20070522Application.pdf

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An IDACDRP Company
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Lisa D. Nordstrom
Senior Attorney \~i=, '
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May 22, 2007
Jean D. Jewell , Secretary
Idaho Public Utilities Commission
472 West Washington Street
P. O. Box 83720
Boise, Idaho 83720-0074
Re:Case No. IPC-07-
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In the Matter of the Joint Petition of Idaho Power Company and C-
Squared Development , LLC for an Exemption from Rules 102 and
103 of the Commission s Master Metering Rules for Electric Utilities
Dear Ms. Jewell:
Please find enclosed for filing an original and seven (7) copies of Idaho Power
Company s Joint Petition in the above-referenced matter.
I would appreciate it if you would return a stamped copy of this transmittal letter in
the enclosed self-addressed , stamped envelope.
Very truly yours
~1fJ 7Z~~Lisa D. Nordstrom
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Enclosures
O. Box 70 (B3707)
1221 W. Idaho St.
Boise, 10 83702
LISA D. NORDSTROM ISB #5733
BARTON L. KLINE ISB #1526
Idaho Power Company
P. O. Box 70
Boise , Idaho 83707
Telephone No. [phone]
FAX Telephone No. [phone]
E-mail: Inordstrom~idahopower.com
Attorneys for Idaho Power Company
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GARY CHRISTENSEN
Squared Development, LLC
950 W. Bannock St., Suite 620
Boise, ID 83702
Telephone No. [phone]
E-mail: gary~1 Othandbannock.com
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE JOINT PETITION
OF IDAHO POWER COMPANY AND C-
SQUARED DEVELOPMENT, LLC FOR AN
EXEMPTION FROM RULES 102 AND 103
OF THE COMMISSION'S MASTER-
METERING RULES FOR ELECTRIC
UTILITIES
) CASE NO. IPC-07-L;(.
JOINT PETITION OF IDAHO
POWER COMPANY AND C-
SQUARED DEVELOPMENT , LLC
COMES NOW , Idaho Power Company (Idaho Power" or "the Company ) and C-
Squared Development, LLC ("Squared"), and pursuant to RP 053 , hereby requests
the Idaho Public Utilities Commission (the "Commission ) issue an order granting Idaho
Power an exemption from Rules 102 and 103 of the Commission s Master-Metering
Rules for Electric Utilities for the mixed use development to be built at Sixth and Front
Streets (the "Development") by C-Squared in Boise, Idaho. In support of this Petition
Idaho Power and C-Squared represent as follows:
JOINT PETITION OF IDAHO POWER COMPANY AND C-SQUARED DEVELOPMENT LLC, Page
I. Background
To further national energy conservation goals , Congress passed the Public Utility
Regulatory Policies Act of 1978 (PURPA) requiring state public utility commissions to
consider adoption of federal standards limiting or restricting the master-metering of
electric service in new multi-occupant buildings. The Commission s subsequent inquiry
in Case No. P-300-15 resulted in the issuance of Order No. 15556 , which adopted
Master-Metering Rules for Electric Utilities effective July 1 , 1980 (codified at IDAPA
31.26.01 et. seq).
The Master-Metering Rules prohibit the master-metering of multi-occupant
residential and commercial buildings if the units "contain an electric space heating,
water heating or air-conditioning (space cooling) unit that is not centrally controlled and
for which the unit's tenants individually control electric usage." IDAPA 31.26.01.102 -
103. The Commission s decision to adopt the Master-Metering Rules was based upon
the premises that:
1 )individually-metered tenants who are responsible for paYing their own
electric bills use less and waste less electric energy than master-metered
tenants who are not
the ultimate consumers of electric energy are better served by a direct
customer relationship with the utility than by discussing utility costs in the
rent or by the landlord paying the role of the public utility,
it is inequitable for electric consumers to pay more or less than the cost of
electricity which they consume themselves , and
JOINT PETITION OF IDAHO POWER COMPANY AND C-SQUARED DEVELOPMENT LLC , Page 2
the adoption of easily understood rules capable of immediate application
without lengthy or costly studies or analysis is a better means of drawing
reasonable lines allowing or disallowing master-metering than rules based
upon complex cosUbenefit analyses that ignore unquantifiable benefits of
individual metering. (Order No. 15556 at 2.
However, the Commission did not flatly prohibit master-metering in newly
constructed multi-occupant residential or commercial buildings. It recognized that "there
are significant economies in centrally supplied space heating, water heating or air-
conditioning for multi-occupant buildings , and that tenants have only limited ability to
affect their share of that electric consumption.(Order No. 15556 at 3.) However
master-metering of multi-occupant residential or commercial buildings is inappropriate if
the tenant has individually regulated electric space heating, or water heating, or air
conditioning over which the tenant can control a significant amount of the unit's electric
consumption. (Order No. 15556 at 3-
The Commission has previously granted exemptions from the general prohibition
against master-metering of multi-occupant residential buildings. In Case Nos. IPC-
91-, IPC-96-7 and WWP-96-, the Commission granted requested exemptions
for retirement and assisted living facilities where utility costs would be covered in the
fees paid by residents and where the facility was designed to be energy efficient. The
Commission found that the nature of the congregate living structure in both design and
operation did not lend itself well to providing the conservation signals that would
otherwise be provided through individual metering and billing. (Orders Nos. 23936
26451 and 26512.In 2005 , the Commission also granted Idaho Power a waiver of
JOINT PETITION OF IDAHO POWER COMPANY AND C-SQUARED DEVELOPMENT LLC , Page 3
Master-Metering Rule 103 (and the tariff found in Section 4 of Rule E) for metering of
commercial mall facilities owned by the Sun Valley Company where Sun Valley agreed
to retrofit the individual thermostats to be centrally controlled and operating efficiencies
would occur. (Order No. 29864.
