HomeMy WebLinkAbout20211013Initial Comments.pdf,t: il I_ lv Fs
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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:
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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
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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
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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