20011221Comments.doc

SCOTT WOODBURY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 1895

Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983

Attorney for the Commission Staff

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF THE APPLICATION OF IDAHO POWER COMPANY TO AMEND SCHEDULE 72—INTERCONNECTIONS TO NON-UTILITY GENERATION. )
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CASE NO. IPC-E-01-38

COMMENTS OF THE
COMMISSION STAFF

COMES NOW the Staff of the Idaho Public Utilities Commission, by and through its Attorney of record, Scott Woodbury, Deputy Attorney General, and in response to the Notice of Application, Notice of Modified Procedure and Notice of Comment Deadline/Protest Deadline issued on November 23, 2001, submits the following comments.
On April 12, 1991, the Commission issued Order No. 23631 approving the current tariff Schedule 72. Since approval of Schedule 72 in 1991, Idaho Power states that it has continued to review its generation interconnection practices and has determined that it would be beneficial to modify Schedule 72 to bring the Schedule into conformance with current standards of best utility practices for non-utility generation interconnection. The purpose of these proposed changes, the Company states, is to provide a template for non-utility generation interconnection that provides a safe, economic and reliable interconnection while at the same time ensuring that Idaho Power’s other customers do not subsidize the costs associated with non-utility generation interconnections.
Description of Changes
Over the years, Idaho Power states that it has gained substantial experience in interconnecting both small and large non-utility generating facilities. Idaho Power’s experience gained by interconnecting non-utility generation projects of varying sizes from the extremely small (300 watts) to the moderately large (10 MW) has led Idaho Power to propose that Schedule 72 be amended to accommodate a range of interconnection requirements with increasing levels of sophistication depending on the size of the generating facility. As a result, the Company is proposing a simple interconnection process for net metering projects, and a more streamlined and simple interconnection process for projects 100 kWs and smaller. Projects greater than 100 kWs and less than 1 MW and projects 1 MW and greater will be required to comply with more complex interconnection standards.

Staff Analysis
One of the primary objectives of an interconnection policy for non-utility generation is to insure that a safe, reliable electrical system is maintained. The proposed Schedule 72 interconnection policy requires customer generators to pay for any necessary equipment, modifications and upgrades to insure safety and reliability. The policy requires submission of designs, plans and specifications; proof that all required permits, licenses, inspections and approvals have been obtained; proof that adequate protective and disconnection equipment has been installed; and spells out other provisions regarding ownership, operation, maintenance, and inspection of necessary equipment.
Idaho Power’s objective in revising the existing interconnection policy is to simplify the interconnection requirements for very small generation facilities and for net metering installations. Staff believes that for the most part, the proposed revisions to the interconnection policy accomplish that objective.
However, one area in which Staff does have some concerns is the requirement for net metering systems for annual certifications from an independent qualified party licensed in the State of Idaho, certifying that the generation facility and equipment are in compliance with all current applicable electrical and safety codes and are able to safely and reliably continue to operate. Staff certainly agrees in principle that periodic inspections and certifications are important, especially for larger generation facilities. However, Staff believes that annual inspections and certifications may be excessive for net metering systems smaller than 25 kW. Staff contends that such frequent inspections for such small systems could potentially encourage even less rigorous compliance with electrical and safety codes. The cost of an annual certification for very small systems would be a significant expense compared to the value of the energy produced by the system over the course of a year. Inspections could become less thorough if they become too routine.
As an alternative, Staff recommends that certification for net metering systems be required of customer generators only once every three years, and whenever any material modifications or additions are made to equipment. However, Staff also recommends that Idaho Power be permitted to perform inspections of disconnection and protective equipment at whatever intervals it chooses using its own personnel or by hiring qualified persons at its own expense. Because Idaho Power must protect the integrity of its own system and insure its safety, Staff believes the Company must not relegate complete responsibility for interconnection safety to customer generators and the inspectors they choose to hire. Schedule 72, as drafted, already includes a provision requiring customers to submit designs, plans, specifications and performance data for their generation facility. It also already contains a provision for Idaho Power to retain the right to inspect customer’s equipment at its discretion.

Staff Recommendations
Staff recommends that the Commission approve Idaho Power’s Application to Amend Schedule 72—Interconnections to Non-Utility Generation. However, Staff recommends that the requirement for annual certifications for net metering systems be on a two-year interval instead of annually.

Respectively submitted this day of December 2001.

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Scott Woodbury
Deputy Attorney General

Technical Staff: Rick Sterling

SW:RS:i/umisc/comments/ipce01.38swrps
STAFF COMMENTS 3 DECEMBER 21, 2001