20220309Comments.pdf

DAYN HARDIE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
TDAHO BAR NO. 9917
IN THE MATTER OF ROCKY MOUNTAIN
POWER'S APPLICATION FOR AUTHORITY
TO REVERT THE BLUE SKY BLOCK
VALUE TO lOO KILOWATT HOURS FROM
2OO KILOWATT HOURS
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Street Address for Express Mail:
1I33I W CHINDEN BVLD, BLDG 8, SUITE 2OI-A
BOISE, ID 83714
Attomey for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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CASE NO. PAC-E-22-02
COMMENTS OF THE
COMMISSION STAFF
STAFF OF the Idaho Public Utilities Commission, by and through its Attorney of
record, Dayn Hardie, Deputy Attorney General, submits the following comments.
BACKGROUND
On January 24,2022, Rocky Mountain Power ("Company"), a division of PacifiCorp,
applied for authority to revert the standard Blue Sky block size to 100 kilowatt hours ("kwh").r
In 2000, Rocky Mountain Power launched the Blue Sky Program ("Program") to allow
customers wanting to be served by Renewable Energy Credits ("RECs") to offset some or all
their usage from renewable energy sources while also supporting renewable energy development.
In Order No. 34545, 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). Case No. PAC-E-19-17.
I Blue Sky blocks are available to customers under Schedule Nos. 70 and 73. The program is voluntary and self-
funded.
1STAFF COMMENTS MARCH 9,2022
The Program is self-funded, and the funds collected from participating customers are
used to cover REC purchases and marketing/administration expenses. Excess funds are made
available to help fund new community-based renewable energy installations.
STAFF ANALYSIS
The Program is a voluntary option for customers who want to reduce the environmental
impact of their electricity consumption through block purchases of RECs. As the Company
continues to evaluate its voluntary Program, evidence of rising REC prices has prompted the
Company to make Program updates that include a revision to the block structure as it was prior
to modification by Order No. 34545.
Through production requests and evaluation of the Application, Staff confirmed that costs
of participation in the Program are tracked separately to avoid shifting costs to nonparticipants,
and that the tariff changes are necessary to maintain the Program due to the increasing price of
RECs. However, Staff is concerned how the Company's proposed changes may affect the
Program, specifically: (1) the Program currently has excess funds available and the proposed
change in the block structure could increase the excess balance; (2) the Company continues to
struggle to receive applications for renewable grant projects that could be funded by the
Program; and (3) constantly changing the Program for expected costs of RECs is becoming
common practice.
Currently, the Program lets customers buy 200 kwh blocks of renewable energy.
Because of the expected increase in the price of RECs, the Company proposes changing blocks
to 100 kWh of renewable energy while maintaining the $1.95 per block cost. The reduction in
block size results in a cost increase to participants who wish to purchase additional blocks to
completely offset their electricity usage. Staff encourages the Company to monitor participation
in the Program as the Company transitions to the proposed new block structure.
The Company based its proposed structure change on an analysis of the current and
forecasted Program budget, with the expectation that the market price for bundled RECs will
increase. The Company alleges the new structure is better suited for REC market price volatility
and may lead to a budget surplus that may fund community-based solar installations. The
Company estimated that only 2o/o of Program funds would be available for community-based
renewable energy installations if the block size remained 200 kWh. The Company forecasted
2STAFF COMMENTS MARCH 9,2022
that if the Program's block size is changed to 100 kwh, 43o/o of Program funds would be
available for community-based renewable energy installations.
The Company currently reports its Program data in the annual Blue Sky Report filed with
the Commission. Upon review of the draft2D2l Blue Sky Report, the Company reports Program
revenues of $69,814 and an excess fund balance of $140,458 for its Idaho Program. Including
the expected increase in the cost of RECs and no changes to the current block structure or rates,
the Program's current budget would still receive enough revenues to recover projected REC
purchases.
Staff believes the proposed changes would increase the Program's surplus balance if the
Company does not receive applications for the community-based renewable energy grants. The
Company received one application for a renewable energy grant during2}2l, but it had to deny
the grant because of the lack of available funds. Despite a surplus balance of available funds, the
Company has received few applications for renewable grant projects. Additionally, the
Company has completed few community-based renewable projects in Idaho. Due to a small
budget in Idaho, larger projects may be harder to fund in the Company's Idaho service territory.
Staff believes, the Company could explore other alternatives like providing partial funding to
projects or other renewable projects that may benefit Idaho customers.
The Company asserts that the Program changes have been approved in four other states.
Staff is aware that keeping the Program consistent among the Company's six States is less of a
burden to the Company and maintains uniformity in Program management operations. Before
the Company makes any future requests regarding Schedule No. 70 and No. 73, Staff would like
to see an analysis of the additional administrative costs of maintaining separate pricing and block
structures for its Idaho jurisdiction. Staff recommends approval of the changes to the Program
block structures with the caveat that the Company will present an analysis of the administrative
burdens of maintaining a separate Program structure for Idaho prior to frling any future Program
changes.
JSTAFF COMMENTS MARCH 9,2022
STAFF RECOMMENDATION
Staffrecommends the Commission approve the Company's proposed changes to Electric
Service Schedule Nos. 70 and73 as filed, which will modiff the block structure of the
Company's Blue Sky Program as detailed above. Staff also recommends the Commission order
the Company to continue to file its annual Blue Sky Report with the Commission each year.
IbRespectfully submitted this day of March2022.
Deputy Attorney General
TechnicalStaff: TravisCulbertson
Taylor Thomas
i : umisc/commentV pace22.2dhtnctl comments
4STAFF COMMENTS MARCH 9,2022
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 9tr DAY oF MARCH 2022,
SERVED THE FOREGOING COMMENTS OF TIm COMMTSSION STAFF, IN
CASE NO. PAC.E-22-02, BY E.MAILING A COPY THEREOF, TO THE
FOLLOWING:
TED WESTON
MICHAEL SNOW
ROCKY MOTINTAIN POWER
1407 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84116
E-MAIL: [e-mail]
michael. snow@pacificorp. com
DATA REQUEST RESPONSE CENTER
E.MAIL OIILY:
datarequest@Faci fi corp.com
EMILY WEGENER
ROCKY MOUNTAIN POWER
I4O7 WN TEMPLE STE 320
SALT LAKE CITY UT 84I 16
E-MAIL: [e-mail]
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SECRET^(RY. /- -
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CERTIFICATE OF SERVICE