20231102Reply Comments.pdf

JAYME B. SULLIVAN
BOISE CITY ATTORNEY
Darrell Early ISB No. 4748
Deputy City Attorney
BOISE CITY ATTORNEY’S OFFICE
150 N. Capitol Blvd.
P.O. Box 500
Boise, ID 83701-0500
[phone]
Email: [e-mail]
Attorneys for Intervenor
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR
AUTHORITY TO IMPLEMENT CHANGES TO
THE COMPENSTION STRUCTURE
APPLICABLE TO CUSTOMER ON-SITE
GENERATION UNDER SCHEDULES 6, 8,
AND 84 AND TO ESTABLISH AN EXPORT
CREDIT RATE METHODOLOGY
Case No. IPC-E-23-14
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 implement changes to the compensation
structure for customer on-site generation under schedules 6, 8, and 84 and to establish an export
credit rate methodology. Boise City, pursuant to Rule 203 of the Commission’s Rules of
Procedure, IDAPA 31.01.01.203, and pursuant to the Notice of Modified Procedure, Order No.
35881, issued on August 10, 2023, hereby submits its formal written comments and states as
follows:
CITY OF BOISE CITY’S REPLY COMMENTS - 1
RECEIVED
2023 NOVEMBER 2, 2023 4:18PM
IDAHO PUBLIC
UTILITIES COMMISSION
CITY OF BOISE CITY’S REPLY COMMENTS - 2
SUMMARY OF RECOMMENDATIONS
In these reply comments, Boise City remains focused on ensuring any transition away
from 1:1 kWh net metering is fair to non-grandfathered customers taking service under
Schedules 6, 8, and 84; in line with the magnitude of any under-recovery of costs asserted by the
Company; and does not unreasonably limit or deter the ability of customers to meet a portion of
or all their energy needs through distributed energy resources (“DERs”). In evaluating the
application, Boise City believes the Commission should consider the understandability of the
changes proposed, the impact of the effective rate increase resulting from the present case in
combination with the general rate case (IPC-E-23-11), and the predictability of rates as it would
for any ratepayer. Boise City recognizes the unique value DERs bring to the Company’s grid and
the important community benefits realized through greater DER deployment, including enhanced
resilience, lower emissions, and lower household energy burden.
Consistent with Boise City’s initial comments and informed by the initial comments of
other parties, Boise City recommends:
1. The Commission evaluate and issue a decision in this docket informed by the combined
impact of any changes in compensation of exported energy and the Company’s general
rate case (IPC-E-23-11).
2.Any change in compensation for exported energy from customer generators should be
predictable, understandable, and offer reasonable stability for customers and the
Company.
3.The Commission consider the impacts and necessity of changing the measurement
interval for exported energy and the need for and value of an Export Credit Rate (“ECR”)
separately, implementing an hourly-netting period effective January 1, 2024 but
evaluating the appropriateness of conversion from retail rate to an ECR in context of the
net impacts from the Company’s general rate case (IPC-E-23-11).
4.The Commission establish a reasonable transition period for non-grandfathered, existing
customer-generators be implemented if changes to compensation of exported energy are
approved.
5.The Commission approve the Company’s proposed modifications to the project eligibility
cap in Schedule 84, increasing the cap to the greater of 100 kW or 100 percent of demand
for commercial, industrial, and irrigation customers.
6.If an ECR is determined to be necessary by the Commission, the resulting ECR should
comprehensively value exported energy, including a value for avoided fuel price risk, and
a reasonable transmission & distribution deferral value.
7.Boise City further recommends that the Company be directed to work with interested
stakeholders to further evaluate opportunities to monetize the renewable energy attributes
associated with exported energy.
UNDERSTANDABILITY OF IMPACT OF PROPOSED CHANGES
Boise City remains concerned that in this present docket (IPC-E-23-14) on-site
generation customers cannot reasonably evaluate or understand the combined impact of the
changes proposed in this docket and the net impact caused by the Company’s General Rate Case
in IPC-E-23-11. The Commission should consider the combined impact of the change in rates
for consumption and the compensation structure for exported energy to evaluate the
reasonableness and fairness of any transition away from the current compensation structure for
exported energy. Underlying rate design and revenue requirement decisions determined in IPC-
E-23-11 drive cost recovery considerations important to this docket. Additionally, consistency
between the two
CITY OF BOISE CITY’S REPLY COMMENTS - 3
dockets on seasonal time periods, hours of highest cost and risk, and incentives to shift demand
away from peak hours are important to the compensation structure for exported energy and will
influence customer behavior.
