20061017Comment.pdf

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RECE!VED
2006 OCT 16 PM 4: ~ I
October 12 , 2006 IDAHO PUUUC
UTILITIES COiv!i.nSSIOi"J
Ms. Jean Jewell , Secretary
Idaho Public Utilities Commission
472 W. Washington
Boise , Idaho 83720
RE: Case No. IPC-O6-17 Schedule 84 Net Metering Tariff-Protest of Dr. Robert
Friedman and Gretchen Hecht
Dear Commissioners:
We recently installed a rooftop solar panel array at our home in Boise and became a Net
Metering Customer. Under Idaho Power s Schedule 84. Because of the size of our array
we are in the Residential Customer Access Net Generation grouping.
We have reviewed Idaho Power s Application dated August 17 , 2006 to modify the net
metering requirements and wish to protest the Application in the following respects:
First, we are opposed to proposal to change the rate for generation in excess of
consumption from the retail rate to 85% of the monthly kWh Avoided Energy Cost.
Although we installed our net metering systems primarily for social reasons we cannot
ignore the economic impact change in the current Schedule 84 would cause.
We have a very small financial margin to identify, and have identified Idaho Power
purchase of our power at full residential prices as a positive impact for our installation.
The relatively small amounts we have received for generation in excess of consumption
improve the buy back economics of our system and they provide us an incentive to
invest in the system in the first place. We were , obviously, required to purchase
equipment at retail cost. This clearly increases the cost of the power that we generate
and we do not have access to the large scale production and wholesale pricing that
large energy producers do.
We also believe that Idaho Power has made a convincing case for the need to change
the program. The application cites only one customer who appears to possibly be
abusing the intent of the program. Policies for net metering customers who are
participating as the program intended should not be based of the conduct of one
exceptional character.
Finally, and in our opinion most importantly, we believe it is in the State of Idaho s best
interest to encourage and reward small producers to add to the power grid with
sustainable, nonpolluting power sources. We cannot imagine that the current system for
payment for generation in excess of consumption materially burdens other customers
who in fact are receiving the benefit of the small amounts of clean , renewable power we
generate. It is our opinion that the Public Utilities Commission should encourage
Idahoans to move in this direction and lowering reimbursement for excess power would
not be supportive of this concept.
Second , if the Commission believes a change in the rate for excess generation should
be changed, we recommend that change only apply to those who become net metering
customers after the date of the Commission s Order. Current net metering customers
should be "grandfathered" at the current rate. We , and all other net metering customers
made our investments based on assumptions about the rate for excess generation and it
would be unfair to change the rules in the middle of the game.
Finally, if the Commission believes some change is required we urge you to investigate
a system that would have an annual balancing-out of generation and consumption. This
would have the effect of allowing net metering customers to "bank" excess generation on
one month and , in effect , use it another month of the year. I understand that Avista
Corporation , and many other utilities across the country, employ such a system.
We hope our input has in some way been helpful to you. If we can be of any further
assistance please feel free to contact us.