20030408_430.pdf

DECISION MEMORANDUM
TO:CO MMISSI 0 NER KJELLAND ER
COMMISSIONER SMITH
COMMISSIONER HANSEN
COMMISSION SECRETARY
COMMISSION STAFF
LEGAL
FROM:SCOTT WOODBURY
DATE:APRIL 3, 2003
RE:CASE NO. PAC-03-4 (PacifiCorp)
PETITION OF NORTHWEST ENERGY COALITION AND RENEWABLE
NORTHWEST PROJECT TO ESTABLISH NET METERING SCHEDULES
FOR P ACIFICORP
On February 27, 2003 , Northwest Energy Coalition and Renewable Northwest
Project petitioned the Idaho Public Utilities Commission (Commission) to initiate proceedings
. for the establishment of new net metering schedules for PacifiCorp dba Utah Power & Light
Company (PacifiCorp; Company) addressing 1) procedures, requirements and standards for the
interconnection and operation of small renewable electric generation systems by electric
customers of PacifiCorp; and 2) related provisions for billing such customers for the net of their
electric consumption less their generation.
Petitioner Northwest Energy Coalition is a non-profit organization which promotes
energy conservation and renewable energy resources, consumer and low-income protection. In
Idaho, the Coalition has 12 member organizations including Idaho Rural Council, Idaho Rivers
United, and the Idaho Community Action Association.
Petitioner Renewable Northwest Project is a non-profit organization which promotes
development of renewable energy sources, including wind, solar, and geothermal technologies in
Idaho, Oregon, Washington and Montana.
As represented, the Petition seeks to correct an imbalance of opportunity between
customers ofldaho s three major investor-owned utilities and their ability to install small electric
generation systems on their property and generate all or a portion of their electric needs, while
remaining interconnected with the electric grid. Petitioners note that the Commission has
DECISION MEMORANDUM
recently approved net metering schedules for Idaho Power Company (under Schedule 84) and
Avista (under Schedule 62). Reference (Idaho Power) Order Nos. 28951 and 29094; (Avista)
Order No. 28035. PacifiCorp has no approved schedule to regulate net metering. While
customers of PacifiCorp presumably could negotiate with the Company on a case-by-case basis
to install small renewable generation systems and receive payment for the generation under
PURP A, these customers, Petitioners contend, are at a disadvantage to similarly situated
customers of Idaho Power and Avista. Specifically, Petitioners contend that customers of
PacifiCorp have no assurance of what type of systems they could install, what interconnection
requirements will be required of them, and what rate they might be credited for electricity they
generate.
Petitioners believe that the new Schedule 84 for Idaho Power Company represents a
good model for PacifiCorp. In its Order approving Idaho Power s tariff, the Commission stated
all customers should be provided the opportunity to participate in net metering, including three-
phase systems and demand metered customers.Order No.28951 at 11; see also Order
No. 29094 (approving 100 kW nameplate capacity limitation for large commercial and irrigation
customers ofldaho Power).
Petitioners assert that the customer profile of PacifiCorp s service territory (with its
high irrigation loads) demands that a higher capacity limit be provided to large commercial and
irrigation customers as with Idaho Power s Schedule 84. However, as Petitioners discussed in
commenting on Idaho Power s proposed amendment to Schedule 84 (Case No. IPC-02-04),
the Petitioners support a billing methodology that credits excess monthly generation at the
customer s retail rate on a per kilowatt hour basis, and allows for a continuous carryover of such
credits.
PacifiCorp Answer and Proposed Net Metering Schedule
On March 20, 2003 , PacifiCorp filed its Answer to the Petition and a Request for
Approval of Proposed Electric Service Schedule No. 135 , Net Metering Service. PacifiCorp
states that the Company was in the process of developing such a schedule in response to the
perceived desire for net metering in Idaho.
PacifiCorp agrees that Idaho Power s Schedule 84 represents a good model for
PacifiCorp and contends that its proposed Electric Service Schedule No. 135 is patterned after
Idaho Power Company s Schedule 84.
DECISION MEMORANDUM
Consistent with Idaho Power s Schedule 84, PacifiCorp s proposed Schedule No. 135
provides a capacity limit of 100 k W for large commercial and irrigation customers, and 25 k W
for customers taking service on electric service schedules applicable to residential and small
commercial customers (Schedules 1 23 and 23A).
While PacifiCorp proposes to credit residential and small commercial customers for
excess generation at the customer s retail rate, PacifiCorp opposes such an approach for larger
commercial irrigation customers and proposes that the larger customers be credited an amount
equal to 85% of the Dow Jones Mid-C Index Price for non-firm energy. Such an approach, the
Company contends, is intended to avoid the subsidy that would exist by paying full retail rates.
The proposed Schedule No. 135 provides that the costs associated with
interconnection of the customer s generating facility with the Company system, including the
cost of any additional metering necessary for service under the schedule, will be paid by the
customer. This requirement, the Company contends, will help avoid other customers subsidizing
net metering customers.
Similar to Idaho Power s Schedule 84, PacifiCorp proposes that Schedule 135 be
available on a first come, first service basis, until the total rated generated capacity of net
metering systems connected under the Schedule equal 714 kW, which is 1/10th of 1% of the
Company s Idaho retail peak demand in 2002. Further, in order to make these schedules
available to a wider range of customers, the Company proposes that no single customer may
connect more than 20% of the total nameplate capacity connected under the schedule.
PacifiCorp proposes that credits for excess generation be provided each month, rather
than allowing for carryover or "banking.Providing a credit each month, the Company
contends, appropriately recognizes the different values of energy during the different months of
the year, therefore mitigating subsidization of large commercial and irrigation net-metering
customers, which credits are based on market prices.
PacifiCorp requests that the matter be processed under Modified Procedure pursuant
to Commission Rule 20 I et seq.
Commission Decision
PacifiCorp has responded to the Petition of Northwest Energy Coalition and
Renewable Northwest Project by filing a proposed Net Metering tariff, Electric Service Schedule
No. 135. Staff recommends that the Petition and the Company s proposed Net Metering tariff be
DECISION MEMORANDUM
processed pursuant to Modified Procedure, i., by written comment rather than by hearing.
Does the Commission agree with the proposed procedure?
Scott Woodbury
VldJM:PACEO304
DECISION MEMORANDUM