20221012Reply Comments.pdf

JAYME B. SULLryAN
BOISE CITY ATTORNEY
Mary Grant ISB No. 8744
Deputy City Attomey
BOISE CITY ATTORNEY'S OFFICE
150 N. Capitol Blvd.
P.O. Box 500
Boise, ID 83701-0500
Telephone: [phone]
Facsimile: [phone]
Email: BoiseCityAttorney(@cit_vofboise.org
mrsrant fa) c it)'o f bo i s e' ore
Attorney for lntervenor
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BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CaseNo. PC-E-22-22IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION TO COMPLETE
THE STUDY REVIEW PHASE OF THE
COMPREHENSTVE STUDY OF COSTS AND
BENEFITS OF ON-SITE CUSTOMER
GENERATION & TO IMPLEMENT CHANGES
TO SCHEDULES 6, 8, AND 84 NON-LEGACY
SYSTEMS
CITY OF BOISE CITY'S
REPLY COMMENTS
The city of Boise City ("Boise City") submits these reply comments on the application
submitted by Idaho Power Company ("Company") to complete the study review phase of the
comprehensive study of costs and benefits of on-site customer generation. Pursuant to Rule 203 of
the Commission's Rules of Procedure, IDAPA 31.01.01.203, and pursuant to the Notice of
Application, Order No. 35464, issued by the Commission on July 14, 2022, and Notice of
Schedule, Order No. 35512, issued by the Commission on August 22, 2022, Boise City submits
its formal written comments and states as follows:
1. Boise City continues to approach the review phase of the Company's application with the
goals of ensuring customer generators are fairly compensated for the full value of energy
CITY OF BOISE CITY'S REPLY COMMENTS - I
delivered to the Company's grid and that the public is provided sufficient opportunities for
participation in this process. Customer clean energy resources can and should play an
important role in the Company's transition to 100% clean and cost-effective energy by
2045 and will continue to provide significant economic benefits to communities across
Idaho.
2. In its initial comments, the Company stated its intention to file a revised Value of
Distributed Energy Resources ("VODER") study "incorporating feedback received
throughout the review process to refine and clarifr salient issues." Idaho Power Company's
Initial Comments at 4. Boise City appreciates the Company's commitment to receiving
input from parties and the public to inform the revised VODER study and offers the
following areas that could benefit from further refinement. Boise City believes the
Company's revised VODER study should: 1) consider additional approaches to
quantifuing the avoided transmission and distribution capacity costs, and 2) clariff how
avoided fuel price risks could be incorporated in an export credit rate ("ECR").
3. Boise City is concerned that the VODER study's deferrable project approach to assigning
value to avoided transmission and distribution capacity costs may under compensate
customer-generators. Boise City recommends the Company consider incorporating an
approved tariffapproach in the revised VODER study. An approved tariff approach relies
on the Company's FERC-approved firm transmission rate, currently $31.42 kWh/year, that
is then adjusted based on distributed solar energy resources' capacity factor, and levelized
to identiff the net present value. The approved tariffapproach would present the avoided
transmission capacity value in terms of additional nansmission capacity available for sale
to other transmission customers. See Ionso PowBn AppRoveo TuNsulssloN TARIFF
CITY OF BOISE CITY'S REPLY COMMENTS - 2
RATE,available at
1'---.-;.-;^a D orahttn'ww. oasis. oati. com/woa/docs/Ipar)/IPCr\,{^^./rPCO Current
s 08-26-22.pdf. An approved tariff methodology could be relatively easily updated
annually, relies on transparent inputs, and directly captures an important cost consideration
affecting customer rates in the fluid and dynamic regional energy landscape. ECRS
implemented in Maine, Oregon, and Utah all utilized this approach, or a similar
methodology, to value distributed energy resources' (*DERS") avoided transmission
capacity costs.
As stated in Boise City's initial comments, the Company should consider incorporating an
evaluation of fuel price risk, beyond market energy prices, in its revised VODER study.
