transition to a new credit value for exports, crediting exports at
Blended Base Energy Rate for the first two years of implementation, and implementing
changes to the export credit value every two years.21
21. The transition plan was included as part of the compromise reached on
several fundamental aspects of the Company's on-site generation service offering as set
forth in the Settlement Agreement, and it would be inappropriate to pull select elements
from a compromise reached on the entirety of issues. Moreover, the Settlement
Agreement was non-binding and is defunct after being rejected by the Commission in its
entirety.22
le /d. at 10.
20 Case No. IPC-E-18-15, Motion to Approve Settlement Agreement (Oct. 1 1, 2019) and Order No. 34509
at 6.
21 CEO Petition alll-12.
22 Case No. IPC-E-18-15, Order Nos. 34509 and 34546.
IDAHO POWER COMPANY'S COMMENTS - 9
22. CEO's request for a Transition Guideline, again, stems from
agribusinesses'desire for predictability and stability relative to export compensation and
a purportedly crucia! need to address these concerns as a result of certain
circumstances.23 ldaho Power recognizes the desire for certainty and, to that end, has
proposed a procedural schedule that would position the Commission to issue an order
directing changes to the on-site generation service offering, including compensation
structure (i.e., measurement interval and ECR) by December 30, 2022, which could be
implemented by the Company as soon as June 1, 2023. The Company's proposed
schedule belies CEO's suggestion that it may be 2024 before any changes to net-
metering compensation are implemented.2a
23. While the Company understands that Cl&l customers would prefer certainty
and predictability in making investment decisions so that they can remain competitive in
their respective markets,2s the Commission has made clear that it is not their role to
guarantee a return on investment for customers and repeatedly emphasized that
customers should consider the uncertainty of program design when deciding whether to
invest in on-site generation.26
24. After delineating the parameters for legacy treatment of Schedule 84
customer generators, the Commission set the standard for Cl&l customer generators
going forward: "Following our pronouncements in the orders in these cases, made after
extensive briefing, public testimony, and deliberation, that the program fundamentals are
23 CEO Response a12,11-12.
2a ld. at 11.
25 ld. at8.
'u See, e.9., Case No. IPC-E-18-15, Order No. 34509 al 12-13; Case No. IPC-E-20-26, Order No. 34854
at 10-11; Case No. IPC-E-21-21, Order No. 352&4 at 10.
IDAHO POWER COMPANY'S COMMENTS - 1O
likely to change in the not too distant future, the reliance on long-term program stability
will no longer be reasonable given the ongoing evaluation of the programs."27
25. The Commission having already concluded that customers should have no
reasonable expectation of program stability moving forward, the request for a Transition
Guideline to address "customer requests for better predictability and stability of export
rates"28 is inapposite.
26. Moreover, asking the Commission to establish a transition period in this
docket is misplaced. lt is unclear, for example, on what basis the Commission would be
able to set a pace for changing the compensation for excess energy prior to implementing
a methodology for compensating excess energy - a critical element that must be known
prior to the Commission having sufficient information to assess the reasonableness
and/or parameters of a transitional period.
27. Stated differently, CEO's proposal of a reasonable sideboard to the pace of
change in export compensation value is unmoored in this docket. !t is the Study Review
and lmplementation Docket - not this one - that includes the necessary data that will
ultimately inform what changes to ldaho Power's existing customer generation service
offering should be implemented and the timing of that implementation. lnterested persons
and parties in the Study Review and lmplementation Docket will have the opportunity to
review the Study and assess the impact of changes to the on-site generation service
offering and the appropriateness of a transition period.
28. As noted by CEO, nothing in the Commission's previous orders prohibits a
non-utility pafi from presenting proposals on how to implement information that results
27 Case No. IPC-E-20-26, Order No. 34854 at 10-11
28 CEO Response at 21.
IDAHO POWER COMPANY'S COMMENTS - 11
from the Study.2e Other parties can and should present proposals on implementation as
informed by the Study; ldaho Power's proposed procedural schedule in the Study Review
and lmplementation Docket provides for all-party comments proposing recommendations
for implementation. ldaho Power is interested in receiving input from CEO and others, but
it cannot elevate the concerns of one class of stakeholders separate from all others, which
would be the effect of following CEO's suggested course of action in its Petition.
