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Home My WebLink About20130724Petition for Reconsideration.pdfSIffi*. An IDACORP ComDanv LISA D. NORDSTROM Lead Counsel 3iji,i Jljl_ 2l+ Pi,'l tr: t+l+ ' ' "-! t L', : I -i I - , July 24,2013 VIA HAND DELIVERY Jean D. Jewell, Secretary ldaho Public Utilities Commission 47 2 W esl Washington Street Boise, ldaho 83702 Re: Case No. IPC-E-12-27 Net Metering Service - ldaho Power Company's Petition for Clarification and/or Reconsideration of Order No. 32846 Dear Ms. Jewell: Enclosed forfiling in the above matterare an originaland seven (7) copies of ldaho Power Company's Petition for Clarification and/or Reconsideration of Order No. 32846. Very truly yours, fud,fu LDN:csb Enclosures 1 221 W ldaho St. (83702) P.O. Box 70 Boise, lD 83707 LISA D. NORDSTROM (lSB No. 5733) JULIA A. HILTON (lSB No. 7740) Idaho Power Company 1221West ldaho Street (83702) P.O. Box 70 Boise, ldaho 83707 Telephone: (208) 388-5825 Facsimile: (208) 388-6936 I no rd strom@ ida hopower. com i h i lto n@ ida hopower. co m Attorneys for ldaho Power Company IN THE MATTER OF IDAHO POWER COMPANY'S APPLICATION FOR AUTHORITY TO MODIFY ITS NET METERING SERVICE AND TO !NCREASE THE GENERATION CAPACITY LIMIT !;ir: rr:rii:t'. ;i:iUr,i- i- '1 .-t: - ': 'l: | ' ?l; ilii L: i,5 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. |PC-E-12-27 IDAHO POWER COMPANY'S PETITION FOR CLARIFICATION AND/OR RECONSIDERATION OF oRDER NO. 32846 ldaho Power Company ("ldaho Powed'or "Company"), petitioner herein, pursuant to RP 33, 325, and 331, ef seg., and ldaho Code S 61-626, respectfully petitions the ldaho Public Utilities Commission ("Commission") for clarification and/or reconsideration of final Order No. 32846, dated July 3, 2013, issued in Case No. IPC-E-12-27. ldaho Power seeks clarification regarding the effective date of excess energy billing changes for net metering service under Schedule 84. To the extent that the Commission feels the requested clarification goes beyond the scope of a clarification, then ldaho Power respectfully requests reconsideration of the issues identified herein. See RP 325. IDAHO POWER COMPANY'S PETITION FOR CLARIFICATION AND/OR RECONSIDERATION OF ORDER NO. 32846 - 1 I. BACKGROUND 1. On November 30, 2012, ldaho Power filed its Application with the Commission requesting authority to modify its net metering service. The Company sought to: (1) increase the net metering service capacity limit from 2.9 megawatts to 5.8 megawatts, (2) change the net metering service pricing structure for residential and small general service customers, (3) change how the Company bills excess net energy under Schedule 84, Customer Energy Production Net Metering, and (4) address a variety of interconnection issues in Schedule 72, Interconnections to Non-Utility Generation. 2. On January 15, 2013, the Commission issued a Notice of Application and Notice of lntervention. Order No. 32715. The ldaho Conservation League; PoweMorks LLC; Pioneer Power, LLC; City of Boise; Snake River Alliance; and ldaho Clean Energy Association, Inc., intervened in the case. A prehearing conference was held on March 21, 2013. The Commission then issued an order setting a case schedule, including public workshops. Order No. 32767. Technical and public hearings took place on June 11,2013, as scheduled by Order No. 32794. 3. On July 3,2013, the Commission issued Order No. 32846 approving and denying portions of the Company's request. Effective October 1,2013, the Commission directed ldaho Power to compensate net excess generation with a kilowatt-hour ("kWh") credit that shall carryover to offset the customer's electricity usage without expiration until the customer is no longer a customer at the site of the net metering generation system. Order No. 32846, pp. 15 and 19. II. EXCESS NET ENERGY EFFECTIVE DATE 4. ln its Application and supporting testimony, ldaho Power requested authorization to provide customers with a kWh credit in the amount of excess net IDAHO POWER COMPANY'S PETITION FOR CLARIFICATION AND/OR RECONSIDERATION OF ORDER NO. 32846 - 2 energy accrued during a billing period that could be carried forward and applied against usage in subsequent billing periods. The Company requested that this change be implemented at the beginning of each customer's January 2014 billing period. Application at pp. 2,8, and 11. 5. On pages 15 and 19 of Order No. 32846, the Commission approved the Company's request to compensate net excess generation with a kWh credit instead of a financial credit but ordered that the credits carryover to offset the customer's electricity usage without expiration until the customer is no longer a customer at the site of the net metering generation system. On page 19, the Commission ordered: "This change to how excess energy is billed wi!! apply to customers effective October 1, 2013. The Company shall file for our approval a Schedule 84 that conforms to the requirements of this Order." 