20211116Formal Comments.pdf

JAYME B. SULLIVAN BOISE CITY ATTORNEY
Ed Jewell ISB No. 10446 Deputy City Attorney BOISE CITY ATTORNEY’S OFFICE 150 N. Capitol Blvd.
P.O. Box 500
Boise, ID 83701-0500 Telephone: [phone] Facsimile: [phone] Email: [e-mail]
[e-mail]
Attorney for Intervenor
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER COMPANY'S APPLICATION TO INITIATE A MULTI-PHASE COLLABORATIVE PROCESS
FOR THE STUDY OF COSTS BENEFITS AND
COMPENSATION OF NET EXCESS ENERGY ASSOCIATED WITH CUSTOMER ON-SITE GENERATION
Case No. IPC-E-21-21
CITY OF BOISE CITY’S FORMAL COMMENTS
The city of Boise City (“Boise City”) submits these formal comments on the proposed
scope of the study to be undertaken by Idaho Power (“Company”) to comprehensively evaluate
the costs and benefits of on-site generation. Boise City submits these initial formal comments
pursuant to Rule 203 of the Commission’s Rules of Procedure, IDAPA 31.01.01.203, and pursuant
to the Notice of Scheduling, Order No. 35193, issued by the Commission on October 7, 2021.
1.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 be fairly compensated for installing on-site generation and to prevent non-participants in the
CITY OF BOISE CITY’S FORMAL COMMENTS - 1
RECEIVED
2021 NOV 16 PM 4:44
IDAHO PUBLIC
UTILITIES COMMISSION
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 customers and answer 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.
3. Boise City recommends the study consistently analyze each study component at various
on-site generation penetration levels. Boise City believes it would be appropriate to analyze each
study component at current penetration levels, at penetration levels 10x greater than current levels,
and at penetration levels 25x greater than current levels. Similarly, Boise City believes the study
should look at a 20-year planning horizon, which is consistent with Company’s Integrated
Resource Plan (IRP) and the lifespan of a distributed energy resource. Boise City believes doing
so would provide insight about the current state of Idaho Power’s net metering program and allow
evaluation of potential future impacts.
4. Boise City believes the Study Framework must be structured to facilitate a
comprehensive review of all risk mitigation benefits provided by customer-generated energy.
Distributed energy resources are uniquely situated to cost-effectively promote system reliability
and customer resiliency, particularly as the Company’s service area and region experience
increasing impacts of climate change. Boise City recommends the Study Framework incorporate
CITY OF BOISE CITY’S FORMAL COMMENTS - 2
the variabilities and system impacts identified in the 2021 IRP Climate Change scenario, with
increased hydro-electric generation variability, high gas prices, and high load growth, across all
identified avoided cost, benefit, and utility cost calculations.
5. Boise City recommends the Commission include the following areas in the Study
Framework, which the Commission ordered Rocky Mountain Power to study in PAC-E-19-08
Order Nos. 34573 and 34798, that were not included in Idaho Power’s proposed Study Framework:
a. Quantify the value of grid stability, resiliency, and cybersecurity protection
provided by customer generators at each penetration level.
b. 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 risk, reduced hydroelectric generation, degraded air quality,
and other impacts that can have direct impacts on Idaho Power customers at
each penetration level.
c. Quantify local economic benefits, including local job creation and increased
economic activity in the immediate service territory at each penetration level.
i. Boise City recommends the Company incorporate the IMPLAN model
analysis used in Maryland's 2018 Cost and Benefits of Solar study. The
method used to calculate the Jobs and Local Economic Impact &
Inflation is described at pages 171-180. DAYMARK ENERGY ADVISORS,
BENEFITS AND COSTS OF UTILITY SCALE AND BEHIND THE METER
SOLAR RESOURCES IN MARYLAND p. 171-180, 2018 available at
https://www.psc.state.md.us/wp-content/uploads/MD-Costs-and-
CITY OF BOISE CITY’S FORMAL COMMENTS - 3
Benefits-of-Solar-Draft-for-stakeholder-review.pdf (last visited
November 10, 2021).
d. Quantify the reduced risk from end-of-life disposal concerns for the Company
compared to fossil-fueled resources at each penetration level.
e. 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.
f. Quantify and analyze the fuel price guarantee value provided by customer-
generators at each penetration level.
g. Quantify the avoided uncertainty in fuel price fluctuations from displaced
resources across the planning period.
