20220630_Application.pdf

SIm..
lnD coRPoompanY
LISA D. NORDSTROM
Lead Counsel
[e-mail]
June 30,2022
VIA ELECTRONIC FILING
Jan Noriyuki, Secretary
ldaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg 8,
Suite 2O1-A (83714)
PO Box 83720
Boise, ldaho 83720-0074
Re: Case No. IPC-E-22-22
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
Dear Ms. Noriyuki
Attached for electronic filing is ldaho Power Company's ("Company") Application in
the above-referenced matter. ln addition, please find attached the DirectTestimony of Grant
T. Anderson filed in support of the Application. AWord version of the testimony will also be
sent in a separate email for the convenience of the Reporter.
Due to the voluminous nature of the Study and its 31 appendices, the Company is
transmitting these files to the Commission via a secure FTP site.
Accompanying this filing is the Company's Press Release and Customer Notice.
Additionally, four (4) bound and three (3) unbound copies of the Study will be hand
delivered to the Commission today.
lf you have any questions about the documents referenced above, please do not
hesitate to contact me.
Very truly yours,
fr;!.ff^l-t".*,
LDN:sg
Attachments
Lisa D. Nordstrom
LISA D. NORDSTROM (lSB No. 5733)
MEGAN GOICOECHEA ALLEN (lSB No. 7623)
ldaho Power Company
1221 West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
lnordstrom@ida hopower.com
mqo icoecheaa llen@ida hooower.com
Attorneys for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSlON
IN THE MATTER OF IDAHO 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 IMPLEMENT
CHANGES TO SCHEDULES 6, 8, AND
84 FOR NON-LEGACY SYSTEMS
CASE NO. IPC-E-22-22
APPLICATION
ldaho Power Company ("ldaho Powe/' or "Company"), pursuant to ldaho Public
Utilities Commission's ("Commission") Rule of Procedure 52 and in accordance with the
directive in Order No. 352841, respectfully requests that the Commission complete the
study review phase of the multi-phase collaborative process being undertaken by the
Company to study the costs, benefits, and compensation of net excess energy associated
1 ln the Mafter of ldaho Power Company's Application to lnitiate a Multi-Phase Collaborative Process for
the Study of Cosfs, Benefits, and Compensation of Net Excess Eneryy Associated with Customer On-Srte
Generation, Case No. IPC-E-21-21, Order No. 35284 at 32-33 (Dec. 30, 2021).
APPLICATION - 1
with customer on-site generation. ln support of this request, ldaho Power hereby submits
the Value of Distributed Energy Resources ("VODER') study as Attachment 1, which,
along with accompanying appendices, represents the comprehensive study of the costs
and benefits of on-site generation ("Study") performed by the Company at the direction of
the Commission2 for the study review and implementation phases.
Idaho Power further requests the Commission: (1) establish a formal process and
timeline for Commission Staff ("Staff'), intervenors, and the public to review and comment
on the Study; and (2) issue an order acknowledging that the Study satisfies the
Commission directives outlined in Order Nos. 34046, 34509, and 352843 and directing
modifications to the Company's on-site generation service offerings be implemented, with
an ultimate goal of establishing more sustainable offerings by implementing a more
equitable pricing and compensation structure.
!n support of this Application, ldaho Power asserts as follows:
I. CUSTOMER ON€ITE GENERATION - CURRENT STATUS AND
STRUCTURAL CONSIDERATIONS
1. ldaho Power has a long history of supporting customer choice and has
offered a net metering option for its customers since 1983, when ldaho Power had a
single customer with on-site generation who wished to interconnect to the Company's
system. Any excess energy that customers generated was sent back to ldaho Power's
2 ln the Mafter of ldaho Power Company's Application for Authority to Establish New Schedules for
Residential and Small GeneralServrbe Cusfomers with On-Site Generation, Case No. IPC-E-17-13,
Order No. 34046 at 31 (May 9, 2018); ln the Matterof the Application of ldaho PowerCompany to Study
fhe Cosfs, Benefits, and Compensation of Nef Excess Eneryy Supplied by Customer On-Site Generation,
Case No. IPC-E-18-15, Order No. 34509 at 17 (Dec. 20,20'19); and Case No. IPC-E-21-21, Order No.
35284- at 32-33.
3ld
APPLICATION - 2
grid, and those customers earned an energy credit that offset their monthly energy
consumption under a billing structure known as "net energy metering" or "net metering".
2. What has become apparent in the intervening decades, as more and more
customers have availed themselves of on-site generation and bi-directional service from
ldaho Power, is that the existing retail rate net metering compensation structure
oversimplifies the arrangement, treating the exchange as one-for-one when the reality of
the transaction for on-site generation customers is not so straightforward.
3. The existing billing structure (i.e., rate design) applied to the Company's
retail customers was designed to account for costs associated with one-way use of the
grid. This structure does not, therefore, accurately reflect the costs to serve customers
that meet some of their own energy needs with on-site, customer-owned systems but still
require services from ldaho Power including bi-directiona! use of the grid as we!! as
energy any time they aren't producing their own power or need more than they can
produce.
4. The result of this misalignment is that net metering customers are being
charged rates that do not appropriately reflect the benefits and costs of interconnecting
customer-owned on-site generation to ldaho Power's system and this, in turn, has
resulted in a situation susceptible to inequitable cost shifts between customers who
choose to install on-site generation and those who do not.
5. ldaho Power's attempts to address this misalignment by modernizing its on-
site generation compensation structure to reflect the value of bi-directiona! energy flow
APPLICATION.3
has resulted in a long series of customer-self generation docketsa from which the instant
Application stems. While the regulatory history related to on-site generation is set forth
more fully in Section 2.2. of the Study, a brief overview of the cases from which this
Application derives is included in Section ll, below.
6. Currently, customers who install on-site generation can interconnect an
exporting system under the terms of Schedule 6, Residential Service On-Site Generation
("Schedule 6"), Schedule 8, Small General Service On-Site Generation ("Schedule 8"),
and Schedule 84. Schedule 84 is the tariff schedule for the Company's commercial,
industrial, and irrigation ("Cl&1") customers to take net metering service.