II. Sixth and Front Mixed Use Development
Squared's proposed Sixth and Front mixed use Development in downtown
Boise consists of a 103-unit residential tower with 75 000 square feet in offices and
about 20 000 square feet of retail usage. While Mr. Christensen designed downtown
Boise s Banner Bank Building to use 50% less energy than is allowable under current
energy codes , the proposed mixed use Development aims to reduce energy usage to
75% below the American Society of Heating, Refrigerating and Air-Conditioning
Engineers ' (ASHRAE) standards. The plans for the Development, which the City of
Boise refers to as "Sustainable Community #1", include:
. A geothermal heat source for the building provided by the City of Boise
Geothermal Heating District.
Hot water in the residential tower will be provided by a central system using
solar energy to preheat the water and geothermal energy to bring it to a
suitable temperature.
. A central indirect evaporative cooling air system and heat pumps should
reduce energy use for cooling the office portion of the development by
approximately 75%.
JOINT PETITION OF IDAHO POWER COMPANY AND C-SQUARED DEVELOPMENT LLC, Page 4
. A central hydronic loop system which will provide both heating and cooling
energy to the residential portion of the building, reducing the overall energy
consumption of the individual heat pumps in the residential units.
Location of transformers and bus ducts closer to the end use will eliminate
more than 2.5 miles of large diameter wire and conduit in the building,
resulting in both power and material cost savings.
. Up to 200kW of solar power electricity will be integrated into the buildings.
The Development plans also include other energy-efficiency efforts such as
more effective insulation , glass glazing, etc.
III. Requested Exemption
Central systems are not generally conducive to individual metering, and the
Master-Metering Rules only allow master-metering in multi-occupant residential or
commercial buildings with centrally controlled systems if the users cannot individually
control electric usage. The proposed Development envisions a hybrid heating/cooling
system; the buildings will have centrally heated water and central space heating/cooling,
but each unit will have its own thermostat and heat pump. Consequently, Idaho Power
and C-Squared request the Commission exempt the residential and office space
portions of the Development from its Master-Metering Rules. Because the retail spaces
on the first level are expected to have usage that is non-typical of residential or office
customers, the Company intends to individually meter each of the first level units.
In light of the ends the Master-Metering Rules were intended to achieve , Idaho
Power and C-Squared believe the requested exemption for the residential and office
space portions of the Development is reasonable for the following reasons:
JOINT PETITION OF IDAHO POWER COMPANY AND C-SQUARED DEVELOPMENT LLC , Page 5
Because the Development strives to get as close to a zero net energy
building as possible and will far exceed current energy efficiency
standards , master-metering is unlikely to foster an increase in individual
energy consumption. Also , the efficiencies of these central systems may
exceed any potential efficiency benefits derived from individual metering.
The central systems improve the overall Development's energy efficiency
and are engineered to reduce the ability of individual users to materially
affect energy usage.This will result in greater uniformity of usage
between occupants, thus mitigating concerns that customers will pay more
or less than the cost of electricity which they consume themselves.
Additional monitoring and sub-metering will be installed to provide
information on usage, and to control customer appliances and lighting
when not in use. While the condominium/office association could not use
the sub-metering information for direct rebilling of customers, the
information may be used to adjust the annual association fees to reflect
relative energy consumption.
IV. Modified Procedure
The Company and C-Squared request that this Petition be processed under
RP 201 , et seq., allowing for consideration of issues to be processed under Modified
Procedure , i.e., by written submissions rather than by an evidentiary hearing. Because
the Commission s determination in this matter is required to finalize the development'
electrical design , Idaho Power and C-Squared request that this Petition be processed in
a timely manner so that the project may progress on schedule.
JOINT PETITION OF IDAHO POWER COMPANY AND C-SQUARED DEVELOPMENT LLC, Page 6
V. Notices
Communications with reference to this Petition should be sent to the following:
Lisa D. Nordstrom
Barton L. Kline
Idaho Power Company
P. O. Box 70
Boise , ID 83707
nord strom (Q). idah opower. com
Ric Gale
VP - Pricing & Regulatory
Idaho Power Company
P. O. Box 70
Boise, ID 83707
rqale(Q).idahopower.com
Gary Christensen
Squared Development, LLC
950 W. Bannock St., Suite 620
Boise , I D 83702
Telephone No. [phone]
E-mail: qarv(Q).1 Othandbannock.com
VI. Conclusion
WHEREFORE, Idaho Power Company and C-Squared respectfully request that
the Commission issue an order granting Idaho Power an exemption from Rules 102 and
103 of the Master-Metering Rules for Electric Utilities for the mixed use Development to
be built at Sixth and Front Streets in Boise, Idaho.
DATED this 2'l day of May, 2007.
DATED this ")...1/day of May, 2007.
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HRISTENSEN
Squared Development, LLC
JOINT PETITION OF IDAHO POWER COMPANY AND C-SQUARED DEVELOPMENT LLC , Page 7