20221026Final Comments.pdf

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Megan Goicoechea Allen
Corporate Counsel
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Attachments
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October 26,2022
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 Fina! Comments in the
above-refe re nced matte r.
Due to the voluminous nature of the Study and its 35 appendices, the Company is
transmitting these files to the Commission via a secure FTP site. The information to
access the FTP site was provided to the parties on June 30,2022.
Additionally, four (4) bound and three (3) unbound copies of the Study in both clean
and redline format 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,
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]
[e-mail]
mooicoecheaa [e-mail]
Attorneys for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COM PANY'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
CASE NO. |PC-E-22-22
IDAHO POWER COMPANY'S FINAL
COMMENTS
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COMES NOW, ldaho Power Company ("!daho 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 FinalComments in the above-referenced case as follows.
I. INTRODUCTION
The 2022 Value of Distributed Energy Resources Study ('VODER Study") that
forms the subject of this docket represents a significant milestone in ldaho Power's efforts
to modernize its on-site generation policies and practices to correspond with the nuances
IDAHO PO\A/ER COMPANY'S FINAL COMMENTS.l
of the current environment. lt was developed and conducted at the Commission's behest
as a means of ensuring that the Commission can make a well-reasoned decision on the
Company's on-site generation service offering, considering the complexity of the issues
and the deep convictions engendered by the topic. Driven by the Commission-approved
Study Framework,l the ultimate objective of the VODER Study is to evaluate the costs
and benefits of on-site generation on ldaho Power's system fairly, objectively, and
holistically.
It is important to remember, however, that while the end goal is to establish a more
sustainable offering by implementing a more equitable pricing and compensation
structure, the current issue to be decided is more limited. That is, having established a
formal process for public review of, and comment on, the VODER Study, the question
now before the Commission is whether the VODER Study satisfies the directives outlined
in Order Nos. 34046, 34509, and 35284.2 To that end, as more fully set forth herein, the
VODER Study complies with the Commission's requirements for a comprehensive study
of the costs and benefits of on-site generation on ldaho Power's system guided by public
comment and participation, and the Company respectfully requests that the Commission
acknowledge it as such.
1 ln the Mafter of ldaho Power Company's Application to lnitiate a Multi-Phase Collabontive Process for
the Study of Cosfg Benefits, and Compensation of Net Excess Energy Associated with Customer On-Sife
Generation, Case No. IPC-E-21-21, Order No. 35284 (Dec. 30, 2021).
2 ln the Matter of ldaho Power Company's Application for Authority to Estahlish New Schedules for
Residential and Small General Seruice Customers with On-Site Generation, Case No. IPC-E-17-13,
Order No. 34046 at 31 (May 9, 2018); ln the Mafter of the Application of ldaho Power Company to Study
fhe Cosfg Benefits, and Compensation of Net Excess Energy Supplied by Customer On-Site Generation,
Case No. IPC-E-18-15, Order No. 34509 at 17 (Dec. 20,2019); and Case No. IPC-E-21-21, Order No.
35284 at 32-33.
IDAHO POWER COMPANY'S FINAL COMMENTS - 2
II. PROCEDURAL BACKGROUND
ln submitting the VODER Study to the Commission in June 2022, the Company
proposed a procedural schedule including time for public workshops and comments 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 export credit rate) by the end of 2022. After considering requests of intervening
parties, the Commission ultimately adopted a more protracted procedural schedule for
processing this case, which initially focuses on the sole issue of whether the VODER
Study satisfies the previous Commission directives and included severalopportunities for
written comments, additional workshops, and three public hearings on this issue.3 The
matter of implementation of potential modifications to the Company's on-site generation
service offering will be addressed subsequently.
The Company appreciates the Commission facilitating an interactive process as
well as the level of public and stakeholder engagement during this proceeding. Pursuant
to the Commission's scheduling order,a initial and reply comments have been submitted
by the Company and the following parties: Commission Staff (.Staff'); Clean Energy
Opportunities for ldaho ("CEO"); City of Boise; ldaho Conservation League ("lCL"); and
ldaho lrrigation Pumpers Association, lnc. ("llPA'). ln addition, over 600 public comments
have been received. ICL included a critique of the VODER Study performed by a
California consulting firm, Crossborder Energy, as an attachment to their lnitial Comments
that was commissioned by !CL, other environmenta! groups, and solar companies:
3 Order Nos. 35512 and 35558.
a Order No. 35512.
IDAHO PO\A/ER COMPANY'S F]NAL COMMENTS - 3
"lndependent Review of ldaho Power's Value of Distributed Energy Resources Study"
("Crossborder Review"). The Crossborder Review was the focus of the Company's Reply
Comments, which set forth the numerous issues with that report, explained why it would
not Iead to fair and equitable rates, and ultimately requested the Commission reject it.
The Company reserved its Final Comments to address the remainder of the wriften
comments.
ln preparing the VODER Study and initiating this docket, it was the Company's
intent to be guided and informed by feedback and input from the parties to this case and
members of the public first, as it refines and clarifies the VODER Study and later, as it
develops its implementation recommendation. As noted in its lnitia! Comments, the
Company identified several areas of the VODER Study that could benefit from refinement
based on the input and recommendations received to date through workshops and written
comments, and accordingly, it planned to clariff and refine the information in its Final
Comments based on the guidance received throughout the study review process.
The result of that effort is the October 2022 VODER Study filed with these Fina!
Comments, which includes modifications, edits, and additions as more fully detailed
herein, incorporating stakeholder and public recommendations for modifications or
additions to the VODER Study where appropriate. When referring to a specific version,
these Final Comments will refer to the study in terms of when it was filed (i.e.,
June/October 2022 VODER Study). Consistent with the scope of this proceeding, the
October 2022VODER Study does not address those recommendations or considerations
set forth in comments that relate to implementation, which wil! be more appropriately
considered in the second phase of this docket, following the Commission's
IDAHO PO\A'ER COMPANY'S FINAL COMMENTS - 4
acknowledgement of the October 2022 VODER Study. Having now been vetted,
informed, and enhanced by feedback from the public and stakeholders, the Company
believes the October 2022 VODER Study provides a solid foundation to proceed to the
next phase of the docket relating to implementation.
III. THE REVISED STUDY
The Company appreciates the robust review undertaken by parties to the case.
Notably, Staff recommended the Commission acknowledge the VODER Study,
contingent on Staffs recommended revisions to an amended study,s and no pafi
recommended the Commission should reject it. The Company has worked diligently over
the course of this proceeding to incorporate the concepts and methods presented by
parties in comments and by the public through public workshops and comments into the
October 2022VODER Study. As such, accompanying this filing are two attachments:
. Attachment 1 is the October 2022 VODER Study that incorporates
modifications into a "clean" version. The Company has also resubmitted all
appendices (those that have changed, are new, and all other unmodified
appendices) so the public and the Commission have a comprehensive VODER
Study on the record for review.
