20220921Comments.pdf

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l,: ( irri I: tZMegan Goicoechea Allen
Corporate Counsel
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September 21,2022
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-22-22
ln the Matter 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
Dear Ms. Noriyuki:
Attached for electronic filing is ldaho Power Company's lnitial Comments in the
above-referenced matte r.
lf you have any questions about the documents referenced above, please do not
hesitate to contact me.
Very truly yours,
Wlarod^n0ilo,t
Megan Goicoechea Allen
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
[e-mail]
Attorneys for Idaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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
IDAHO POWER COMPANY'S
IN!T!AL COMMENTS
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COMES NOW, ldaho Power Company ("ldaho Powef or "Company"), and
pursuant to the Notice of Schedule, Notice of Workshops, and Notice of Comment
Deadlines issued by the ldaho Public Utilities Commission ("Commission") in Order No.
35512, respectfully submits its initial comments in the above-referenced case as follows.
IDAHO PO\A'ER COMPANY'S INITIAL COMMENTS - 1
I. BACKGROUND
Pursuant to the Commission's directive in Order No. 35284,1 the Company filed its
Application in this matter on June 30, 2022 ("Application'), requesting that the
Commission complete the study review phase of the multi-phase collaborative process
being undertaken by the Commission, interested parties, the public, and the Company to
study the costs, benefits, and compensation of net excess energy associated with on-site
customer generation. ln conjunction with its Application, Idaho Power submitted the Value
of Distributed Energy Resources ("VODER") study along with accompanying appendices,
representing the comprehensive study of the costs and benefits of on-site customer
generation ("Study") performed by the Company for the study review and implementation
phases.
VUith its filing, the Company requested that the Commission initiate the study
review and implementation phase by (1) establishing a formal process and timeline for
Commission Staff ("Staff'), intervenors, and the public to review and comment on the
Study; (2) issuing an order acknowledging that the Study satisfies the Commission
directives outlined in Order Nos. 34046, 34509, and 352842 and directing modifications
to the Company's on-site generation service offerings to be implemented.
1 ln the Matter of ldaho Power Company's Application to lnitiate a Multi-Phase Collabomtive Prccess for
the Study of Costs, Benefits, and Compensation of Net Excess Eneryy Associated with Customer On-Site
Generation, Case No. IPC-E-21-21, Order No. 35284 at 32 (Dec. 30,2021).
2 ln the Matter of ldaho Power Company's Application for Authoity to Establish New Schedules for
Residential and Small GeneralService Cusfomers with On-Site Genention, Case No. IPC-E-17-13,
Order No. 34046 at 31 (May 9, 2018); ln the Matter of the Application of ldaho Power Company to Study
fhe Costg Benefits, and Compensation of Net Excess Energy Supplied by Customer On-Sife Generation,
Case No. IPC-E-18-15, Order No. 34509 at 17 (Dec. 20, 2019); and ln the Mafter of ldaho Power
Company's Application to lnitiate a Multi-Phase Collaborative Process forthe Study of Costs, Benefits,
and Compensation of Net Excess Energy Associated with Customer On-Sife Generation, Case No. IPC-
E-21-21, Order No. 3528/. at 32-33 (Dec. 30, 202'l).
IDAHO PO\A'ER COMPANY'S INITIAL COMMENTS - 2
The following persons timely intervened in the case pursuant to the Amended
Notice of Parties filed on August 22, 2022: the Company, Staff, Clean Energy
Opportunities for ldaho ('CEO'), IdaHydro, ldaho lrrigation Pumpers Association, lnc.
('llPA'), Idaho Conservation League ("lCL"), lndustrial Customers of Idaho Power
('lClP"), City of Boise, Richard E Kluckhohn, pro se, and Wesley A. Kluckhohn, pro se
("Kluckhohn"), Micron Technology, lnc. ("Micron"), ldaho Solar Owners Network ("lSON'),
and ABC Power Company, LLC ('ABC Powe/') (collectively the "Parties'). The
Commission also issued a Notice of Schedule, Notice of Workshops, and Notice of
Comment Deadlines on August 22,2022, which scheduled severalpublicworkshops and
set deadlines for written comments,3 \Mile the Company's initial filing requested the
Commission both (1) acknowledge the Study, and (2) order modifications to the on-site
customer generation service offering,a the Commission adopted Staffs recommended
procedural schedule, which initially focuses only on the study review phase. The
Company believes the procedural schedule adopted by the Commission is preferred as
it will allow adequate time for the Commission to consider all comments on the Study
before it establishes a process and schedule for considering implementation
recommendations on the Study.s
Pursuant to the scheduling order, the Company held a public workshop on the
Study on August 31,2422. Subsequently, Staff held public workshops on September 6
and September 7. After that, and at the request of CEO, the Parties met for a technical
3 Order No. 35512.
a Application at 2.