7. As the record demonstrates, ldaho Power continues to support customer
choice and interest in renewable energy and has devoted significant time and resources
to ensure that customers with on-site generation will ultimately have a service offering
available to them that is scalable, sustainable into the future, and fair to all customers.
This effort has been years in the making, and ldaho Power is pleased to have reached a
significant milestone in the process with this filing and associated submission 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.
aSee, e.9., CaseNo. IPC-E-17-13;CaseNo. IPC-E-18-15;lntheMafterof ldahoPowerCompany's
Application for Authority to Study the Measurcment lnterual, Compensation Structure, and Value of Net
Excess Energy for On-Site Generation Under Schedule 84 and to Temporaily Suspend Schedule 84 Net
Metering Seruice to New ldaho Applicanfs, Case No. IPC-E-19-15; ln the Matter of ldaho Power
Company's Application for Authoi$ to Modity Schedule 84's Meteing Requirement and to Grandfather
Existing Customers with Two Meters, Case No. IPC-E-20-26; and Case No. IPC-E-21-21.
APPLICATION - 4
II. RELEVANT REGULATORY HISTORY
Case No. IPC-E-17-13
8. ln Case No. IPC-E-17-13, the Company launched its effort to have the
Commission review and modiff the outdated net metering offerings to better align with
the actual circumstances. As a first step in this process, the Commission removed
residential and small general service ('R&SGS") customers with exporting systems from
Schedule 84 and created two new tariff schedules: Schedule 6 and Schedule 8.5
Schedule 84 continued to define the terms for Cl&l customers with exporting systems.o
9. ln order to more accurately assign the appropriate share of fixed costs and
unquantified benefits of on-site customer generation, the Commission also directed the
Company to "initiate a docket to comprehensively study the costs and benefits of on-site
generation on ldaho Power's system, as wellas proper rates and rate design, transitional
rates, and related issues of compensation for net excess energy provided as a resource
to the Company.'7
Case No. IPC-E-18-15
10. Case No. IPC-E-18-15 was initiated by ldaho Power to study the costs,
benefits, and compensation of net excess energy supplied by customer on-site
generation.s Subsequently, the Company, Staff, and various stakeholders undertook a
thorough, data-driven evaluation of the Company's on-site generation offering and
5 Case No. IPC-E-17-13, Order No. 34046 at 30-31 (May 9, 2018).
6 ld. at 31.
7 ld.
I Case No. IPC-E-18-15, Petition to lnitiate Docket (Oct. 19, 2018)
APPLICATION - 5
through this collaborative process the parties were able to reach a compromise on a
significant number of critical elements to the Company's on-site generation offering
("Seft lement Agreement").
11. However, the Commission ultimately rejected the proposed Settlement
Agreement because the process did not satisfy the requirements that it had established
in Case No. IPC-E-17-13.s As a result, the Commission reiterated that no changes to the
Company's net-metering program would be considered unti! ldaho Power has prepared
and filed a "credible and fair study" of the costs and benefits of distributed on-site
generation.
12. ln its Order, the Commission outlined a "study design" phase and a "study
review" phase. During the "study design" phase, Staff and the Company will both "host
public workshops to share information and perspectives on net-metering program design
with the public and to listen to customer concerns and input.'1o ln the "study review"
phase, the public will have the opportunity to comment on whether the study sufficiently
addressed their concerns and their opinions on what the study shows.11
13. While the Commission did not change the Company's net-metering service
offering at that time, it did establish criteria to define legacy treatment for existing systems
under Schedule 6 and Schedule 8.12
e Case No. IPC-E-18-15, Order No. 34509 at 6 (Dec. 20,2019).
10 /d. at 9-10.
11 ld.
12 See Case No. IPC-E-1 8-15, Order No. 34509 at 14-15 and Order No. 34546 at 8-1 1 (Feb. 5, 2020)
APPLICATION - 6
Case No. IPC-E-19-15
14. The Company initiated Case No. IPC-E-19-15 while the issues in Case No.
IPC-E-18-15 were still under Commission review. ln the application, ldaho Power
highlighted concerns that Schedule 84 customers were continuing to rely on the
expectation of the ongoing application of the net monthly billing and compensation
structure and asked the Commission to initiate the new docket to consider similar issues
as to what was under review in Case No. IPC-E-18-15, but for Cl&l customers taking
service under Schedule 84. Subsequent to the Commission rejecting the Settlement
Agreement in Case No. IPC-E-18-15, ldaho Power withdrew its application in Case No.
!PC-E-19-15, indicating the matters related to compensation structure and export credit
rate for Schedule 84 would be appropriately considered in the new future comprehensive
study docket as prescribed in Case Nos. IPC-E-17-13 and IPC-E-18-15.
Case No. IPC-E-20-26
15. The Company initiated Case No. IPC-E-20-26 for authorization to change
Schedule 84's two-meter requirement to a single-meter requirement for new customer-
generators and to establish legacy treatment for existing customer-generators under the
current rules as of December 1,2020. The Commission ultimately established criteria
similar to Case No. IPC-E-18-15, defining legacy treatment for existing Schedule 84
systems.l3
Case No. IPC-E-21-21
16. On June 28,2021, ldaho Powerfiled Case No. IPC-E-21-2| requesting that
the Commission initiate the multi-phase process for a comprehensive study of the costs
13 Case No. IPC-E-20-26, Order No. 34854 at 11 (Dec. 1,2020\.
APPLICATION - 7
and benefits of on-site generation as directed in Order No. 34046.1a After considering
more than 250 written public comments, oral testimony at a public hearing, and written
comments filed by eleven parties to the proceeding, the Commission issued Final Order
No. 35284 approving a Study Framework detailed therein.
