20220711ICL Comment_1.pdf

:: i i /,: i\i. !i. r.. i-l E LLl
Emma E. Sperry (IN BarNo.37224-84)
710 N 6m Street
Boise,ID 83701
(208) s37-7993 x230
[e-mail]
j,I , nt! l. .tr'li fil l.Jr)
Attorney for the ldaho Conservation League
BEFORE TIIE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF CLEAII
ENERGY OPPORTT]NITIES FOR
IDAHO'S PETITION FOR AN
ORDER TO MODIFY THE
SCIIEDT]LE 84 1OOKW CAP & TO
ESTABLISH A TRANSITION
GTIIDELINE FOR CIIANGES TO
SCHEDTILE 84 EXPORT CREDIT
COMPENSATION VALT'ES
CASE NO. IPC.E-22.I2
IDAIIO CONSERVATION LEAGUE
COMMENT
The Idaho Conservation League (ICL) submits the following comment in support of
Clean Energy Opportunities for Idaho's (CEO's) petition to separate the issue of implementing a
new system size cap for Schedule 84 self-generating customers from the proceedings to study
and adjust the export credit rate for all self-generating customers (hereafter known as the "ECR
proceedings"). ICL also supports CEO's request to adjust the Schedule 84 system size cap to
100% of a customer's capacity needs and implement the transition guidelines for the export
credit value received by new Schedule 84 customers that CEO outlined in its petition.r
A. There is nothing in previous Commission orders that would prohibit the opening of
a new docket to implement an adjusted Schedule 84 system size cap.
l. In Order 34854, the Commission stated that "there will be opportunities to
address [the system size cap] during or after the forthcoming comprehensive
I See Clean Energ5r Opportunities for Idatro Petition, Case No. IPC-E-22-22,16 (Apr. 27,2022).
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study."2 In Order 35284,the Commission stated that a "separate docket is not
necessary to study [the system size cap]."3
2. Consistent with both orders, CEO's petition requests that the Commission open a
new docket to implement one of the two potential Schedule 84 system size caps
that were already studied in ldaho Power's recently released Value of Distributed
Energy Resources (VODER) study. Contrary to Idaho Power's implication in its
Motion to Dismiss, the CEO petition does not request a separate study.a As such,
a new docket that creates an opportunity to address the implementation of a
Schedule 84 system cap based on the VODER study findings is well within the
"plain reading" of Orders 35284 and 34854 and is not a "collateral attack" on
Commission orders.s
B. The Commission has previously opened separate dockets to address system design
criteria during the pendency of the ECR proceedings.
3. In IPC-E-20-26,ldaho Power asked to change the system design criteria to allow
Schedule 84 customers to use a single meter to measure net energy consumption
as well as access the legacy net metering program.6 In IPC-E-20-30, Idaho Power
requested to change the system interconnection criteria and create a non-export
option for self-generators.T In both dockets, Idaho Power did not assert that
Commission orders prohibited any program changes until the completion of the
ECR proceedings. Rather, the Company explained that its requested change
2 Order 34854,DC-E-20-26,12 @ec. 1,2020).
3 Order 35284,WC-E-21-21,25 @ec. 30,2021).
4 Idaho Power Company Answer and Motion to Dismiss, WC-E-22-12,15 (para. 44) (May 18,2022).
s IPC Motion to Dismiss at I I (para. 22); 14 (para. 43).
6 Idaho Power Company Application,DC-E-20-26, 5 (June 19,2Ol9).
7 Idaho Power Company Application, IPC-E-20-30, 2 (July 20, 2020).
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would reduce complexities and costs for potential self-generators and increase
customer options while giving the utility an opportunity to further study the
results of the system changes. Similarly, CEO's requested change in this case will
reduce costs and complexities for potential self-generators.
C. Idaho Power's recently released Value of Distributed Energy Resources (VODER)
study provides the necessary background information for the Commission to
implement an adjusted Schedule 84 system size cap within the IPC-E-22-12 docket.
4. The utility released its VODER study on June 30, 2022.This study discusses
issues related to the Schedule 84 system size cap including interconnection
requirements, the potential for Idaho Power to have the ability to remotely control
large Schedule 84 customer systems for the purposes of managing the distribution
system, and other implementation and operational considerations.8
5. The release of this study has met the "condition precedent to any consideration of
programmatic changes," and the Commission, the utility, intervenors, and the
public now have the necessary information to engage in a proceeding to
implement changes to the Schedule 84 system size cap.e
D. There is a demonstrated need to accelerate the decision regarding the Schedule 84
system size cap.
6. As described in CEO's petition, Idaho Power has capacity shortfalls that could be
alleviated by increased customer self-generation.l0 [n its motion to dismiss, the
utility argues that it "conducted an extensive investigation to identiff the least-
8 tdaho Power Company,2022 Talue of Distibuted Energt Resources (I/ODER) Study,97-102 (Jwe,2022).
e IPC Motion to Dismiss at 16 (para.46).
r0 CEO Petition at 5 (para. 10). The utility has recently sought permission in two separate dockets to quickly add
resources to address needed capacity via demand response (IPC-E-21-32) and storage (DC-E-22-13).
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cost, least-risk method of meeting the capacity deficit" and found that storage, not
self-generation, was its best option. It is unclear, however, if the utility even
considered, let alone thoroughly evaluated, Schedule 84 customer self-generation
as an option to address capacity shortfalls.lt As described in the VODER study,
customer self-generation provides capacity value to the utility.l2 This evidence of
capacity shortfalls, which was not available when the Commission issued Order
35284, supports opening a docket that can quickly implement an adjusted
Schedule 84 system size cap which will increase Schedule 84 customers' ability
to produce more solar capacity.
