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HomeMy WebLinkAbout20020510Consumer Comments.pdfJeanJevvell From:Ed Howell Sent:Friday,May 10,2002 5:51 PMTo:Jean Jewell;Ed Howell;Gene Fadness;Tonya Clark Subject:Commentacknowledgement WWW Form Submission: Friday,May 10,2002 4:51:28 PM Case:IPC-E-02-04 Name:Kristy Webb Street Address:2158 Addison Ave.E.City:Twin Falls State:Idaho ZIP:83301Home_Telephone:(208)733-1769 E-Mail:crw@magiclink.comCompany:Idaho Powermailinglistyesno:yes Comment description:Idaho Rural Council P.O.Box 118Bliss,Idaho 83314 Idaho Public Utility Commission via e-mail Re:Comments on Idaho Power Company?s Net Metering Tariff Case Number IPC-E-02-04 Dear Commissioners: The Idaho Rural Council supports net metering.We believe that it is an investment in Idaho?s future and an important first step in developing renewable energy. It also encourages distributed generation.We believe renewable energy and distributedgenerationhaveimportantenergy,economic and environmental benefits for Idaho. Unfortunately,Idaho Power Company?s Proposed Net Metering Tariff falls seriously short of providing Idaho and its customers the full benefits of net metering. Idaho Power?s proposal discriminates against irrigators. Idaho Power?s proposal would give small commercial and residential customers credit for energy generated and provided to the company for an indefinite period of time (an indefinite carryover). Idaho Power?s proposal would give irrigators credit for energy generated and provided to the company only for the month it was produced (a monthly billing period forirrigators).Irrigators will be paid for energy in excess of the power consumed in aparticularmonthat85%of the market price for non-firm energy in the Pacific Northwest - a small fraction of what irrigators pay Idaho Power for the energy they use. The proposal is particularly disadvantageous for irrigators because they will probably produce power primarily in months they do not irrigate. The Idaho Rural Council recommends that Idaho Power?s net metering tariff forirrigatorsuseeither:1)the indefinite carryover Idaho Power had proposed for small commercial and residential customers or 2)an annual billing period. Idaho Power?s proposal discriminates against wind power. 1 Idaho Power?s proposal allows net metering on electrical generators with a name platecapacityofnomorethan100kW. Idaho Power?s small ?name plate capacity?proposal precludes most efficient wild turbines.The proposal discourages the use of wind power for net metering. The Idaho Rural Council recommends that Idaho Power?s net metering tariff allowgeneratorswithanameplatecapacityof300kW.This will allow customers to use small, but efficient wind turbines. Idaho Power?s proposal should include fair and consistent interconnection standards The absence of clear,consistent,and fair interconnection standards will discourage customers from availing themselves of net metering.Customers need to know what it interconnection will cost when deciding whether to generate power for net metering.Clear and consistent interconnection standards assures customers of nondiscriminatory access to the net metering tariff.Clear and consistent interconnection standards would also give the Commission a better opportunity to estimate how many customers can realisticallyparticipateinnetmetering. The Idaho Rural Council does not have the expertise necessary to suggest detailed interconnection standards.We believe that the Commission should require Idaho Power Company to prepare these standards.The proposed standards can then be submitted to the Commission and the public for comment. A clear,consistent and fair set of interconnection standards are essential to a successful net metering program. Conclusion A strong net metering tariff from Idaho Power Company would encourage renewable energyanddistributedenergyproductionisIdaho.Unfortunately,Idaho Power Company?s proposal falls far short of taking advantage of the potential for net metering in Idaho.We encourage the Idaho Public Utility Commission to require Idaho Power to