. Attachment 2 is a version of the October 2022 VODER Study that has
"tracked changes" to show all modifications, edits, and additions that were
incorporated after the June 2022VODER Study was submitted.
Table 1 provides a general overview of the modifications the Company made to the
October 2022 V ODER Study.
5 Staff lnitialComments at 20 and Staff Reply Comments at 9
IDAHO POWER COMPANY'S FINAL COMMENTS - 5
Table 1
of
.Addition of Net Billing houly measurement inlerval .119s Appendix 3.5 and 3.6
analysis br Schedule 8,4 crctomers .New Figures 3 17 - 3.20
Topic Other CommenBDerriptlonItem Secfion't 32 Measurement
lntenal
Ar*ld Emqy {leilied the lllustrdir nrtre dthe titne pedtds
ussdfrr tho eneqy price iryfs used in Ote sludy
and odaes the edailagns ad d[sadnntages of
actuC lcd-time rnilltet Fhag
2 1.1
4 1.2 2 Aroided Energy .Addilional explanation and data that supports
4.1.2 3 SEasonal Time emluation of -on-peak" and "0ff-peak" time periods
Vadant ECR for expoilad enerry from cuslomer-gen€relors
.]i1sv trppendix 4.8 and 4 9
.New Figures 4.4 and 4 5
3
4.1.3 An*lcd E Ergy .AddionC exCrution dhe daia tht aryorts theCogts: lm to non&m eneqy adlEtrurt
Fimv. Nmfrm
1
4 14 Aroided Enerry: .Addilional analysis on the aaluation of the need fur
Transmission a transmigsion or wheeling charg€ br the ECR
Charge
5
t1.1.5 A,rr&d Btergf .AdflionJ udysis m the etafudion d a tnl+oat .NGU Fr$n 4.7
Fual4ost Hedgo hedge bn€fit ad other methods dscucsed byBcoel stak holCors
6
.Additional analysis on strmgths and neaknesses .New Figure 4 9
of other avoided generdion capacity melhods
emluated(eg,PCAF)
Avoided
Generation
Capacity
7 4.2 13
Artiled
Generatin
Caf.dty
{lsilied tha rtionCe h uiltztoig the SCgf b the
laf,&ed cost brv*lip caecfy
8 12.3.1
4 3.3 Transmission & .Added discussion of othertransmission and
Distrihnion distdfution defenal methods mentioned by
Defenal stakeholders
9
.Added clsilhdion of the oncepts d rnqird. .l{e; Fr$rc '1.17 - '1.19;ar€r8ge, ad peak tne loesas Rerieod Frgue 420{ffied rseumgtins sd cdcrdcims frr anrage
line lossea thd tie to the Ootryen/s line loes atudy
ild hil line hsses sa a&essed fur both cape.*yrd eneqy
10 1.1.1 Ax*hd Line
Loeses
Avoided
Em,ironmenlal
Costs
.lncluded additional detail &out carbon pice adders
in ldaho Po*pr's IRP pices and requirements to
oHain and track renewaHe energy credils
11 45
hegllnin Cosis {lrifiedthe milhods andresrils dlddro Pon/s
VsiaUe Energy Resorces lilegrdion Cost $rdy
Arnided .Added discussion regardirg capacily deficiency
Generation year and impact to the raluation melhodology
Capacity
135
Corpeosem
Smldtrc
.Adffirn of i'ld Bllfing horly conpensetfun
rtucture 0il imped a*yisbrSchedde 81
.iferAppen& 3.5 rtd 3.6
.l,lery Frgusc 6.7 - 6.10
11 6.{
Project Eligitilily 'lncluded edditional discussion regarding mlualion .New Figure 9 1 - 9 3
Cap ofexisting cap and evaluatpn ofmodffied cap and
considardion fur saftty and rcliatility hctors
15 91
92
IDAHO POWER COMPANY'S FINAL COMMENTS - 6
!n the sections that follow, the Company outlines each of the modifications or
additions that were made in response to specific party recommendations. Throughout
responding to discovery, discussing the VODER Study at its public workshop, and
reviewing and responding to comments, the Company also identified severalareas of the
June 2022 VODER Study that may benefit from minor revision, new analysis, or
expanded discussion. !n sum, the Company has incorporated many edits to the October
2022 VODER Study, some of which are intended to provide clarity and enhance
readability and understandability of the materials and many of which were in response to
feedback received by parties or the public. To assist in the Commission's review, the
Company has organized the following in order of how the topics appear in the VODER
Study.
A. Measurement lnterval
!n the June 2022 VODER Study, the Company presented information quantiffing
the impact of moving from net energy metering ("NEM') to net billing, under both an hourly
and a real-time measurement for Schedule 6 and 8 customer classes. The Company did
not perform a similar assessment for Schedule 84 customers, as nearly all existing
Commercial, lndustrial, and lrrigation ('Cl&!') customers taking service under Schedule
84 interconnected under a two-meter configuration and were granted legacy treatment
(i.e., grandfathered) by the Commission in Case No. IPC-E-20-26.6 However, the
Company had provided hourly meter data for these customer segments with Appendix
3.4 to the June 2022VODER Study. ln preparing responses to discovery, the Company
6 ln the Mafter of ldaho Power Company's Application for Authoity to Modify Schedule 84's Meteing
Requirement and to Grandfather Existing Cusfomers with Two Meters, Case No. IPC-E-20-26, Order No.
34854 (Dec. 1 ,2020) and Order No. 34892 (Jan. 14, 2021).
IDAHO PO\A'ER COMPANY'S FINAL COMMENTS - 7
determined that whlle the majority of the customers currently taking service under
Schedule 84 may have been granted legacy treatment, presenting an analysis similar to
that which was completed for Schedules 6 and 8 may provide the public, parties, and the
Commission information that may be informative in the implementation phase of this
proceeding. As such, the Company has amended Section 3 of the October 2022 VODER
Study to include a discussion about the impact of moving from NEM monthly
measurement to a net billing hourly measurement for Cl&l customers. The Company has
also developed two new appendices which accompany the October 2022 VODER Study,
Appendix 3.5 and 3.6, the 2021 Measurement lnterval and Bill lmpact for Schedule 84
commercial and irrigation customers, respectively.
