20011219Farm Bureau Comments_1.pdf

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IDAHOFARMI
P.O. Box I
Botse, tdaho B3Z0i-0167. [phone]
FAX (208) 342{585
Decembet 17,2001
Ms. Jean D. Jewell
ldaho Public Utilities Commission
472 W . Washington
P.O. Box 83720
Boise, !D 83720-0074
RE: Case No. !PC-E-01-39 ldaho Power Company's Application for Approval of a
New Schedule 84 - Net Metering
Dear Ms. Jewell:
The ldaho Farm Bureau Federation representing more than 52,700 member ldaho
families has reviewed ldaho Power Company's application regarding Net Metering and
wish to submit the following comments regarding the application.
Schedule 84, Net Metering and the related Schedule 86 and Schedule 72 are all vita!
elements of co-generation of electrical power in the state and for assisting public
utilities meet the rapid expansion of electrical power needs in a rapidly growing area like
ldaho. We feel strongly that innovative approaches to electrical generation must be
encouraged by a proper rate structure, tax incentives and a supportive public utility as
well as a public utility commission that recognizes that energy needs, environmental
needs and innovation must be blended together to the benefit of all of society.
ln ldaho Power's application we do not understand the 2.9 megawatt limit the company
is seeking and representing as something that is considered an industry standard. ln
recent history industry standard for purchase of electricity meant nothing as wholesale
energy costs soared through the ceiling and customers were left with bills that certainly
wrenched the family over any kind of energy standard cost that we had ever envisioned.
We also do not understand why schedule 24 was omitted, for under that schedule all of
the irrigation pumpers are included. This effectively eliminates a segment of ldaho
Agriculture that is most critica! to include for they are the large electrical users that are
most likely to invest in co-generation facilities. lf we are to weather such energy crises
in the future, it appears to the ldaho Farm Bureau Federation that we need industry
standards that recognize volatility in the oil and gas market plus droughts and wib
fluctuations in demand could lead to a repeat performance of what we have just
experienced and would not care to experience again. ldaho has the potentialto head
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off such crises with wind power, bio generation and other co-generation possibilities but
cannot accomplish much with such a stringent limit to such generation.
Many of our members are high use customers for the pump irrigation needs of their
farms. These members also have land suitable for wind farms, but limiting net metering
to schedule 1 and 7 customers would seem to preclude such generation for their own
needs as well as supplying the electrical grid. We are also aware that a smaller wind
generation unit is being introduced into the state that will supply electricity to individual
customers and they too would like to otfset some of their electrical consumption with
net metering. ln addition we have many dairies in the state that could generate
considerable electricity from digesters that would offset much of their annual usage of
commercial electricity but the proposal of ldaho Power seems so limiting that most of
these ideas could not be brought on line.
The purpose of net metering is to allow ldaho Power customers to make use of their
own renewable energy resources. Unfortunately !PC-E-01-30 limits the process so
severely that it simply eliminates the possibility. Many irrigation customers use more
than 25kW which is the limit per customer proposed in this rule. The ldaho Farm
Bureau Federation requests that there not be an upper limit, for most of the large
irrigators exceed the 25kW limit and almost alldairies of 1000 cows or more will exceed
the limit if they go to bio-generation.
ldaho is a rapidly growing dairy state with this industry now the largest agriculture
industry in the state. Environmentally, large dairies are having trouble handling waste
and are under immense pressure to improve waste management on the dairy. One of
the innovative ways they can handle waste and mostly eliminate noxious lagoon odors
is to divert the waste to bio-generators and convert the waste to methane that is burned
and drives turbines that generate electricity. Net metering would drive this process and
is severely needed, but IPC-E-01-30 does not support this important process or this
critica! industry. ldaho Farm Bureau recommends that this proposal be modified to be
of beneflt to the bio generation industry and assist in solving the energy needs of the
area as well as assist in solving the environmental problems associated with high solid
lagoon operations. Odor problems at the dairy can be solved, but it will take the
cooperation of public utilities to bring the process into an affordable scenario.
The ldaho Farm Bureau Federation also recommends that the PUC establish
guidelines and rules to support net metering on a yearly basis. We note that ldaho
Power only discusses monthly net metering, but most co-generation facilities need
consideration for both the productive months and less productive months to be
accounted on a yearly basis. The results to ldaho Power would be the same, but the
end result to the generator would eliminate the fluctuations of winter non use, summer
high level of irrigation demand and windy vs non-windy fluctuations. Many states have
net-yearly metering as a part of their regulated industry and we would recommend that
ldaho adopt such a program.
ln closing, it appears that net-metering is a process that can stimulate a win-win
scenario for ldaho Power and for individual generators as well as supply a reliable
source of renewable energy to the grid. This proposal is entirely too limiting to stimulate
any increase in co-generation and the ldaho Farm Bureau Federation would
recommend that the Public Utility Commission modify this proposalto allow more and
broader use by farmers in ldaho as well as individual homeowners.
Thank you for allowing us to comment on this extremely important conceptual proposal
and please keep us included in any decisions, discussions or hearings regarding this
issue. lt is of vital concern to the farming community in ldaho.
Sincerely,[ry
Frank Priestley, President
ldaho Farm Bureau Federation
C: IFBF Officers, Directors & Staff
County Presidents
Governor Dirk Kempthorne
ldaho Dept. of Water Resources
IFBF Dairy Committee
United Dairymen of ldaho
Milk Producers of ldaho
Idaho Dept. of Agriculture
Idaho Dept. of Environmental Quality
ldaho Power CompanY