20020513MotivePower Comments.pdf

May 10,2002
Jean D.Jewell
Commission Secretary
Idaho Public Utilities Commission
P.O.Box 83720
Boise,ID 83720-0074
Re:Case No.IPC-E-02-04
Dear Ms.Jewell:
Before the Idaho Public Utilities Commission in the matter of the application of Idaho
Power Company for Amendments to Schedule 84 -Net Metering.
On behalf of MotivePower,Inc.(MPI),of Boise,Idaho,I would like to offer
comments on the subject case:
Comments
1.MPI disagrees with only permitting "large generating facilities"of 100 kW
being included in this plan as it will exclude some Idaho Power customers from
this plan.
2.MPI disagrees with only making the net metering option available to customers
who own and/or operate a generation facility that is fueled by solar,wind,
biomass,hydropower,or fuel cells as these restrictions also exclude some Idaho
Power customers from this plan.
3.MPI disagrees with the proposal that no single customer be permitted to connect
in excess of 580 kW or 100kW per metered site rather than specifying a kW-hr
limit.
Specific Points on MPPs Three Comments
1.In its Order No.28951,the Commission directed Idaho Power to file a net
metering proposal for the Company's remaining customers.While Idaho Power
offered testimony supporting its position limiting the plan to 100 kW,this rating
still appears arbitrary.So what happens to the customer with a 200 kW rating,
350 kW,500 kW,etc?This arbitrary limit on generating facilities up to 100
kW will exclude some customers from participating in this program;therefore,
the Idaho Power proposal does not appear to comply with point 1 of Order
28951.
2.It does not appear that this net metering program was designed to be a "green
power"program,yet the fuel source restriction appears to favors such sources.
Why should a facility that already has power generating capacity from other fuel
sources,i.e.diesel and natural gas fuel,not be permitted to participate in this
program?It does not appear that there should be any restriction placed on the
generating fuel source used.
3.MPI does not understand the reasoning of Idaho Power in setting limits of 580
kW per customer and 100 kW per meter point.The site kW rating is not a
good measure of the total energy transferred from the site to Idaho Power.A
simple comparison between a 500 kW site A operating two hours a day and a
100 kW site B operating 20 hours a day illustrates the point.
Site A:500 kW x 2 hrs =1,000 kW-hr
Site B:100 kW x 20 hrs =2000 kW-hr
Site B is one fifth the rating but transfers twice as much energy as Site A.
Idaho Power states that these limits were selected to ensure that net metering is
available to a wider spectrum of potential customers.As illustrated,a large
number of small customers could have a bigger impact on Idaho Power than a
fewer number of larger customers.It would appear that if any limits are
imposed,the limits should be based on kW-brs rather than nameplate rating.
Conclusion
It appears that the Idaho Power proposal excludes and discriminates against some Idaho
Power customers.The PUC Commission should reconsider the intent of its Order
28951 to determine if the Idaho Power proposal truly meets the spirit of the
assignment.
Respectfully submitted,
Norman E.Anderson
Vice President Engineering
MotivePower,Inc.
4600 Apple Street
Boise,ID 83716
Phone:[phone]
Fax:[phone]
Email:[e-mail]
Copies to:
Barton L.Kline Maggie Brilz
Senior Attorney Director of Pricing
Idaho Power Company Idaho Power Company
P.O.Box 70 P.O.Box 70
Boise,ID 83707-0070 Boise,ID 83707-0070