20210113Comments.pdf

Kelsey Jae (ISB No. 7899)
Law for Conscious Leadership
920 N. Clover Dr.
Boise,ID 83703
Phone: [phone]
kel sey@kel seyj aenune z.com
Attorneyfor the ldqho Sierra Club
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Lisa Young
Idaho Sierra Club
503 W. Franklin St.
Boise,lD 83702
Telephone: (208) 384-l 023
li [e-mail]
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO
POWER COMPAITY'S
APPLICATION FOR AUTHORITY
TO ESTABLISH TARIFF 68,
INTERCONNECTIONS TO
CUSTOMER DISTRIBUTED
ENERGY RESOURCES
CASE NO. IPC.E.2O-30
COMMENTS
Improvements in the technologies associated with solar photovoltaics, inverters and
storage have dramatically lowered the costs associated with distributed energy resources
("DERs"). These technological advances are changing the traditional centralized generation
utility model and with that, the entire electric utility industry.
As Idaho Power Company ("Idaho Power" or "the Company") acknowledged in response
to several of the Production Requests submitted by Commission Staff in this docket, there
currently is a "relatively low level of DER penetration on Idaho Power's system". Idaho Power
IDAHO SIERRA CLUB COMMENTS .IPC.E.2O-30. I
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further stated that it won't review its proposed process related to smart inverters 'ountil there is a
significant increase in DER penetration".
We submit these comments believing that technological changes will continue to make
DERs even more cost-effective, that increased utilization of DERs is in the interest of the Idaho
public and that Idaho Power should be proactive in supporting these developments.
As the Commission and Staffare well aware, the rise of solar PV installations has
spawned multiple dockets that address related topics. We ask that you take notice of the
comments Sierra Club submitted in the related docket IPC-E-20-26. Among the points raised,
Sierra Club believes those comments make at least a prima facie case that additional Irrigator
owned solar generation would provide benefits to all Idaho Power customers.
Increased use of distributed solar in Idaho agriculture could serve as an insurance policy
to protect Idaho agricultural interests from future economically harmful rate increases while
providing Idaho citizens with access to federal funds from income tax incentives and/or federal
actions like the REAP program. Certainly, such outcomes are in the public's interest for Idaho.
But delay by Idaho Power in reviewing options for supporting the rise of customer owned DERs
puts those outcomes at risk.
The map below displays in various colors the more than 175 of Idaho Power's
distribution level "feeder" lines where Irrigation load makes up more than half of the load on
those lines during peak load hours. The colored regions show the areas where economic
conditions could allow significant increases in DER penetration to the benefit of all Idaho Power
customers.
IDAHO SIERRA CLUB COMMENTS . IPC.E-20.30 .2
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As SCE has noted in a recent publication related to the distribution system (see
Reimagining the Grid,
https://www.edison.com/home/our-perspective/reimagining-the-grid.html) the electric utility is
the parly best capable of extracting the potential benefits associated with distribution system
level control of inverters and storage including at least power quality, voltage control, load loss
avoidance, green athibute harvesting, plus capacity resource and distribution system level capital
offsets.
While it may be adequate in the short-term, we don't believe that the passive approach
Idaho Power has proposed in this docket (ust setting a dead band on smart inverters without
IDAHO SIERRA CLUB COMMENTS . IPC.E-20.30 .3
committing to promptly begin studying how to better utilize DERs) is in the longer-term interest
of the Idaho public.
Customers within the majority of Idaho Power's service territory could soon find their
options to make investments in their agricultural operations constrained if ldaho Power is not
more proactive in analyzingthe opportunities for increasing DER penetration.
ln Sum:
Proactively enabling the increased use of distributed solar in Idaho agriculture is in
Idaho's public interest.
Delay by Idaho Power in reviewing options to support the rise of customer-owned DERs
impedes the ability of customers to capture the associated benefits.
The proposal Idaho Power has made in this docket to just establish settings for smart
inverters without committing to study options for harnessing more of the benefits that
DERs could potentially provide is not in the longer-term interest of the Idaho public.
Our Ask:
For too long the rise of distributed resources has been viewed by many utilities as a
competitive threat - increases in customer owned generation produce an offsetting reduction in
the utility's opportunities to add to the assets in their rate base.
While increases in customer owned generation offset some traditional opportunities for
the utility to add assets to their rate base, the potential for new solutions benefiting both the
utility and customers have yet to be adequately explored.
IDAHO SIERRA CLUB COMMENTS .IPC-E-20-30.4
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We ask the Commissioners to use this docket as an opportunity to encourage Idaho
Power to begin studying a compromise approach where in the future the Company can get "half
a loaf'by owning (as potentially rate base able investments) inverters, storage and
communications equipment associated with DER installations.
Specifically, we ask the Commission to order Idaho Power to begin as soon as possible to
gather relevant data by performing a study on its system of the potential to use storage and
improved control processes on its distribution system to harness the benefits that DERs can
potentially provide.
DATED this l3th day of January,Z02l.
Respectfully submitted,
ls\e
Kelsey Jae
Attorney for Sierra Club
IDAHO SIERRA CLUB COMMENTS .IPC-E.20.30 - 5
CERTTFICATE OF SERVICE
I hereby certiff that on this 13th day of January,202l,I delivered true and correct copies
of the foregoing comments to the following persons via the method of service noted:
Electronic Mail Delivery (See Order No. 34602)
Idaho Public Utilities Commission
JanNoriyuki
Commission Secretary
secretary@puc. idaho. gov
Idaho PUC Staff
Edward Jewell
Deputy Afforney General
Idaho Public Utilities Commission
edward [e-mail]
Idaho Power
Lisa D. Nordstrom
Tim Tatum
Connie Aschenbrenner
[e-mail]
[e-mail]
[e-mail]
[e-mail]
Idaho C onservation League
Ben Otto
botto@idahoconservation. org
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Kelsey Jae
Attorney for Sierra Club
IDAHO SIERRA CLUB COMMENTS .IPC.E-20-30.6