III. CEO'S REQUEST HAS ALREADY BEEN MADE AND RULED UPON.
29. CEO's argument that its Petition is not intended to challenge Order No.
35284 is unconvincing when one reviews the record: "The Petition is not a collateralattack
on any existing order - it is a new request to implement a change to a system design
parameter, the 100kW cap, after ldaho Power files the study yet on a faster schedule than
ldaho Power would otherwise propose."3o
30. CEO's request to modify the project eligibility cap for Schedule 84 customers
is not a new request and its attempt to characterize it as such is belied by the record in
Case No. IPC-E-21-21. As stated in CEO's initialcomments on ldaho Power's application:
To complete this study process in a fair, focused, and timely manner,
we propose that a path for studying the pros and cons of updating the
Cl&l cap according to customer demand be completed under a
separate docket launched as soon as possible after an order issues
on this study design proposal. The separate Cl&l cap docket should
review a cap no less than a customer's peak electric load.31
This request was reiterated in CEO's reply comments:
The added costs to C!&l customers imposed by the 100kW project
eligibility cap and the discouragement of investments in customer-
owned generation should continue no longer than absolutely
2e CEO Response at 6.
30 ld.
31 Case No. IPC-E-21-21 , lnitial Comments of CEO Regarding the Scope of the Study at 6 (Oct. 1 3,
2021).
IDAHO POWER COMPANY'S COMMENTS - 12
necessary. Given prior discussion with stakeholders, CEO believes
the pros and cons of changing the project eligibility cap for Cl&l
customers could be resolved in a more-timely manner. CEO proposes
that the Company file an application proposing changes to the Cl&l
cap, which should be no less than a customer's peak electric load, as
soon as possible.32
31. Moreover, CEO's request was squarely addressed by the Commission in
Order No. 35284:
CEO proposed that the Company file an application proposing
changes to the Cl&l cap, which should be no less than a customer's
peak electric load, as soon as possible. CEO 1113012021 Comments
at 5. CEO emphasized that this element of the evaluation should
occur in a separate docket and that the Commission has broken out
other eligibility issues in the past. CEO 10/1312021 Comments at 2,
4,6and7.
We find that a separate docket is not necessary to study these items.
The Company has the necessary data and expertise to provide a
thorough evaluation of the 25 kW and 100 kW predetermined caps
through this study. We also find it reasonable to expand the analysis
al125o/o of customers' demand. The analysis of the project eligibility
cap should also include an evaluation of concerns previously echoed
in Order No. 28951 and Order No. 29094, such as safety, service
quality, and grid reliability.33
32. The Commission has made clear that the nature of the issue requires a
holistic approach, and as a result, it has previously declined to address it outside of the
process already established by the Commission.3a CEO's attempt to circumvent the
Commission's prior ruling by submitting a new docket on this issue is improper and should
not be allowed
32 Case No. IPC-E-2'|-21, Reply Comments of CEO at 5 (Nov. 30,2021).
33 Case No. IPC-E-21-21, Order No. 352M at 25.il See Case No. IPC-E-20-26, Order No. 34854 at 12 (Dec. 1,20201("Finally, we acknowledge the
comments submitted regarding the 100 kW cap and meter aggregation rules but decline to address them
in this docket. There will be opportunities to address these issues during or after the forthcoming
comprehensive study.") and Case No. IPC-E-21-21, Order No. 35284 at 25 ('We find that a separate
docket is not necessary to study these items.').
IDAHO POWER COMPANY'S COMMENTS - 13
IV. NON.FIRM. NON.DISPATCHABLE ENERGY SOURCES ARE NOT A VIABLE
SOLUTION TO ADDRESS THE ANTICIPATED CAPACITY DEFICIT.
33. As justification for the urgent nature of its request and the need for a parallel
proceeding to the Study Review and lmplementation Docket, CEO cites the Company's
impending capacity deficit, suggesting that agribusinesses could help mitigate the issue
if the project eligibility cap were modified.3s The idea that customer generation offers a
solution to projected capacity deficits is a common theme that has been raised in many
of the on-site generation dockets and was also raised by the City of Boise in comments it
submitted in relation to CEO's Petition: "The Ci$ believes all available resources,
including customer-owned [Distributed Energy Resources], should be pursued to meet
th is capacity defi cit cost-effectively a nd efficiently."36
34. Unfortunately this proposal is misplaced. As the Company has explained
previously, it is not able to rely on non-firm, non-dispatchable resources to meet its near-
term system deficiencies.3T
35. Idaho Power is expeditiously working to ensure it is able to meet the
forecasted capacity deficit with firm, dispatchable resources. To this end, it conducted an
extensive investigation to identiff the least-cost, least-risk method of meeting the capacity
deficit, including evaluation of several alternative options, and ultimately determined that
dispatchable battery storage was the best solution to meet peak summer demand and is
currently seeking approval to acquire this resource.3s
35 CEO's Response at7-8.s City of Boise Written Comments at 1-2 (Jul. 13,2022).
37 ldaho Power Company's Answer and Motion to Dismiss at 17-18.
