20210113Comments.pdf

Benjamin J. Otto (ISB No. 8292)
710 N 6ft Street
Boise,ID 83701
Ph: [phone]x112
Fax: [phone]
botto@idahoconservation. org
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Attomey for the Idaho Conservation League
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO
POWER COMPAI\Y'S
APPLICATION FOR AUTHORITY
TO ESTABLISH TARIFF
SCHEDULE 68,
INTERCONNECTIONS TO
CUSTOMER DISTRIBUTED
ENERGY RESOURCES
CASE NO. IPC.E-20-30
IDAHO CONSERVATION LEAGUE
COMMENTS
The Idaho Conservation League (ICL) recommends the Commission approve Idaho
Power's Application with a few minor modifications. Overall, ICL supports the use of smart
inverters to improve power quality for the benefit of solar-owners and Idaho Power's grid. We
have reviewed Idaho Power's application and testimony, production responses, and consulted
with industry-leading experts at Grid Lab.l Our review confirms that Idaho Power's proposal to
establish a new Schedule 68 and the proposed inverter settings are reasonable. We recommend
Idaho Power clarify the process to veriff the correct inverter settings upon installation and
provide trainings for installers to ensure adherence to the new Schedule 68. We also recommend
the Commission direct Idaho Power to monitor the growth of distributed energy resources and
report annually in the Demand Side Management report on opportunities to implement additional
smart inverter functions and address distribution circuits experiencing reliability issues.
t https://gridlab.org/mission-approach/
IPC-E-20-30
ICL COMMENTS January 13,2021
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Adoption of Schedule 68
ICL supports establishing Schedule 68 as the applicable schedule for customer-owned
generation. We agree that distinguishing this category of retail customers from other generation
sellers is an appropriate clarification. Idaho Power's proposed modifications described by
Witness Aschenbrenner on pages l5 through 26 will help clari$ requirements and improve
program administration.
Smart Inverter Settings
Smart Inverters have the potential to improve the value of distributed energy systems for
both customer-owners and the remaining gdd. ICL supports the requirement for all customer-
owned systems to use smart inverters that comply with IEEE 1547 standards. We appreciate
ldaho Power's diligence in filing proposed Schedule 68 within 60 days of the final adoption of
the IEEE 1547 and 1547.1standards. We have reviewed Idaho Power's proposed settings with
an eye on the following criteria: ease of implementation, impact on power quality, and the
impact on customer-owner. Because this is a relatively new technology and standard, ICL
consulted with industry experts at Grid Lab to review Idaho Power's proposal. Grid Lab has
worked on the IEEE 1547 standard and related smart inverter settings for utilities and other state
commissions. We found this report, Regulating Voltage, Recommendationsfor Smart Inverters,
to be particularly helpful for a non-technical audience.2 Overall, our review shows Idaho
Power's proposed settings are easy to implement, will improve power quality, and will not
negatively impact customer-owners.
Non-Export Option
ICL supports Idaho Power's proposed non-export option as applied to systems up to 3
MVA. For larger systems above 3MVA, Idaho Power proposes additional metering and
2 https ://gridlab.org/works/regulating-voltage-report/
IPC-E-20-30
ICL COMMENTS 2 January 13,2021
communication equipment for all systems partially "to maintain an accurate load and resource
forecast".3 The Company also proposes to require site-specific interconnection studies for these
systems.a ICL recommends the Commission direct Idaho Power to only require additional
metering and communications equipment if the site-specific studies reveals this is required to
avoid unreasonable impacts to the system. Making full use of the site-specific studies to address
these larger systems is a better use of resources than a blanket requirement for potentially
expensive additional equipment.
Energt Storage Devices
ICL supports Idaho Power's proposal to allow DC coupled storage that is paired with a
generation system to be treated as a single system. We appreciate ldaho Power's proposal to not
apply any additional interconnection requirements on paired storage systems.
Implementation Issues
ICL recommends the Commission direct Idaho Power to do two things to improve the
implementation of this new schedule and new technology. First, individual solar installers will
have to enter specific software seffings in each inverter to implement Schedule 68. To assist with
compliance, ICL recommends Idaho Power provide simple education materials and training
sessions for all solar installers in the service territory. A simple opportunity could be to work
with CED Greentechs, the largest distributor of solar system equipment in the area, and the Idaho
Clean Energy Association to easily reach all active system installers. ICL also recommends
Idaho Power clarify how they will assure correct software settings during system inspections.
3 Ellsworth at 24.
4 Ellsworth at 24-25.
5 https://www.cedgreentech.com/location/boise-id
rPC-E-20-30
ICL COMMENTS J January 13,2021
Second, we recommend the Commission direct Idaho Power to provide annual reporting
to address the growth of distributed energy systems in the area. As Idaho Power explains,
customers of all sizes continue to express interest in generation and storage systems. Over time,
this changing mix of loads and generation can influence the larger grid. And as the amount of
distributed resources grows to significant scale, new opportunities for smart inverter-based
services may arise, as Witness Ellsworth alludes to on page 14. To prepare for this rapidly
coming future, ICL recommends Idaho Power produce an annual report describing the levels of
distributed energy systems, any impacts to distribution circuits, and the potential for additional
smart-inverter based functions. ICL recommends this report that addresses customer-owned
resources could be included in the annual Demand-Side Management program report.
Conclusion
ICL appreciates Idaho Power's proposed Schedule 68. We recommend the Commission:
' APProve Schedule 68'
o Require Idaho Power to provide education materials and training to solar
installers.
o Require Idaho Power to clarify how installers will verify inverter settings.
o Require annual reporting on distributed energy system growth, impacts, and
opportunities.
ICL respectfully submits these comments on this l3th day of January 2021,
/s/Otto
Benjamin J. Otto
Idaho Conservation League
IPC-E-20-30
ICL COMMENTS 4 January 13,2021
CERTIFICATE OF SERYICE
I hereby certify that on this I 2th day of Janu ary, 2021 , I delivered true and correct copies
of the foregoing COMMENTS to the following persons via the method of service noted:
/s/Otto
Benjamin J. Otto
Electronic mail only (See Order 34602)
Jan Noriyuki
Commission Secretary
secretary@puc. idaho. gov
j [e-mail]. gov
Idaho Power
Lisa D. Nordstrom
Tim Tatum
Connie Aschenbrenner
[e-mail]
[e-mail]
c aschenbre mer @idahopower. com
[e-mail]
Idaho Siewo Club
Lisa Young
Mike Heckler
[e-mail]
Michael.p.heckler@gmai l.com
Kelsey Jae
Law for Conscious Leadership
kelsey@kelseyj aenune z.com
Idaho Clean Energt Association
Preston N. Carter
Givens Pursley, LLP
[e-mail]
kendrah@givenspursley. com
Kevin King
Idaho Clean Energy Association
[e-mail]
IPC-E-20-30
ICL COMMENTS 5 January 13,2021