B. Export Credit Rate
Several parties made recommendations regarding the valuation of the Export
Credit Rate ("ECR"). The Company has incorporated the pafi recommendations as
follows:
Avoided Enerov
Generally, the feedback received related to the avoided energy component of the
ECR mostly centered around implementation recommendations. While no party
recommended an alternative method be considered from the three that were contained
in the June 2022 VODER Study (i.e., lRP, ICE Mid-C, and ELAP), there were comments
that primarily centered around the timeliness of updating inputs. For example, CEO noted
"rather than a weighted average, avoided energy could be credited with rea!-time prices"T
and highlighted that if real-time market prices are not used for valuing exports, "the
7 CEO lnitialComments at 2.
IDAHO PO\A'ER COMPANY'S FINAL COMMENTS - 8
method should use recent market prices rather than three years of historica! market
prices."8 CEO requested the VODER Study be updated to discuss the different options
for implementation (e.9., hourly, one-year average, or multi-year average) and to discuss
the tradeoffs between accuracy, stability, and predictability that each alternative
provides.e The October 2022VODER Study incorporates several updates to Sections 3.1
and 5.1 to clariff the considerations CEO highlighted.
!n their lnitial Comments, Staff recommended the VODER Study be amended to
present data and analysis to inform an energy-based differentiated ECR and include
additional discussion regarding the non-firm energy adjustment.l0 CEO's lnitial
Comments suggested that the VODER Study should be modified to "acknowledge the
firmness value that the Company, PUC Staff, and signatory parties found in the prior
study."1t The October 2022 VODER Study has been revised to incorporate additiona!
data and information to support an energy-based differentiated ECR and the non-firm
adjustment in Sections 4.1.2.2 and 4.13, respectively; however, the VODER Study does
not include a value agreed upon by a limited number of parties to a settlement that was
rejected by the Commission.l2
Staff also recommended the Company modify the VODER Study to include an
"analysis of the cost to move exports to the market during the timeframe that customer-
I CEO lnitialComments at 2.
e CEO Reply Comments at 7.
10 Staff lnitial Comments at 7-8.
11 CEO lnitialComments at 3.
12 See Case No. IPC-18-15, Order No. 34509 at 6.
IDAHO POWER COMPANY'S F]NAL COMMENTS - 9
generators export onto the Company's system."'t3 A discussion has been added to
Section 4.1.2.2 of the October 2022VODER Study addressing Staffs recommendation.
ln their Reply Comments, Staff recommended the Company amend the VODER
Study to include a "detailed discussion on the fuel-cost hedge benefit" suggesting it
should "explain how fuel-cost hedge benefits relate to each of the proposed sources for
energy valuation, as well as the advantages and disadvantages of the Maine PUC
valuation method."la ICL indicated "the VODER study is incomplete without substantive
discussion of fuel hedging benefits from DER development," and the City of Boise
similarly recommended that an "evaluation of price-risk hedge or similar methodology be
incorporated in any ECR where the avoided cost of energy is not directly tied to real-time
hourly market conditions."ls ln their Reply Comments, CEO recommended "the updated
VODER study should reflect that there are methodologies for assigning value to this
component of the ECR.'16 Finally, in their Reply Comments, llPA indicated they do not
advocate for fuel pricing hedging, stating this activity does not bring value to customers."17
To address concerns raised by the parties, the October 2022 VODER Study more
comprehensively addresses fuel-price risk in a new section (Section 4.1.5).
13 Staff Reply Comments at 4.
1a ld. at4-5.
15 City of Boise lnitialComments at 3
16 CEO Reply Comments at 6.
17 llPA Reply Comments at 11.
IDAHO PO\A'ER COMPANY'S FINAL COMMENTS - 1O
Avoided Generation Cap acitv
ln their lnitial Comments, Staff noted the VODER Study complied with Order No.
35284 for determining the avoided cost of capacity component in the ECR "with two
exceptions," indicating the VODER Study should be amended to: (1) address the impact
to the avoided cost of capacity as the first deficit year changes, and (2) update the method
used to calculate the avoided capacity cost for the seasonal time-variant scenario.ls In
their lnitial Comments, ICL was critical of the use of a simple cycle combustion turbine
("SCCT") as the basis forvaluing the avoided generation capacity component, suggesting
the resource was selected 'without explanation, analysis, or context,"te ard highlights
year-over-year variability that may result from an Effective Load Carrying Capability
('ELCC') based method, finally recommending the VODER Study address "the much
simpler peak capacity allocation factor ("PCAF') calculation as an alternative method to
cure these defects."2o
ln their Reply Comments, Staff provided three additiona! recommendations for
amending the VODER Study, recommending it include additional analysis and
explanation for: (1) strengths and weaknesses for determining capacity contribution using
different methods, including the PCAF, (2) the basis for selecting the proper surrogate
resource for valuing capacity, and (3) the planning reserve margin ("PRM") and its non-
relevance in valuing capacity contributions.2l ln its Reply Comments, llPA points out "the
18 Staff lnitialComments at 9,21
le lCL lnitialComments at 5.
20 ld. at6.
21 Staff Reply Comments at 10.
IDAHO POWER COMPANY'S FINAL COMMENTS - 11
PCAF overestimates capacity contribution because it does not scientifically identify hours
where IPC is expected to be in capacity deficit," and highlights that the PCAF "is neither
widely used nor a mathematically sound measure of capacity contribution."22 Finally, llPA
refuted ICL's suggestion that a battery would be a more reasonable basis for the avoided
capacity valuation and similarly noted grossing up capacity by the PRM, as suggested by
the Crossborder Review, would be inappropriate.23
The Company has included analysis and discussion as recommended by the
parties in the October 2022VODER Study. Sections 4.2.1.3,4.2.2.1, and 4.2.3.1 have
been added or modified to address each of the suggestions, notably highlighting severa!
important considerations to be evaluated by policy makers who may consider
implementing a PCAF-type method for avoided capacity costs.
ln its Reply Comments CEO recommended that the VODER Study be amended
"to clariff that the realtime contribution to peak can be used to accurately calculate ECR
capacity value components even in the event an hourly netting period is selected for billing
purposes."24 This suggestion was in response to Staff noting that "the measurement on a
real-time basis is more accurate than on a hourly basis.'2s CEO's recommendation is
more appropriately considered in the implementation phase of the case; however, the
Company highlights it would be inappropriate for a valuation methodology to be based on
one method and the billing construct to be based on a less granular measurement, as
22 llPA Reply Comments at 56.
23 ld. al7.
24 CEO Reply Comments at 7.
25 Staff lnitial Comments at 6.
IDAHO POWER COMPANY'S FINAL COMMENTS.l2
CEO suggests. As demonstrated in the VODER Study, the ECR will be higher if calculated
under a real-time measurement interval (i.e., there wil! be more exports under a more
granular measurement, which will lead to a higher value), but it would be a mismatch to
then apply an ECR valued under one measurement interval (such as real-time) to exports
quantified under a different measurement interva! (such as net hourly). While the
Company does not believe CEO's suggestion should be reasonably considered, it is more
appropriate for CEO to raise this issue in the implementation phase of the case.
