20211013Initial Comments.pdf

Kevin King
PO Box2264
Boise,lD 83702
Ph: (208)850{880
staff @ ida hoclea nenergv.org
Board Chair of the ldaho Clean Energy Association
IN THE MATTER OF IDAHO POWER COMPANY'S
APPLICATION TO INITIATE A MULTI-PHASE
COLTABORATIVE PROCESS FOR THE STUDY OF
COSTS, BENEFITS, AND COMPENSATION OF NET
EXCESS ENERGY ASSOCIATED WITH CUSTOMER
ON-SITE GENERATION
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BEFORE THE IDAHO PUBTIC UTIUTIES COMMISSION
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cAsE NO. IPC-E-ZL-ZL
ldaho Clean Energy Association
INITIAL COMMENTS ON STUDY
FRAMEWORK
It is our position that this framework (provide September 30,20211should be designed to provide the
basis for a study that will be detailed and focused on the
"cost, benefits and compensation ol net excess energy dssoclated wlth customer on*lte
generotion"
as stated in the IPC-E-21-21 initial application. We reiterate this as we believe that within this
framework there are areas of focus that fall outside the value of net excess energ'y, benefits and
compensation and relate directly to utility rate making and profitability methodology that the Company
has identified as necessary to evaluate costumer on-site generation.
Within the primary objectives of this study that have been suggested by the parties we would like to
emphasize that a "fair, just and reasonable" study should be done by a non-bias third party. lt is difficult
for any person or entity, directly related to or effected by the study, to perform a study without injecting
a personal/professional bias. This opinion is supported by the first statement in the "companies'
objectives";
'The Company's prlmary objeaive of the study process is to estoblish o sustainable on-site
generation offefing that limit subsldies by implementing a more equitoble pricing and
co m p e nsoti on stru du re.o
To be clear, the ICEA supports fair compensation for exports, which should resolve the claimed
"subsidies" regarding exports. ln terms of minimizing subsidies across classes, this study is not the place
to presume that reducing one's usage via on-site generation creates "subsidies" any different than other
customers who reduce their usage. IPC-E-18-16 showed that the big dollar subsidies were among
lPC-E-2L-ZL
ICEA lnitialComments October L3,2021,
classes other than Schedule 5 & 8 so let's focus on exports.
With that said, it is also important to note in section 2 of the primary objectives it states
"o. The rates and dollar bill credit to on-site generdtion who expott energy on to the
Compony's grid (Export Credit Rote -"ECR")."
This statement is premature as there has not been any decision on whether the value of an export credit
is to be quantified as an energy credit "kWh credit" or financially based credit "dollar bill credit". When
creating the framework for this study it is important that we do not infer the outcome and this
statement presumes that the outcome should be a financially based value for any net excess energy
credits.
Another aspect of this study that we feel is missing altogether is aligning it with our federal, state,
municipality, and individual goals to developing alternative energy resources. For example, ldaho State
Executive Order No. 2O2O-t8 begins with an emphasis on developing energy resources in our own state
and noting the importance of having a clean and diverse energy portfolio and customer-owned
generation presents opportunities encouraged by ldaho policy. lt is the policy of the State of ldaho to
promote development of the state's energy resources to increase energy supply in an economically
efficient manner while maintaining the integrity of ldaho's natural resources, encourages public
dialogue and educating citizens on the importance of the state's clean and diverse energy portfolio and
developing ldaho's energy resources will benefit the state by creating diverse and sustainable forms of
energy and new job opportunities for ldahoans.
Going back to the title of this study, we should be focused on exports, not consumption. lf we were to
follow the recommendation of A Regulotor's Guidebook: Colculoting the Benefits ond Costs of
Distributed Solor Generotion,lnterstote Renewoble Energy Council(IREC).lt poses the question on p15,
"Q2: WHAT lS BEING CONSIDERED - ALL GENERATION OR EXPORTS ONLY". This guidebook answers that
question with the following statement,
'We recommend assessing only DSG exports to the grid."
Any costs and benefits associated with exports should be part of the value stack for exports. This study
is not the place to estimate how fixed costs might or might not be allocated to customer-generators in a
rate case. The opportunity to consider rate designs for consumption and fixed cost recovery was in IPC-
E-18-16, and the intervenors in that docket made some great recommendations.
