20191217Comments.pdf

DAYN IIARDIE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BARNO.9917
J.JLiU
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Street Address for Express Mail:
I I33I W CHINDEN BLVD, BLDG 8, SUITE 201.A
BOISE, ID 837I4
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTT]R OF ROCKY MOUNTAIN
POWER'S PETITION TO INCREASE THE
BLUE SKY BLOCK VALUE FROM IOO TO
2()O KILOWATT HOURS
CASE, NO. PAC-E-I9-17
STAFF OF the Idaho Public Utilities Commission, by and through its Attorney of
record, Dayn Hardie, Deputy Attomey General, submits the fbllowing comments.
BACKGROUND
On October 25,2019, Rocky Mountain Power ("Company"), a division ofPacifiCorp,
filed an Application requesting the Commission's approval to increase the size ofeach Blue Sky
Block ("Blue Sky Block" or "Block") offered under Schedule 70-Renewable Energy Rider-
and Schedule 73-Renewable Energy Rider Bulk Purchases (collectively "Blue Sky Program" or
"Program")--from 100 kilowatt hours ("kWh") to 200 kWh. Application at l. The Company
requested an effective date of January I , 2020 and that its Application be processed by Modified
Procedure. 1d. at 7.
The Company proposes to modify the size of the Blue Sky Blocks available to customers
who voluntarily sign up for Schedule 70 or Schedule 73 from 100 kWh to 200 kWh in response
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STAFF COMMENTS DECEMBER 17,2019
RECEIVED
li9 DtC l7 All ll: l0
COMMENTS OF THE
COMMISSION STAFF'
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to changes in the Renewable Energy Credit ("REC") market between 2003, when the Program
was established, and present. ld.at4;See 2018 Blue Sky Annual Report.
The Blue Sky Program is self-funded. 1d. at 5. Funds from customers taking service
under the Program are used to acquire RECs and cover administrative costs, Program growth,
and maintenance . Id. AII funds remaining after accounting tbr Program expenses are made
available to help fund new community-based renewable installations. 1d.
Schedule 70 Blue Sky Blocks currently cost $ 1 .95 each per month. 1d. at 3. Under
Schedule 73, customers can buy Blocks fbr $0.70 per Block per month plus a $1,500 per year
fixed charge, ifcustomers buy at least 1,212 Blue Sky Blocks. For purchases ofover 750,000
Blue Sky Blocks annually, the Company offers individually negotiated contracts. Id. al3-4.
The proposed changes to the Blue Sky Program do not alter individually negotiated
contracts. /./. at 4.
As of September 201 9, there were 1,699 participants in the Blue Sky Program. Id. at 5.
The proposed modifications will allow additional customers to take service under Schedules 70
or 73, enabling residential, commercial, or industrial customers to meet their renewable energy
goals. 1d.
STAFF ANALYSIS
Blue Sky is a voluntary program lor customers who want to reduce the environmental
impact oftheir electricity consumption through the Company's block purchase ofbundled RECs.
The decrease in REC prices since 2003. when the Block size and price were first established,
allows the Company to double the kWh hours with no change to the participant Block price.
Staffrecommends the Commission accept the proposed kWh Block purchase increase from 100
kwh to 200 kWh for $1.95. Stal} also recommends that the Company purchase RECs where
they find the most competitive pricing for customer inveslment, with a preference for RECs
sourced from Idaho. Further, Staff recommends the Company file an annual Blue Sky Report
containing Idaho program audit data fbr Staff review by March 3 I .
2 DECEMBER 17,20I9STAFF COMMENTS
Program Verification
Rocky Mountain Power retires RECs purchased through the BIue Sky Program for its
customer participants. The Blue Sky Program is certified through Green-E, which verifies the
clean energy and carbon offset transactions made tbr customers through a yearly audit. As part
of the verification process, a Green-E auditor confirms that the Company's Blue Sky Program is
in compliance with its Schedule Nos. 7O-Renewable Energy Rider and 73-Renewable Energy
Rider Bulk Purchase.
In Order No. 29329, Staffand the Company were directed to "periodically revisit and
evaluate the program," but the Company is not required to provide annual reports, including
program data, to the Commission. Yearly audits have only occurred as a result of the Green-E
annual verification process. Staff has worked with the Company to cvaluatc program data and
performance in order to verily that program participants are charged appropriately for monthly
Block purchases, ensure there is no shift ofprogram costs to non-panicipating customers. and
verify the Company achieves a balance between Program administrative costs and revenues.
In the last several years, the audit process has been initiated by a Green-E auditor's
request for Staff confirmation that the Program is in compliance before Staffreceived Program
data for review. Staff, in coordination with the Company, recommends that the Company submit
an annual Idaho Blue Sky Report that includes Program data to the Commission by March 3l ,
and coordinate the ycarly audit with Staffbefore a compliance determination is requested by the
Green-E audit of the Blue Sky Program.