Avoided Transmission & Distribution ('T&D"l Capacitv
The June 2022VODER Study presented a single method for determining the value
from customer exports in deferring or delaying the need to invest in new T&D
infrastructure. This method was singularly presented because the Company has the
historical and projected data necessary to model the impacts of customer-generation on
deferring T&D capacity. The method presented in the June 2022 VODER Study was
found by industry expert Kurt Strunk, Managing Director at NERA Economic Consulting,
to be "the most targeted analysis possible and is most consistent with the established
goal that pricing should reflect cost causation."26 The Company agrees with Mr. Strunk's
opinion. ln its lnitia! Comments, Staff found that the Study complied with Order No. 35284
for the evaluation of avoided T&D capacity costs and "provided a credible method to
assess exports that contribute to avoiding capacity limits on each segment of the T&D
systems, and it provided detailed information to support its analyses.'27 llPA also
26 Affidavit of Kurt G. Strunk at 8.
27 Staff lnitialComments at 10.
IDAHO POWER COMPANY'S FINAL COMMENTS - 13
supported the use of the method presented in the June2022VODER Study.28 !n its lnitia!
Comments, ICL was critical of the method utilized in the VODER Study and suggested
that the "NERA regression model used by Crossborder fits incrementalT&D investments
to historic peak load growth, allowing projection of future costs and those avoided by peak
load reduction."2s
The Company previously addressed the inappropriateness of utilizing the methods
highlighted in the Crossborder Review in its Reply Comments filed in this case.3o Mr.
Strunk, NERA's Managing Director found: 'Crossborder Energy's estimates of ldaho
Power's avoided transmission and distribution investment attributable to behind-the-
meter solar exports are not accurate, are overstated, and are based on an inappropriate
implementation of marginal costing techniques.'31 ln its Reply Comments, llPA's expert
witness noted many of the same issues identified by the Company and Mr. Strunk,
ultimately finding "there are numerous issues with the ICL's regression approach to
avoided cost."32 However, in Reply Comments, Staff and CEO both recommend the
Company amend the VODER Study to include a discussion of alternative methods that
may be used in evaluating avoided T&D capacity costs.33 Lastly, the City of Boise
28 llPA lnitial Comments at 6.
2e lCL lnitial Comments at 7.
m ldaho Power Reply Comments at 14-20.
31 Affidavit of Kurt G. Strunk at 7.
32llPA Reply Comments at 8.
33 CEO Reply Comments at 8-9 and Staff Reply Comments at 7
IDAHO POWER COMPANY'S FINAL COMMENTS - 14
recommended the Company modify the Study to include a discussion about what they
refer to as "an approved tariff approach.'il
As a result of the feedback from the parties on this issue, the October 2022 VODER
Study introduces a new section (Section 4.3.3) where the recommendations have been
included and/or addressed.
Avoided Line Losses
Severalparties recommended additionaldiscussion be included in the avoided line
Ioss section of the VODER Study. Specifically, Staff noted: (1) it was unable to reconcile
the losses utilized in the June 2022 VODER Study to the 2012 Line Loss Study, (2) it
could not identify how line losses were attributed to avoided capacity, and (3) if another
method for determining avoided generation capacity was utilized, the line loss factor
would need to be explicitly applied.35 ICL referenced the Crossborder Review, suggesting
the line losses applied in the June 2022 VODER Study were understated.36 llPA raised a
concern that certain line losses (i.e., transmission line losses) may already be included in
the ELAP prices, so they may already be reflected in those energy prices.37
ln Reply Comments, Staff further clarified its request for an amended VODER
Study to include: 'the concepts of marginal line losses, average line losses, peak line
losses, and energy line losses, to resolve any ambiguity and overlap between these
il City of Boise Reply Comments at 2
35 Staff lnitial Comments at 11.
36lCL lnitialComments at 8.
37llPA lnitial Comments at 7.
IDAHO POWER COMPANY'S FINAL COMMENTS - 15
concepts." llPA suggested the results in the Crossborder Review were incorrect, stating
"the Crossborder study provides no supporting evidence and utilizes flawed Iogic.'38
The Company has updated Section 4.4 in the October 2022 VODER Study to
include a discussion about transformer Iine losses and included Figure 4.20 to
demonstrate how the line losses applied against the avoided energy and capacity
components of the ECR were quantified.
Avoided Environmental Costs
Staffs lnitial Comments found the June 2022 VODER Study complied with
previous Commission orders related to other potentia! avoided costs, with "one minor
exception," recommending "that the information from the Response to Production
Request No. 46 [explaining the requirements to obtain and track Renewable Energy
Credits ("REC') for customer-generatorsl be included in an amendment to the Study to
provide transparency to the pUblic."3s CEO maintains "customers with self-generation who
export to the Company should have the option to sel! to the utility the environmental
attributes of their exports," ultimately suggesting the ECR be increased to reflect the value
of the environmental aftributes associated with their generation.a0 ICL claimed in its lnitial
Comments that "the socia! cost of carbon emissions, health benefits of reduced air
pollution, land use costs, localeconomic benefits, reliability and resiliency, and customer
38llPA Reply Comments at 10.
3e Staff lnitialComments at 11-12.
40 CEO lnitial Comments at 4.
IDAHO PO\A'ER COMPANY'S FINAL COMMENTS - 16
choice are all quantifiable, yet not offered or analyzed," and it therefore supported the
Crossborder Review's quantification of these attributes of $87.2OlM!ryh.41
ln Reply Comments, llPA takes the position that "no environmental attributes
should be incorporated into the net export rate' because'all environmental attributes of
the net exporter should be retained by the net exporter," further pointing out that valuing
these types of attributes in an ECR would lead to 'double counting."az Finally, CEO
indicates in its Reply Comments that it supports Staffs recommendation for the VODER
Study to be updated to "provide information related to the intricacies and requirements to
obtain and track RECs, including a review of what quantity of exports from a particular
customer would warrant incurring the costs of registering and recording those exports as
RECs.'a3 Section 4.5 of the Study has been revised to provide clarity on ldaho Power's
IRP carbon price adder and adds discussion regarding the intricacies and requirements
to obtain and track RECs.
lnteoration Costs
ln their lnitial Comments, Staff indicated they believe the June 2022VODER Study
complied with the Commission-approved Framework in its evaluation of integration costs,
noting: "the results of [the 2020 Variable Energy Resource lntegration Study] are
adequate for the VODER Study analysis because the baseline scenario was targeted to
2023 and it reasonably approximates the existing resource portfolio."# Staff also pointed
a1 ICL lnitial Comments at 1.