5 Staff Decision Memorandum at 2 (August 16,2022).
IDAHO POIA'ER COMPANY'S INITIAL COMMENTS - 3
workshop on September 12,2022, to discuss the project eligibility cap. The scope of the
technical workshop was limited to the interconnection requirements associated with
systems larger than 100 kW and did not address the policy considerations associated
with modifying the cap, which will be more appropriately considered in developing
recommendations for implementation.
ldaho Power seeks to continue the collaborative approach in the review of the
Study and values the participation of Parties and the public in this docket. The Company
appreciates the opportunity to offer these initial comments on the Study now that the
public vetting process (study review phase) has begun. As set forth below, the Company
received valuable input during the workshops held to date, and it looks forward to
receiving additional feedback during the written comment phase. Public and Parties'
comments will continue to guide the Company as it seeks to clariff and refine aspects of
the Study to ensure a solid foundation before proceeding with recommendations for
implementation.
II. STUDY REVIEW & REVISED VODER STUDY
\Mth the Study filed on June 30, 2022, the Company endeavored to provide a
comprehensive study that encompassed the components of the Commission-approved
Study Frameworko and provide a reasonable basis for a complete public review prooess.
The Company believes it is important to clariff that the intent of the filed Study, perhaps
most notably, the Export Credit Rate section, was to provide illustrative, or indicative,
pricing based on various potential methods for evaluation during the present study review
phase. Contrary to what has been implied by some in the course of the Study review
6 Case No. IPC-E-21-2'1, Order No. 352&4 at 25.
IDAHO POVVER COMPANY'S INITIAL COMMENTS - 4
phase, the Company did not propose that any specific method be implemented at this
time. As noted in its Application: "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."T Ultimately, the Company believes a
Commission-approved or acknowledged Study could be leveraged for implementation
recommendations from the Company, Staff, Parties, and the public, to provide a
comprehensive and transparent process for potential modifications to the on-site
customer generation service offering and compensation structure. The data utilized in the
Study was representative of the Study timeframe and intended to present a relative order
of magnitude and allow for a comparison of methods to support the public record in this
docket. To ensure its continued utility and congruity, the precise values used in the Study
are subject to change upon Commission approval of any changes to the on-site customer
generation service offering.
As of the date of these initialcomments, the Company has reviewed the numerous
public comments submitted to the Commission and the feedback and questions received
during public workshops hosted by the Company and Staff, as well as discovery
submitted by the parties to the case. Wrile the Company drafted the Study with the best
information available at the time it was filed, the review process undergone to date has
highlighted some areas of the Study where the Company could provide additional clarity
and analysis. To ensure stakeholder and public input has been appropriately incorporated
7 Application at 9. See also rd. at 14 ("The Company has not yet developed a recommendation for
potential modifications to its on-site generation offerings for the Commission's consideration. . .").
IDAHO POWER COMPANY'S INITIAL COMMENTS - 5
into the Study, the Company intends to file a revised Study with its final comments on
October 26, 2022, incorporating feedback received throughout the review process to
refine and clariff salient issues. The revised Study will not include any substantive
modifications but will aim to clariff and refine the information based on the guidance
received throughout the review process to provide a solid foundation on which the Parties
can make recommendations for potentia! modifications to its on-site customer generation
offerings for the Commission's consideration. The Company believes this approach will
supplement the robust record from the study review process and offer the Commission a
complete work product that could be acknowledged to inform recommendations for
implementation and ultimately Commission approval for modifications to the customer-
generator service offering.
