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WELDON B. STUTZMAN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-0318
IDAHO BAR NO. 3283
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Street Address for Express Mail:
472 W WASHINGTON
BOISE ID 83702-5983
Attorney for the Commission Staff
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.
COMMENTS OF THE
COMMISSION STAFF
CASE NO. IPC-07-
COMES NOW the Staff of the Idaho Public Utilities Commission, by and through its
Attorney of record, Weldon B. Stutzman, Deputy Attorney General, and in response to the
Notice of Joint Petition and Notice of Modified Procedure issued in Order No. 30326 on May 31
2007, submits the following comments.
BACKGROUND
On May 22 2007, Idaho Power Company and C-Squared Development, LLC filed a Joint
Petition asking the Commission to approve a limited exemption from the Commission s Master-
Metering Rules. C-Squared is planning to construct a large mixed use building in downtown
Boise consisting of 103 residential units, 75 000 square feet of office space and approximately
000 square feet of retail space. The project is planned to reduce energy usage to 75% below
the American Society of Heating, Refrigerating and Air Conditioning Engineers standards for
buildings of this size by using a geothermal heat source and a central system using solar energy
STAFF COMMENTS JUNE 21 , 2007
to preheat water. A central indirect evaporative cooling air system and heat pumps will also
reduce energy use. The building will have centrally heated water and central space
heating/cooling, and 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 building from the Commission s Master-Metering Rules. The retail spaces on the first
level will be individually metered.
The Commission s 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 has granted exemptions from the general prohibition against master-metering of
multi-occupant buildings where the particular project did not lend itself well to individual
metering and billing. Idaho Power and C-Squared assert that the multi-use building, in this case
is appropriate for an exemption of the Master-Metering Rules for the residential and office space
portions of the building.
STAFF REVIEW
The limits on master-metering were originally established in the late 1970's to encourage
energy conservation. The rationale was that if customers were individually metered, they would
get the benefits from their energy conserving actions on their energy bills. That concept and goal
still remain valid for most customers, including most multi-tenant structures. For those buildings
that are at the leading edge of energy conserving design however, electrical energy usage can be
reduced enough that most actions of the individual occupant will have minimal impact upon the
overall electrical energy usage. In these cases, individual metering produces little if any energy
savings, and imposes additional costs that may not be justified. In some cases, such as the design
of the building that is the subject of this Application, individual metering may impose conditions
on the design that could actually increase total energy consumption estimates over the estimates
for the design without master-metering.
The design of the building in this Application includes many innovative features to
achieve its extraordinarily low electrical energy usage projections, including the use of
alternative energy sources, innovative heating/cooling systems and energy conserving structural
features. The heating and cooling systems are hybrid systems that include a centrally controlled
STAFF COMMENTS JUNE 21 , 2007
geothermal-based, hydronic heating/cooling system, supplemented with individual geothermal-
source heat pump units that are individually controlled with thermostats in each unit.
Central heating/cooling systems are not generally conducive to individual metering, and
the Commission s rules only require individual metering of such systems if the users have
independent control of their electrical usage. In this case, the hybrid system provides a
combination of central and individual control. However, the bulk of the energy requirements for
heating and cooling are expected to be provided by the centrally controlled hydronic system.
This leaves individual users with control over only the smaller portion of total projected energy
usage provided by the heat pumps, and since the heat pumps will use a geothermal source as the
primary energy input, only a portion of the energy usage under the users' control will be
electrical energy. Therefore, the actions of any individual user will have minimal impact on total
electrical energy usage, negating the primary objective of individual metering.
Domestic hot water is also to be provided by a central system, which is also expected to
use minimal electrical energy. Solar energy will be used to preheat the water and geothermal
energy will be used to bring it up to a suitable temperature.
The design also includes an innovative control system that will allow for control and
monitoring of many of the electrical circuits used for appliances and lighting. The Application
indicates this system could be used to identify tenants that might be using significantly more or
less energy for appliances and lighting, and adjust tenant association fees to reflect energy
consumption.
Staff notes that sub-metering of master-metered multi-tenant buildings and rebilling of
tenants for measured energy usage is not permitted under the Company s tariff. While the
Application indicates that the monitoring system would not provide sufficient information to use
for the purposes of rebilling of customers, using this information to adjust association dues does
raise some concerns. While Staff does not oppose using the information from this monitoring
system to make adjustments in association dues of users with extreme variations in electrical
energy usage, basing a portion of all tenants' association dues upon usage information available
from the monitoring system would appear to be a violation of the Company s tariff.
Staff notes that this monitoring may provide very useful information about customer
behavior when electrical usage is not metered for billing purposes. As buildings become more
energy efficient, the plug load, or electrical usage of appliances and other consumer devices
becomes one of the largest factors in overall electrical usage. Current data on plug load usage
STAFF COMMENTS JUNE 21 2007
especially with modern appliances such as home computers and big screen televisions, is not
readily available. In conjunction with its recommendation for master-metering in this case, Staff
encourages Idaho Power and C-Squared development to develop a plan for gathering and
evaluating whatever energy consumption information can be made available from this
monitoring and control system. Staff further requests that Idaho Power consolidate this
information into a public releasable format and share it with the Commission.
The net impact of all of these innovative design features is a reduction in the amount of
expected electrical energy usage that is subject to individual user control to levels that are so
low, master-metering of electrical energy is unlikely to have a significant influence on consumer
behavior, and is even less likely to have even a minimal impact on electrical energy usage.
Therefore, Staff supports this request for a waiver of the Commission s master-metering rules.
Staff believes that other energy efficient and innovative buildings will be designed for
which master-metering would no longer be appropriate. Obtaining an exemption to the
Commission Rules for each individual case could become an administrative burden, not only for
the developers, but the Company and Commission as well. In an effort to reduce this burden
Staff is working with the Company to develop a methodology or criteria that would generically
define building designs for which individual metering would not be expected to provide
additional savings, and an exemption to the Commission s Rules would be appropriate. The goal
is to develop language that could be added to the Company s tariff and allow an exemption from
master-metering for any multi-tenant building that meets this criteria. Staff believes such a
process would save the Commission, the Company and building developers the time and effort
required for individual exemptions, without jeopardizing the energy conservation goals behind
the master-metering restrictions.
STAFF RECOMMENDATION
Staff recommends the Commission approve the request of Idaho Power Company and
Squared Development, LLC for an exemption from the Commission s master-metering rules.
STAFF COMMENTS JUNE 21 , 2007
Respectfully submitted this
Technical Staff: Wayne Hart
i:umisc:commentslipceO7 .12. wswh.doc
STAFF COMMENTS
A\ 1'-day of June 2007.
Weldon B. Stutzman
Deputy Attorney General
JUNE 21 , 2007
CERTIFICATE OF SERVICE
HEREBY CERTIFY THAT I HAVE THIS 21ST DAY OF JUNE 2007
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN CASE
NO. IPC-07-, BY MAILING A COpy THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
BARTON L KLINE
LISA D NORDSTROM
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
MAIL: bkline(fP,idahopower.com
Inordstrom(fP,idahopower. com
JOHN R GALE
VP - PRICING & REGULATION
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
MAIL: rgale~idahopower.com
GARY CHRISTENSEN
SQUARED DEVELOPMENT LLC
950 W BANNOCK ST, SUITE 620
BOISE ID 83702
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SECRETARY
CERTIFICATE OF SERVICE