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Home My WebLink About20211013Initial Comments.pdf,t: il I_ lv Fs i,i: *il,i l3 PH 2:55 -,:isi i-.r.1 Ji;r-riE JAYME B. SULLIVAN BOISE CITY ATTORNEY Ed Jewell ISB No. 10446 Deputy City Attomey BOISE CITY ATTORNEY'S OFFICE 150 N. Capitol Blvd. P.O. Box 500 Boise,ID 83701-0500 Telephone: (208) 608-7950 Facsimile: (208) 384-4454 Email : ej ewell(dcityofboise. org boisecitvattornev@citvofboise.ore Attorney for lntervenor BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION Case No. IPC-E-21-21IN THE MATTER OF IDAHO POWER COMPA}ry'S APPLICATION TO INITIATE A MULTI-PHASE COLLABORATTVE PROCES S FOR THE STTJDY OF COSTS BENEFITS AND COMPENSATION OF NET EXCESS ENERGY ASSOCIATED WITH CUSTOMER ON-SITE GENERATION CITY OF BOISE CITY'S INITIAL FORMAL COMMENTS The city of Boise City ("Boise City") submits these initial formal comments on the proposed scope of the study to be undertaken by ldaho Power to comprehensively evaluate the costs andbenefits of on-site generation. Boise City submits these initial formal comments pursuant to Rule 202 of the Commission's Rules of Procedure, IDAPA 31.01.01 .202, and pursuant to the Notice of Initial Comment Deadline, Order No. 35176, issued by the Commission on September 22,2021. l. Boise City has an interest in ensuring the study design will comprehensively evaluate the costs and benefits of customer-owned on-site generation so its citizens have the opportunity to CITY OF BOISE CITY'S INITIAL FORMAL COMMENTS - I be fairly compensated for installing on-site generation and to prevent non-participants in the program from being unfairly and unreasonably burdened by the decisions of others. Only through a fair, just, and reasonable program design can both ends be attained. The study framework must represent a balanced approach and must reasonably account for all costs and benefits from on-site generation. The study must address the concerns of Idaho Power customers and ansrver their questions about on-site generation. The study must also provide the Commission with a basis to analyze future proposals to change the net-metering program. 2. Pursuant to the procedure established for this docket, Boise City and other parties to the case submitted proposed additions to the Company's Study Framework to Commission Staff, which Staff integrated into Commission Staff s Study Framework submitted to the Commission on September 30, 2021. For easy reference, Boise City's proposed additions to the study are attached as Attachment l. 3. To ensure a balanced perspective in the study design, Boise City looks forward to listening to members of the public in forthcoming workshops and during the telephonic public hearing on October 28,2021. ^lee Order No. 35193 (outlining the dates and times for public workshops, the public hearing, and comment deadlines). Boise City also anticipates drawing from the extensive public record developed in IPC-E-I8-15, wherein numerous members of the public expressed their unresolved questions about on-site generation. Boise City intends to integrate the customer concerns in its final comments to be filed with the Commission on November 16,2021. Boise City believes that customer concerns, in addition to the utility's concerns, must be addressed for the study to be considered comprehensive. CITY OF BOISE CITY'S INITIAL FORMAL COMMENTS - 2 DATED this l3th day of October20}l P{-t ( Ed Jewell Deputy City Attorney CITY OF BOISE CITY'S INITIAL FORMAL COMMENTS - 3 CERTIFICATE OF SERYICE I hereby certiff that I have on this l3th day of October 2021, served the foregoing documents on all parties of counsel as follows: Jan Noriyuki Commission Secretary Idaho Public Utilities Commission 472West Washington Boise, ID 83702 i an. noriyuki(Epuc. idaho. eov Lisa Nordstrom Idaho Power Company PO Box 70 Boise, lD 83707 lnordstrom(iD i dahopower. com dockets@idahopower. com Connie Aschenbrenner Idaho Power Company PO Box 70 Boise, D 83707 caschenbrenner(4 idahopow er. com Erick Shaner Deputy Attomey General Idaho Public Utilities Commission I 1331 W. Chinden Blvd., Bldg No. 8, Suite 201-A (83714) PO Box 83720 Boise,lD 83720-0074 erick. shaner(€lpuc. idaho. sov Peter J. Richardson Richardson, Adams, PLLC 515 N 27ft St. Boise, tD 83702 p et er(a) ri ch a rd s o nad am s. com Dr. Don Reading 6070 Hill Road Boise,ID 83703 dread in e (@ m i ndspri ne. or s O U.S. MailO Personal Deliverytr Facsimileg Electronic Means w/ Consenttr Other: tr U.S. Mailtr Personal Deliverytr Facsimileg Electronic Means w/ ConsentO Other: U.S. Mail Personal Delivery Facsimile Electronic Means w/ Consent Other: U.S. Mail Personal Delivery Facsimile Electronic Means w/ Consent Other: U.S. Mail Personal Delivery Facsimile Electronic Means w/ Consent Other: U.S. Mail Personal Delivery Facsimile Electronic Means w/ Consent Other: tr o trg tr tr tr trg tr tr tr trg tr tr tr trg tr CITY OF BOISE CITY'S INITIAL FORMAL COMMENTS - 4 Tom Arkoosh Arkoosh Law Offices 913 W. River St., Suite 450 P.O. Box 2900 Boise, ID 8370 tom. arkoosh(d arkoo sh. com erin.cecil@arkoosh.com Benjamin J. Otto Idaho Conservation League 710 N. 6ft St. Boise, D 83702 botto@ idahoconservation. orq Kevin King Idaho Clean Energy Association POBox2264 Boise, lD 83702 staff(E idahocl eanenerey. ore Michael Heckler Courtney White Clean Energy Oppornrnities for Idaho Inc 3TTSPlantation River Dr., Suite 102 Boise, ID 83703 mike@cl eanenergvopportunities. com courtney@cleanenerqyopportunities. com Kelsey Jae Law for Conscious Leadership 920 N. Clover Dr. Boise, ID 83703 kel s ev (a) kel seyj ae. com Joshua Hill Idaho Solar Owners Network 1625 S. Latah Boise, ID 83705 i oshuashi ll fa) email. com tottens @ amsidahs.eals tr U.S. Mailtr Personal Deliverytr FacsimileV Electronic Means w/ Consenttr Other: U.S. Mail Personal Delivery Facsimile Electronic Means w/ Consent Other: U.S. Mail Personal Delivery Facsimile Electronic Means w/ Consent Other: U.S. Mail Personal Delivery Facsimile Electronic Means w/ Consent Other: U.S. Mail Personal Delivery Facsimile Electronic \{sans w/ Consent Other: U.S. Mail Personal Delivery Facsimile Electronic Means w/ Consent Other: tr U.S. Mailtr Personal Deliverytr Facsimileg Electronic Means w/ Consenttr Other: tr tr og tr tr tr trg tr tr tr trg tr tr tr trg tr tr tr trg tr Jim Swier Micron Technologies 8000 South Federal Way Boise, lD 83707 iswier(dmicron.com CITY OF BOISE CITY'S INITIAL FORMAL COMMENTS . 5 Austin Rueschhoff Thorvald A. Nelson Austin W. Jensen Holland & Hart, LLP 555 lTth Street Suite 3200 Denver, CO 80202 daru eschho ftlrz) ho I I andharl. c o m tnel son (d.ho I I andhart. com awj ensen(@hollandhart.com aclee(D hollandhart. com sl qarganoamari@hollandhaft . com Kiki Leslie A. Tidwell, 704 N. River St. #l Hailey, ID 83333 ktinsv@cox.net Eric L. Olsen Echo Hawk & Olsen PLLC 505 Pershing Ave., Suite 100 PO Box 6l 19 Pocatello,ID 83205 elo(a)echohawk.com Richard E. Kluckhohn, pro se Wesley A. Kluckhohn, pro se 2564W. Parkstone Dr. Meridian,ID 83646 kluckhohn(Eemail.com wkluckhohn@mac.com Ryan Bushland ABC Power Company, LLC 184 W. Chrisfield Dr. Meridian,ID 83646 ryan.bushland(@abcpower.com George Stanton Comet Energy, LLC 13601 W. McMillan Rd, Suite 102 PMB 166 Boise, ID 83713 Georee. stanton(@ cometenergy. biz tr U.S. Mailtr Personal Deliverytr Facsimileg Electronic Means w/ Consenttr Other: U.S. Mail Personal Delivery Facsimile Electronic Means w/ Consent Other: U.S. Mail Personal Delivery Facsimile Electronic Means w/ Consent Other: tr U.S. Mailtr Personal Deliverytr Facsimileg Electronic Means w/ Consenttr Other: U.S. Mail Personal Delivery Facsimile Elecffonic Means w/ Consent Other: U.S. Mail Personal Delivery Facsimile Electronic Means w/ Consent Other: tr tr tr tr tr tr tr trg tr tr tr trg tr tr tr trg tr CITY OF BOISE CITY'S INITIAL FORMAL COMMENTS - 6 TylerGrange Idahome Solar, LLC 2484 N. Stokesberry Pl. #100 Meridian,ID 83646 wler@idahomesolar. com tr U.S. Mailtr Persoaal Deliverytr Facsimileg Elochonic Means il Conseirttr Other: Mchelle Steel Paralegal, City of Boise CITY OF BOISE CITY'S INITLAL FORIvIAL COMMENTS - 7 ATTACHMENT I City of Boise lnformal Comments on the Proposed Study Design to Determine the Costs and Benefits of Distributed Generation tPc-E-27-2L The city of Boise City ("City'') proposes the following additions to the scope of the comprehensive cost benefit analysis ordered in Order No. 34509, IPC-E-18-15. Items from PAC-E-19-08. Order No. 34573: t. Quantify the value of grid stability, resiliency, and cybersecurity protection provided by customer generators at each penetration level. 2. Quantify the value to local public health and safety from reduced local impacts of global warming such as extreme temperatures, reduced snowpack variation, reduced wildfire ris( reduced hydroelectric generation, degraded air quality, and other impacts that can have direct impacts on ldaho Power customers at each penetration level. 