20220401Final_Order_No_35362.pdf

ORDER NO. 35362 1

Office of the Secretary
Service Date
April 1, 2022
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

On January 24, 2022, PacifiCorp dba Rocky Mountain Power (“Company”) applied to
the Idaho Public Utilities Commission (“Commission”) for authority to revert the standard Blue
Sky block size to 100 kilowatt hours (“kWh”) from 200 kWh.1 The Company requested its
Application be processed by Modified Procedure with an effective date of April 1, 2022.
On February 16, 2022, the Commission issued a Notice of Application and Notice of
Modified Procedure setting deadlines for the public and the Company to file comments. See Order
No. 35324. Staff filed comments to which the Company did not reply. No other comments were
filed.
Having reviewed the record in this case, we now issue this final Order authorizing the
Company to revert the standard Blue Sky block to 100 kWh.
BACKGROUND
In 2000, the Company launched the Blue Sky Program (“Program”) to allow customers
wanting to offset some or all their usage with Renewable Energy Credits (“RECs”). In Case No.
PAC-E-19-17, the Commission authorized the Company to increase the size of each block offered
under the Program from 100 kWh to 200 kwh (at no additional cost to the participating customer).
See Order No. 34545. Staff stated that the Program was self-funded, and the funds collected from
participating customers are used to cover REC purchases and marketing/administration
expenses—any unused funds are made available to help fund new community-based renewable
energy installations. Id.
THE APPLICATION
Due to the recent price increase for RECs, the Company requests to change the size of
each block offered under the Program from 200 kWh back to 100 kWh while continuing to charge
$1.95 per block.

1 Blue Sky blocks are available to customers under Schedule Nos. 70 and 73.
IN THE MATTER OF ROCKY MOUNTAIN
POWER’S APPLICATION FOR
AUTHORITY TO REVERT THE BLUE SKY
BLOCK VALUE TO 100 KILOWATT HOURS
FROM 200 KILOWATT HOURS
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CASE NO. PAC-E-22-02

ORDER NO. 35362
ORDER NO. 35362 2

The Program is self-funded, and the funds collected from participating customers are
used to cover REC purchases and marketing/administration expenses. Remaining funds are made
available to help fund new community-based renewable energy installations. Due to the recent
increase in REC prices, the Company estimated that only 2% of Program funds would be available
for community-based renewable energy installations if the block size remained 200 kWh. The
Company forecasted that if the Blue Sky block size is changed to 100 kWh then about 43% of
Program funds would be available for community-based renewable energy installations.
STAFF COMMENTS
Staff supported the Company’s proposed changes to Schedule Nos. 70 and 73 as filed.
Id. at 4. Staff recognized that the proposed changes would modify the block structure of the
Program and recommended that the Commission require the Company to continue filing annual
Blue Sky Reports. Id. In 2021, the Company’s Blue Sky Report indicated revenues of $69,814 and
an excess fund balance of $140,458 for its Idaho Program. Id. at 3. Staff believed even without
changes to the current block structure or rates, that the Program’s current budget would receive
adequate revenue to recover projected REC purchases and that the Program might continue to run
a surplus budget if few or no applications for community-based projects were received. Id.
Staff recommended the Company explore providing partial funding to projects or other
renewable projects that benefit Idaho customers—making funding requirements less restrictive
and potentially increasing the Company’s ability to use unused funds for community-based
projects. Id. Staff’s concerns were based on the Company’s lack of applications for community-
based renewable energy grants. Id.
Staff stated that it would like to see an analysis of the additional administrative costs
of maintaining separate pricing and block structures for its Idaho jurisdiction before the Company
makes any future requests regarding Schedule Nos. 70 and 73. Staff recommended approval of the
proposed changes to the Program block structure, but recommended the Company present an
analysis of the administrative burden of maintaining a separate Program structure for Idaho prior
to filing for approval of any future Program changes. Id.
COMMISSION FINDINGS AND DECISION
The Company is an electric corporation under Idaho Code § 61-119, and a public utility
under Idaho Code §61-129. The Commission has jurisdiction over the issues in this case under
Title 61 of Idaho Code, including Idaho Code §§ 61-301, -502, and -503. The Commission has
ORDER NO. 35362 3

reviewed the record, including the Application and Staff’s comments. Based on its review, the
Commission now approves the Company’s Application to revert its Blue Sky block size from
200kWh back to 100kWh.
The Commission finds it reasonable to approve the changes to the Blue Sky Program,
effective as of April 1, 2022. We continue to direct the Company to focus on procuring least-cost
RECs to match Program demand, with preference given to non-PacifiCorp projects in Idaho, when
feasible.
In Order No. 29329, we “direct[ed] Staff and the Company to periodically revisit and
evaluate the program to assure that program participants are not paying a premium for the same
renewable energy benefits enjoyed by all PacifiCorp customers.” Order No. 29329 at 6. We
understand the REC market is not static—but everchanging—and appreciate the Company being
proactive to seek amendment of the Program and ensure its offerings remain consistent with the
market forces. Based on the record and the changing REC market, we believe it is appropriate to
update the Program in Idaho.
A unique component of the Program is the availability of unused funds to assist
community-based renewable energy programs. We encourage the Company to explore ways to
make sure these funds are available and used to assist eligible recipients in its Idaho service
territory. We hope the Company will explore opportunities to use unused funds to partially fund
projects when adequate funds are not available to fully fund a single project. It is important that if
one of the components of the Program includes using unused funds to provide funding to
community-based renewable projects that those funds are made available. Given the de minimis
number of applications and grant requests in recent years, we direct the Company to explore ways
to ensure the unused funds are distributed to qualifying projects that would benefit from the grants.
This may require the Company to change its promotion, application process, eligibility criteria,
qualifications, or structure for funding.
If the Company wishes to amend the Program at any point in the future, it should be
accompanied by an analysis of the additional administrative costs of maintaining separate pricing
and block structures in Idaho from its other jurisdictions.
We direct the Company to continue filing an annual “Blue Sky Program Report.” This
Report should help keep the Program Block size and cost aligned with the REC market prices. It
ORDER NO. 35362 4

will also give the Commission an opportunity to review the Company’s efforts and success in
approving grants for qualifying initiative projects.
O R D E R
IT IS HEREBY ORDERED that the Company’s Application to revert renewable
energy Blocks for the Blue Sky Program to 100kWh from 200 kWh is approved, effective April
1, 2022.
IT IS FURTHER ORDERED that the Company shall evaluate—or to the extent
necessary adjust the requirements for—its community-based renewable energy program grants to
ensure funds are available for use in Idaho.
IT IS FURTHER ORDERED that the Company shall continue to monitor the REC
market and propose amendments to the Program as necessary to ensure Program viability.
IT IS FURTHER ORDERED that the Company shall file a Blue Sky Program Report
with the Commission each year.
THIS IS A FINAL ORDER. Any person interested in this Order may petition for
reconsideration within twenty-one (21) days of the service date of this Order regarding any matter
decided in this Order. Within seven (7) days after any person has petitioned for reconsideration,
any other person may cross-petition for reconsideration. See Idaho Code § 61-626.
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ORDER NO. 35362 5

DONE by Order of the Idaho Public Utilities Commission at Boise, Idaho this 1st day
of April 2022.

ERIC ANDERSON, PRESIDENT

JOHN CHATBURN, COMMISSIONER

JOHN R. HAMMOND, JR., COMMISSIONER

ATTEST:

Jan Noriyuki
Commission Secretary

I:\Legal\ELECTRIC\PAC-E-22-02 Blue Sky\orders\PACE2022_final_dh.docx