42 llPA Reply Comments at 11.
43 CEO Reply Comments at 9.
# Staff lnitialComments at 12.
IDAHO POWER COMPANY'S FINAL COMMENTS - 17
out "[t]his component does not have any options to considef and highlighted that the
Company has committed to updating its Variable Energy Resource ("VER') lntegration
Study as part of the 2023 or 2025 lRP.as ln their lnitial Comments, ICL suggested the
2020 VER Integration Study cannot be relied on because it is *dated,'40 pointing to the
addition of future resources that, in ICL's opinion, may lower the costs associated with
integrating solar. ICL suggested a use case from the 2020 VER lntegration Study that
produces a lower result, which they note the Crossborder Review concurs.aT
ln their Reply Comments, CEO indicated the ICL lnitial Comments and the
Crossborder Review warrant further discussion in the VODER Study.as The October 2022
VODER Study expanded the discussion in Section 4.6.2 about why the integration study
base case scenario (Case 1) most aligns with the Company's current system.
C. Compensation Structure
Staff notes that while the information contained in this section was not outlined in
a prior Commission order, it is "confident the material presented is transparent,
understandable, and provides impacts to current non-legacy customer-generators."4e As
noted in the "Measurement Interval" section, the Company had previously only included
a bill impact analysis for Schedule 6 and 8 customers when the June 2OZ2VODER Study
was submitted. While nearly all of the Cl&l customers taking service under Schedule 84
45 ld. al12-13.
ao ICL lnitialComments at 8.
q ld. al9.
48 CEO Reply Comments at 10
4e Staff lnitial Comments at 13.
IDAHO POWER COMPANY'S FINAL COMMENTS - 18
in 2021 had previously received legacy treatment, the Company has completed a bill
impact analysis for those customers, assuming a transition to net billing with an hourly
measurement. The discussion in Section 6.4 has been expanded to include Schedule 84
customers and Appendix 3.5 and 3.6 have been added to the October 2022 VODER
Study.
D. Class Cost-of€ervice
Staffs lnitialComments found the class cost-of-service presented in the June 2022
VODER Study "complied with Order No. 35284," stating "the Company provided
information that is accurate, transparent, understandable, and showed results that the
Company has not recovered its authorized revenue requirement from customer-
generators.'so Through discovery, Staff asked clariffing questions about the treatment of
Schedule 84 customers in the class cost-of-service study. The October 2022 VODER
Study has been modified to include the clarifications addressed through discovery in an
expanded discussion in Section 7.
ln its lnitial Comments, CEO took exception with a single statement in the VODER
Study, suggesting because the Company developed the VODER Study, it was done
"through a one-way lens,"51 evidenced by the statement "opportunity exists to better align
the pricing structure with the underlying cost structure."S2 The October 2022 VODER
Study modifies the above-referenced statement. No other party submitted comments
regarding this section.
n ld. a114.
51 CEO lnitialComments at 5.
52 ld. (referencing June 2022 VODER Study at 86)
IDAHO POWER COMPANY'S FINAL COMMENTS - 19
E. Proiect Eligibility Cap
ln its lnitial Comments, Staff found the Project Eligibility Cap section in the June
2022 VODER Study complied with the Commission-approved Study Framework, but
suggested additional factors to be considered in setting the cap.53 Specifically, Staff
recommended the Company amend the VODER Study to incorporate: (1) information
provided through discovery requests, (2) the policy factors to be considered when
establishing the project eligibility cap, and (3) an evaluation of potential gaming and
manipulation between Public Utilities Regulatory Policies Act of 1978 ('PURPA") and
customer-generation. ln their Reply Comments, Boise City agreed with Staffs
recommendations to amend the Study, however they requested that a discussion about
potential gaming between PURPA and customer-generation be excluded from the
VODER Study.n
ln its lnitial Comments, CEO highlighted what it characterized as an absence of a
discussion required by Commission Order No. 35284 regarding "the pros and cons of
setting a cap according to a customer's 1O0o/o and 125o/o demand as opposed to
predetermined caps of 25 kW and '100 kW."55 However, CEO pointed out that information
received via discovery and a technical workshop made progress in addressing that
deficiency, and in its Reply Comments agreed with Staffs suggestions to amend the
VODER Study with information received through discovery.56
53 Staff lnitial Comments at 14.
* City of Boise Reply Comments at 4
55 CEO lnitial Comments at 6.
56 CEO Reply Comments at 12.
IDAHO PO\A'ER COMPANY'S FINAL COMMENTS - 20
The October 2022 VODER Study incorporates the information requested by Staff
and CEO in their respective comments. The Company notes that CEO requested certain
information provided throughout discovery not be added, due to concerns that it may be
misleading (specifically requesting the Company not include data about the number of
service points that are currently beloMabove the current cap).s7 It is important to note that
the Company administers each of its tariffs - including the on-site generation tariffs -
according to service points. Demonstrating how many service points may currently be
limited by the existing project eligibility caps may be informative for the Commission,
parties, or members of the public in understanding how the cap is currently applied. To
address CEO's concerns that the information could be misleading, the October 2022
VODER Study includes a discussion about the existing caps, how they are administered,
and how the information should not be interpreted to suggest a 1-1 relationship between
service point and customer.
ln its lnitial Comments, llPA was supportive of a modified cap, contingent upon
both the ECR and base rates being designed to address the subsidies of customer
generation.ss However, llPA's Reply Comments further refined its recommendation to
suggest it would be open to a modified project eligibility cap so long as some safeguards
are established to ensure there is no gaming opportunities for PURPA developers to
circumvent that process.se These issues are important and should be addressed by
parties in the implementation phase of the case.
57 ld.
58 llPA lnitialComments at 8.
5s llPA Reply Comments at 4
IDAHO POWER COMPANY'S FINAL COMMENTS - 21
F. Other Areas of Study
ln its Initial Comments, Staff highlighted that the Company included additional
items in Section 10.2 of the June2022 VODER Study that were "not required to be studied
in Order No. 35284,"60 pointing out that this section details resources available to the
public on the Company's website to assist customers in making informed decisions about
the economics of on-site generation. ln their Reply Gomments, CEO took exception with
Figure 10.3 from the June 2022VODER Study (presenting an example of a typical home's
payback under a Net Energy Metering and Hourly Net Billing compensation structure),
suggesting it compromises the objectivity of the VODER Study.61
The Company believes it was appropriate to include the other areas of study in this
section, as the Commission-approved Study Framework directed the Company to include
an explanation of how potential customer-generators "will have accurate and adequate
data and information to make informed choices about the economics of on-site generation
systems."62 As pointed out by Staff in its Reply Comments, in Order No. 34509, the
Commission unequivocally advised .stakeholders in the on-site generation industry
[including the Company] to be completely transparent with potential investors that a
utility's rate schedule, including program fundamentals, is subject to change.'63 The
Company works diligently to provide information to its prospective on-site generation
customers to keep them informed about the potential for modifications to the on-site
m Staff lnitial Comments at 18.