17. The Commission found that the Study Framework "meets our directive for
a credible and fair study" and reminded ldaho Power to "use the most current data
possible" that is readily available to the public and submitted to the Commission's
decision-making record.ls The Commission ordered that the Company "complete the
study in 2022 as soon as feasible" and indicated that "persons and parties will have
another opportunity to participate during the study review phase."to
Case No. IPC-E-22-12
18. Recently, another on-site generation related docket was initiated, which
seeks relief as to matters within the scope of the Study. On April 27,2022, Clean Energy
Opportunities for ldaho ('CEO") submitted a Petition asking that the Commission open a
separate docket, specific to CI&l customers, for the purposes of modiffing the on-site
generation project eligibility cap for Schedule 84 customers and establishing transition
guidelines regulating 'the pace at which the compensation for excess energy may change
for Schedule 84 customers if and when an Export Credit Rate is implemented."lT
1a Case No. IPC-E-21-21, Application (Jun. 25,2021).
15 Case No. IPC-E-21-21, Order No. 35284 at 9. See also Case No. IPC-E-18-15, Order No. 34509 at 9-
't0.
16 Case No. IPC-E-2 1-21 , Order No. 352M at 32 and 1 0.
17 ln the Mafter of Clean Energy Oppoftunities for ldaho's Petition for an Oder to Modify the Schedule 84
100kW Cap & To Establish a Tnnsition Guideline for Changes to Schedule 84 Expott Credit
Compensation Values, Case No. IPC-E-22-12, CEO Petition at 1 (Apr. 27,2022).
APPLICATION - 8
19. ldaho Power filed an Answer and Motion to Dismiss CEO's Petition on May
18,2022, asserting, inter alia, that the Petition improperly seeks to allow a single customer
class to bypass the process that the Commission has repeatedly determined is
necessary, constitutes an impermissible collateral attack on Order No. 35284, and is
redundant insofar as it raises issues within the scope of this Study.
20. On June 28,2022, the Commission issued Order No. 35453 seeking written
comments on whether the case should proceed or be dismissed.
I!I. THE COMPREHENSIVE STUDY
21. Following the Commission's Order in Case No. IPC-E-21-21, the Company
pursued the Study in accordance with the foundational principles outlined by the
Commission: The Study must (1) "use the most current data possible, and the data must
be readily available to the public, and in the Commission's decision-making record"; (2)
be designed "in coordination with the parties and the public, and the final scope of the
study will be determined by the Commission"i and (3) "be written so it is understandable
to an average customer, but its analysis must be able to withstand expert scrutiny."l8
22. Pursuant to this guidance, the Company largely utilized data from 2021 and
has included all underlying data and supporting documentation relied upon in
development of the Study as appendices thereto. ln addition, party and public comments
received throughout Case No. IPC-E-21-21were critical in shaping the Study Framework
ultimately approved by the Commission. As described more fully in Section lV, below, the
Company also solicited feedback from parties and the public while the Study was under
development through a public workshop. The Company also used this opportunity to seek
18 Case No. IPC-E-18-15, Order No. 34509 at 9.
APPLICATION - 9
public comment on the understandability of the concepts being described. The Company
included a glossary in the Study that describes key terms and acronyms and, where
appropriate, utilized figures and images to further enhance understandability of technical
concepts. While customer understandability was a high priority in the written Study, the
underlying analysis relies on a robust technical assessment of the costs and benefits of
customer generation on ldaho Power's system.
23. Driven by the Commission-approved Study Framework, the ultimate
objectives of the Study were to evaluate the costs and benefits of on-site generation on
ldaho Power's system fairly, objectively, and holistically. The Study and its appendices
represent the culmination of ldaho Powe/s efforts, documenting the analysis of the
benefits and costs of on-site customer generation within ldaho Power's service area.
24. As elucidated by the Commission, a fullcost-of-service evaluation, in-depth
study of rate design options, and implementation of transitional rates are outside the
scope of this proceeding.le As a result, billing structure is not at issue in this case. Rather
this proceeding is concerned with identifuing potential modifications to the compensation
structure for customer-generators that could occur in advance of a general rate case.
25. Pursuant to the Commission-approved Study Framework,2o the Study
addresses the following topics: (1) measurement interval; (2) export credit rate; (3)
frequency of export credit rate updates; (4) compensation structure; (5) class cost-of-
service; (6) recovering export credit rate expenditures; (7) project eligibility cap; (8) other
1s Case No. IPC-E-21-21, Order No. 35284 al24-25.
20 An overview of the Study Framework as authorized by the Commission vis-a-vis the Study is provided
on pages 27 through 30 of the testimony of Company witness Grant T. Anderson.
APPLICATION - 1O
areas of study; (9) implementation considerations including transitional rates and
administrative and communication materials.2l The Study includes 31 appendices which
contain the underlying data and supporting documentation for the information contained
within the Study. The comprehensive Study incorporates data for residential, small
general, commercial, industrial, and irrigation customers with exporting systems installed
and active for all 12 months of 2021.
26. lmportantly, the Study itself does not advocate for a single position regarding
potential modifications to the current net metering service, but rather examines several
methods of valuing customer-owned generation energy exports and explores other
important considerations.
IV. THE COLLABORATIVE PROCESS
27. Utilizing a collaborative approach, the Company sought input from the
public and stakeholders in pursuing the Study. On April 19,2022, the Company issued a
press release notifying the public of a public workshop to be held on May 2, 2022.Ihe
press release informed the public that "the workshop willfocus on the export credit rate -
the amount customers with on-site generation systems, such as rooftop solar panels, are
credited for the excess energy they send back to Idaho Powe/s grid." Additionally, the
press release notified the public that during the workshop, ldaho Power would "share
information on the possible methods for evaluating the export credit rate" and the
workshop would be an opportunity for "customers and interested stakeholders to provide
21 Notably, the two matters that CEO is pursuing through a separate docket, Case No. IPC-E-22-12,tall
squarely within the Study Framework and are addressed in Sections 9 and 11 of the Study.
APPLICATION - 11
feedback to the Company."zz The Company also sent notice to all parties in Case No.