amend its netmeteringtarifftomorefullyrealizethepotentialofnetmetering. Thank you for considering our comments. Kristy WebbPresident,Idaho Rural Council Transaction ID:5101651.28Referredby:http://www.puc.state.id.us/scripts/polyform.dll/ipuc User Address:67.234.149.90 User Hostname:67.234.149.90 2 Jean Jewell L From:Ed Howell Sent:Monday,May 06,2002 11:47 AM To:Jean Jewell;Ed Howell;Gene Fadness;Tonya ClarkSubject:Comment acknowledgement WWW Form Submission: Monday,May 06,200210:47:09 AM Case:IPC-E-02-04 Name:Bill Chisholm,IRC Energy CoordinatorStreet_Address:19073E Hwy 30City:Buhl State:Idaho ZIP:83316Home_Telephone:208-543-4418 E-Mail:chisholm3@mindspring.com Company:Idaho Power Companymailinglistyesno:yesComment_description:May 6,2002 Bill Chisholm,Energy Coordinator Idaho Rural Council19073EHwy30Buhl,Idaho 83316 Idaho Public Utilities Commission 472 Washington St.Boise,Idaho 83720 Comments:IPC-E-02-04 While the Idaho Rural Council is encouraged by the expanded net meteringopportunitiesbeingofferedtoallclassesofcustomersbythisfiling;we are deeply concerned with the 2.9 Mega watt limit being imposed.Net metering presents anopportunityforIdahoPowercustomerstoinvesttheirenergydollars,not merely spend them.These investments are not merely economic investment opportunities,but environmental and security investment opportunities as well. Albert Einstein said,'We cannot solve our problems at the same level of thinking at which we created them."The recent energy crisis and future energy crises will come about because we have failed to change our level of thinking,to invest in solutions.It isgoingtotakesometimetogetuptospeed,to make net metering a viable reality,but while that is true setting our sights so low at the 2.9 Mega watt level,which could be eaten up by big operators before the infrastructure is in place to make it more available to residential,small business and smaller agricultural operations would discourageparticipation.We therefore urge the Idaho Public Utilities Commission to set the netmeteringlimit,if a limit is even needed at 10%of Idaho Power's load.We need to encourage,not discourage distributed electrical production along with conservation and energy efficiency.That is the kind of thinking that will prevent future energy crisis and the kind of socio-economic and environmental upheaval that we have recentlyexperienced. Submitted by, Bill ChisholmEnergyCoordinatorIdahoRuralCouncil Transaction ID:561047.9 Referred by:http://www.puc.state.id.us/scripts/polyform.dll/ipuc 1 Jean Jevvell From:Ed Howell Sent:Thursday,May 09,2002 11:56 AM To:Jean Jewell;Ed Howell;Gene Fadness;Tonya Clark Subject:Commentacknowledgement WWW Form Submission: Thursday,May 09,200210:55:30 AM Case:IPC-E-02-04 Name:Bill Chisholm,IRC-Energy CoordinatorStreet_Address:19073E Hwy 30City:Buhl State:Idaho ZIP:83316 Home Telephone:208-543-4418E-Mail:chisholm#@mindspring.com Company:Idaho Power Companymailinglistyesno:yes Comment description:May 9,2002 Bill ChisholmEnergyCoordinator Idaho Rural Council19073EHwy30Buhl,Idaho 83316 Idaho Public Utilities Commission P.O.Box 83720Boise,Idaho 83720-0074 Additional Comments:IPC-E-02-04 These additional comments expand the previous comments submitted by the Idaho Rural Council on this matter.Net metering does not only present an opportunity for the individual customer to benefit by the investment of their energy dollars in a renewable net metering project;all Idaho Power rate payers benefit by the stability andsustainabilitythatwillcomeaboutwithamorediverseanddistributedrenewable energyproductionbase. In addition to the previous comments regarding the 2.9 Mega-watt cap suggested by Idaho Power,which we believe should be raised to 10%of their projected needs,we believe that in order to move net metering along,individual cap sizes,particularly foragriculturalprojectsshouldberaisedaswell.Net metering projects need to have the economic incentives in them that encourage investment.So for irrigators the cap shouldberaisedfrom100kwto300kwandputonanannual,rather that a monthly true up.