20230629Application.pdf

1407 W. North Temple
Salt Lake City, UT 84116

June 29, 2023 VIA ELECTRONIC FILING

Jan Noriyuki Commission Secretary Idaho Public Utilities Commission
11331 W. Chinden Blvd.
Building 8, Suite 201-A Boise, ID 83714 RE: CASE NO. PAC-E-23-17
IN THE MATTER OF THE APPLICATION OF ROCKY MOUNTAIN POWER TO COMPLETE THE STUDY REVIEW PHASE OF THE STUDY OF THE COSTS AND BENEFITS OF ON-SITE CUSTOMER GENERATION Please find attached Rocky Mountain Power’s electronic filing of this Application in the above
referenced matter. The appendices, both confidential and non-confidential and will be provided
through Box. You will receive a separate email with the Box link to access these files. Informal questions related to this matter may be directed to Mark Alder at [phone].

Sincerely,

Joelle Steward Senior Vice President of Regulation and Customer/Community Solutions Enclosures
CC: Service List – Case No. PAC-E-19-08
RECEIVED
Thursday, June 29, 2023 2:47:33 PM
IDAHO PUBLIC
UTILITIES COMMISSION
Page 1 of 2
CERTIFICATE OF SERVICE
I hereby certify that on this 29th of June, 2023, I caused to be served, via electronic mail a true and correct copy of Rocky Mountain Power’s Application To Complete The Study Review Phase Of The Study Of The Costs And Benefits Of On-Site Customer Generation to the service list in Case No. PAC-E-19-08 to the following: Service List
Eric L. Olsen ECHO HAWK & OLSEN, PLLC
505 Pershing Ave., Ste. 100 P.O. Box 6119 Pocatello, Idaho 83205 [e-mail]

12700 Lake Avenue, Unit 2505
Lakewood, Ohio 44107 [e-mail]
Benjamin J. Otto Idaho Conservation League 710 N. 6th Street
Boise, Idaho 83702
[e-mail]
Idaho Clean Energy Association, Inc.
Givens Pursley LLP
601 W. Bannock Street Boise, ID 83702 [e-mail] [e-mail]
Monsanto
Thomas J. Budge Racine Olson, PLLP
P.O. Box l39l;201 E. Center
Pocatello, Idaho 83204-1391 [e-mail] [e-mail]
Brubaker & Associates Brian C. Collins Maurice Brubaker
Katie Iverson
16690 Swingley Ridge Rd., #140 Chesterfield, MO 63017 [e-mail] [e-mail]
[e-mail]

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Commission Staff
Deputy Attorney General
Idaho Public Utilities Commission 11331 W. Chinden Blvd., Bldg No. 8, Suite 201-A PO Box 83720 Boise, ID 83720-0074
[e-mail]
Rocky Mountain Power
Rocky Mountain Power 1407 West North Temple, Suite 320 Salt Lake City, Utah 84116 [e-mail]
PacifiCorp
825 NE Multnomah, Suite 2000 Portland, OR 97232 [e-mail]
Rocky Mountain Power 825 NE Multnomah, Suite 2000 Portland, OR 97232 [e-mail]
Dated this 29th day of June, 2023. __________________________________ Carrie Meyer Adviser, Regulatory Operations
APPLICATION OF Page 1 ROCKY MOUNTAIN POWER
Joe Dallas (ISB# 10330) PacifiCorp, Senior Attorney 825 NE Multnomah Street, Suite 2000
Portland, OR 97232 Email: [e-mail] Attorney for Rocky Mountain Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION OF ROCKY MOUNTAIN POWER TO COMPLETE THE STUDY REVIEW PHASE OF THE STUDY OF THE COSTS AND BENEFITS OF ON-SITE CUSTOMER GENERATION
) CASE NO. PAC-E-23-17 ) ) 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
application (“Application”) to the Idaho Public Utilities Commission (“Commission”) requesting
the Commission complete the study review phase of the multi-phase stakeholder engaged process
being conducted by the Company to evaluate the methods, inputs, and assumptions for valuing on-
site generation that is exported to the grid. In support of its Application, the Company hereby
submits its on-site generation study (“Study”) as Attachment No. 1 in accordance with the study
scope (“Study Scope”) which was approved by the Commission on August 26, 2020.1
The Company requests the Commission establish a timeline for Commission Staff
(“Staff’), intervenors, and the public to review and comment on the Study. Additionally, Rocky
Mountain Power requests that the Commission issue an order acknowledging that the Study
satisfies the Commission requirements as defined in Order No. 34753.
In support of its Application, the Company states as follows:

1 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, Order No. 34753.
APPLICATION OF Page 2 ROCKY MOUNTAIN POWER
I. BACKGROUND
1. Rocky Mountain Power is a division of PacifiCorp, an Oregon corporation, which
provides electric service to retail customers in the states of Idaho, Wyoming, and Utah. Rocky
Mountain Power is a public utility in the state of Idaho and is subject to the Commission's
jurisdiction with respect to its prices and terms of electric service to retail customers in Idaho
pursuant to Idaho Code §61-129. Rocky Mountain Power provides retail electric service to
approximately 89,000 customers in the state.
A. Net Metering Regulatory History
2. Pursuant to the Commission’s order2 on June 20, 2003, the net metering program
was made available to the Company’s Idaho customers through Schedule 135 with participation
capped at 714 kilowatts, or one-tenth of one percent of the Company’s 2002 retail peak demand.
3. Net metering customers use the Company grid virtually all the time while offsetting
part or all of their energy requirement and are provided a credit at the retail rate for the energy they
produce and export to the grid. During periods when the customer’s generating facility is not
operating or not producing sufficient energy to meet the customer’s usage, energy is delivered to
the customer from Company facilities.
4. During each billing period, a customer’s generation exported to the grid is netted
against the kilowatt-hour usage taken from the Company. If the energy generated by the customer
and delivered to the Company exceeds the energy supplied by the Company to the customer during
the billing period, the customer is billed for the appropriate power and other non-energy charges
and compensated for any net exported energy through a financial credit, based on the applicable
standard service tariff.

2 In the Matter of the Petition of NW Energy Coalition and Renewable Northwest Project to Establish Net Metering
Schedules for PacifiCorp, Case No. PAC-E-03-4, Order No. 29260 (June 20, 2003).
APPLICATION OF Page 3 ROCKY MOUNTAIN POWER
5. In February 2016, the Company applied to the Commission for authority to modify
Schedule 135 by raising the net metering cap from 714 kW to 2,000 kW. The Commission declined
to increase the overall cap on the net metering program indicating that, when it approved the 714
kW cap in 2003, it found the cap should be reviewed after it was reached and that the review should
include a report regarding the required level of subsidization by non-participants.3 The
Commission also stated that the Company had not expressed any immediate reliability concerns
and that subsidization level at the time was small albeit still growing. Based, in part, on this
reasoning, the Commission found it was unnecessary to cap overall participation “at this time”4
and removed the overall and individual participation caps effective May 1, 2016. The Company
was ordered to file annual status reports with specific information about the Company’s net
metering program and to file earlier reports “if the Company at any time expects its net metering
service will materially and negatively impact its system and/or its customers.”5
6. On June 14, 2019 in Case No. PAC-E-19-08, the Company filed for authority to:
(i) close Electric Service Schedule 135 to new customer participation and cap it at the levels in
place, effective at midnight local time, December 31, 2019, (ii) allow existing net metering
customers and those that apply for or complete interconnection before January 1, 2020, to continue
to stay on the program at the site until June 1, 2029; (iii) offer, as an alternative, its proposed Net
Billing program to new customer generators through Schedule 136 for those who apply for
interconnection starting February 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

3 In the Matter of PacifiCorp d/b/a Rocky Mountain Power’s Application to Modify Electric Service Schedule 135 –
Net Metering Service, Case No. PAC-E-16-07, Order No. 33511 at 7 (April 29, 2016). 4 Id.
5 Id., at 8.
APPLICATION OF Page 4 ROCKY MOUNTAIN POWER
generation interconnection requests; (v) 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 and (vi) recover the exported energy credits from the Net
Billing program through the Company’s annual ECAM. 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. 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.
7. 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”. 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, transitional rates, and related
issues of compensation for net excess energy provided as a resource to the Company.”6 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

6 Idaho Power Application, Idaho Power Company’s Petition to Initiate Docket, Case No. IPC-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 No. 34046, at 31 (May 9, 2018).
APPLICATION OF Page 5 ROCKY MOUNTAIN POWER
interest, or otherwise in accordance with law or regulatory policy.7 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, design the study in coordination with the parties and the pubic, 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.”8
8. Based on the outcome of the Idaho Power settlement rejection, on April 23, 2020,
the Company filed a supplemental application to its June 14, 2019 application in Case No.
PAC-E-19-08, requesting 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

7 Idaho Power Application, Order No. 34509 (“Idaho Power Order”), Case No. IPC-E-18-15, December 20, 2019.
8 Idaho Power Order, at 9.
APPLICATION OF Page 6 ROCKY MOUNTAIN POWER
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. In
response to the supplemental application, Staff issued comments recommending the Commission
issue an order requiring the Company to study components of on-site generation beyond what was
in the Company’s proposal.
9. On August 26, 2020 the Commission issued Order No. 34752 and Order No. 34753.
Order No. 34752, which was later adopted by Order No. 34798, granted grandfathered status to
existing customers with on-site generation systems according to the following terms:
• The grandfathered status runs with the meter site, not the customer.
• If a system is offline for over six months, or is moved to another site, the
grandfathered status of the system is forfeited.
• The customer may increase the capacity of the grandfathered system by no more
than 10% of the originally installed nameplate capacity, or 1 kW, whichever is
greater.
• The term of the grandfathering period is 25 years.
10. In Order No. 34752, an existing customer was defined as a customer who had
successfully interconnected an on-site generation system as of the service date9 of Order No. 34798
or a customer who has applied to the Company for interconnection of an on-site generation system
as of the service date of the adopting order and who successfully interconnects their system within
one year of the date of their application. Order No. 34753 ordered the Company to conduct a study
of on-site generation and included a scope of the study as an attachment to the order.