IPC-E-21-21 informing them of the workshop and how to participate.
28. ln addition to several parties that had participated in previous cases, more
than 40 members of the public attended the workshop, and a recording and copy of the
presentation materials were made publicly available on ldaho Power's website following
the workshop. At the workshop, the Company presented an overview of the
methodologies identified within the Study Framework and asked for public feedback
regarding the methods under study for determining the value of excess net energy.23
29. 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 of
the Study.
30. Following the workshop, the Company received five comments from the
public and one comment from CEO.
31. Generally, the public comments discussed the need for affordability and
accessibility of solar generation and highlighted that environmental and societal benefits
should drive ldaho Power to incentivize and promote customer generation. Two
comments mentioned a perceived unfairness with "changing rates" for non-legacy
22 A copy of the press release for the workshop is aftached as Exhibit 1 to the Direct Testimony of Grant
Anderson.
23 A copy of the presentation is aftached as Exhibit 2 to the Direct Testimony of Grant Anderson.
APPLICATION - 12
customers. Comments also expressed a desire for a fair study and an understandable
report.2a
32. CEO provided comments on four topics that they suggest for consideration:
(1) CEO suggests that ldaho Power consider the potential for customer-generator exports
to allow ldaho Power to avoid costs associated with purchasing additional renewable
energy credits ("REC"); (2) CEO proposed ldaho Power considerwhether it could provide
incentives to reduce the cost for customers to install on-site generation to avoid
distribution system upgrades; (3) CEO suggested that time-of-use ("TOU") rates would
be befter focused on incenting changes in consumption patterns than the export credit
rate; and (4) CEO believes the study should address the value of exports from customers
with on-site generation in reducing fuel price risk.
33. As more fully set forth in pages 34 through 36 of the testimony of Company
witness Grant T. Anderson, the Study addresses CEO's recommendations (1), (2), and
(4) as follows: Section 4.5.2 of the Study, Crediting Customers for Value of Renewable
Energy Credits, addresses CEO's comment regarding the potentialfor customer exports
to avoid costs associated with purchasing additional RECs; Section 4.3.1 of the Study,
Transmission and Distribution Capacity Cost: Method and Assumptions, discusses this
proposal to offer incentives for on-site generation systems interconnected in locations that
avoid distribution system upgrades; and Section 4.1 of the Study, Avoided Energy Costs,
evaluates the value from customer-generator exports related to fuel price risks.
34. With respect to CEO's third recommendation, the Company is not opposed
to evaluating TOU rates for consumption pursuant to CEO's suggestion that TOU rates
2aA copy of public comments is included as Exhibit 3 to Direct Testimony of Grant Anderson.
APPLICATION - 13
would be better focused on incenting changes in consumption patterns than the export
credit rate. That, however, is a question of rate design, which is outside the scope of this
Study.2s
V. STUDY REVIEW AND RECOMMENDATIONS
35. The fina! stages of the multi-phase study process should continue in the
spirit of transparency, collaboration, and fairness. The Study explores severa! methods
of valuing customer-owned generation energy exports and explores other important
considerations, and ldaho Power looks forward to receiving input on the Study from the
Commission Staff, intervenors, and members of the public as part of the study review
process.
36. There are severa! key findings supported by the Study. First, it is clear from
the Study that the Company has the technical capability to reduce the measurement
interva! for on-site generation exports and that such a modification would improve the
accuracy of cost assignment and compensation for on-site generation customers.
Second, the Study presents multiple valid methods of valuing excess energy from on-site
generators, each of which differ materially from current retail energy rates, suggesting
consideration of modifications is warranted. Lastly, the Study presents several
implementation considerations that can adequately inform the appropriate timing of
transitioning to a successor service offering.
37. The Company has not yet developed a recommendation for potential
modifications to its on-site generation offerings for the Commission's consideration,
though as outlined by the proposed schedule in Section Vl below, it does propose to do
so as part of the case. The Company believes its ultimate recommendation will be best
25 Case No. IPC-E-21-21, Order No. 35284 al24-25.
APPLICATION - 14
guided and informed by feedback and input received from parties to the case and
members of the public.
38. The Company anticipates recommendations would address the following:
Compensation Structure - Recommendations on (1) a proposed
measurement interval; (2) export credit rate value and structure.
Frequencv of Updates - Recommendations on the appropriate
frequency of export credit rate updates to balance customer stability
and the need for regular updates to track avoided costs.
Recoverv of Exoort Credit Expenditures - Recommendations on the
mechanism to recover export credit expenditures.
Proiect Elioibilitv Cap - Recommendations related to the project
eligibility cap for exporting systems.
Transitional Rates - Recommendations on the need for a transitional
period to a modified export credit rate, including the appropriate
timing to transition.
39. lf the Commission ultimately authorizes a successor service offering for
non-legacy on-site customer-generators, the Study contemplates the following
considerations be evaluated: (1) transitional rates, and (2) administrative updates and
commu n ication materials.
40. As further discussed in Section 11.1 of the Study, Transitional Rates, the
Study does not set forth a specific proposal for implementation but recognizes that the
Commission, with input from parties, the public, and the Company, can assess if a
transition period is fair, just, and reasonable for on'site customer-generators with non-
legacy systems once changes to the compensation structure are known.
APPLICATION - 15
V!. PROPOSED STUDY REVIEW AND IMPLEMENTATION SCHEDULE
41. The Company envisions scheduled events would occur sequentially to first
allow for public vetting of the Study before stakeholders, including the Company, take
positions on recommended methods for implementing a successor service offering for
non-legacy on-site customer-generator systems.