ilr. coNcLusroN
ln initiating this docket, ldaho Power noted that it intended to be guided and
informed by the feedback and input received in this case, which has already proven to be
a practical and effective approach in helping to identify areas of the Study that could
benefit from refinement. The Company anticipates it will continue to receive valuable
insight moving forward that may identiff other areas to hone and that can be incorporated
into the revised Study to be filed by the Company with its final comments on October 26,
2022. The revised Study will not include any substantive modifications but will aim to
clariff and refine the information based on the guidance received throughout the review
process to provide a solid foundation on which the Parties can make recommendations
for potential modifications to its on-site customer generation offerings for the
Commission's consideration. The Company appreciates the opportunity to participate in
IDAHO POWER COMPANY'S INITIAL COMMENTS -6
this collaborative process and looks forward to continuing to work with Staff, the Parties,
and the public in the spirit of transparency, collaboration, and faimess.
DATED at Boise, ldaho, this 21 day of September 2022.
Sicrdu^0flforr
MEGAN GOICOECHEA ALLEN
Attorney for ldaho Power Company
IDAHO POVI/ER COMPANY'S INITIAL COMMENTS - 7
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 21st day of September 2022, I served a true
and correct copy of ldaho Power Company's lnitial Comments upon the following
named parties by the method indicated below and addressed to the following:
Commission Staff
Riley Newton
Chris Burdin
Deputy Attorney Genera!
ldaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg No. 8
Suite 201-A (83714)
PO Box 83720
Boise, lD 83720-0074
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Chris.burdin@puc. idaho.qov
ldaHydro
C. Tom Arkoosh
Amber Dresslar
ARKOOSH LAW OFFICES
913 W. River Street, Suite 450
P.O. Box 2900
Boise, ldaho 83701
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Amber.d ressla r@a rkoosh.com
erin. [e-mail]
ldaho Conselation League
Marie Kellner
ldaho Conservation League
710 North 6th Street
Boise, ldaho 83702
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ldaho lrrigation Pumperc Association, lnc.
Eric L. Olsen
ECHO HAWK & OLSEN, PLLC
505 Pershing Avenue, Suite 100
P.O. Box 6119
Pocatello, ldaho 83205
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Lance Kaufman, Ph.D
4801 W. Yale Ave.
Denver, CO 80219
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IDAHO PO\A/ER COMPANY'S INITIAL COMMENTS - 8
City of Boise
Mary Grant
Deputy City Attorney
Boise City Attorney's Office
150 North Capitol Boulevard
P.O. Box 500
Boise, ldaho 83701-0500
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bo isecitvatto rn ev@citvofboise. oro
Wil Gehl
Energy Program Manager
Boise City Dept. of Public Works
150 N. Capitol Blvd.
PO Box 500
Boise, ldaho 83701-0500
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lndustrial Customers of ldaho Power
Peter J. Richardson
RICHARDSON ADAMS, PLLC
515 North 27th Street (83702)
P.O. Box 7218
Boise, ldaho 83707
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Dr. Don Reading
6070 Hill Road
Boise, ldaho 83703
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Micron Technology, Inc.
Austin Rueschhoff
Thorvald A. Nelson
Austin W. Jensen
Holland & Hart, LLP
555 Seventeenth Street, Suite 3200
Denver, Colorado 80202
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[e-mail]
awiensen @holland hart.com
Jim Swier
Micron Technology, Inc.
8000 South FederalWay
Boise, ldaho 83707
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aclee@holla nd hart.com
IDAHO POWER COMPANY'S INITIAL COMMENTS.9
Glean Energy Opportunities for ldaho
Kelsey Jae
Law for Conscious Leadership
920 N. CIover Dr.
Boise, ldaho 83703
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Michae! Heckler
Courtney White
Clean Energy Opportunities for ldaho
3778 Plantation River Dr., Suite 102
Boise, lD 83703
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cou rtnev@clea nenerqvopportu n ities. com
mike@cleanenerovooportu n ities. com
Richard E. Kluckhohn, pro se
Wesley A. Kluckhohn, pro se
2564 W. Parkstone Dr.
Meridian, lD 83646
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ldaho Solar Owners Network
Joshua Hill
1625 S. Latah
Boise, lD 83705
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ABC Power Company, LLC
Ryan Bushland
184 W. Chrisfield Dr.
Meridian, lD 83646
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[e-mail]
\bs^t &rsi.
Stacy Gust, Regulatory Administrative
Assistant
IDAHO POWER COMPANY'S INITIAL COMMENTS - 1O