The ICEA appreciates the opportunity to work on this study and is looking fonivard to future
collaboration with stakeholders
Respectfully submitted October L3, 2O2t Ko*r> K*n
ldaho Clean Energy Rs#ciation
tPc-E-zt-zt
ICEA lnitialComments October L3,2O2L
CERTIFICATE OF SERVICE
t hereby certify that on this 13th day of October, 2021, I delivered true and correct copies
of the foregoing SCOPING COMMENTS to the following persons via the method of service
noted:
Electronic Mail Delivery (See Order No. 34602)
ldaho Public Utilities Commission
Jan Noriyuki
Commission Secretary
secretary@ puc. ida ho.gov
ldaho PUC Staff
Erick Shaner
Deputy Attorney General
ldaho Public Utilities Commission
erick.sha ner@ puc.idaho.gov
ABC Power Company, LLC
Ryan Bushland
184 W. Chrisfield Dr.
Meridian, lD 83645
ryan.bushla nd @abcpower.com
City of Boise
Deputy City Attorney
Boise City Attorney's Office
150 N. CapitolBlvd.
PO Box 500
Boise, lD 83701-0500
ejewe I I @cityof boise.org
boisecitvattornev@ citvof bo ise.org
Comet Energy, LLC
George Stanton
13501W. McMillan Rd, Suite 102
PMB 166
Boise,lD 837L3
Geo rge.sta nto n @cometenergy. biz
ldahome Solar, LLC
Tyler Grange
2484 N. Stokesberry Pl. f100
Meridian, lD 83545
tvler@ idahomesolar.com
ldaho lrrigation Pumpers Association, lnc.
Eric L. Olsen
lPc-E-zt-zL
ICEA lnitialComments
Echo Hawk & Olsen PLLC
505 Pershing Ave., Suite 100
PO Box 5119
Pocatello, lD 83205
[e-mail]
ldaho Power Company
Lisa D. Nordstrom
Connie Aschenbrenner
ldaho Power Company
1221 West ldaho Street,83702
P.O. Box 70 Boise, ldaho 83707
lnordstrom @ ida ho power.com
dockets @ ida hopower.com
caschenbrenner@ idahopower.com
ldaHydro
C. Tom Arkoosh
Arkoosh Law Offices
913 W. River Street, Suite 450
P.O. Box 2900
Boise,lD 83701
[e-mail]
[e-mail]
ldaho Conservation League
Benjamin J. Otto
710 N. 5th St. Boise,ldaho 83702
botto@ idahoconservation.org
ldaho Solar Owners Network
Joshua Hill
1525 S. Latah
Boise, lD 83705
[e-mail]
[e-mail]
lndustrial Customers of ldaho Power
PeterJ. Richardson
Richardson Adams, PLLC
October L3,2O2L
515 N. 27th St., P.O. Box 7218
Boise, ldaho 83702
oeter@ richardsonada ms.com
Dr. Don Reading
6070 Hill Road Boise, ldaho 83703
dreadins@ mindsorins.com
Richard E. Kluckhohn, pro se
Wesley A. Kluckhohn, pro se
2564 W. Parkstone Dr.
Meridian, ID 83546
[e-mail]
[e-mail]
Micron Technology, lnc.
Jim Swier
8000 South FederalWay
Boise,lD 83707
[e-mail]
Austin Rueschhoff
Thorvald A. Nelson
Austin W. Jensen
Holland & Hart, LLP
555 17th Street Suite 3200
Denver, CO 80202
da rueschhoff@ holla nd ha rt.com
tnelson @ holland hart.com
awjensen@ holland hart.com
aclee@ holla ndhart.com
glsarsanoa mari@ holland hart.com
tPc-E-21-21
ICEA lnitialComments
Kiki Leslie A. Tidwell, pro se
704 N. River St. #1
Hailey, lD 83333
[e-mail]
Clean Energy Opportunity for ldaho
MichaelHeckler
Courtney White
m [e-mail]
courtnev@cleanenergvopporu nitv.com
Kelsey Jae
Law for Conscious Leadership
[e-mail]
Kevin King
ldaho Clean Energy Association
October L3,2O2l