42. ln anticipation of a scheduling conference with Staff and intervenors, the
Company proposes a procedural schedule like the following that will allow participants to
review and provide input on the Study and would facilitate the Company and other parties
making recommendations to the Commission in the early fall of this year:
June 30,2022 Idaho Power Files Study
August 22-25,2022 Staff and Company host public workshop(s) on Study
September 5,2022 Party initial comments on Study
September 26,2022 All Party reply comments on Study
October 12,2022 All Party comments proposing recommendations for
implementation (accompanied by all supporting workpapers)
All Party final reply comments on implementation
recommendations (accompanied by all supporting workpapers)
Company Final Response
November 14,2022
November 30,2022
December 5,2022 IPUC public hearing(s)
December 30,2022 Target date for IPUC order
Approximatc Date Evcnt
APPLICATION - 16
43. This proposed proceduralschedule would position the Commission to issue
an order directing changes to the on-site customer generation service offering by
December 30,2022.
44. Following issuance of an order, the Company would request that the
Commission allow for the implementation of potential changes over at least a S-month
period, meaning any Commission-approved changes to the on-site generation service
offering would not occur before June 1 ,2023. This time would allow for the evaluation of
actions necessary before implementation, including required system changes, tariff
updates, and customer and installer communication.
VII. STAKEHOLER & CUSTOMER NOTIFICATION
45. ldaho Power has issued a news release to notiff the public of this
Application.
46. ln addition, ldaho Power will directly notiff all existing customers, including
residential and small general customers (those taking service under Schedules 1, 6,7,
and 8) and large general service, industrial, and irrigation customers (those taking service
under Schedules 9, 19, 24, and 84) of the Application with a bill insert in their next billing
cycle. The bill insert will notify all customers that ldaho Power has filed a comprehensive
study analyzing the benefits and costs of on-site customer generation within Idaho
Power's service area. The customer notice also explains that the study provides
information that the Commission, ldaho Power, and other stakeholders will use to
determine what changes to ldaho Power's existing customer generation offering should
be implemented and the timing of that implementation. A copy of the press release and
customer bil! insert are included as Attachment 2 to the Application.
47. ldaho Power will also send direct mai! letters to all existing and pending on-
site generation customers notifying them of the case. Legacy customers wil! receive a
APPLICATION - 17
letter notiffing them thatthe Company has filed the Studywith the Commission, reminding
them of legacy status and how to maintain legacy status, and will provide information on
how they can participate in the proceeding. Non-legacy customers will receive a letter
notiffing them that Company has filed the Study with the Commission, informing them
they may be impacted by the outcome of the case, and will provide information on how
they can participate in the proceeding. A draft of the letters is included as Attachment 3
to the Application.
48. ldaho Power has also served a copy of this Application on the parties of
record in Case No. IPC-E-21-21that established the Study Framework.
VIII. MODIFIED PROCEDURE
49. ldaho Power believes that a hearing is not necessary to consider the issues
presented herein, and respectfully requests that this Application be processed under
Modified Procedure pursuant to Commission Rules of Procedure201, ef seg. lf, however,
the Commission determines that a technical hearing is required, the Company stands
ready to present the accompanying direct testimony of Grant T. Anderson in support of
its Application.
IX. COMMUNICATIONS AND SERVICE OF PROCEEDINGS
50. Service of pleadings, exhibits, orders, and other documents relating to this
proceeding should be served on the following:
Lisa D. Nordstrom
Megan Goicoechea AIlen
IPC Dockets
1221West ldaho Street (83702)
P.O. Box 70
Boise, lD 83707
Inordstrom@idahopower. com
mqoicoecheaa lle n@ida hooower. com
dockets@ida hopower.com
Timothy Tatum
Connie Aschenbrenner
Grant Anderson
1221 West ldaho Street (83702)
P.O. Box 70
Boise, !D 83707
caschenbren [e-mail]
qa nderson@ida hooower. com
ttatum@idahopower. com
APPLICATION - 18
X. REQUEST TO INITIATE PROCEEDINGS TO COMPLETE STUDY REVIEW
PHASE & EVALUATE IMPLEMENTATION OPTIONS
51. The Company requests that the Commission initiate the study review and
implementation phases of the comprehensive study of costs and benefits of on-site
customer generation as outlined by the Commission in Order No. 34509.26 Specifically,
the Company requests the Commission (1) establish a formal process for public review
of, and comment on, the Study; (2) issue an order acknowledging that the Study satisfies
the Commission directives outlined in Order Nos. 34046, 34509, and 35284, and directing
modifications to the Company's on-site generation service offerings be implemented.
DATED at Boise, ldaho, this 30th day of June 2022
X*!.ff^l-t^-*,
LISA D. NORDSTROM
Attorney for ldaho Power Company
26 Case No, IPC-E-18-15, Order No. 34509 at 9-'t0.
APPLICATION.l9
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 30th day of June2022. I served a true and correct
copy of IDAHO POWER COMPANY'S APPLICATION upon the following named parties
by the method indicated below, and addressed to the following:
Commission Staff
Riley Newton
Deputy Attorney General
ldaho Public Utilities Commission
1'1331 W. Chinden Blvd., Bldg No. 8
Suite 201-A (83714)
PO Box 83720
Boise, lD 83720-0074
Hand Delivered
_U.S. Mai!
_Overnight Mail
_FAX_FTP SiteX Email [e-mail]
ldaHydro
C. Tom Arkoosh
ARKOOSH LAW OFFICES
913 W. River Street, Suite 450
P.O. Box 2900
Boise, Idaho 83701
_Hand Delivered
U.S. Mail
_Overnight Mai!
_FAX_FTP SiteX Email [e-mail]
erin. cecil@a rkoosh.com
ldaho Conservation League
Benjamin J. Otto
ldaho Conservation League
710 North 6th Street
Boise, ldaho 83702
_Hand Delivered
U.S. Mail
Overnight Mail
_FAX
FTP Site
x Email botto@ida
ldaho lrrigation Pumpers Association, lnc.
Eric L. Olsen
ECHO HAWK & OLSEN, PLLC
505 Pershing Avenue, Suite 100
P.O. Box 6119
Pocatello, ldaho 83205
_Hand Delivered
U.S. Mail
_Overnight Mai!