(See the attached work sheet) We appreciate the opportunity to be a part of this process. Sincerely,Bill ChisholmEnergyCoordinator Idaho Rural Council Calculation of Needed Wind Capacity to balance annual power costsunderIdahoPower's net metering proposal for irrigation Enter your specific information in the blue cells Annual Power Cost 1 Irrigation Pump Horsepower 100Operatingtimehour/year 2,000 kWh used by Irrigation Pwnp 165,778 Number of months of operation 6 Customer charge per meter per month/in season $10.07 Customer charge per meter per month/out of season $2.50 Demand Charge $/kW in season $3.58 Annual customer charge $75 Pump startup excess -power use during system startup 25%Billed demand kW 104Monthlydemandcharge $371 Annual demand charge $2,226 In season energy rate $0.045657 Annual energy charge $7,569 Total Power Bill $9,794 Annual Power Sales Percent of power generated that is net metered 12% Percent of power sold at 85%of Mid C rate 88% Sales price net metered $0.045657 Mid Columbia rate $0.021Averagesalespriceper kWh $0.023959 Number of kWh needed to be generated to balance bill 408,805Windcapacityfactor%15%Average hours at rated capacity 1,314SizeofturbineneededkW311Dollarsofincomefrompowergeneration $9,794 Transaction ID:591055.30 Referred by:http://www.puc.state.id.us/scripts/polyform.dll/ipuc User Address:67.234.149.98 User Hostname:67.234.149.98 2 Jean Jewell From:Ed Howell Sent:Monday,May 06,2002 3:56 PM To:Jean Jewell;Ed Howell;Gene Fadness;Tonya ClarkSubject:Comment acknowledgement WWW Form Submission: Monday,May 06,20022:56:20 PM Case:IPC-E-02-04 Name:Dan Hennis Street Address:2792 Desert Wind RDCity:Mtn.Home State:Idaho ZIP:83647-5020Home_Telephone:(208)796-2747 E-Mail:D.M.Hennis@juno.com Company:mailing list yes no:yesComment_description:Comments for Net-Metering In "the real world" 1)I agree with the comment made that,"Wind power is no more non-firm than hydro"in that in our day-and-age our Met.people do quite well at forecasting both short and long range trends,(El Nino &La Nina). 2)We really don't have any State approved definitions of wind farms,sizes,registrations,(USDA or?),expectations,etc. 3)I join with the hundreds of people who have come to my little farm,to ask that wind power not just be allowed in Idaho,but be strongly encouraged through either realistic Renewables Portfolio or state production tax credits .that match federal production tax credits.A Quarter or a Dollar a month is well worth it to have clean,cheap power,with hydro put into more reserves.At the risk of sounding like a Democrat,perhaps a tax of that amount could go to a grant/loan program to help foster wind power projects in Idaho. I know I would jump at a chance to get a low-interest State grant/loan to purchase turbines.Perhaps the program could be similar to the money Oregon has lent out to help the intermediate and large net-meterers to get started.In just one year,we could be well on our way to as much as 5Mw of wind projects across southern Idaho alone.Just think of the added revenues that would be gained in state with a few intermediate windplantsbeinginstalledandifoutdamswerefull.Fish and wild life would prosper and recreation would boom as well as increasing development on a stable healthy scale.In full view of our entire State energy plan,it is a "must"to marry wind and hydro.Winds are best in the spring and fall whereas,Hydro is best used in summer and winter,with reserves for those rare windless anomalies.It is common knowledge that hydro plants work far more efficiently at a fuller level.This is not "eye wash,"these are facts! 4)I ask again,why is one of our most valuable State offices shoved into the corner of a related office and stunted from being able to take the action that is needed?!?In other words,why isn't there a "State Department of (Renewable)Energy,"instead of an after-thought office in the IDWR?!?Isn't Idaho's Energy Resources important enough to warrant an office with the power to help Idaho's power needs?!?! 