IMPLEMENTATION CONSIDERATIONS FOR AN ECR
While related to the ECR, the Commission should consider implementation of the
measurement interval as an independent component of the Company’s application. As stated in
its initial comments, Boise City continues to recommend adoption of an hourly netting period.
The Commission must balance both accuracy and understandability in setting a fair
compensation structure for exported energy. Boise City believes hourly measurement will be
significantly more understandable to customers than real-time billing and is far more granular
than the current monthly netting period. As Commission Staff explain in initial comments,
“regardless of real-time or hourly netting, the Company would continue to collect import and
export data on an hourly basis”. Initial Comments of Commission Staff at 12. If real-time
netting were adopted, customers would still see aggregated hourly data but will need to
understand that data was measured instantaneously throughout the hour. Boise City recommends
the Commission approve an hourly netting period effective January 1, 2024, as a reasonable
improvement in billing accuracy that also maintains understandability for customers.
If the Commission decides implementation of an ECR is necessary to ensure
compensation for exported energy is fair, just, and reasonable, Boise City continues to
recommend the Commission ensure compensation changes are gradual, easily understandable to
all customers, promote rate stability, and send the appropriate price signals in this dynamic
energy landscape so as to not deter additional adoption of DER.
CITY OF BOISE CITY’S REPLY COMMENTS - 4
In its initial comments, Boise City identified concerns with the Company’s proposal to
implement an ECR from January to May, with an impending update alongside the Power Cost
and Fixed Cost Adjustments (“PCA”, “FCA” on June 1, 2024. Ultimately, Boise City is
concerned with predictability of rates and the limited time for customers to adapt to and
understand the new compensation structure. If the Commission decides to implement an ECR in
this docket, Boise City believes the proposals from Commission Staff and Clean Energy
Opportunity for Idaho (“CEO” to make the ECR effective January 1, 2024, but delay the update
until June 1, 2025 is reasonable. Initial Comments of Commission Staff at 31. Initial Comments
of CEO at 2. Particularly in the context of the on-going General Rate Case, it is critical that
customers be afforded a reasonable period to adjust to a new billing and compensation structure
prior to any update.
For existing non-legacy customer generators, Boise City continues to recommend the
Commission implement a transition period to any adopted ECR structure. The multi-year process
resulting in the Company’s proposal to change compensation for exported energy in this docket
is not the same as a reasonable, clearly communicated transition period that ensures gradualism
in ratemaking for non-legacy customer generators and balances the interest of all rate payers.
Immediate implementation of the ECR as proposed by the Company would dramatically increase
the monthly bills of non-legacy customers beyond a reasonable level, particularly in comparison
to the level of under-recovery asserted by the Company. A time-limited transition to an ECR for
non-legacy customers is reasonable and fair to all customers. While many different structures for
transitional rates could be considered by the Commission, Boise City recommends the adoption
of a transition framework similar to the transition schedule agreed to by parties in IPC-E-18-15.
IPC-E-18-15 Settlement Agreement at 4-5. In this framework, every 2 years beginning in 2024,
CITY OF BOISE CITY’S REPLY COMMENTS - 5
the ECR would be phased in by 25% until 100% of the value of exported energy is based on the
approved ECR in 2032.
MODFICIATIONS TO PROJECT ELIGIBLITY CAP
Boise City continues to support the Company’s proposal to increase the project eligibility
cap for Schedule 84 to the greater of 100 kW or 100% of customer demand. Additionally, Boise
City supports Staff’s recommendation to approve the Company’s proposal excluding energy
storage systems from the nameplate capacity for purposes of determining the project eligibility
cap. Initial Comments of Commission Staff at 6. The Company’s proposal balances the need to
maintain reliability, facilitates larger customers fairly offsetting their energy consumption from
on-site generation, and encourages the adoption of storage.
ECR VALUATION
Informed by the initial comments of Vote Solar and CEO, Boise City recommends any
ECR adopted by the Commission include a value for the avoided fuel price risk delivered by
exported energy. In the absence of the Company proposing a methodology for fuel price hedge
in its application, Boise City recommends the Commission approve the avoided fuel price risk
value equal proposed by Vote Solar and CEO equal to 5% of avoided energy costs. Initial
Comments of Vote Solar at 26. Initial Comments of CEO at 3. Incorporation of a reasonable fuel
price hedge value appropriately recognizes the unique value exported energy delivers to the
Company’s system, reducing exposure to volatile fossil-fuel market prices.