_FAX_FTP SiteX Email [e-mail]
City of Boise
Ed Jewell
Deputy City Attorney
Boise City Attorney's Office
150 North Capitol Boulevard
P.O. Box 500
Boise, ldaho 83701-0500
_Hand Delivered
U.S. Mail
_Overnight Mail
_FAX_FTP SiteX Email [e-mail]
[e-mail]
APPLICATION .20
ldaho Glean Energy Association
Kevin King
Board President
P.O. Box2264
Boise, lD 83702
_Hand Delivered
U.S. Mail
_Overnight Mail
_FAX_FTP SiteX Email [e-mail]
lndustrial Customers of ldaho Power
Peter J. Richardson
R]CHARDSON ADAMS, PLLC
515 North 27th Street (83702)
P.O. Box 7218
Boise, ldaho 83707
_Hand Delivered
_U.S. Mail
_Overnight Mail
_FAX_ FTP SiteX Email [e-mail]
Dr. Don Reading
6070 Hill Road
Boise, ldaho 83703
_Hand Delivered
_U.S. Mail
_Overnight Mail
_FAX_ FTP SiteX Email [e-mail]
Micron Technology, lnc.
Austin Rueschhoff
Thorvald A. Nelson
Austin W. Jensen
Holland & Hart, LLP
555 Seventeenth Street, Suite 3200
Denver, Colorado 80202
Hand Delivered
U.S. Mai!
Overnight Mail
_ FAX
_ FTP SiteX Email [e-mail]
tnelson@hollandha rt.com
[e-mail]
q lqa rqano-a mari@holla nd hart. com
Jim Swier
Micron Technology, lnc.
8000 South FederalWay
Boise, ldaho 83707
Hand Delivered
U.S. Mail
Overnight Mai!
_ FAX
_ FTP SiteX Email [e-mail]
aclee@holland ha rt.com
Glean Energy Opportunities for ldaho
Kelsey Jae
Law for Conscious Leadership
920 N. Clover Dr.
Boise, ldaho 83703
Hand Delivered
U.S. Mail
Overnight Mail
_ FAX
_ FTP SiteX Email [e-mail]
APPLICATION - 21
Michael Heckler
Courtney \Mlite
Clean Energy Opportunities for ldaho
3778 Plantation River Dr., Suite 102
Boise, lD 83703
_Hand Delivered
U.S. Mail
_Overnight Mail
_FAX_FTP Site
X Email
cou rtnev@clea nenerqvopportu n ities. com
mike@cleanenerqvopportun ities.com
Richard E. Kluckhohn
Wesley A. Kluckhohn
2564 W. Parkstone Dr
Meridian, lD 83646
Hand Delivered
U.S. Mail
Overnight Mail
_ FAX
_ FTP SiteX Email [e-mail]
[e-mail]
Kiki Leslie A. Tidwell
704 N. River Street #1
Hailey, ldaho 83333
Hand Delivered
U.S. Mail
Overnight Mail
_ FAX
_ FTP SiteX Emai! [e-mail]
ABC Power Co. LLC
Ryan Bushland
184 W. Chrisfield Dr.
Meridian, lD 83646
Hand Delivered
U.S. Mail
Overnight Mail
_ FAX
_ FTP SiteX Email [e-mail]
Idahome Solar, LLC
Tyler Grange
2484 N. Stokesberry Pl. #100
Meridian, !D 83646
Hand Delivered
U.S. Mail
Overnight Mail
_ FAX
_ FTP SiteX Email [e-mail]
APPLICATION -22
Comet Energy LLC
George Stanton
13601 W McMillan Rd. Ste 102 PMB 166
Boise, lD 83713
Hand Delivered
U.S. Mail
Overnight Mail
_ FAX
_ FTP SiteX Email [e-mail]
ldaho Solar Owners Network
Joshua Hill
1625 S. Latah
P.O. Box 8224
Boise, lD 83707
Hand Delivered
U.S. Mail
Overnight Mail
_ FAX
_ FTP SiteX Email [e-mail]
[e-mail]
&r"*,
Stacy Gust, Regulatory Administrative
Assistant
APPLICATION - 23
BEFORE THE
IDAHO PUBLIC UTILITIES GOMMISSION
GASE NO. IPC-E-22-22
IDAHO POWER COMPANY
ATTACHMENT 1
VALUE OF ON.SITE DISTRIBUTED ENERGY
RESOURCES (VODER) STUDY
SEE ATTACHED SEPARATE DOCUMENTS
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
GASE NO. IPG-E-22-22
IDAHO POWER COMPANY
ATTACHMENT 2
CUSTOMER NOTICE
-IUHOPffi.NEWSRELEASE
ldaho Power Files Customer Generation Study
June 30,2022
BOISE, ldaho - At the direction of the ldaho Public Utilities Commission (IPUC), ldaho Power has filed a
study analyzing the benefits and costs of on-site customer generation within the company's service
area. The study provides information that the IPUC, ldaho Power and other stakeholders will use to
determine whether changes should be made to ldaho Power's existing customer generation offering for
all customer classes (Schedule 5, Schedule 8 and Schedule 84).
The completed study, which opens case IPC-E-22-22,includes a review of methods to determine
benefits and costs that come when excess energy is generated by on-site generation systems, such as
solar and wind, that interconnect with the ldaho Power grid. The elements of the study, approved by the
IPUC in case IPC-E-21-21 last year, include several components of on-site customer generation:
The measurement interval of excess energy generated by customers (i.e., net hourly or
real-time)
The Export Credit Rate (ECR), which is how customers are compensated (in the form of a
rate credit) for excess energy they send back to ldaho Power's grid
An evaluation of the eligibility caps for on-site customer generation systems, which are
currently set at 25 kilowatts (kW) for residential customers and 100 kW for commercial,
industrial and irrigation customers
Other factors - including the timing of potential updates to the ECR, an evaluation of
expiring credits and billing structure considerations - with the goal of keeping the
public well informed of any potential changes to customer generation
Next, the IPUC will set a schedule to process the case and interested stakeholders will have an
opportunity to submit public comments on the study. ldaho Power has proposed a schedule that could
allow for the IPUC to issue a determination as to the future structure of this service offering by the end
of 2022, with implementation no earlier than June L,2023. To view the study and supporting data, visit
idahopower.com/study. To provide feedback to the IPUC regarding the study, visit puc.idaho.gov and
reference Case No. IPC-E-22-22.