38 See ln the Matter of ldaho Power Company's Application for a Certificate of Public Convenience and
Necessity to Acquire Resources to be Online by 2023 to Secure Adequate and Reliable Service to its
Customers, Case No. IPC-E-22-'13, Application for a Certificate of Public Convenience and Necessity
(Apr.29, 2022).
IDAHO POWER COMPANY'S COMMENTS - 14
36. ldaho Power provides this explanation not to detract from the benefits of
customer choice and interest in on-site generation, of which there are many, but to
articulate why the solution offered by CEO (customer generation) does not meaningfully
address the issue (anticipated capacity deficit).
V. PUBLIC COMMENTS
37. The ldaho Conservation League ("lCL"), City of Boise, and other members
of the public filed comments in support of the Petition before July 19,2022. Many of the
arguments and positions made echo those of CEO in its Petition and Response, which
are addressed herein and in the Company's Answer and Motion to Dismiss. ln addition,
ldaho Power addresses certain specific points raised by ICL and City of Boise as follows.
38. ldaho Power appreciates ICL's recognition of its past efforts to improve the
customer generation service offering to ease impacts on customers in Case Nos. IPC-E-
20-26 and IPC-E-20-30. As further elaborated below, these cases and others were
pursued based on customer feedback and demonstrate incremental efforts to improve
the status quo:
. ln 2016, ldaho Power proposed a change to Schedule 84 metering
requirements in Advice No. 16-05 in order to reduce barriers to participation
for primary service-levelcustomers who desired to install on-site generation
by modifying the requirements related to the second meter's location and
voltage. The Company initiated the change based on feedback from
customers that wanted to instal! net metering systems but found compliance
with the existing metering requirement, which required installation of a
second meter adjacent to the load meter, to be cost prohibitive. The
IDAHO POWER COMPANY'S COMMENTS - 15
proposed tariff changes made it easier and less costly for Cl&l customers
to install systems by allowing the Company the discretion in determining
whether the second meter would be located adjacent to, or on the
customer's side of the Point of Delivery.
. ln Case No. IPC-E-2O-26,3e the Company asked the Commission to modifo
the metering requirement under Schedule 84 from a two-meter to single-
meter requirement. The request to remove the two-meter requirement for
new Schedule 84 customers was based on concerns voiced by customers,
installers, and stakeholders, of the incrementa! costs and complexities that
exist as a result of the two-meter requirement.ao
. ln Case No. IPC-E-20-30,41 ldaho Power sought, in part, to implement
interconnection rules for customers with Distributed Energy Resources
("DERs") that do not wish to export excess net energy to the Company.
Notably with respect to Cl&l customers with non-exporting systems, the
Company requested that there be no limit on total nameplate capacity,
which enabled Cl&l customers greater flexibility to install systems where
they can consume all generation on-site.
39. ldaho Power also appreciates ICL's acknowledgment that the Study fulfills
the "condition precedent to any consideration of programmatic changes,"42 while the
3e Case No. IPC-E-20-26, Application (Jun. 19,2020|
ao /d. at 5.al ln the Matter of ldaho Power Company's Application for Authority to Establish Tariff Schedule 68,
lnterconnections to Customer Distributed Energy Resources, Case No. IPC-E-20-30, Application (Jul. 20,
2020).
az ICL Comment at 3 (Jul. 11 ,2022) (quoting ldaho Power Company's Answer and Motion to Dismiss at
16).
IDAHO POWER COMPANY'S COMMENTS - 16
Company awaits Commission confirmation and acknowledgement that the Study satisfies
its directives.
40. The multi-phase process outlined by the Commission consisted of:
(1) A "study design" phase - during which Staff and the Company were
instructed to "host public workshops to share information and
perspectives on net-metering program design with the public and to
listen to customer concerns and input."a3
(2) A "study review" phase - during which the public wi!! have the
opportunity to comment on whether the study sufficiently addressed
their concerns and their opinions on what the study shows.4
41. The "study design" phase having been accomplished in Case No. IPC-E-21-
21, the "study review" phase, initiated with the filing of the Study in Case No. IPC-E-22-
22, is now underway. Consistent with the process directed by the Commission and in the
interest of efficiency and fairness, it is the Study Review and lmplementation Docket from
which any changes to the on-site generation service offerings should flow.
42. Attempting to justify pursuit of changes to the Schedule 84 project eligibility
cap via a separate proceeding, ICL claims that the cap, being a "design issue, not a cost
or compensation issue," should not be addressed in what it characterizes as a "financial
proceeding,"4s to wit: "The program design issues related to system caps are better
addressed in a separate docket that is not also evaluating the complex cost and
compensation issues of the ECR."46 However, this position is directly at odds with the
a3 Case No. IPC-E-18-15, Order No. 34509 at 9-10
44 ld.
a5 ICL Comment at 6.