61 CEO Reply Comments at 13.
62\PC-E-21-21, Order No. 35284 at 27.
63 Staff Reply Comments at 8 (citing Order No. 34509 at'13).
IDAHO PO\A'ER COMPANY'S FINAL COMMENTS.22
generation offering. Further, in past proceedings, parties have raised concerns that if the
Commission were to adopt a net billing construct, solar installers may not have access to
the information they need to make informed investment decisions. As such, the Company
believes it is important for the Commission to understand the types of information that it
makes available to its customers and the data that currently is and will be available, if it
ultimately determines a modification to the on-site generation offering is warranted.
Based on the feedback from CEO, the October 2022 VODER Study excludes
Figure 10.3 from the June 2022 VODER Study; however, the discussion about what
information the company makes available to customers is still included.
!V. NEXT STEPS / PROCEDURAL RECOMMENDATIONS
Several parties ask the Commission to address next steps, including scoping of
the implementation phase in its order either acknowledging or rejecting the October 2022
VODER Study. Specifically, Boise City asked the Commission to identifo 'clearly
established next steps and a general framework for a schedule" and to "direct the
Company to file a proposal for revisions" as part the order issued acknowledging the
VODER Study. 64 ICL acknowledges "that the Commission has the authority to authorize
modifications in this docket," and subsequently asks "for clarity on the scope of such
changes."65 CEO suggests that "in its next order in this docket, the Commission direct
only the Company to file recommendations," noting "all parties should then have
opportunity to submit initial comments and all parties should have the opportunity to
il City of Boise Reply Comments at 4
65lCL Reply Comments at 5.
IDAHO PO\A/ER COMPANY'S FINAL COMMENTS - 23
reply."6o Similar to other comments, CEO points out "the public is unclear of what and
when matters will be decided and when such decisions wil! be made effective."67
Parties also make recommendations for the Company to provide an additional
notice, formally noticing customers of the transition into the implementation phase of this
proceeding, along with making customers aware of the Company's proposals related to
modiffing the on-site generation offering.6s
After careful consideration of the Parties' procedural recommendations, the
Gompany believes having the Commission issue an order directing further process would
provide sufficient clarity as to appropriate next steps in the case. As such, ldaho Power
respectfully requests the Commission consider including the following in its upcoming
order in the matter upon acknowledgement or rejection of the October 2022 VODER
Study:
(1) Direct ldaho Power to file a proposal recommending modifications to the
on-site generation offering by December 30, 2022, and;
(2) Direct Staff to confer with the parties to align on a procedural schedule
recommendation that can be presented to the Commission for their
consideration as soon as practicable.
While some parties request the Commission specifically outline the scope of the
changes to be considered, the Company believes the Commission's previous orders have
provided clarity on the scope of changes to be considered. Notably, in Order No. 35284
66 CEO Reply Comments at 13-14.
67 ld. at 14.
68 City of Boise Reply Comments at 5 and ICL Reply Comments at 5.
IDAHO POWER COMPANY'S FINAL COMMENTS - 24
that authorized the Study Framework, the Commission highlighted that the fo!lowing items
were within scope for the Study: Measurement lnterval (pgs. 12-14), Export Credit Rate
(pgs.14-22and26-27), Recovering ExportCredit Rate Expenditures (pgs.22-23), Project
Eligibility Cap (pg. 25), lmplementation lssues, (p9.27), Export Credit Rate Expiration
(pg. 28), and Frequency of Export Credit Rate Updates (pg. 29;. os The Company believes
this list of issues would be reasonably included in an implementation proposal put forth
by the Company.
The Commission already declined to include certain previously contemplated
issues, such as Cost of Service and Rate Design (pgs. 23-25), Off-Site Exporting
Facilities (pgs. 29-30), and other AdditionalAreas of Study (pgs. 30-32), within the scope
of this proceeding.T0 n/frile the Company believes the Commission's prior orderwas clear
in what would be considered "in-scope" for near-term changes to the on-site generation
offering, it respectfully requests the Commission clarify in its upcoming order if the
Company's understanding is incorrect.
Finally, some comments suggest that there should be additional meetings and/or
further opportunities for comment to discuss the Company's proposals prior to the
Company filing its recommendations for implementation.Tl The Company has been
committed to utilizing a collaborative approach in developing and pursuing the study;
public and party involvement has been robust and instrumental in this process. There is
6e Case No. IPC-E-21-21, Order No. 35284.
70 ld.
71 CEO Reply Comments at 13-14 (suggesting an "all-party" meeting for the Company to share and
discuss its tentative recommendations) and ICL Reply Comments at 6 (requesting that parties be allowed
to comment and organize meetings to review the Company's proposal before it is submitted to the
Commission).
IDAHO POWER COMPANY'S FINAL COMMENTS - 25
no need at this stage, however, for another round of comments and/or meetings in
advance of the Company submitting its recommendation for potential modifications to its
on-site generation offerings. The proceduralschedule has provided ample opportunity for
comment and participation during this phase of the docket . A robust record of public and
party comments already exists that has been crucial in refining the VODER Study and will
ultimately help inform the Company's proposa!. There willalso be further opportunities for
participation via the three scheduled public hearings and the extended comment period.72
While all-party discussions to resolve issues prior to Commission consideration
can often be productive, efficient, and beneficia!, the Company does not believe that
approach is appropriate under the unique circumstances of this case. Rather, considering
the regulatory background and the level of public interest, it is important to ensure an
abundantly transparent process and that members of the public have equal opportunities
to weigh in as the parties. Moreover, at the conclusion of the current phase of the docket
the record will be more than sufficient for the Company to make a wel!-informed
recommendation based on what it believes is in the best interest of al! customers - those
with and those without on-site generation - and for the Commission to meaningfully
evaluate the proposal. Consequently, the Company does not believe additional meetings
would be productive at this point in the proceeding and are not necessary to formulate
the Company's implementation recommendation.
The Company agrees with parties that the public should be noticed of any
proposed changes and intends to distribute bill inserts to all customers and issue a press
release bringing the matter to the public's attention once it files its proposal of changes to
72 Order No. 35558.
IDAHO POWER COMPANY'S FINAL COMMENTS - 26
the on-site customer generation service offering. Persons and parties will have another
opportunity to participate during the study implementation phase.
