20200423Supplemental Application.pdf

1407 West North Temple, Suite 330 Salt Lake City, Utah 84116 April 23, 2020 VIA ELECTRONIC FILING
Diane Hanian Commission Secretary Idaho Public Utilities Commission 472 W. Washington
Boise, ID 83702
Re: CASE NO. PAC-E-19-08
IN THE MATTER OF THE APPLICATION OF ROCKY MOUNTAIN POWER
TO CLOSE THE NET METERING PROGRAM TO NEW SERVICE &
IMPLEMENT A NET BILLING PROGRAM TO COMPENSATE CUSTOMER
GENERATORS FOR EXPORTED GENERATION
Dear Ms. Hanian: Please find an electronic filing of Rocky Mountain Power’s Supplemental Application in the above
referenced matter, along with Attachment 1. Hard copies of the Application and Attachment 1 and CDs containing the workpapers can be provided upon request.

Informal inquiries may be directed to Ted Weston, Idaho Regulatory Manager at [phone]. Very truly yours,

Joelle Steward Vice President, Regulation

RECEIVED
2020 April 23,PM4:28
IDAHO PUBLIC
UTILITIES COMMISSION

Emily Wegener (pro hac vice) Rocky Mountain Power
1407 West North Temple, Suite 320 Salt Lake City, Utah 84116 Telephone: [phone] Email: [e-mail]
Adam Lowney (ISB#10456) McDowell Rackner Gibson PC 419 SW 11th Avenue, Suite 400 Portland, OR 97205
Telephone: [phone] Fax: [phone] Email: [e-mail]
Attorneys for Rocky Mountain Power BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF ROCKY MOUNTAIN POWER TO CLOSE THE NET METERING PROGRAM TO NEW SERVICE & IMPLEMENT A NET BILLING PROGRAM TO COMPENSATE
CUSTOMER GENERATORS FOR EXPORTED GENERATION
) CASE NO. PAC-E-19-08 ) ) ) SUPPLEMENTAL APPLICATION
) OF ROCKY MOUNTAIN POWER )

Rocky Mountain Power, a division of PacifiCorp (“Company” or “Rocky Mountain
Power”), in accordance with Idaho Code §61-502, §61-503, and RP 052, respectfully submits this
supplemental application (“Supplemental Application”) to the Idaho Public Utilities Commission
(“Commission’).
In support of its Supplemental Application, the Company states as follows.
I. APPLICATION HISTORY
1. On June 14, 2019 the Company filed for authority to (i) close Electric Service
Schedule 135 – Net Metering Service, (“Net Metering”), to new customer participation and cap it

at the levels in place, effective at midnight local time, December 31, 2019, (ii) require projects that
apply for interconnection before January 1, 2020 to complete interconnection within a one year
period of application to be eligible to stay in the Net Metering program; (iii) allow existing Net
Metering customers and those that apply for or complete interconnection before midnight local
time, on December 31, 2019 to continue to stay in the program at the site until June 1, 2029; (iv)
offer a new Electric Service Schedule 136 – Net Billing Service, (“Net Billing program” or
“Schedule 136”) for customers who apply to install customer generation after January 31, 2020;
(v) implement an $85 application fee for customers that apply to interconnect a customer
generation system under the Net Billing program; and (vi) recover the exported energy credits,
(“Export Credit”) from the Net Billing program through the Company’s annual Energy Cost
Adjustment Mechanism (“ECAM”).
2. The Application did not seek to modify the retail rates that customers pay for the
service the utility provides, but only to implement a new customer generation program that uses
an export credit rate, which is supported by the testimony of Company witness Daniel J. MacNeil
and an accompanying study (the “Export Credit Study”).1 Rocky Mountain Power’s proposed Net
Billing program consists of the following separate Export Credit elements for which customer-
generators will receive compensation: (1) avoided energy costs; (2) avoided line losses; and
(3) integration costs.
3. The Application provided customers notice of the Company’s proposal to close
Schedule 135 to new customer participation and implement a new program, Electric Service
Schedule No. 136 – Net Billing, for customers with on-site generation where the amount paid for
exported energy from customer owned on-site generation would meet the customer indifference
1 Rocky Mountain Power’s Exhibit No. 1.