As part of previous rulings, the IPUC granted legacy (grandfathered) status to eligible Schedule 5 and 8
(residential and small general service) on-site generation systems as of December 20,20L9.
Eligible Schedule 84 (commercial, industrial and irrigation) systems received legacy status as of
December t,2O2O. Customers who do not have legacy systems are subject to changes to the on-site
generation compensation structure, including the value of the ECR. Customers are notified when
applying for interconnection that the value of excess energy is subject to change. While not at issue in
this case, all on-site generation customers, regardless of legacy status, are subject to changes in rates
(energy prices), billing components and billing structure.
a
a
a
a
About ldaho Power
ldaho Power, headquartered in vibrant and fast-growing Boise, ldaho, has been a locally operated
energy company since 1916. Today, it serves a 24,000-square-mile area in ldaho and Oregon.
The company's goal to provide 100% clean energy by 2045 builds on its long history as a clean-energy
leader that provides reliable service at affordable prices. With 17 low-cost hydroelectric projects at the
core of its diverse energy mix, ldaho Powe/s residential, business and agricuhural customers pay among
the nation's lowest prices for electricity. lts 2,000 employees proudly serve more than 500,000
customers with a culture of safety first, integrity always and respect for all.
IDACORP lnc. (NYSE: IDA), ldaho Power's independent publicly traded parent company, is also
headquartered in Boise, ldaho. To learn more, visit idahooower.com or idacoroinc.com.
Jordan Rodriguez
Communications Specialist
irodriguez@ idahooower.com
208-388-2460
ldaho Power Files Customer
Generation Study
At the direction of the ldaho Public Utilities Commission
(IPUC), ldaho Power has filed a study analyzing the
benefits and costs of on-site customer generation
within the company's service area. The study provides
information that the IPUC, ldaho Power and other
stakeholders will use to determine whether changes
should be made to ldaho Power's existing customer
generation offering for all customer classes (Schedule 6,
Schedule 8 and Schedule 84).
The completed study, which opens case IPC-E-22-22,
includes a review of methods to determine benefits and
costs that come when excess energy is generated by
on-site generation systems, such as solar and wind, that
interconnect with the ldaho Power grid.
How can customers participate?
Next, the IPUC will set a schedule to process the case
and interested stakeholders will have an opportunity to
submit public comments on the study. ldaho Power has
proposed a schedule that could allow for the IPUC to issue
a determination as to the future structure of this service
offering by the end of 2022, with implementation no
earlier than June 1, 2023.To view the study and supporting
data visit idahopower.com/study. To provide feedback
to the IPUC regarding the study, visit puc.idaho.gov and
reference Case No. IPC-E-22-22.
What if my on-site generation
system has legary status?
As part of previous rulings, the IPUC granted legacy
(grandfathered) status to eligible Schedule 6 and 8
(residential and small general service) on-site generation
systems as of December 20, 2019. Eligible Schedule 84
(commercial, industrial and irrigation) systems received
legary status as of December 1,2020.
Customers who do not have legacy systems are subject to
changes to the on-site generation compensation structure,
including the value of the Export Credit Rate (ECR).
Customers are notified when applying for interconnection
that the value of excess energy is subject to change. While
not at issue in this case, all on-site generation customers,
regardless of legacy status, are subject to changes in rates
(energy prices), billing components and billing structure.
Thank you for reading this notice.
We value your business.
StmtoPci[,ER"O Printed on recycH paper.
02022 ldaho Power
31 180-t-0193An IDACORP Company
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-22-22
IDAHO POWER COMPANY
ATTACHMENT 3
CUSTOMER LETTER
SIIMIOPO'I'ER,
Re: Update on Value of Distributed Energy Resources (VODERI Study
Hello,
As a customer with on-site generation (e.g., rooftop solar), you are receiving this letter because we want
to keep you informed about a new case that is being considered by the ldaho Public Utilities Commission
(IPUC) where they are reviewing a study that was recently completed by ldaho Power. Below are details
about the case - as well as information on how you can participate.
Please note - you have a lesacv (i.e., grandfathered) system, which means your on-site generation
compensation structure (1to f kilowatt-hour usage offset) will not change until 2045. See the questions
and answers be
legacy status.
low for more n on legacy status and how to ensure you retain your system's
Why did ldaho Power
At the direction of the I this study analyzing the benefits and costs of on-site
customer generation within rea. The study provides information that the IPUC,
ldaho Power and other stakehold ine whether changes should be made to ldaho
Powe/s existing customer gene
Schedule 84).
I customer classes (Schedule 6, Schedule 8, andn
a
a
The completed study, which opens case I a iew of methods to determine
benefits and costs that come when excess energy is customer generation systems,
such as solar and wind, and sent back to ldaho Powe
What is included in the study?
The elements of the study, approved by the IPUC in case IPC-E-21-21 last several
components of on-site customer generation:
a
a
The measurement interval of excess energy generated by custo rs (i.e., net hourly or real-time)
The Export Credit Rate, which is how customers are compensated (in the form of a rate credit,
currently a "kilowatt-hou/' credit) for excess energy they send back to ldaho Power's grid
An evaluation of the maximum system sizes allowed for on-site customer generation, which are
currently set at 25 kilowatts (kW) for residential customers and 100 kW for commercial, industrial
and irrigation customers
Other factors, including the timing of potential updates to the Export Credit Rate, an evaluation of
expiring credits, and billing structure considerations, and a plan to keep the public well informed of
any potential changes to customer generation
What if my on-site generation system has legacy status?