V. PUBLIC INVOLVEMENT
As noted previously, this docket derives from a series of prior cases that started in
2017 when the Company launched its effort to have the Commission review and modiff
the outdated net metering offerings to better align with then-current circumstances.T3 A
subsequent case attempted to resolve the matter through a settlement agreement
reached through negotiations with Staff and various stakeholders, but the Commission
ultimately ruled that process was insufficient under the circumstance not only due to the
absence of the comprehensive study it previously ordered, but because it did not
adequately engage the public. Given the intense public interest in the case and
importance of the issues, the Commission made clearthat public engagementwas crucial
in study design, study review, and beyond.Ta
The Company, Commission Staff, and all other stakeholders
to the case would do wellto Iisten to and understand the public
sentiment regarding the importance of distributed on-site
generation to ldaho Power's customers. ln Order No. 34046
we said, "The Company must continue to listen to and
understand, and address its customers' concerns in these
cases." Order No. 34046 at25. Given the quantity and tone
of the public comments, it appears as if this has not yet
happened. We expect that a well-developed underlying
record will provide a basis for any future changes. A
comprehensive and transparent analysis should allay
many of the concerns expressed by customers.Ts
73 Case No. IPC-E-17-13, Application (Jul. 27,2017).
7a Case No. IPC-E-18-15, Order No. 34509 at 6-10.
75 ld. at 10 (emphasis added).
IDAHO POWER COMPANY'S FINAL COMMENTS - 27
The Company received the message and has actively pursued public involvement
as it worked to fulfil the Commission's mandates. Utilizing a collaborative approach, the
Company sought input from the public and stakeholders in both designing and pursuing
the VODER Study and now as it seeks to refine and clariff the VODER Study. As part of
this process, the Company has held several public workshops aimed at listening to
members of the public to ensure the Study was informed by customers and interested
parties.T6 The Company has made its materials publicly available and has worked in
earnest to provide clear, transparent, and factual information regarding the VODER Study
to its customers.
As of October 25,2022,681 public comments have been received. The Company
understands the great interest shown in this case and appreciates those members of the
public that have chosen to participate, which represent roughly 0.1 percent of the
Company's total customers. As Staff notes, approximately 1/3 of the comments were
received from customers who acknowledge owning a solar system and being enrolled in
NEM.77
Several of the comments include information or recommendations related to
implementation, which as discussed above will be more properly addressed in the next
phase of this proceeding. Because the purpose of the VODER Study is to develop a range
of potential methodologies that may serve as a basis to inform future implementation
76 On October 20,2021, the Company held a workshop as part of the development of the scope in Case
No. IPC-E-21-21. OnMay 2,2022, and in preparation of the study based on the scope established by the
Commission in Order No. 35284 (December 30,2021), the Company held a public workshop to solicit
input on several elements associated with the ECR. On August 31 , 2022, the Company held a public
workshop presenting the VODER Study and providing the public with an opportunity to ask clarifying
questions and provide comments.
77 Staff Reply Comments at 8.
IDAHO PO\A'ER COMPANY'S FINAL COMMENTS - 28
recommendations, the October 2022 VODER Study does not incorporate the various
implementation recommendations or considerations.
As they relate to the VODER Study itself, many of the commenters may not be
aware that it stems from a series of preceding cases that have laid the groundwork for
the study process. !n other words, many of the issues raised have already been
addressed by the Commission. For example, when the Commission set the Study
Framework in Case No. IPC-E-21-21, it explicitly considered whether a "third-party"
should conduct the study, ultimately rejecting that course of action:
The Commission finds that the Company is best positioned to
access and study the extensive data and issues specific to the
ldaho Power system at a reasonable cost. We understand the
argument that third-pafi evaluators have a different
perspective and the results may be believed to be more
credible by some customers. However, third-pafi studies
may be more generic and not fully reflect the
environmental requirements in ldaho or the peculiarities
and/or particulars of the Company's system. Studies
conducted in other states provide insight but are not
determinative of what is most reasonable for ldaho Power's
customers. The Company is directed to provide sufficient
data along with the study conclusions so that others have
insight as to how the results were derived.Ts
ln a similar vein, some of the comments appear to overlook the role that party and
public feedback have already played in shaping the VODER Study to this point. For
example, following the Commission's approval of the final Study Framework,Te the
Company voluntarily and proactively solicited feedback from parties and the public while
78 Order No. 35284 at 11.
7e Case No. IPC-E-21-21, Order No. 35284.
IDAHO POWER COMPANY'S FINAL COMMENTS - 29
the VODER Study was under development through a public workshop.so The workshop,
which was aftended by several parties that participated in prior on-site customer
generation cases and more than 40 members of the public, 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.8l The
Company received questions during the workshop and invited written comments following
the workshop as well. Only five public comments were received, along with comments
from a single intervening party - CEO.82 No other comments were submitted including
from other parties to this case. As such, the Company developed the June 2022 VODER
Study consistent with the specific methods the Commission previously directed should be
reasonably considered. Notwithstanding, the Company has worked in earnest to
incorporate new methods presented by the parties in their lnitial and Reply Comments
(e.9., the PCAF capacity method) that were not previously requested to be included.
A number of public comments express a general distrust of the VODER Study and
the conclusions reached and call for adoption of the Crossborder Review as the basis for
any modifications to the Company's on-site generation offering. As the Company
explained in its Reply Comments, ldaho Power routinely conducts complex studies to
inform Commission decisions in ratemaking matters such as this and has a vested
interest in ensuring the information it puts forth is fair, credible, and unbiased, unlike a
privately retained consultant. Moreover, the Crossborder Review is flawed in several
m See Direct Testimony of Grant Anderson, Exhibit 1 for the press release for the workshop.
81 See Direct Testimony of Grant Anderson, Exhibit 2 for the presentation.
82 See Application at 11-'14 and Direct Testimony of Grant Anderson at 32-36 and Exhibit 3 for more
details on the workshop, comments received, and how they were addressed.