standard. The Company issued a press release and customer letters were sent to all Schedule 135
customers to inform them of the proposed changes and recommended grandfathering treatment.
4. The Company provides electric service to over 83,000 customers in Idaho, of which
1,241 are Schedule 135 customers. As of the date of this update, only 12 customers have filed
comments with the Commission, some of which stated they invested expecting no changes to the
tariff. Neither the Commission nor Company ever made that promise. However, the Company
recognizes that Schedule 135 customers have made a significant investment; therefore the
Company’s proposal included a ten-year grandfather period for the Schedule 135 Net Metering
program that, as explained in Mr. Robert E. Meredith’s testimony,2 provides customers sufficient
time to recover their investment. After the grandfathering period, these customers would still
continue to benefit from their investment through reduced usage from the Company and
compensation for exported energy.
5. Participation in the Net Metering program continues to grow significantly. Last
June at the time of the Application there were approximately 820 customers participating under
Schedule 135, with installed capacity of 5.8 megawatts. As of the end of March 2020 there are
1,262 customers with 9.3 megawatts of installed capacity an increase of 60 percent in nine months.
II. IPC-E-18-15 ORDER NOS. 34509 & 34546
6. On October 19, 2018, Idaho Power Company filed a petition relating to net billing
styled as a Petition to Study the Costs, Benefits, and Compensation of Net Excess Energy Supplied
by Customer On-Site Generation (“Idaho Power’s Application”). This Petition was filed in
response to an order from the Commission requiring it “to comprehensively study the costs and
benefits of on-site generation in Idaho Power’s system, as well as proper rates and rate design,
2 Meredith direct testimony, page 19 lines 14 – 20.

transitional rates, and related issues of compensation for net excess energy provided as a resource
to the Company.”3
7. On October 11, 2019 Idaho Power and Commission Staff jointly submitted a
Motion to Approve Settlement Agreement. The settlement requested the Commission approve
changes to Idaho Power’s net metering program. The Commission rejected the settlement in part
due to the absence of a comprehensive study that demonstrated system impacts and a compensation
structure for excess generation. The Commission also rejected it on the grounds that Idaho Power
did not notify customers that the outcome of the case could result in changes to its net metering
program and because there was insufficient record to support that the settlement was reasonable,
in the public interest, or otherwise in accordance with law or regulatory policy.4
8. The Commission directed Idaho Power to prepare and file a “credible and fair
study” of the costs and benefits of distributed on-site generation and provided guidance about what
would constitute an acceptable study. Specifically, the Commission directed that the study should
use current data, make the data publicly available, and design the study in coordination with the
parties and the public, resulting in a study that is both understandable by the public and can
withstand public scrutiny. The Commission established a “study design” phase and a “study
review” phase. During the “study design” phase, both Commission Staff and Idaho Power must
“host public workshops to share information and perspectives on net-metering program design
with the public and to listen to customer concerns and input.”5
3 Idaho Power Application, Idaho Power Company’s Petition to Initiate Docket, Case No. IC-E-18-15, October 19, 2018, at ¶ 1, citing Idaho Power’s Application for Authority to Establish New Schedules for Residential and Small General Service Customers with On-Site Generation, Case No. IPC-E-17-13, Commission Order 34046, at 31 (May 9, 2018). 4 Idaho Power Application, Order No. 34509 (“Idaho Power Order”), Case No. IPC-E-18-15, December 20, 2019. 5 Idaho Power Order, at 9.