As part of previous rulings in 2019 and 2020, the IPUC granted legacy status to eligible on-site customer
generation systems. Legacy systems will continue to receive the "1 to 1 kilowatt-hour" compensation for
excess energy until the end of the legacy period, or untilthey forfeit legacy status (see question on
criteria for legacy systems below). The legacy period, unless othenarise forfeited, will end:
1221 W. ldaho St. (83702)
P.O. Box 70
Boise, lD 83707
. December 20,2045 for residential and small general service customers (Schedule 6 and 8)
o December t,2045 for large general service, industrial and irrigation customers (Schedule 841,
841 and 84A).
Customers who do p! have legacy systems are subject to changes to the on-site generation
compensation structure, including the value of the Export Credit Rate. When ldaho Power receives a
custome/s on-site generation application, the customer is notified that the value of excess energy is
subject to change.
As a reminder, legacy status only applies to the compensation structure (e.g.; kWh credits for the excess
energy your system sends to I /s grid, monthly measurement interval, credit transfers). Your
credits will continue to you use from ldaho Power as a "1to 1" offset. All
customers, including o regardless of legacy status, are subject to changes in
rates (energy prices),
ldaho Power.
structure for the service and energy provided by
Who received legacy status?
o Customers who interconnectedo Customers who submitted an o
ber20,2OL9,or
on or before December 20,20L9,
and provided evidence of a binding financial on-site generation system by
January 19,2020, and who completed the np by December20,2O2O.
t,
non ber L,2020,
ber L,202L.
What are the criteria for legacy systems (and reasons legacy status may be forfeitedl?
It is the on-site generation system, not the customer, that receives legacy status at the meter site and at
its originally installed nameplate capacity. The IPUC clarified the following criteria for legacy systems:
o A customer who moves into a property with a legacy net-metering system will "inherit" the
legacy system.o When a customer moves from a property with a legacy system, that customer does not get to
take the legacy status of the system with them to their next property.
o lf a system is offline for more than six months, or is moved to another site, the legacy status of
the system is forfeited.o lf a customer expands their system, the expansion must be metered separately to retain the
legacy status of the original system. lf the expansion is not metered separately, the entire
system will lose legacy status.
e Customers who interconnected their system by Decembero Customers who submitted an on-site generation applicatio
and interconnected their system as a two-metered system
compo
To allow for the replocement of degraded or broken panels, the customer may increase the
capacity of their legacy system by no more than 10% of the originally installed nameplate
capacity or 1 kilowatt, whichever is greater.
How can t participate?
Next, the IPUC will set a schedule to process the case and interested stakeholders will have an
opportunity to submit public comments on the study. ldaho Power has proposed a schedule that could
allow for the IPUC to issue a determination as to the future structure of this service offering by the end
of 2022, with implementation no earlier than June L,2023.
a
To view the study and su
regarding the study, visit
pport
You can find more
FAQs, at
Customer Care team at
Sincerely,
Your ldaho Power Customer Generation
visit idahopower.com/study. To provide feedback to the IPUC
and reference Case No. IPC-E-22-22.
Generation, including information about this case and
ion. lf you have additional questions, you can callour
about
Jil
-
<ErmroPo,l,ER.
Re: Update on Value of Distributed Energy Resources (VODER) Study
Hello,
As a customer with on-site generation (e.g., rooftop solar), you are receiving this letter because you may
be impacted by future changes to ldaho Powe/s service offering for on-site customer generation. Our
goal is to keep you informed about a new case that is being considered by the ldaho Public Utilities
Commission (IPUC) where they are reviewing a study that was recently completed by ldaho Power.
Below are details about the case - as well as information on how you can participate.
Why did ldaho Power conduct this study?
At the direction of the IPUC,prepared a study analyzing the benefits and costs of on-site
customer generation s service area. The study provides information that the IPUC,
ldaho Power and use to determine whether changes should be made to ldaho
Powe/s existing
Schedule 84).
all customer classes (Schedule 5, Schedule 8, and
The completed study, which includes a review of methods to determine
benefits and costs that come excess generated by on-site customer generation systems,
such as solar and wind, and sent back to
What is included in the study?
The elements of the study, approved by the IPUC in
components of on-site customer generation:
year, include several
The measurement interval of excess energy by (i hourly or real-time)
The Export Credit Rate, which is how customers are compensated (in t a rate credit,
grid
generation, which are
kW for commercial, industrial
Other factors, including the timing of potential updates to the Export Credit Rate, an evaluation of
expiring credits, and billing structure considerations, and a plan to keep the public well informed of
any potential changes to customer generation
How does this affect me?
As a customer with an active or pending on-site generation system, you are subject to changes to the
on-site generation compensation structure, as noted on the Customer Generation Application and in the
email response from ldaho Power confirming your application was received. Currently, customers
receive a kilowatt-hour (kWh) credit for any excess energy their systems send to the ldaho Power grid
each month. This study explores the option of a monetary credit instead of a kWh credit, and a shorter
credit measurement interval (e.g. hourly instead of monthly). This study review and implementation
phase could lead to future changes in the on-site generation compensation structure, including the
value of the Export Credit Rate.
1221 w. ldaho 5t. (83702)
P.O. Box 70
Boile, lD 83707
a
a
a
a
currently a "kilowatt-hou/'credit) for excess energy they send
An evaluation of the maximum system sizes allowed for on-site
currently set at 25 kilowatts (kW) for residential customers and
and irrigation customers
How can I participate?
Next, the IPUC will set a schedule to process the case and interested stakeholders will have an
opportunity to submit public comments on the study. ldaho Power has proposed a schedule that could
a!!ow for the IPUC to issue a determination as to the future structure of this service offering by the end
of 2022, with implementation no earlier than June L,2023.
To view the study and supporting data, visit idahopower.com/study. To provide feedback to the IPUC
regarding the study, visit ouc.idaho.eov and reference Case No. IPC-E-22-22.
You can find more information about Customer Generation, including information about this case and
FAQs, at lf you have additional questions, you can call our
Customer Care team at
Sincerely,
Your ldaho Power