IDAHO POWER COMPANY'S FINAL COMMENTS.30
respects and includes assumptions and methodologies inconsistent with ldaho regulatory
precedent and incongruous with the Commission-approved Study Framework.s3
ldaho Power understands that several commenters ardently support on-site
generation, and many conflate changes to the net-metering service offering as intended
to discourage customer self-generation. A number of commenters raise concerns related
to how they may be impacted by changes to the program, seek the continuation of retail
rate net metering (for both existing and new customers), and/or call for expanded legacy
treatment for those customer systems that were not previously granted legacy treatment
under prior Commission orders. Many of the comments express a desire for the
Commission to implement policies and frameworks that will encourage the adoption of
distributed generation through subsidization in customer rates in the Company's service
area
The Company earnestly supports customer choice in clean energy sources and
wants to make sure that on-site customer generation can continue to play a role in its
energy portfolio by ensuring that rates paid for excess generation are fair and equitable
to both generating and non-generating customers.e \Mile elevating the short-term
financial interests of some stakeholders above the long-term interests of all customers
might provide immediate gratification for some, Idaho Power is concerned this approach
83 See a/so llPA Reply Comments at 4 (stating the analytic choices in the Crossborder Review'are not
reasonable and should not be adopted. . . The Commission should disregard all aspects of the
Crossborder study.')
e See a/so llPA Reply Comments at 2 ('[D]istributed energy, when properly priced and tariffed, can play
an important role in the IPC's energy portfolio. But thls role should be the outcome of economically
supportable analysis, and not the outcome of a general policy goal to increase distributed generation for
its own sake.")
IDAHO POWER COMPANY'S FINAL COMMENTS - 31
is not economically supportable and would ultimately harm the long-term viability of solar
energy. Instead, a more meaningfulapproach focused on increased reliability, efficiency,
and economic viability should be pursued to help ensure on-site generation continues to
thrive.
vr. coNcLustoN
This docket represents another incremental step towards fulfilling the
Commission's ultimate objective: "The Company's future net-metering programs will be
based on a credible and fair study, developed with public input, and will reasonably
balance the interests of customers with net metering, and customers without net
metering."85
The VODER Study examines several methods of valuing customer-owned
generation energy exports and explores other important considerations that will ultimately
help inform the Commission as it considers programmatic changes. The VODER Study
was developed and pursued using a collaborative approach that has continued in the
study review process. Specifically, the input provided by the parties and public has
identified areas of the VODER Study that could benefit from further clarification and
refinement, which have been incorporated into the October 2022 VODER Study. While
not substantively modiffing the initial study, ldaho Power believes the information
incorporated into the October 2022 VODER Study that accompanies these Final
Comments provides a solid foundation on which modifications to its on-site customer
generation offerings can be proposed for the Commission's consideration in the next
phase of this docket.
85 Case No. IPC-E-18-15, Order 34509 at 15.
IDAHO POWER COMPANY'S FINAL COMMENTS - 32
ldaho Power respectfully requests the Commission issue an order (1) finding the
October 2022VODER Study satisfies the study directives outlined in Order Nos. 34046,
34509, and 35284; (2) directing ldaho Power to file a proposal recommending
modifications to the on-site generation offering by December 30, 2022: and (3) directing
Staff to confer with the parties to align on a procedural schedule recommendation that
can be presented to the Commission for their consideration.
DATED at Boise, ldaho, this 26h day of October 2022.
Wtriut^ufifllo,,t
MEGAN GOICOECHEA ALLEN
Attorney for ldaho Power Company
IDAHO PO\A'ER COMPANY'S FINAL COMMENTS - 33
CERTIFICATE OF SERVIGE
I HEREBY CERTIFY that on the 26th day of October 2022, ! served a true and
correct copy of ldaho Power Company's Final Comments upon the following named
parties by the method indicated below, and addressed to the following:
Commission Staff
Riley Newton
Chris Burdin
Deputy Attorney General
ldaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg No.8
Suite 201-A (83714)
PO Box 83720
Boise, lO 83720-0074
_Hand Delivered
_U.S. Mail
_Overnight Mail
_FAX_FTP SiteX Email [e-mail]
Ch ris. bu rd in @puc. ida ho.qov
IdaHydro
C. Tom Arkoosh
Amber Dresslar
ARKOOSH LAW OFFICES
913 W. River Street, Suite 450
P.O. Box 2900
Boise, ldaho 83701
_Hand Delivered
_U.S. Mail
_Overnight Mai!
_FAX_FTP SiteX Email [e-mail]
Amber.dresslar@a rkoosh.com
erin.cecil@a rkoosh.com
Idaho Gonservation League
Marie Kellner
ldaho Conservation League
710 North 6th Street
Boise, ldaho 83702
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_Overnight Mail
_FAX_FTP SiteX Email [e-mail]
ldaho lrrigation Pumpers 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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_FAX_FTP SiteX Emai! [e-mail]
IDAHO POWER COMPANY'S FINAL COMMENTS - 34
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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boisecitvattornev@citvofboise. orq
\Ml 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, lnc.
Austin Rueschhoff
Thorvald A. Nelson
Austin W. Jensen
Holland & Hart, LLP
555 Seventeenth Street, Suite 3200
Denver, Colorado 80202
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tnelson@holla ndhart.com
awie nsen @holland hart.com
Jim Swier
Micron Technology, lnc.
8000 South FederalWay
Boise, ldaho 83707
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aclee@holland ha rt. com
IDAHO POWER COMPANY'S FINAL COMMENTS.35
CIean Energy Opportunities for ldaho
Kelsey Jae
Law for Conscious Leadership
920 N. Clover Dr.
Boise, ldaho 83703
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Michael Heckler
Courtney \Mite
Clean Energy Opportunities for ldaho
3778 Plantation River Dr., Suite 102
Boise, lD 83703
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cou rtnev@cleanenerqvopportu n ities. com
mike@cleanenerovopportu n ities. com
Richard E. Kluckhohn, pro se
Wesley A. Kluckhohn, pro se
2564 W. Parkstone Dr.
Meridian, lD 83646
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[e-mail]
ldaho Solar Owners Network
Joshua Hil!
1625 S. Latah
Boise, lD 83705
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[e-mail]
ABC Power Company, LLC
Ryan Bushland
184 W. Chrisfield Dr.
Meridian, lD 83646
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[e-mail]
&^"J=
Stacy Gust, Regulatory Administrative
Assistant
IDAHO PO\A/ER COMPANY'S FINAL COMMENTS - 36
BEFORE THE
IDAHO PUBLIG UTILITIES COMMISSION
GASE NO. IPC-E-22-22
IDAHO POWER COMPANY
ATTACHMENT 1
OCTOBER 2022 VALUE ON-SITE DISTRIBUTED
ENERGY RESOURCES (VODER) STUDY
(GLEAN VERSTON)
SEE ATTACHED SEPARATE DOCUMENTS
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-22-22
IDAHO POWER COMPANY
ATTACHMENT 2
OCTOBER 2022 VALUE ON.SITE DISTRIBUTED
ENERGY RESOURCES (VODER) STUDY
(LEGISLATIVE VERSION)
SEE ATTACHED SEPARATE DOCUMENTS