9. The Idaho Power Order also held that grandfathering existing net metering
customers was permitted under Idaho law and directed Idaho Power to grandfather existing
customers as of the date of the order.6
III. ISSUES TO BE STUDIED
10. The Company’s Application addresses two issues: (1) fair treatment of existing Net
Metering customers by grandfathering them for ten years while closing the program to new
participants; and (2) implementing a new Net Billing program utilizing an Export Credit value for
energy exported from customers with on-site generation back onto the Company’s grid. The
Application focuses on determining whether it is fair, just, or reasonable to pay new customer
generators the Company’s full retail rate for their non-firm energy exported to the grid.
11. Customers should be indifferent whether they get power from the Company, the
market, or a neighbor who generates more power than they can use and wants to feed that excess
power back onto the grid.
12. Rocky Mountain Power notified customers of its intent to close Schedule 135 to
new service and implement an alternative Schedule 136 – Net Billing to better align the costs and
benefits of net metering.
13. The proposed Net Billing program compensates customers with on-site generation
for energy exported to the grid based on a thoroughly vetted Commission approved Surrogate
Avoided Resource (“SAR”) methodology used for power purchases from other small generators.
This method can be understood by the interested public and has withstood public scrutiny. This
consistent approach of valuing non-firm must-take energy is fair to all customers and power
producers.
6 Id.

IV. POST IDAHO POWER ORDER
14. On March 10, 2020 the Company met with the intervening parties to discuss how
best to proceed in light of Idaho Power’s Order. The parties agreed to proceed with a two-phase
process; Phase 1 to develop the study design, and Phase 2 for the study review. The parties also
developed a proposed schedule. The Company respectfully requests that the Commission authorize
Phase 1 to proceed according to the schedule proposed by the parties.
15. The Company also agreed that it would update the previously submitted Export
Credit Study with the most current information available. Accordingly, the Company submits
Attachment 1 to this Supplemental Application as the updated Export Credit Study. The Export
Credit Study provides the Company’s position on the value of energy exported from customer
owned on-site generation to the Company’s grid, including the following information:
16. Avoided Energy Costs: The avoided energy costs were calculated based on the
Commission approved SAR Methodology for determining avoided costs for standard qualifying
facility resources up to at least 100 kilowatt in nameplate capacity. The updated prices are based
on the April 16, 2020 SAR calculation provided by Commission Staff. The Company’s
Application also included on-peak and off-peak pricing based on Energy Imbalance Market
(“EIM”) prices during calendar year 2018. The Company updated on-peak and off-peak prices to
reflect EIM prices from calendar year 2019. These updated on-peak/off-peak prices support an
average annual export credit of $22.34 per megawatt-hour (“MWh”) as supported in Attachment
1 to this Supplemental Application.
17. Avoided Line Losses: Line losses are the difference between the total generation
injected into the grid, and the total metered volume at customer sites. A kilowatt-hour produced
by a generator is not equivalent to a kilowatt-hour delivered to a customer. The Company’s
avoided energy costs are typically measured based on generation and market purchases at

transmission voltages, while the metered volumes for residential generation exports are measured
at the secondary voltage level. Because residential generation exports travel across the secondary
voltage network, avoided line losses are estimated based on marginal primary voltage losses. The
average value of avoided line losses during the 12 months ending May 31, 2021 is $3.36/MWh.
18. Integration Cost: The Company uses flexible resources to accommodate
fluctuations in the balance of its system attributable to load, wind, solar, and other resources that
are not under the Company’s control. Integration costs represent the cost of holding reserves with
flexible resources to reliably maintain the load and resource balance. Integration costs in the
Application were based on the 2017 Integrated Resource Plan (“IRP”). The inflation adjusted
integration costs in the Application were $0.64/MWh. Since filing the Application on June 14,
2019 the Company filed its 2019 IRP with updated integration costs. The Company updated the
Export Credit to include the 2019 IRP integration costs of $0.25/MWh.
V. GRANDFATHERING
19. The Company’s Application filed on June 14, 2019 requested closure of Schedule
135 – Net Metering as of midnight on December 31, 2109, and notice was provided to customers,
as set forth in paragraph 3, and the Company plans to provide additional notice to all its customers
as set forth in paragraph 24.
20. Idaho Code §61-622 paragraph (4) states:
The period of suspension of such new tariff, schedule, rate, fare, toll, rental, charge,
classification, contract, practice, rule, service or regulation shall not extend beyond thirty (30) days when such new tariff, schedule, rate, fare, toll, rental, charge, classification, contract, practice, rule, service or regulation would otherwise go into effect, pursuant to section 61-307, Idaho Code, unless the commission in its
discretion extends the period of suspension for an initial period not exceeding five
(5) months, nor unless the commission after a showing of good cause on the record grants an additional sixty (60) days. Prior to the expiration of said periods of suspension the commission may, with the consent in writing signed by the party filing such new tariff or schedule, permanently or further suspend the same.

