20161121_5121.pdf

DECISION MEMORANDUM
TO:COMMISSIONER KJELLANDER
COMMISSIONER RAPER
COMMISSIONER ANDERSON
COMMISSION SECRETARY
LEGAL
WORKING FILE
FROM:MARK ROGERS
DATE:NOVEMBER 15,2016
SUBJECT:IDAHO POWER COMPANY’S TARIFF ADVICE NO.16-05;
MODIFICATIONS TO SCHEDULE 84-CUSTOMER ENERGY
PRODUCTION NET METERING SERVICE.
On October 19,2016,Idaho Power Company (“Idaho Power”)filed a Tariff Advice with
the Idaho Public Utilities Commission (“Commission”)to revise its Tariff Schedule 84—
Customer Energy Production Net Metering Service,with an effective date of November 18,
2016.On November 10,2016,the Company filed a supplement to the Tariff Advice moving the
effective date to November 22,2016.As Schedule 84 is currently written.Schedules 9,19 and
24 customers are required to meter their Generation Facility’s production through a second meter
adjacent to the customer’s Point of Delivery at the same voltage as the retail meter required to
measure and bill consumption.When Schedule 84 was designed it was not considered that a
customer may in fact want to meter from a location other than adjacent to their Point of Delivery.
However,by doing so,the costs for these customers to participate in net metering could be
reduced.In this Tariff Advice,Idaho Power proposes to modify the requirements of the second
meter’s location and voltage to reduce barriers to participation for the aforementioned customer
classes.
BACKGROUND
Idaho Power’s Schedule 84 is available throughout the Company’s service territory
within the State of Idaho for customers intending to operate Net Metering Systems to generate
electricity to reduce all or part of their monthly energy usage.As stated,Schedule 9,19 and 24
DECISION MEMORANDUM 1 November 15,2016
customers are required to meter their facility’s production through a second meter adjacent to the
customer’s Point of Delivery,at the same voltage as the retail meter required to measure and bill
consumption.To comply with these requirements.certain customers from these Schedules
would incur large and unnecessan’costs that are currently limiting their participation in net
metering.According to the Company,it has received inquiries from customers who want to
install net metering systems,but find compliance with the existing metering equipment to be cost
prohibitive.Consequently,the Company has reevaluated its existing tariff and now proposes to
modify the requirements regarding the location and voltage of the required second meter.As
stated by the Company,the modification will simply allow Idaho Power the flexibility to reduce
the cost responsibility for the potential net metering customer,and it is not expected to result in
any incremental or increased costs borne by the Company or non-participants.
STAFF ANALYSIS
Staff reviewed the Company’s Tariff Advice and believes the proposed modifications are
reasonable.Staff will address issues with the current tariff in more detail below,specifically
with respect to the second meter’s location and voltage,and the impacts to Schedules 9,19 and
24.
Of the Company’s 320 Primary Service customers under Schedules 9 and 19,only five
are enrolled in net metering.Part of the reason for the low participation is that the current tariff
requires the installation of a second meter adjacent to the customer’s Point of Delivery if the
facility exceeds 25 kW in size.Furthermore,the second meter must measure generation at the
same voltage as the retail meter.Since customers taking Primary Service under Schedule 9 and
19 generally have campuses spread over a large area,the Point of Delivery for Primary Service
could be a significant distance from where the Generating Facility site would be located.In the
case of one customer interested in additional net metering,its Point of Delivery is a Primary
Voltage location on its campus nearly four city blocks away from the Generating Facility.
Consequently,the cost to install the second meter at the customer’s Point of Delivery with line
extensions to the Generating Facility could be as expensive as $6.25 per watt;nearly three times
the total installed cost per watt of a typical net metering facility.
The proposed tariff changes mitigate unnecessary installation costs by allowing the
Company discretion in determining whether the second meter would be located adjacent to,or on
DECISION MEMORANDUM 2 November 15,2016
the customer’s side of the Point of Delivery.In the event that the meter is on the customer’s side
of the Point of Delivery,the new Generation Interconnection Point will most likely be on a
Secondary Voltage line.In this case,the meter would not be reading at the same Primary
Voltage as the retail meter,but rather at the Secondary Voltage of the distribution system.
Therefore,the requirement to change the metering voltage must be modified to coincide with the
change of the meter’s location.
Staff inquired into what effect these modifications would have on Schedule 24 customers,
as this Schedule does not have a Primary Sen’ice option.As the Tariff is written,any customer
participating in net metering that is not taking service under Schedules 1,4,5 or 7 would be
required to install the second meter.Given that these customers would potentially have two
meters,the possibility of moving the second meter onto a customer’s side of the Point of
Delivery is still possible;however,it would most likely be measuring at the same voltage as the
retail meter.
Staff further inquired about whether there could be any metering or operational issues
that could occur from moving the location and changing the voltage of the second meter.The
Company informed Staff that it is capable of accurately measuring the Generating Facility’s
output regardless of whether or not it is located on a Primary or Secondary Service line,and
regardless of whether or not it is located adjacent to the Point of Delivery.After reviewing the
Company’s Application,Staff believes that the proposed changes are reasonable.
STAFF RECOMMENDATION
Staff has reviewed the Company’s revised tariff and believes the modifications
adequately remove the aforementioned barriers to Schedule 84 participation for customers taking
service under Schedules 9,19 and 24.Staff recommends approval of the revised tariff as filed.
DECISION MEMORANDUM 3 November 15,2016
COMMISSION DECISION
Does the Commission wish to approve Idaho Power’s proposed changes to its Tariff
Schedule 84 —Customer Energy Production Net Metering Service,with an effective date of
November 22,2016?
udmemos/NEM Tariff Advice—16-OS
DECISION MEMORANDUM 4 November 15,2016