20141121SRA Comments.pdf

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November 21,2014
To: Idaho Public Utilities Commission
From: Ken Miller, Clean Enerry Program Director, Snake River Alliance
Re: Snake River Alliance Comments In the Matter of the Application of Avista Corporation for the Request
to Use Available Funds From Schedule 95 to Promote Rooftop Solar Installations on Commercial
Buildings, Case No. AVU-E-14-10.
On behalf of our members throughout Avista Utilities' Idaho service area, the Snake River Alliance
appreciates the opportunity to provide its comments on the above-referenced case, filed with the
Commission on Sept. t7,20L4. These comments are submitted to the Commission in response to its
Notice of Application and Order No. 33151.
In its application, Avista requests approval "to use, when available, funds from Schedule 95 Optional
Renewable Power Rate to promote grants for rooftop solar installations, 20 kW or smaller, on
commercial buildings in Idaho." The Alliance wholeheartedly supports Avista's application and
congratulates Avista's initiative to promote the installation of clean, renewable energy in Idaho. We urge
the Commission to approve the application.
Since 2002,Avista's Schedule 95 Optional Wind Power Rate allows its Idaho customers to purchase
blocks of renewable power through its "Buck-a-Block" program. The program enables customers to
purchase blocks of wind power for $1 a block (55 kilowatt hours). The program was revised in 2004
from an Optional Wind Power Rate to an Optional Renewable Power Rate, raising each block from 55
kWh of renewable energyto 300 kwh.
Over time, as customer participation leveled off and the cost of RECs declined, the program's surplus
revenues exceeded costs by about $200,000, prompting Avista to seek additional avenues to promote and
secure additional energy for the "Buck-a-Block" program. The result is this application, which would
permit Avista to use additional Schedule 95 funds, when they are available, to offer grants for rooftop
solar photovoltaic systems of 20 kilowatts or smaller.
The renewable energy generation, which Avista says comes primarily from the Stateline Wind Energy
Box425 | Pocarruo,lD 83204 | 2C8.2337212
M,IM,.SNAKERIVERALLIANCE.OHG
Box1731 | Borsr,lD 83701 | 2C8.344.9161
Center, is represented by renewable energy certificates (RECs, or "green tags"). Avista reports that in
20!3, approximately 3,500 customers purchased nearly 227,000 blocks, representing 68,000 MWh.
In exchange for grants to finance some or all of a solar PV system, recipients "would agree to allow their
installation to be made available for the education of its building occupants and members of the
community." A priority for grants would be school districts and buildings "where the visibility of the
installation will have the greatest impact for both educational purposes as well as soar energy
generation." So the grant program is a win-win: Avista and its grant recipients will help promote solar
power, and net-metered recipients also benefit from the financial value of the new solar generation
through lower power bills.
The Alliance agrees with Avista that another benefit from the program will be to help the utility better
understand how additional solar power fits into its overall system. "Additional program benefits may
include the increased availability and potential reduced cost of solar equipment, as well as providing a
utility experience with the installation of small scale distributed generation on a potentially diverse
group of buildings and geographic locations in ldaho and Washington."
The Alliance is a strong advocate of additional renewable energy and energy efficiency acquisitions by
Idaho's regulated electric utilities. Inasmuch as this proposal would assist Avista's efforts to publicize
renewable energy and add more renewable energy to its portfolio, we are grateful that Avista developed
such an innovative program that will help advance the 20L2ldaho Energy Plan's stated goals of
promoting renewable enerry in its diverse forms.
The Alliance once again appreciates the opportunity to recommend approval of Avista's application.
Respectfully submitted,
Ken Miller
Clean Energy Program Director
Snake River Alliance
P.O. Bo 1731
Boise,lD 83701
(208) 344-et6t
[e-mail]
Hand Delivered
fean fewell
Commission Secretary
Idaho Public Utilities Commission
472W. Washington St.
Boise,lD 83702
Via E-Mail
David I Meyer, Esq.
Vice President and Chidf Counsel for Regulatory and GovernmentAffairs
Avista Corporation
74Ll E. Mission Avenue, MSC-13
Spokane, WA99220-3727
E-mail : [e-mail]
Linda Gervais
Manager, Regulatory Poliry
Avista Corporation
t4ll E. Mission Avenue, MSC-13
Spokane, WA99220-3727
E-mail: [e-mail]