Boise City also recommends the Commission modify the basis for calculating the
avoided generation capacity value of exported energy in any adopted ECR. While Boise City is
not advocating for a specific methodology for determining capacity value, Boise City does not
agree with the Company’s proposal to use single cycle combustion gas-fire turbine (“SCCT”) as
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the avoided cost parameter. Instead, the Commission should adopt an avoided capacity value
based on the cost of 4-hour battery storage instead of a SCCT. Battery storage, and not a SCCT,
is the planned next capacity resource in both the 2021 and 2023 Integrated Resource Plan
preferred portfolios. Utilizing the next planned, additional resource that can be deferred instead
of an alternative surrogate avoided resource aligns the generation capacity value with the
Company’s resource planning. Boise City believes using the next capacity resource in the most
recently filed IRP is more accurate, understandable to customers, and consistent with the
Company’s proposal to use actual and forecasted project costs to determine distribution capacity
value.
CONCLUSION
Boise City appreciates the opportunity to provide comments on the Company’s
application to modify the compensation structure, measurement interval, and project eligibility
requirements for on-site generation customers and respond to the detailed initial comments
offered by intervening parties. In summary, Boise City continues to recommend consideration of
the impacts of the Company’s general rate case on this docket, a reasonable transition to any new
compensation structure, approval of the modified project eligibility cap, and consideration of a
more comprehensive compensation structure if a transition to an ECR is approved in this docket.
DATED this day of November 2023.
______________________________
Darrell Early
Deputy City Attorney
2nd
for
CITY OF BOISE CITY’S REPLY COMMENTS - 8
CERTIFICATE OF SERVICE
I hereby certify that I have on this _____ day of November 2023, served the foregoing
documents on all parties of record as follows:
Jan Noriyuki
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Ste. 201-A
Boise, ID 83714
[e-mail]
U.S. Mail
Personal Delivery
Facsimile
Electronic
Other: __________________
Chris Burdin
Deputy Attorney General
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Ste. 201-A
Boise, ID 83714
[e-mail]
U.S. Mail
Personal Delivery
Facsimile
Electronic
Other: __________________
Lisa D. Nordstrom
Megan Goicoechea Allen
Idaho Power Company
P.O. Box 70
Boise, ID 83707
[e-mail]
[e-mail]
[e-mail]
U.S. Mail
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Other: __________________
Tim Tatum
Connie Aschenbrenner
Grant Anderson
Idaho Power Company
P.O. Box 70
Boise, ID 83707
[e-mail]
[e-mail]
[e-mail]
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2nd
CITY OF BOISE CITY’S REPLY COMMENTS - 9
Eric L. Olsen
Echo Hawk & Olsen PLLC
P.O. Box 6119
Pocatello, ID 83205
U.S. Mail
Personal Delivery
Facsimile
Electronic
Other: __________________
Lance Kaufman, Ph.D.
2623 NW Bluebell Place
Corvallis, OR 97330
[e-mail]
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Facsimile
Electronic
Other: __________________
Matthew Nykiel
Bard Heusinkveld
Idaho Conservation League
710 N. 6th St.
Boise, ID 83702
[e-mail]
[e-mail]
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Tom Arkoosh
Arkoosh Law Offices
P.O. Box 2900
Boise, ID 83701
[e-mail]
[e-mail]
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Michael Heckler
Courtney White
Clean Energy Opportunities for Idaho
3778 Plantation River Dr., Suite 102
Boise, ID 83703
[e-mail]
[e-mail]
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Jim Swier
Micron Technology, Inc.
8000 South Federal Way
Boise, ID 83707
[e-mail]
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Austin Rueschhoff
Thorvald A. Nelson
Austin W. Jensen
Holland & Hart, LLP
555 17th Street, Suite 3200
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[e-mail]
CITY OF BOISE CITY’S REPLY COMMENTS - 10
Denver, CO 80202
[e-mail]
[e-mail]
[e-mail]
[e-mail]
Abigail R. Germaine
Elam & Burke PA
251 E. Front St. Suite 300
P.O. Box 1539
Boise, ID 83701
ar elamburke.com
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Kate Bowman, Regulatory Director
Vote Solar
299 S. Main St. Suite 1300
PMB 93601
Salt Lake City, UT 84111
kbowman votesolar.or
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________________________________
Michelle Steel,
Paralegal
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