Boise City's tnitial Comments at 3. The specific methodology of valuing avoided energy
costs in an ECR has not yet been proposed by the Company or approved by the
Commission. Assessing and valuing avoided fuel price risk independent of market prices
is reasonable and would be more comprehensive. Boise City recommends the Company
consider the methodology in Maine's Distributed Solar Valuation Study ("Maine Study")
provides as one approach to valuing the hedge associated with natural gas volatility
displaced by DERs. MerNe PueI-rc UnLruss CouurssroN, MArNE DrstnreurED SoLAR
VeluertoN Sruoy p.39 - 40, 2014 available at: https://energynews.us/wp-
loads/2018107 126.-C-MPUC Value of Solar This
calculation could be relatively easily replicated using the Company's approved rate of
return and historical Treasury bill rates over the last 5 years.
5. Boise City agrees with Commission Staff s recommendation to amend the VODER study
to include additional information on the safety and reliability assurances in place for
4
CITY OF BOISE CITY'S REPLY COMMENTS - 3
proposed DERs, independent of the project eligibility cap. Staff Comments at 16. Boise
City also supports incorporating information that further explains the different
interconnection requirements for potential projects with a nameplate capacity under 100
kW, greater than 100 kW but less than 1 MW, and greater than I MW. Boise City does not
believe the study needs to be updated to include an evaluation of potential gaming and
manipulation between Public Utilities Regulatory Policies Act of 1978 ("PURPA") and
customer-generation.
6. Boise City generally agrees with the concems identified by Clean Energy Opportunities
for Idaho ("CEO") in applying seasonal time-variant pricing to exported energy but not
allowing customer generators access to time-variant consumption prices. CEO lnitial
Comments at 2-3. An ECR and overall customer generation program that symmetrically
incorporates seasonal time-variation could efficiently encourage distributed energy storage
and provide relevant pricing signals to customers and should be fuither evaluated as a part
of any implementation proceedings.
7. Boise City believes it is in the public interest for the Commission to issue an order either
acknowledging or rejecting the revised VODER study as consistent or inconsistent with
the Commission's expectations as stated in Order No. 34509 before the Commission
considers any changes to net-metering. Boise City believes it is critically important for the
understandability of the process and public acceptance of any future compensation
structure. Boise City recognizes that further delay and uncertainty around customer
generation is not desirable but believes this can be mitigated with clearly established next
steps and a general framework for a schedule determined in this order on the study review
phase. If the Commission issues an order acknowledging the study complied with
CITY OF BOISE CITY'S REPLY COMMENTS - 4
established directives, the Commission could also concurrently direct the Company to file
a proposal for revisions to the program along with any associated tariff drafts within a
reasonable timeframe, direct staff to work with parties to propose comment and reply
comment deadlines, and re-caption the docket to reflect the change in scope to
implementation, thereby letting customers know that changes are on the table.
8. Relatedly, Boise City believes customers should be formally noticed of the Company's
proposed compensation structure or any transition into an implementation phase of this
proceeding. The company's original customer notice only hypothetically considered
changes to the customer generation offerings, stating "Idaho Power has proposed a
schedule that could allow for the IPUC to issue a determination as to the future structure
of this service offering by the end of 2022, with implementation no earlier than June l,
2023". Affachment 2 to the Company's Application at l. As with the study review phase,
robust oppornrnities for public input and customer notice will be imperative to any
implementation consideration.
9. Boise City appreciates the opportunity to provide reply comments on the VODER study
review phase. Boise City looks forward to the Company's revised VODER study and
continuing to engage in a process that supports a robust renewable on-site generation
program.
DATED this l2th day of October2022.