6. Boise City recommends the Commission direct the Company to study specific
environmental benefits and avoided costs of energy exported to the grid by renewable on-site
generation. In addition to the areas to be studied from PAC-E-19-08, Boise City requests the
Commission include the following items:
a. Quantify the total avoided carbon emissions from renewable on-site customer-
generators at each penetration level.
b. Calculate the avoided costs of compliance with carbon emissions regulation at
each penetration level and incorporating the following carbon costs:
i. 2021 IRP Planning Case Carbon Cost.
ii. $51 per metric ton of CO2 – this is the 2020 social cost of carbon at 3%
discount rate as determined by the Interagency Working Group on
Social Cost of Greenhouse Gases. INTERAGENCY WORKING GROUP ON
CITY OF BOISE CITY’S FORMAL COMMENTS - 4
SOCIAL COST OF GREENHOUSE GASES, UNITED STATES GOVERNMENT,
TECHNICAL SUPPORT DOCUMENT: SOCIAL COST OF CARBON, METHANE,
AND NITROUS OXIDE INTERIM ESTIMATES UNDER EXECUTIVE ORDER
13990 p. 5, 2021 available at https://www.whitehouse.gov/wp-
content/uploads/2021/02/TechnicalSupportDocument_SocialCostofCa
rbonMethaneNitrousOxide.pdf (last visited November 10, 2021).
iii. $93 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 social cost of carbon for setting carbon
prices. Kaufman, N., Barron, A.R., Krawczyk, W., A NEAR-TERM TO
NET ZERO ALTERNATIVE TO THE SOCIAL COST OF CARBON FOR SETTING
CARBON PRICES, NAT. CLIM. CHANG. p.10, 1010-1014 (2020) available
at https://doi.org/10.1038/s41558-020-0880-3 (last visited November
10, 2021).
c. Quantify the benefits from the following avoided environmental impacts of
renewable on-site generation at each penetration level:
i. Methane:
1. Quantify the avoided methane leakage from displaced resources,
incorporating natural gas production, transmission rates and
intra-plant leakage/loss throughout. The Gas Index 2020 “Where
Leaks Occur” report identified 338 grams of methane per Mcf
of natural gas leaked out of the production and transmission
systems that deliver natural gas to Boise. THE GAS INDEX, p.6,
CITY OF BOISE CITY’S FORMAL COMMENTS - 5
(2020) available at https://thegasindex.org/ (click on
“Download Report” last visited November 10, 2021).
2. Utilizing the identified total methane leakage avoided from
renewable on-site generation, quantify the avoided social cost of
methane utilizing the February 2021 Interagency Working
Group on Social Cost of Greenhouse Gases reported at $1500 in
2020 dollars per metric ton of methane. INTERAGENCY WORKING
GROUP ON SOCIAL COST OF GREENHOUSE GASES, UNITED
STATES GOVERNMENT, TECHNICAL SUPPORT DOCUMENT:
SOCIAL COST OF CARBON, METHANE, AND NITROUS OXIDE
INTERIM ESTIMATES UNDER EXECUTIVE ORDER 13990 p. 5, 2021
available at https://www.whitehouse.gov/wp-
content/uploads/2021/02/TechnicalSupportDocument_SocialC
ostofCarbonMethaneNitrousOxide.pdf (last visited November
10, 2021).
ii. Water: Quantify the avoided acre feet and avoided cost of water from
decreased water use required for electric generation due to renewable on-
site generation at each penetration level. Reference the method used by
Crossborder Energy and Arizona Public Service in the 2013 study for the
Arizona Corporation Commission. CROSSBORDER ENERGY, THE
BENEFITS AND COSTS OF SOLAR DISTRIBUTED GENERATION FOR
ARIZONA PUBLIC SERVICE p. 12-13, (Beach, R.T., McGuire, P.G. eds.,
2013) available at
CITY OF BOISE CITY’S FORMAL COMMENTS - 6
https://www.seia.org/sites/default/files/resources/AZ-Distributed-
Generation.pdf (last visited November 10, 2021).
iii. Land: Quantify the land use required per MW of utility scale solar and
wind generation in an acre/MW calculation. Utilizing the 2021 IRP
preferred portfolio, quantify the potential avoided acres and avoided
land costs attributable to renewable on-site generation compared to
utility scale solar deployment at each penetration level.
d. Quantify and evaluate the following capacity values for renewable on-site
generation:
i. Quantify and evaluate the capacity resource value for customer-
generators with 4 hours of available on-site energy storage at each
penetration level according to the method agreed to for calculating
capacity payments in the IPC-E-18-15 settlement agreement and
according to effective load carrying capacity (ELCC) value.
ii. Quantify and evaluate the customer-generator capacity resource value
for solar PV customer-generators at each penetration level and
according to the method agreed to for calculating capacity payments in
the IPC-E-18-15 settlement agreement and according to ELCC value.
