20130607Boise to IPC 1-5.pdf

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R. Stephen Rutherford-- ISR No. 5410
Chicf Deputy City Attorney
Borsr Crrv ArlonNryrs Orrtr:n
150 N. Capitol Blvd.
P.O. Box 500
Boise, ID 83701-0500
Telephone: [phone]
Facsimile: 208.384.4454E-mail: [e-mail]
John R. Hammond, Jr. - ISB No. 5470
FrsrrrR Puscrr & AlnsnuAN, LLP
U.S. BANK PI,AZA- 7.h Floor
101 S. Capitol Blvd., Suite 701
P.O. Box 1308
Boise, ID 83701
Telephone: [phone]
Facsimile: 208.331.2400
E-mail [e-mail]
Attorneys for City of Boise
:tllI Jii:: -i li'i lil'35
Before thc
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF TIJE APPLICATION
OF IDAFIO POWIIR COMPANY
FOR AUTHORITY TO MODIFY
ITS NET METERING SERVICE
AND TO INCREASts THE
GENERATION CAPACI'|Y LIMIT
Case No. IPC-E-12-27
THE CITY OF tsOISE'S
RESPONSES TO THE FIRST
PRODUCTION REQUESTS OF
IDAHO POWER COMPANY
COMES NOW, 'l'he City of Boise (the "City"), and in response to ldaho I'ower
Compuny's First Productictn Request to the City of Boise, datedMay 20,2013, hereby submits
the following information:
REQUEST ,-NO. 1: On page 6, linc 4 Mr. Woods states, "It appears that this rate design
would in fact create a subsidy for a subset of net metering customers." Please in detail describe
the potcntial subsidy refbrenced by Mr. Woods. If possible, please provide a numerical cxample.
TTIE CIT-Y OF BOIST]'S RESPONSES 1'O THE FIRST
PRODI.ICTION REQUESTS OF IDAHO POWER COMPANY - I'age I
RBSPONSE TO REOUBST NO. l: As stated in the tcstimony and commented by
others in the public hearing, the proposed rate structure provides an incentive for large residential
customers from the existing residential class to move into the net metering class in a manner that
produces very little on-site electricity. Since fixed cost recovery in the existing non-net metering
residential class is accomplished via per kwh usage charges, the incentive for large residential
customers to move out of the residential class and into the net-metering class with minimal
investment in minimal electrical production reduces fixed cost recovery revenue in the
residential class without benefit to any customer in the residential class.
Under the proposed rate structure, net-zero customers will pay significantly more in
revenue to Idaho Power Company ("lPCo"), while low solar productionlhigh-use customers will
pay significantly less in revenue to IPCo. While this may be consistent with the statement by the
company that the net company impact is zero, it only provides incentives for low production
/high-use customers to continue with net metering service.
REOUEST NO. 2: On page 3,line 26, Mn Gilliam states, "The actions and changes
proposed by IPCO in this case are individually and collectively designed to make customer-sited
generation more difficult to install or more expensive to utilize, or both." Does the City of Boise
possess any statement fiom the Company regarding the intent of this filing as being designed to
accomplish the objective of making "customer-sited generation more difficult to install or more
expensive to utilize, or both?"
RESPONSE TO REOUEST NO. 2: The City of Boise does not possess a direct
statement from the Company; ncvertheless, examining the proposed policies and their outcomes
can lead one to conclude that the intent of the design was to make customer-sited generation
either more difficult to install or more expensive to utilize, or both. Charging a $100 application
fee for a minor system upgrade or zeroing out a customer's annual net excess energy without
compensation are two such examples.
THE CITY OF BOISE'S RESPONSES TO THE FIRS'I'
PRODUCTION REQUESTS OF IDAHO POWER COMPANY -Page2
RBOUEST N0.3: On page 24,line 10, Mr. Gilliam states. "A number of studies have
been performed around the country which compare the benefits provided by distributed solar
generation behind thc meter with the costs incurred by the host utility. In virtually all cases, the
benefits have exceeded the costs." Please provide the studies referenccd by Mr. Gilliarn that
substantiate this claim.
RESPONSE TO REOUEST NO. 3: The Vermont Public Service Board conducted an
evaluation of net metering which included a comprehensive lilerature review (available as Table
I in the following report to the Vermont legislature: http://publicservice.vermont.gov/sites
/psd/files/Topics/Renewable_EnergyAlet_Metering/Act%20125%205tudy%20201 30 i l5%o20;Fin
al.pdf). The process concluded with the Vermont Public Service Depanrnent stating that, "The
Dcpartment's general assessment is that Vermont's current net metering policy is a successful
aspect of State's overall energy strategy that is cost-effectively advancing the state's renewable
energy goals."
Within the literature review, nearly all the reports that examined both the costs and
benefits concluded that net metering's benefits exceeds its costs. ln the case of New York,
which has much lower solar installation than ldaho, the outcome was mixed, depending upon
future cost scenarios.
In addition, there have recently been studies conducted for Arizona, as well as New
Jersey and Pcnnsylvania. Both reports found net benefits associated with distributed generation
(http://www.solarfuturearizona.com/TheBcnefitsandCostso[SolarDistributedGenerationforAPS.p
df; http//seia.net/sitc/wp-content/uploads/2}|Z|O5/MSEIA-Final-Ilenefits-ol-Solar-Report-2012-
I I -01 .pd0.