21. As part of this Supplemental Application, the Company respectfully requests
closure of Schedule 135 to new customers as dictated under Idaho Code §61-622, based on the
original closure date requested in its Application, by statute would be effective July 31, 2020 at
midnight local time, and recommends that customers on Schedule 135 as of that date be
grandfathered on that schedule until July 31, 2030. Customers who submit an application to
interconnect before midnight on July 31, 2020 would have one year to interconnect their customer
generation system in order to still be grandfathered on Schedule 135.
22. The Company requests that Electric Service Schedule 136 – Net Billing be effective
September 1, 2020 for all new customers. Schedule 136 is the same as Schedule 135 with one
difference — any energy exported to the GRID will be compensated at the Export Credit Rate.
Initially that Export Credit Rate would be the same as retail energy charges until the Commission
issues a final ruling on the value of the Export Credit. This treats existing Schedule 135 customers
fairly and puts potential new customer generator program participants on notice that the Export
Credit will change.
23. The Company requests that any customer who files an interconnection application
after July 31, 2020 would be subject to the new Net Billing program that results from this docket.
VI. CUSTOMER COMMUNICATION PLAN
24. During the March 10, 2020 meeting the Company and parties agreed to a two-phase
process and developed a proposed procedural schedule. The schedule had the Company
supplementing its Application with an updated Export Credit Study to be filed by April 23, 2020.
The proposed procedural schedule also included Staff filing comments for the April 28th decision
meeting recommending Commission approval of the two phase process and procedural schedule.
The schedule includes the Company and Commission Staff holding public workshops in June. As
soon as the Company has identified locations, times, and dates for the workshops the Company

will send new customer notices of the Application’s proposal with the meeting information to all
customers. The Company will include a telephonic option in case public meetings are not possible
due to COVID-19. This option will also make it easier for customers to participate.
25. The Company is also adding a link to its webpage directing interested customers to
a page that will provide additional information about the proposed changes to the net metering
program.
26. One of the reasons the Commission rejected Idaho Power’s settlement was because
Idaho Power did not notify customers that the outcome of their case could result in changes to its
net metering program. The Company has notified customers of its intent to change the net metering
program and intends to reiterate that intention in the new customer notice.
VII. COST OF SERVICE
27. The Company’s Application was supported by testimony from Mr. Meredith, who
testified that under the existing tariffs, net metering customers don’t pay their full cost of service.
This Commission has previously directed that cost of service and rate design issues should be dealt
with in a general rate case. Accordingly, the Company will provide a current cost of service study
in its general rate case that is targeted to be filed on June 1, 2020, and any rate design changes will
be addressed in that docket.7
VIII. CORRESPONDENCE OR COMMUNICATIONS
Correspondence and communications regarding this Application should be addressed to:
Ted Weston Idaho Regulatory Affairs Manager Rocky Mountain Power 1407 West North Temple, Suite 330
Salt Lake City, Utah 84116
Telephone: [phone] Email: [e-mail]
7 Case No. PAC-E-20-03.

Emily L. Wegener
Rocky Mountain Power 1407 West North Temple, Suite 320 Salt Lake City, Utah 84116 Telephone: [phone] Email: [e-mail]
`
In addition, Rocky Mountain Power requests that all data requests regarding this Application be
sent in Microsoft Word to the following:
By email (preferred): [e-mail]

By regular mail: Data Request Response Center PacifiCorp 825 Multnomah, Suite 2000
Portland, Oregon 97232