3. Quantify local economic benefits, including localjob creation and increased economic activity in the immediate service territory at each penetration level. a. Recommend ldaho Power incorporate the IMPLAN model analysis as completed in Maryland's 2018 Cost and Benefits of Solar study completed by Daymark. Methodology detailed at 171-180. https://www.psc.state.md.us/wp-content/uploads/MD-Costs-and- Benefits-of-So la r-Draft-for-sta keho lder-review. pdf 4. QuantifiT the reduced risk from end-of-life disposal concerns for the Company compared to fossil-fueled resources at each penetration level. 5. Explain how seasonal and time-of-delivery price differences will be used to help align customer generated exported energy with the Company's system needs at each penetration level. 6. Quantify and analyze the fuel price guarantee value provided by customer tenerators at each penetration level. a. Quantify the avoided uncertainty in fuel price fluctuations from the displaced marginal resource across the planning period. Other ltems to Studv: 7. Utilize consistent and reasonable penetration levels of on-site generation throughout study. Current levels, 10x, and 25x would be appropriate. 2. Quantifu the total avoided carbon emissions from on-site generators and the benefit of avoided costs of compliance with carbon emissions regulation at each penetration level and incorporating the following carbon costs: a. 2021 IRP Planning Case Carbon Cost. b. S51 per metric ton of COz-2020 social cost of carbon at 3% discount rate from lnteragency Working Group on Social Cost of Greenhouse Gases. (https://www.whitehouse.eov/wp- content/uploads/2021l02lTechnicalsuoportDocument SocialCostofCarbonMethaneNitr ousoxide.pdf at 5) c. Sgg per metric ton of CO2- to achieve Net zero emissions by 2040 as identified in Kaufman, N., Barron, A.R., Krawczyk, W. et al. A near-term to net zero alternative to the 7 social cost of carbon for setting carbon prices. (https ://www. natu re.com/a rticles/s41558-020-0880-3#citeas) 3. Quantifu the benefits from the following avoided environmental impacts of distributed PV at each penetration level: a. Methane: Quantify the avoided methane leakage from the displaced marginal natural gas resource, incorporating natural gas production, transmission rates and intra-plant leakage/loss throughout. The Gas lndex 2020 "Where Leaks Occur" report identified 338 grams methane per Mcf natural gas through the production and distribution systems to Boise. Utilizing the identified total methane leakage avoided from distributed PV, quantify the avoided social cost of methane utilizing the February 2021 lnteragency Working Group on Social Cost of Greenhouse Gases reported 51500 in 2020 dollars per metric ton of CH4. (https://www.whitehouse.eov/wo- content/uploads/2021/02lTechnicalsupportDocument SocialCostofCarbonMethaneNitr ousOxide.pdf at 5) b. Water: Quantifu the avoided acre feet and cost of water from decreased water use required for electric generation as Crossborder Energy quantified in Arizona Public Service costs and benefits of distributed generation study (https://www.seia.orelsites/default/files/resources/AZ-Distributed-Generation.pdf at L2l- c. Land: Quantitr/ the land use required per MW of utility scale solar generation in an acre/MW calculation. Utilizing 2021 IRP preferred portfolio, quantify potential for avoided land costs and acres preserved by distributed PV compared to planned utility scale solar deployment. 4. Quantify and evaluate the customer generator capacity resource value for customer generators with 4 hours of available on-site energy storage at the penetration levels indicated above according to the method agreed to for calculating capacity payments in the IPC-E-18-15 settlement agreement and according to ELCC value. 5. Quantify and evaluate the customer generator capacity resource value for solar PV customer generators at the penetration levels indicated above and according to the method agreed to for calculating capacity payments in the IPC-E-18-15 settlement agreement and according to ELCC value. 6. Utilizing the 2021 IRP Climate Change scenario with increased hydro variability year over year, high gas price, and high load growth, quantify the avoided costs at each penetration level of d istributed energy resources. 7. Using the method to calculate the avoided cost of energy agreed to in the IPC-E-18-15 settlement agreement, compare the avoided cost of energy rates a customer-generator would have received given a typical rooftop solar PV output profile in southern ldaho, with the cost of the Company's actual marginal resource for each hour of the year in 2Ot8,2079, and 2020. 2