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 Idaho, with the cost of the
Company’s actual marginal resource for each hour of the year in 2018, 2019, and 2020.
CITY OF BOISE CITY’S FORMAL COMMENTS - 7
8. Compare the stated cost-shift of the current value of customer-generated net-excess
energy to:
a. The inter-class cost shift from the residential customer class to the irrigation
customer class in 2021.
b. Forecasted gross revenue and fixed cost-recovery from residential customer
load growth across planning period.
c. The difference between the projected costs of operating and maintaining
Langley Gulch to the actual costs of operating and maintaining Langley Gulch.
9. Additionally, Boise City recommends the Commission-ordered Study Framework
include the following items and overarching principles to promote transparency and credibility:
a. Direct the Company to make publicly available, as an appendix or attachment
to the study, all data, assumptions, and inputs utilized in the resulting analysis
of the comprehensive benefits and costs of excess energy generation.
b. Ensure the focus of the study and any cost-of-service methodologies or rate
design within the approved Study Framework are only evaluating the costs
associated with net-excess energy produced by customer generators and not the
energy consumption of those customer generators.
10. Boise City believes that customer concerns, in addition to utility concerns, must be
addressed for the study to be considered comprehensive and useful for informing future
Commission decisions. The Study Framework must ensure that the resulting study can credibly
answer key customer questions. Specifically, the Study Framework must enable the Company to
clearly explain the basis for and impacts of any proposed compensation changes for current non-
grandfathered customer-generators and future customer-generators. The Study Framework must
CITY OF BOISE CITY’S FORMAL COMMENTS - 8
also enable the Company to explain, particularly to customers without on-site generation, the fair
value of the net-excess energy produced by their neighbors.
11.Boise City believes that a robust renewable on-site generation program can be a
key resource in Idaho Power’s portfolio. Boise City believes that the unique characteristics of the
resource help to mitigate Idaho Power’s exposure to risks brought about by climate change such
as less predictable runoff and more extreme temperatures. Further, renewable on-site generation
allows customers greater control over their energy bills, creates impactful jobs in Idaho Power’s
service territory, and can help protect against fuel price volatility. Boise City is interested in a
strong and sustainable net-metering program that fairly compensates program participants for all
the benefits they provide to Idaho Power’s system now and into the future. Idaho Power’s service
territory benefits from abundant natural sunlight, a growing population base, and a summer peak
that can be at least partially offset by renewable on-site generation. Boise City believes a strong
and fair net metering program would be a benefit to all Idaho Power customers.
DATED this 16th day of November 2021.
______________________________
Ed Jewell Deputy City Attorney
CITY OF BOISE CITY’S FORMAL COMMENTS - 9
CERTIFICATE OF SERVICE
I hereby certify that I have on this 16th day of November 2021, served the foregoing
documents on all parties of counsel as follows:
Commission Secretary
Idaho Public Utilities Commission 472 West Washington Boise, ID 83702 [e-mail]
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Idaho Power Company PO Box 70
Boise, ID 83707 [e-mail] [e-mail]
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Idaho Power Company
PO Box 70 Boise, ID 83707 [e-mail]
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Deputy Attorney General
Idaho Public Utilities Commission 11331 W. Chinden Blvd., Bldg No. 8, Suite 201-A (83714) PO Box 83720 Boise, ID 83720-0074
[e-mail]
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Richardson, Adams, PLLC 515 N 27th St. Boise, ID 83702
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6070 Hill Road Boise, ID 83703 [e-mail]
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Tom Arkoosh Arkoosh Law Offices
913 W. River St., Suite 450
P.O. Box 2900 Boise, ID 8370 [e-mail] [e-mail]
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Idaho Conservation League 710 N. 6th St. Boise, ID 83702 [e-mail]
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Courtney White Clean Energy Opportunities for Idaho Inc. 3778 Plantation River Dr., Suite 102 Boise, ID 83703
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Micron Technologies
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Austin Rueschhoff Thorvald A. Nelson
Austin W. Jensen
Holland & Hart, LLP 555 17th Street Suite 3200 Denver, CO 80202 [e-mail]
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Echo Hawk & Olsen PLLC
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Comet Energy, LLC 13601 W. McMillan Rd, Suite 102 PMB 166
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Tyler Grange Idahome Solar, LLC
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Meridian, ID 83646 [e-mail]
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Michelle Steel Paralegal, City of Boise
CITY OF BOISE CITY’S FORMAL COMMENTS - 13