7. Second, a fundamental premise of the Petition is fairness which includes
"allow[ing] CI&I customers timely opportunity to invest in technologies such as
solar to manage their own electricity costs and remain competitive in their
respective markets."l3 Schedule 84 customers have expressed their interest in and
need for additional solar capacity but are unable to procure it due to longstanding
discrepancies in the way these customers are treated.la Under the current system,
which caps residential solar at 25 kW, residential customers have the ability to
procure 100% of theirpower from solar. Schedule 84 customers, however, do not
have this same access and must endure additional costs in installing multiple
meters in order to get more power from solar. Further, Idaho Power's conjecture
that Schedule 84 customers cafllot currently procure solar arrays due to supply
Ir See Ellsworth Direct Testimony, PC-E-22-13 (Apr.29,2022).
t2 See P.C, I/ODER Study a169. The utility estimates the on-peak value of self-generation exports to be between
16.9 cents and 19.5 cents per kWh, more than 150% the retail price of electricity.
13 CEO petition at 6 (para.l2).
14 CEO petition at 28.
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chain issues is not a relevant irqrriry." All utility customers should have equal
rigfut and option to procure their energy from alternate sources which enable them
to manage their electricity bills and guard against the utility's current push to add
infrastructure costs. A docket that implements a new system cap for Schedule 84
customers can correct this longstanding problem.
8. Finally, if the decision regarding the Schedule 84 system size cap remains apart
of the ECR proceediog, it will not be addressed for a significant period of time,
leaving Schedule 84 customers without recourse to expand their solar
procurement. As Idaho Power correctly points out, the ECR proceedings are
"importan[t] and complex[]" and thus necessitate additional time for intervenor
and public engagement.16 These proceedings will likely continue well into 2023,
meaning that Schedule 84 customers, most of whom rely on additional energy in
the summer, and, as the Company noted, could face supply chain delays, will go
another full year or longer without the ability to procure additional solar
capacity.rT lnstead of waiting for the resolution of the ECR proceedings, the
narrow issue of the Schedule 84 system size cap can be addressed more quickly in
a separate docket.
9. The above factors, including new evidence about utility capacity shortfalls,
historic discrepancies in the way Schedule 84 customers are able to procure their
energy needs from solar compared to residential customers, and the prolonged
15IPC Motion to Dismiss at 17 (para. 50).
t6 Id. at 6 $nra.47).
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timeline of the ECRproceedings support the opening of the PC-E-22-I2 docket
which can quickly and effectively provide a resolution to these issues.
E. Separating the technical issue of Schedule 84 system size cap from the financial
proceeding to evaluate and determine the export credit rate @CR) for all solar
generating customers will streamline the ECR proceeding and improve the
accessibility of the ECR proceeding for intervenors and the general public.
10. The systern size cap for Schedule 84 customers is a design issue, not a cost or
compensation issue. Despite claiming that the cap issue is integrally related to
determining the value of the EC&18 Idaho Power's evaluation of the cap in the
VODER study presents no analysis of any relationship between the system cap
and the overall value of the ECR.le Other than considerations for implementation,
the only issues with a modified cap that Idaho Power discusses in any detail are
interconnection requirements and distribution system operations, indicating that
the utility's main concems with regard to the system cap are technical matters
unrelated to the value of the export credit. 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.
11. The issues raised in the ECR proceeding related to compensation rate and the
mechanisms for administering the compensation rate are already sufficienfly
complex for the public to understand. Including an additional technical design
question will serve to further complicate the ECR proceedings and reduce the
ability of intervenors and the public to engage fully on any one issue. Idaho
r8 PC Motion to Dismiss at 16 $nra.47).te IPC, YODER Study at l0l.
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Power recognizes the challenges associated with combining multiple issues into
one proceeding. For example, Order No. 34509 instructed the Company 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."20 The
Company excluded the system size cap from its public workshop which focused
on the export credit rate.2r Separating the issues into two dockets - one related to
cost/compensation and one related to Schedule 84 system size cap - will facilitate
a process that is more understandable by the general public.
12. Finally, in its VODER study, Idaho Power states that further evaluation of
interconnection issues is needed in order to revise the Schedule 84 cap, and it
suggests doing this evaluation via technical workshops. The IPC-E-22-12
Schedule 84 system cap docket would serve as a better venue for these workshops
and would beffer separate Schedule 84 system cap workshops from any ECR
workshops.
F. CEO's proposed changes to the Schedule 84 system size cap as well as its proposed
transition guidelines for the credits offered to Schedule 84 customers are reasonable
in light of ldaho Power's capacity needs and the demonstrated needs and interest of
Schedule 84 customers, as described above.
20 Order No. 34509,IPC-E-18-15, 9 (Dec. 20,2019).
2r See Idaho Power Company Application,DC-E-22-22, 12 (June 30,2022) ("The workshop focused on the export
credit rate components because the majority of public comments and parties'interest throughout Case No. IPC-E-21-
21 centered on the compensation for excess net energy. As a result, the Company felt it was essential to provide an
overview at a public workshop and seek to solicit feedback from the public and parties related to how the Company
was addressing that specific part ofthe Study.")
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Respectfully submitted this 1Ift day of July,2022.
lslErnmafi.;p9ru.
Emma E. Sperry
Attomey for the Idaho Conservation League
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