46 ld.
IDAHO POWER COMPANY'S COMMENTS - 17
plain language of the Commission's mandate: "lt is critical for the Commission to have a
credible and fair study in front of it before it can make a well-reasoned decision on the
Company's net-metering program design."aT Thus, the Commission's own words
undermine ICL's attempt to narrow the scope of the Study Review and lmplementation
Docket as only constituting a "financial proceeding."
43. Likewise, ICL misstates facts in support of its claim that "ldaho Power
recognizes the challenges associated with combining multiple issues into one
proceeding" as demonstrated by it holding a public workshop that focused only on the
ECR. Contrary to ICL's characterization, the workshop referred to was not held as a result
of Order No. 34509 in Case No. IPC-E-18-15, which directed that public workshops be
held as part of the "study design" phase (which the Company complied with during Case
No. IPC-E-21-211.te The publicworkshop ICL refers to was held on May 2,2022, and was
not ordered by the Commission but was a voluntary workshop hosted by the Company to
seek public input during the development of the Study. As articulated in the Company's
materials filed in IPC-E-22-22, the May 2022 workshop focused on the ECR because
most public comments and parties' interest in Case No. IPC-E-21-21 centered on the
compensation for excess net energy.ae lt was not intended to be inclusive of all items
previously directed to be studied by the Commission.
44. The Company does not believe that pursuing the Schedule 84 project
eligibility cap in a separate docket is justified or judicious. The multi-phase process should
a7 Case No. IPC-E-18-'15, Order No. 34509, at 9 (emphasis added).
a8 /d. See a/so Case No. IPC-E-21-21, Order 35284 at2 for information on public workshops as part of
that phase. On October 20,2021, ldaho Power held a public workshop where it presented the scope of
the study.
ae Case No. IPC-E-22-22, Application at 12.
IDAHO POWER COMPANY'S COMMENTS - 18
continue as directed by the Commission and changes should be considered for all
customer classes in the same proceeding, i.e. the Study Review and lmplementation
Docket.
VI. CONCLUSION
45. ldaho Power understands that its current and prospective net metering
customers desire more certainty regarding the future structure of the on-site generation
service offering as soon as possible - ldaho Power does as well. The Company's
arguments here should not be interpreted as a desire to slow down or stop necessary
changes. Given the manner in which these cases are typically processed, it is unlikely
that a final order informed by public participation would be issued materially sooner in this
Cl&l-specific docket than an order in the more comprehensive Study Review and
lmplementation Docket. However, simultaneous dockets will necessarily require
additional party arld Commission resources to process both concurrently and may
increase the likelihood that an order providing more comprehensive certainty in the Study
Review and lmplementation Docket is delayed.
46. Consequently, as more fully set forth herein, allowing Cl&l customers to avail
themselves of a separate, expedited process in order to address one component of the
Schedule 84 service offering would be inefficient and inequitable. The issue of the project
eligibility cap and the propriety and parameters of a transitional period should be
considered and addressed holistically in consideration of other program fundamentals
and on the same footing as other customer classes in the Study Review and
lmplementation Docket. Therefore, ldaho Power respectfully requests that the
Commission dismiss CEO's Petition.
IDAHO POWER COMPANY'S COMMENTS - 19
Dated at Boise, ldaho, this 19h day of July 2022.
Wfficte*v^0fifun
MEGAN GOICOECHEA ALLEN
Attomey for ldaho Power Company
IDAHO POWER COMPANY'S COMMENTS.2O
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 19th day of July 20221 served a true and correct
copy of the within and foregoing ldaho Power Company's Comments upon the following
named parties by the method indicated below, and addressed to the following:
Riley Newton
Deputy Attorney General
ldaho Public Utilities Commission
PO Box 83720
Boise, ldaho 83720-007 4
Clean Energy Opportunities for
tdaho, lnc.
Kelsey Jae
Law for Conscious Leadership
920 N. Clover Drive
Boise, ldaho 83703
Michael Heckler
Courtney White
Clean Energy Opportunities for ldaho
3778 Plantation River Drive, Suite 102
Boise, lD 83703
ldaho Conservation League
Benjamin J. Otto
ldaho Conservation League
710 N.6th Street
Boise, ldaho 83701
City of Boise
Public Works Department
150 N. Capitol Blvd.
P.O. Box 500
Boise, ldaho 83701 -0500
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mike@cleanenerovopportun ities.com
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Stacy Gust, Regulatory Administrative
Assistant
IDAHO POWER COMPANY'S COMMENTS - 21