Mary Grant
Deputy City Attomey
CITY OF BOISE CITY'S REPLY COMMENTS - 5
CERTIF'ICATE OF SERVICE
I hereby certiff that I have on this 12th day of October 2022, served the foregoing
documents on all parties of counsel as follows:
Jan Noriyuki
Commission Secretary
Idaho Public Utilities Commission
472West Washington
Boise, D 83702
j an. noriyuki@puc. idaho. eov
LisaNordstom
Megan Goicoechea Allen
Idaho Power Company
PO Box 70
Boise,ID 83707
lnordstrom(D idahopower. com
[e-mail]
dockets@idahopower. com
Timothy Tatum
Connie Aschenbrenner
Grant Anderson
Idaho Power Company
PO Box 70
Boise,ID 83707
[e-mail]
caschenbrenner@ idahopower.com
ganderson@ idahopower.com
RileyNewton
Chris Burdin
Deputy Attorney General
Idaho Public Utilities Commission
1 1331 W. Chinden Blvd., Bldg No. 8,
Suite 201-4 (83714)
PO Box 83720
Boise, D 83720-0074
riley.newton(dpuc. idaho. eov
chris.burdin@puc. idaho. sov
O U.S. Mailtr Personal Deliverytr Facsimileg Electronic Means w/ Consenttr Other:
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CITY OF BOISE CITY'S REPLY COMMENTS - 6
Peter J. Richardson
Richardson, Adams, PLLC
515 N 27th St.
Boise, ID 83702
oeter(E richardsonadams. com
Dr. Don Reading
6070 Hill Road
Boise,ID 83703
dread in s (4) mi ndsprin e. ore
Tom Arkoosh
Arkoosh Law Offices
913 W. fuver St., Suite 450
P.O. Box 2900
Boise,ID 8370
tom. arkoosh(@ arkoo sh. com
erin.cecil@arkoosh. com
Marie Kellner
Idaho Conservation League
710N.66 St.
Boise, D 83702
mkel lner(d idahoconservation. ore
Kevin King
Idaho Clean Energy Association
PO Box2264
Boise, D 83702
staff@ idahocleanenerqy. ore
Michael Heckler
Courtney White
Clean Energy Opportunities for Idaho tnc.
3TTSPlantation River Dr., Suite 102
Boise,ID 83703
m i ke(cucleanenerqyopportunities. com
courtnev(E cl eanenergyopportunities. com
Kelsey Jae
Law for Conscious Leadership 920 N.
Clover Dr.
Boise, ID 83703
kelsey(rDkelseyi ae. com
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CITY OF BOISE CITY'S REPLY COMMENTS - 7
Joshua Hill
Idaho Solar Owners Network
1625 S. Latah
Boise,ID 83705
i oshuashi I l(a) emai l. com
[e-mail]
Jim Swier
Micron Technologies
8000 South Federal Way
Boise, D 83707
iswier(rimicron.com
Austin Rueschhoff
Thorvald A. Nelson
Austin W. Jensen
Holland & Hart, LLP
555 lTth Street Suite 3200
Denver, CO 80202
darueschho fI(@ho I landh a rt. com
tnelson@hollandhart. com
Eric L. Olsen
Echo Hawk & Olsen PLLC
505 Pershing Ave., Suite 100
PO Box 6119
Pocatello,ID 83205
[e-mail]
Lance Kaufrnan, Ph.D
4801 W. Yale Ave.
Denver, CO 8-219
lance(rDbardwellconsultine.com
Richard E. Kluckhohn, pro se
Wesley A. Kluckhohn, pro se
2564W. Parkstone Dr.
Meridian, ID 83646
[e-mail]
[e-mail]
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[e-mail]
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CITY OF BOISE CITY'S REPLY COMMENTS - 8
Ryan Bushland
ABC Power Company, LLC
184W. ChrisfieldDr.
Mqidiaq ID 83646
rvan.bushland@abcoower. com
[e-mail]
tr U.S. Mailtr Personal DeliveryB Facsimiled ElectronicMeansw/Consenttr Othier:
MaryR Cirant
Deputy City Attorney, City ofBoise
CITY OF BOISE CITY'S REPLY COMMENTS - 9