Program Issues
Through the audit process, StafTpreviously identified two outstanding Program issues:
(1) the purchase price for a 100 kwh block went down over time resulting in a significant
surplus of funds for qualifying initiatives, and (2) there had been no Idaho applicants for
qualilying initiatives or projects for over five years.
In the last several years the Company has purchased 100 kwh Blocks for about $0. 15
with the remaining amount going to an account to fund qualifying initiatives.r Because the intent
I [n a call with the PacifiCorp Blue Sky program manager to discuss Staff recommendations for 2018, PacifiCorp
estimated that it cost $0.l5 to make the cunent 100 kWh block purchase and about $0.30 to make a 200 kWh block
purchase.
-)STAFF COMMENTS t)li(llrMIlliR I 7. 2019
ofthe Program is to oftset the energy requirements ofparticipants by purchasing Blocks of
renewable energy, Staff supports the Company's proposal to offer an additional 100 kWh per
Block. This change doubles the amount of carbon reduction and still provides I'unding for
qualifying projects, with no additional investment beyond the $1.95 per Block that participants
currently pay.
In Order No. 29329, the Commission noted "the projected lcvel ol Program participation
in Idaho remains quite small, much lower than in the Company's other service area jurisdictions.
and that no change in marketing is proposed Io incrcase participation levels." In previous audits,
Staffhas expressed similar concerns that Blue Sky Program outreach and promotion was
insufficient in Idaho. Staff recommended that the Company develop partnerships with Idaho
non-profits and schools in order to promote cducational opportunities for renewable energy and
qualifying initiatives. During the 2019 audit the Company notificd StalT that they are working
'\r'ith interested parties on several Idaho qualifying initiatives. Additionally, the Company has
made positive changes to promote the Blue Sky Program in Idaho by eliminating qualifying
initiative participation barriers. These changes include streamlining the application process,
removing project investment requirements, and opening award applications year-around.
REC Sourcing
The Company has requested to source RECs on a priority basis beginning with the six
states PacifiCorp serves, followed by the region, with a preference for RECs sourced from newcr
facilities. Stalf recommends that the Company purchase R-ECs where they find the most
competitive pricing for customer investment. In line with previous Commission direclion, Staff
recommends that the Company continue to source RECs for the Program that are not already
purchased or generated by PacifiCorp. Order No. 29329 at6.
Program Change Contingency
The Company is filing the Blue Sky Block purchase change in six other states and has
asked that the proposed changes in Idaho bc contingent upon the Company receiving approval
from all states to maintain uniformity in program management. While Stalf appreciates the
efficiencies that can be achieved by Program uniformity. StafTrecommends that the renewable
energy tariff Program change become effective upon the Commission's approval, rcgardless of
,+STAI.'t-'COMMEN'I'S I)I]CEMBER 17,2OI9
adoption in other states. Because the proposed Blue Sky Block size does not alter individually
negotiated REC contracts currently in place or change Program participation costs, Staffdoes not
believe the proposed Program change is an administratively burdensome undertaking for a
minimal number of Blue Sky Program participants in Idaho.
STAFF RE,COMMENDATION
Staff recommends:
1. The Commission allow the Company to increase the Blue Sky kilowatt-hour
block purchase to 200 kWh at the existing $ 1.95 rate, effective January 1, 2020.
2. The Commission order the Company to file a Blue Sky annual report for its ldaho
service territory by the March 3 1 and include program data to be used in the
annual audit.
3. The Commission direct the Company to prioritize the source of RECs to those
available at least cost, with preference given to Idaho projects.
4. The Commission approve the renewable energy Block purchase change and the
Blue Sky Report submission in Idaho, regardless of adoption in other states.
Respectfu y submitted this day of December 2019.
II
Attorney General
Technical Staff: Rachelle Famsworth
Brad Iverson-Long
i:umisc/commentrpace 19. I Tdhrfbl comments
D
5S'IAFF COMMENTS DECEMBER 17,2019
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE TI-IIS 17TH DAY OI,' DECEMBER 2019,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NO. PAC.E-19-I7, BY MAILING A COPY THEREOF, POSTAGE PREPAID,
TO THE FOLLOWING:
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
datarequcst@pacifi corp.com
SEC ARY
CERTIFICATE OF SERVICF,
TED WESTON
ROCKY MOTINTAIN POWER
I4O7 WN TEMPLE STE 330
SALT LAKE CITY UT 84I16
E-MAIL: [e-mail]
DANIEL E SOLANDER
SENIOR COUNSEL
ROCKY MOUNTAIN POWER
I4O7 WN TEMPLE STE 320
SALT LAKE CITY UT 84116
E-MAIL: [e-mail]