TI'E CITY OF I}OISE'S RESPONSES TO THE T-IRST
PRODUCTION REQUESTS OF IDAHO POWER COMPANY - Page 3
REQUEST NO.4: On page 26,line 4, Mr, Gilliam states, "l[the benefits here in Idaho
are at all similar to those determined in other jurisdictions, it means that IPCo's current retail
rates are likely a fair approximation of the value of distributed generation, and potentially under-
compensating solar system owners. More specifically, it means that any perceived cost shift
from solar adopters to non-solar customers is more than compensated by the benefits of adding
new inoremental energy sources with the attributes derived from solar energy." Has the City of
Boise performed any analysis to substantiate this claim, or the applicability of Mr. Gilliam's
statement to Idaho Power's service area? If so, please provide this analysis.
ITESI'ONIE TO REOUEST NO. 4: No formal analysis was prepued by the City of
Boise; nor was one needed to substantiate the statement. The response to Request No. 3 cites
numerous reports that conclude customer-sited solar is a net benefit. The statement referred to
by IPCo in this request simply notes that if the conclusion of an Idaho specific study is at all
similar to the conclusions of the aforementioned reports, then retail net metering is "rough
justice" for ratepayers in ldaho. Indeed, the examination conducted by Tom Beach on behalf of
the Idaho Conservation League proved just this point. Mr. Beach's IPCo-specific study
contained in his testimony finds net benefits associated with the deployment of customer-sited
solar generation.
REOUEST NO. 5: On page 27, line 2, Mr. Gilliam states, "If IPCO's proposals are
approved, cunent net-metering customers will be paying substantially more than they had
planned." Please provide any analysis performed to substantiate this claim.
RPSPONSE TO REOUEST NO. 5: No analysis was performed; nor is a study needed
to arrive at the suggested conclusion. IPCo's proposals both reduce the energy charge which can
be offset by customer-sited solar and increase the flat monthly customer charge, which cannot be
offset by solar, as clearly seen in Larkin Exhibit 1. Further, customers are not compensated for
THE CITY OF BOISE'S RESPONSES TO THT: FITIST
PITODUCTION REQUISTS OF lDAllO POWER COMPANY -Page 4
annual net excess generation. If IPCo's proposals are implemented, net-metering customers as a
group will both pay more aud save less.
DATED At Boise, Idaho, this 7th day of June,2013.
THE CITV OF I}OISE'S RESPONSES TO THE FIRST
PRODUCTION REQUESTS OF IDAHO POWER COMPANY - Page 5
Respectfully Submitted,
. HAMMOND, JR.
Puscrr & AlnnnuAN, LLP
CERTIFICATB.QF SERVICE
I HEI{EBY CERTIFY That on this 7il'day of June,20l3,l caused a true and correct copy
of the foregoing to be served upon the fbllowing in the marmer indicated below:
COMMISSION STAFF
ItrX
truuIx
Jean Jewell, Commission Secretary n
Ioauo PueLrc UrrLrttrs CoutvtsstoN f,
472 W . Washinglon Street
P.O. Box 83720
Boise, Idaho 83720-0074
Karl K1ein, Deputy Attorney General
Iperto PusLrc UnLtrtrs Coutvttsstot t
472 W . Washington Street
P.O. Box 83720
Boise, Idaho 83720-0074
Lisa D. Nordstrom
Regulatory Dockets
IpeHo PoweR CoupeNv
1221 W. Idaho St.
P.O. Box 70
Boise,Idaho 83707
Matt Larkin
Greg Said
InaHo PowER CoupRNv
1221 W. Idaho St.
P.O. Box 70
Boise,Idaho 83707
Beqiamin J. Otto
7lo N. 6'h St.
Boise,Idaho 83701
Chris Aepelbacher, Project Director
PowTRWonKS LLC
5420 W. Wicher Rd.
Glenns Fery, Idaho 83623
Personal Delivery
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MPANYTDAHO POWER CO
trTilux
nnunx
ON I,EAGUEIDATIO CONStrRVATI
unntrE
POWBRWORKS r-r.c
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THE CITY OF BOISE'S RESPONSES TO THE FIRST
PRODUCTION REQUESTS OF IDAHO POWER COMPANY - Page 6
Peter J. Richardson
RrcuaRpsoN & O'LenRY
515 N.27'h St.
P.O. Box 7218
Boise,lD $7A2
John Steiner
24597 Collett Rd.
Oreana, ID 83650-5070
Ken Miller, Clean Energy Director
Sxnre RrvenAllleNcr
Box 1731
Boise, ID 83701
Dean J. Miller
McDrvtrr & Mlllnn t,lP
420W. Bannock St.
P.O. Box 2564-83701
Boise,lD 83702
Board of Directors
P.O. Box l2l2
Boise,ID 83701
Ionuo CleaN ENERov Assn.INc. t]
PIONEB WER, u,c
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SNAKE RTVER ALLIANCE
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IDAHO CLEAIY ENERGY ASSN.INC.
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THE CI'TY OF BOISE'S RESPONSES TO THE FIRST
PRODUCTION REQUESTS OF' IDAHO POWER COMPANY - Page 7