5)I wish to stress the need to correct the present misconception about outputs VS surplus.To make a Net-Metering law that is based on outputs alone is asinine to say the least.A law should,where possible,be positive in intent.The current agreement in Net-Metering to govern by placarded output is grossly in error.This action is counter-productive and will foster lying and deceit in this new and growing industry in my opinion.If people are to embrace the Idea of wind power,it must make reasonable sense and,not be a burden or financially impractical.In order to meet their needs,small - intermediate wind farmers will begin to do things like "velcro placarding"to survive and 1 make this work for them.This is not only dangerous,but will cause a feeling of mistrust even greater than is now experienced between the utility and the wind farmer.I imploreyoutotaketheaffirmativeactiontodemandthatcapsbesetatareasonablelevelandgovernedprimarilyonsurplusoutputandnotbytheplacardalone.These caps need to be realistic to work.In this industry,there are many provisions to regulate the output ofthesemillsbyshuntregulatorordiversionregulatorbesidesthecommonoutputregulators.To overlook the use and existence of these controls is like making cars with no brakes.Their sizes would be unfairly stunted to render them useless in a horse-dominated world. 6)It has been my professional experience over the last 3 years that the 25Kw cap is onlymarginallyacceptableinonlythemostidealconditions.Since we must 3X to 4X size the turbines in most areas to approach a break-even point,the next available size of turbine is the 65Kw units,(for small scale),and 250Kw,(for larger farms).Therefore,for Net-Metering to work for the masses,it must be set at a realistic level for the winds we receive.This could and should be the logic in setting the upper cap also.As I stated in the meeting,an Ag farmer with a 400MwH/year load,will need to install at least 200Kw of turbines.I seem to remember some kind of cap of 2.9Mw.This will be reached withonly15farmersintheentirestate!A SMW cap could be reached with only 25 farmers! Perhaps a more realistic "real world"cap should be more like 300 to 400Mw.I know of more than a dozen farmers in just two counties that wish to Net-Meter if they could begovernedonsurplusnotplacardedoutput.There are some 17 to 25 counties across Southern Idaho that could take advantage of this option if the caps and regulations were realistic.This one option alone,would free up vast quantities of present demand onhydroresources,allowing farmers to grow more and better crops as well as allowing the rest of the state to progress without the pressure of skyrocketing power prices.This is not to mention the many other benefits too lengthy to state here.Like my analogy,please do not staple our hands to our feet and expect everybody to work faster. 7)Please consider that our State has NO incentives,funding,or other financialassistanceofconsequencefocusedatharvestingthevastwindresource.With the thirdbestwindinthewest,you would think we would be at least the third MOST AGGRESSIVE STATE and not the LAST!!!When the Islands and third world countries shine over us at a rate exceeding 5 to 1,I get ashamed of the lax efforts made in my government. Sorry,I did not want to say it so coldly.I had promised to not "hammer "you guys,but this is how I feel and how outsiders see Idaho. Transaction ID:561456.20 Referred by:http://www.puc.state.id.us/scripts/polyform.dll/ipuc User Address:67.250.133.207 User Hostname:67.250.133.207 2 Jean Jewell fC From:Ed Howell Sent:Wednesday,May 08,2002 8:54 PMTo:Jean Jewell;Ed Howell;Gene Fadness;Tonya ClarkSubject:Commentacknowledgement WWW Form Submission: Wednesday,May 08,2002 7:54:21 PM Case: Name :Maureen Bol ing Street Address:401 BrooksCity:Ëazelton State:ID ZIP:83335 Home Telephone:E-Mail:baubo@homeinternet.net Company:ID PowerComment_description:Please approve net metering and make it as accessible as possible sothatmoreindividualsandbusinessescanparticipate.Thanks, Maureen Boling Transaction ID:581954.21 Referred by:http://www.puc.state.id.us/scripts/polyform.dll/ipuc User Address:216.222.12.52 User Hostname:216.222.12.52 1