20011221DWR Comments_1.pdf

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State of Idahgrcrrvro EI
DEPARTN/IBFM OF UATTR RESOURCES
1301 North Orcha4fifitffi,ppispfl:80706 - P.O. Box 83720, Boise, ID 83720-0098
Phone: [phone]Ub I'ek-(ZOB) fzz-7C6e Web Site: wrwv.idwr.state.id.us
.-r i li-lT i LS C0fiHlSSI Slt DIRKKEMPTHORNE
Governor
KARLJ. DREHER
DirectorDecember 21,200t
The Idaho Public Utilities Commission
47 2 W . Washington Street
Boise, D 83702-5983
Re:Case No. IPC-E-01-39
Application of Idaho Power Company for Approval of a New Tariff Schedule 84 - Net
Metering
The Idaho Department of Water Resources Energy Division submits the following comments
concerning the above-mentioned case.
The Idaho Energy Division recommends consideration by both the Idaho Public Utilities
Commission and Idaho Power of modification of the proposed net-metering in three areas:
eligible customer classes, individual project size limit and total Idaho Power system limit.
Elieible Customers
Idaho Power's net-metenng tariff proposal covers only Schedule 1 (Residential) and Schedule 7
(Small General Service) customers. Net-metering also has potential application for the
agricultural sector including the dairy operations with anaerobic digestion that could potentially
produce power from methane and wind power opportunities. Typically these agricultural users
fall under the Idaho Power's Schedule 9 (Large General Service) and Schedule 24 (Irrigation
Service). The net-metering proposal excludes these classes. The net-metering case should take
into consideration these customer classes. We are aware that the rate schedule for irrigation
service may pose some problems in billing because demand charges are included in the
calculation of total energy costs. An alternative might be to develop simplified power sales
agreements specifically for Schedule 9 and Schedule 24 power producers.
System Size Limitations
The proposed tariff sets a limit on the generation facility of 25 kW of nameplate capacity or less
For residential (Schedule 1) and small commercial sectors (Schedule 7), we believe this limit to
be appropriate.
For other tariffs (e.g. inigation), we believe it should be set higher than 25 kW. For example,
some aggregated irrigation loads could be as high as 8,000 kW. The average size of irrigation
pump tested by the Idaho Energy Division in previous years within the Idaho Power service area
is approximately 150 hp (112 kW).
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Additionally, the size limit of 25 kW also has no relevance to economies of scale for wind power
generation. The cost per unit of rated output for a25 kW turbine can be as much as be three
times the cost for a 660 kW turbine. Wind power generation at the larger scales compatible with
electricity loads of Idaho irrigators are more likely to be cost effective. We recommend that
consideration of a larger size limit for customers not in schedule I and 7 be investigated.
Limit on Overall Enrollment
Idaho Power is proposing a net-metering service available on a first come, first serve basis until
the cumulative generation nameplate capacity connected equals 2.9 MW. This limit is based on
applying 1/l0th of lVo (O.LVo) of the company's retail peak demand for year 2000. The company
contends this is an industry standard. We recommend that the commission stipulate that when
this limit is reached, it should be reviewed to determine if it should be raised.
Thank you for the opportunity to comment.
Sincerely,
ht.rw
HOPPIEROBERT W.
Administrator
Energy Division
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