20211116Final Comments.pdf

Peter J. Richardson
ISB No. 3195
Richardson Adams, PLLC
515 N. 27th Street
P.O. Box 7218
Boise,Idaho 83702
Telephone: [phone] I
Fax: [phone]
peter@richardsonadam s. com
Attorneys for the [ndustrial Customers of ldaho Power
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BEFORE THE
IDAHO PUBLTC UTILITIES COMMISSION
CASE NO. IPC-E-21-21
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATTON 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
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*F[NAL'' COMMENTS OF THE
INDUSTRIAL CUSTOMERS OF
IDAHO POWER
COMES NOW, The Industrial Customers of Idaho Power, hereinafter referred to as the
*ICIP" and pursuant to Order No. 35193 of the ldaho Public Utilities Commission
('Commission"), and hereby files its "Final" Comments as to "the appropriate scope of the Study
Framework . . . to study the costs, benefits, and compensation of net excess energy associated
with customer on-site generation." I
I
INTRODUCTION _ BACKGROUND
Idaho Power Company ("Idaho Power") initiated this docket for the purpose of initiating
a "comprehensive" study of the costs and benefits of on-site generation as directed in
Commission Order No. 34(X6 in May of 2018. In Order No. 35 193 the Commission established
I See page 2 ofOrder no. 35l96At p. 2.
the procedural schedule for the parties to recommend an appropriate scope of the study
framework to be used in furthering the Commission's ultimate goal of a comprehensive study of
on-site generation.2 In response, the ICIP filed comments as to the proper scope of study by
noting that issues associated with off-site Non-Exporting net metering facilities be included
within the scope of the Commission's anticipate "comprehensive" study.3
In response comments, the PUC Staffappears to object to the scope proposed by the ICIP
- no other party expressed any objection to the ICIP's proposal. According to the Commission
Staff, the ICIP's proposal, "is outside of the scope of 'studying the cost and benefits' of onsite
generation.'{ Although observing that the issue is "important," the Staffoffered no explanation
and cited to no authorities to support its conclusory assertion that the [ClP's proposal is beyond
the scope of this docket.s
II
OFF-SITE GENERATION FACTLITIES ARE
ALREADY PART OF THE STUDY AND THE ICIP'S RECOMMENDATION IS NOT
EXPANSIVE NOR OUTSIDE OF THE SCOPE OF THIS PROCEEDTNG
The use of the generic phrase "on-site" generation to describe the practice of net-
metering may have confused the Staff s analysis. Idaho Power already provides for, and this
Commission has approved, net-metering generators to be aggregated to a single meter not
physically located at the site of the customer's generation, (a.k.a. 'off-site' generation). The
general rules applicable to meter aggregation are found in Schedule 84 of the ldaho Power's
currently approved tariffs. While the concept of meter aggregation is currently artificially
2 td.
3 See ICIP Scope of Study Comments, filed in IPC-E-21-21 on September 15,2021
4 See Staff Comments, filed in ICIP-E-21-21 on October 13,2O2l at page 16.5ld.
ICIP Final Comments
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restricted to semi-contiguous properties6 owned by the same entity, the concept of off-site net
metering is already firmly grounded in Commission orders and [daho Power's tariffs and is
already available for Schedules l, 7, 19 and24.
Thus, the proposal of the ICIP to further examine o{f-site generation issues as part of this
net-metering docket is, by definition, already an essential ingredient or component to the topic at
hand. Off-site generation (offsite net-metering) is thus well within the Commission's scope of
net-metering and is an appropriate topic for discussion in this docket. The ICIP therefore
respectfully reiterates its initial request to include this issue among the myriad of topics that are
apparently being welcomed to the issues list without controversy.
DATED this l6th day of November 2021
Peter J.
zuCHARDSON ADAMS, PLLC
CERTIFTCATE OF SERVICE
I HEREBY CERTIFY that on the l6th day of November 2021,a true and correct copy of the
within and foregoing FINAL COMMENTS OF THE INDUSTRIAL CUSTOMERS OF IDAHO
POWER in Docket No. IPC-E-21-21 was served electronically to:
IDAHO POWER COMPAI\TY
Lisa Nordsffom
Connie Aschenbrenner
COMMISSION STAFF
Erick Shaner
I nordstrom (a) i dahopower. com
caschenbrenner@) idahopower.com
dockets@ idahopower. com
Erick. shaner(@nuc, i daho. gov
6 The contiguous property requirement is loosely and inexplicably defined to include parcels
separated by generically described "public ...rights of way" which presumably includes roads,
canals, access easements, highways and etc. tdaho Power No. 29, Tariff No. l0l, Third Revised
Sheet No. 84-5 at Section 2(a)(iii).
ICIP Final Comments
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COMMISSION SECRETARY
Jan Noriyuki jan.norivuki@nuc. idaho. gov
secretary@nuc. idaho. gov
IDAHYDRO
Tom Arkoosh [e-mail]
[e-mail]
IDAHO CONSERVATION LEAGUE
Benjamin J. Otto [e-mail]
IDAHO CLEAN ENERGY LEAGUE
Kevin King staff(a).idahocleanenerey.ors,
CLEAN ENERGY OPPORTUNITIES FOR IDAHO
Michael Heckler [e-mail]
Courfrrey White [e-mail]
Kelsey Jae [e-mail]
MICRON TECHNOLOGY, INC.
JimSwier
Austin Rueschhoff
Thorvald A. Nelson
Austin W. Jensen
CITY OF BOISE
Ed Jewell
KIKI LESLIE A. TIDWELL
Kiki Leslie A. Tidwell
[e-mail]
druschhoff@hollandhart. com
tnelson@hol landhart.com
ajensen@holl andhart.com
gl sarsanoamari @ hol landhart.com
ejewel [e-mail]
boisecityattomev@citvofboi se.ors
[e-mail]
IDAIIO IRRIGATION PUMPERS ASSOCIATION
Eric L. Olsen [e-mail]
RICHARD E. KLUCKHOHN Tnd WESLEY A. KLUCKHOHN
Richard E. Kluckhohn [e-mail]
Wesley A. Kluckhohn [e-mail]
ABC POWER COMPANY, LLC
Ryan Bushland ryan.bushlandfa)abcpower.com
ICIP Final Comments
tPc-E-z1-21
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