Informal questions may be directed to Ted Weston, Idaho Regulatory Affairs Manager at (801)
220-2963.
IX. REQUEST FOR RELIEF
Electric Service Schedule No. 136 – Net Billing is designed to provide for growth of
renewable distributed generation in the Company’s service territory by appropriately
compensating customers for exported generation that is supplied to Rocky Mountain Power’s
system, while at the same time ensuring that the Company’s other customers who are not
participating in the Net Billing program are not harmed by subsidizing Net Billing customers. The
Net Billing program is designed to provide compensation based on costs that the Company would
otherwise spend to obtain electricity.
WHEREFORE, Rocky Mountain Power respectfully requests that the Commission issue
an order authorizing the Company to: (i) close Electric Service Schedule 135 to new customer
participation and cap it at the levels in place, effective at midnight local time, July 31, 2020 per

Idaho Code §61-622 paragraph (4); (ii) allow existing net metering customers and those that apply
for or complete interconnection before July 31, 2020 to continue to stay on the program at the site
until July 31, 2030; (iii) offer a Net Billing program to new customer generators through Schedule
136 for those who apply for interconnection starting September 1, 2020; (iv) implement an $85
application fee for customers that apply to interconnect a customer generation system under the
Net Billing program that will reflect the one-time cost to the Company associated with processing
and reviewing customer generation interconnection requests; (v) require projects that apply for
interconnection before August 1, 2020 to complete interconnection within a one year period of
application to be eligible to stay in the Net Metering program and (vi) recover the exported energy
credits from the Net Metering and Net Billing program through the Company’s annual ECAM.
DATED this 23rd day of April, 2020.
Respectfully submitted,
ROCKY MOUNTAIN POWER

______________________________
Emily Wegener (pro hac vice)
1407 West North Temple, Suite 320
Salt Lake City, Utah 84116 Telephone No. [phone] Facsimile No. [phone] E-mail: [e-mail]

Attorney for Rocky Mountain Power

Attachment 1
PacifiCorp
State of Idaho
Export Credit Summary by Element
Average*
Month Energy Losses Integration Total Energy Losses Integration Total Total
$/MWh $/MWh $/MWh $/MWh $/MWh $/MWh $/MWh $/MWh $/MWh
6/1/20 $24.53 $3.62 ($0.51) $27.63 $13.03 $1.63 ($0.27) $14.39 $16.82
7/1/20 $25.87 $4.94 ($0.41) $30.40 $18.78 $3.03 ($0.29) $21.52 $23.09
8/1/20 $29.98 $4.34 ($0.44) $33.87 $19.39 $2.29 ($0.29) $21.39 $23.51
9/1/20 $30.26 $5.28 ($0.49) $35.05 $17.05 $2.41 ($0.28) $19.18 $21.96
10/1/20 $25.45 $4.06 ($0.39) $29.12 $19.46 $2.63 ($0.30) $21.78 $23.09
11/1/20 $24.11 $4.85 ($0.40) $28.56 $18.17 $3.26 ($0.30) $21.14 $22.37
12/1/20 $27.71 $7.78 ($0.38) $35.11 $22.17 $5.53 ($0.30) $27.40 $28.77
1/1/21 $23.84 $6.30 ($0.18) $29.95 $19.29 $4.59 ($0.15) $23.73 $24.73
2/1/21 $27.06 $6.90 ($0.20) $33.75 $19.25 $4.42 ($0.14) $23.53 $25.26
3/1/21 $19.80 $3.74 ($0.17) $23.37 $17.55 $3.06 ($0.15) $20.46 $21.00
4/1/21 $23.39 $3.61 ($0.21) $26.79 $16.33 $2.21 ($0.14) $18.39 $19.93
5/1/21 $17.84 $2.47 ($0.17) $20.13 $15.55 $1.67 ($0.15) $17.07 $17.56
Annual* $24.97 $4.80 ($0.33) $29.44 $18.02 $3.06 ($0.23) $20.84 $22.34
Summer* $27.60 $4.54 ($0.46)$31.67 $17.11 $2.35 ($0.28)$19.17 $21.38
Winter* $23.63 $4.94 ($0.26)$28.30 $18.47 $3.41 ($0.21)$21.68 $22.82
Definitions:
On-Peak 4pm-10pm MPT Mon-Fri Summer Jun‐Sep
Off-Peak All other, including all day on holidays Winter Oct‐May
* Average values reflect equal delivery in all hours
On-Peak Off-Peak