9 The service date of Order No. 34798 was October 2, 2020.
APPLICATION OF Page 7 ROCKY MOUNTAIN POWER
II. THE STUDY
11. The Study Scope, included as “Attachment No. 1: Scope of Rocky Mountain
Power’s On-Site Generation Study” to Order No. 34753 in Case No. PAC-E-19-08, outlines the
requirements to assess various aspects related to the valuations of on-site generation that is
exported to the grid. This evaluation involves examining the methods, inputs, and assumptions
used for this purpose. The Study Scope specifically identifies highlights several areas of
investigation, including the components of the export credit rate (“ECR”), integration costs, and
implementation issues pertaining to the ECR.
12. As directed by the Study Scope, the Study provides the Commission and
stakeholders with the information needed to evaluate potential changes to the ECR for on-site
customer generators in the future. It is important to note that the Study does not put forth specific
ECR proposal. Instead, its purpose is to evaluate the cost and benefits associated with energy
exported by on-site generators and obtain feedback from stakeholders regarding their
considerations when valuing an ECR.
13. There are 33 required items in the Study Scope that range from the recovery of the
ECR in the ECAM to avoided line losses. The Study addresses each of these items and gives a
snapshot of the Company’s approximately 2,200 on-site customer generation customers in Idaho.
Within the Study, the Company has evaluated the effects of netting customer-generated imports
over differently time periods and the revenue requirement impact for each scenario. Furthermore,
a detailed analysis of the export credit rate is conducted, focusing on its different such as the
avoided energy value, the avoided capacity value, and the avoided risk. Additionally, the Study
also looks at implementation issues, including the magnitude of export credits expected to expire
and the potential impact to customers based on various expiration periods.
APPLICATION OF Page 8 ROCKY MOUNTAIN POWER
III. STUDY REVIEW PHASE SCHEDULE
14. The Company recommends a schedule for the study review phase that allows for
the Company to present its study to customers and stakeholders through a workshop and also
allows time for input from interested parties. The following is a proposed schedule:
• Company and staff public workshops to be held in August
• Party comments to be filed in early October
• Company reply comments due late October or early November 2023
IV. CUSTOMER AND STAKEHOLDER COMMUNICATIONS
15. Rocky Mountain Power is notifying its customers of this Application by means of
a press release sent to local media organizations and bill inserts included in customer bills over the
course of a billing cycle. The press release and bill insert are included as Attachment No. 2 and
Attachment No. 3 to this application respectively. The Company plans to hold two virtual public
meetings where the study will be introduced to customers and the Company will be present to take
feedback and answer questions about the study. In addition, copies of this Application will be
made available for review on the Company’s website at
www.rockymountainpower.net/idahostudy or at local offices in its Idaho service territory.
V. CORRESPONDENCE OR COMMUNICATIONS
16. Correspondence and communications regarding this Application should be
addressed to:
Mark Alder Idaho Regulatory Affairs Manager
Rocky Mountain Power
1407 West North Temple, Suite 330 Salt Lake City, Utah 84116 Telephone: [phone] Email: [e-mail]

APPLICATION OF Page 9 ROCKY MOUNTAIN POWER
Joe Dallas (ISB# 10330) PacifiCorp, Senior Attorney 825 NE Multnomah Street, Suite 2000
Portland, OR 97232 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 Mark Alder, Idaho Regulatory Affairs Manager at
[phone].
VI. MODIFIED PROCEDURE
17. The Company believes that consideration of the proposals contained in this
Application do not require an evidentiary proceeding, and accordingly requests that this
Application be processed under modified procedure pursuant to Rules 201-204, which allows for
consideration of these issues by written submissions rather than by an evidentiary hearing. Rocky
Mountain Power respectfully requests that the Commission issue an Order authorizing that this
proceeding be processed under modified procedure.
VII. REQUEST FOR RELIEF
18. WHEREFORE, Rocky Mountain Power respectfully requests that the Commission
establish a formal process for public comment on the Study and issue an order acknowledging that
the Study satisfies the Commission directive as defined in Order No. 34753.

APPLICATION OF Page 10 ROCKY MOUNTAIN POWER
DATED this 29th day of June, 2023.
Respectfully submitted,
ROCKY MOUNTAIN POWER

______________________________
Joe Dallas (ISB# 10330) PacifiCorp, Senior Attorney
825 NE Multnomah Street, Suite 2000
Portland, OR 97232 Email: [e-mail] Attorney for Rocky Mountain Power