6. ldaho Power does not request reconsideration of the substantive excess generation billing decision; it merely requests that the Commission allow the Company to implement the kWh billing and carryover provisions approved for net metering customers beginning with each custome/s January 2014 billing period as ldaho Power originally proposed in its Application, instead of the October 1, 2013, effective date identified in Order No. 32846. ldaho Power is in the process of transitioning to a new customer relationship and billing system, which is currently expected to become operational in September 2013. lmplementing the ordered modifications to the billing of excess generation at the beginning of each net metering customer's January 2014 billing period will a!!ow a few months of operational experience with the new billing system prior to modifying the system's billing and kWh tracking logic. A successful transition to the new billing system wi!! require Company support staff and the third- party system integrator to be completely dedicated to the system implementation IDAHO POWER COMPANY'S PETITION FOR CLARIFICATION AND/OR RECONSIDERATION OF ORDER NO. 32846 - 3 process and the subsequent system stabilization efforts once the new system becomes operational. With these personnel constraints in mind, ldaho Power believes that performing the system modifications necessary to facilitate the kWh crediting provision for net metering customers by the October 1, 2013, effective date would put at risk the Company's ability to successfully transition to the new billing system. 7. Commission Rule of Procedure 331 requires that ldaho Power state the nature and extent of evidence or argument it will present or offer if reconsideration is granted. Should the Commission determine that either of the requested issues for clarification is more appropriate for reconsideration, Idaho Power believes that the evidentiary record could be augmented by written comments or oral argument at the discretion of the Commission, and the Company is prepared to do so in support of its need for an additiona! three months to implement the Commission's directive. !!r. coNcLUStoN 8. ldaho Power respectfully requests the Commission clarify and/or reconsider Order No. 32846 to authorize ldaho Power to implement excess energy billing changes for net metering service under Schedule 84 effective with each net metering customer's January 2014 billing period. Respectfully submitted this 24th day of July 2013. IDAHO POWER COMPANY'S PETITION FOR CLARIFTCATION AND/OR RECONSIDEMTION OF ORDER NO. 32846.4 Attorney for ldaho Power Company CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 24th day of July 2013 I served a true and correct copy of IDAHO POWER COMPANY'S PETITION FOR CLARIFICATION AND/OR RECONSIDERATION OF ORDER NO. 32846 upon the following named parties by the method indicated below, and addressed to the following: Commission Staff Karl T. Klein Deputy Attorney Genera! ldaho Public Utilities Commission 472 West Washington (83702) P.O. Box 83720 Boise, ldaho 83720-007 4 ldaho Conservation League Benjamin J. Otto ldaho Conservation League 710 North Sixth Street (83702) P.O. Box 844 Boise, ldaho 83701 PowerWorks LLG Chris Aepelbacher, Project Engineer PowerWorks LLC 5420 West Wicher Road Glenns Ferry, ldaho 83623 Pioneer Power, LLC Peter J. Richardson RICHARDSON ADAMS, PLLC 515 North 27th Street (83702) P.O. Box 7218 Boise, ldaho 83707 John Steiner 24597 Collett Road Oreana, ldaho 83650-5070 City of Boise R. Stephen Rutherford Chief Deputy City Attorney Boise City Attorney's Office 150 North Capital Boulevard P.O. Box 500 Boise, ldaho 83701 -0500 X Hand Delivered _U.S. Mail Overnight Mail FAXX Email Karl. Klei n@ puc. idaho. qov Hand DeliveredX U.S. Mail _Overnight Mail _FAXX Email botto@idahoconservation.orq Hand Delivered U.S. Mail Overnight Mail FAXX Emall ca@powerworks.com Hand Delivered U.S. Mail Overnight Mail FAXX Emai! peter@richardsonadams.com Hand Delivered U.S. Mail Overnight Mail FAXX Emai! isteiner@rtci.net _Hand DeliveredX U.S. Mail _Overnight Mail FAX IDAHO POWER COMPANY'S PETITION FOR CLARIFICATION AND/OR RECONSIDERATION OF ORDER NO. 32846 - 5 Email BoiseCitvAttornev@citvofboise.orq John R. Hammond, Jr. BATT FISHER PUSCH & ALDERMAN, LLP U.S. Bank Plaza, Tth Floor 101 South Capitol Boulevard, Suite 701 P.O. Box 1308 Boise, ldaho 83701 ldaho CIean Energy Association Inc. Dean J. Miller McDEVITT & MILLER LLP 420 West Bannock Street (83702) P.O. Box 2564 Boise, ldaho 83701 Board of Directors ldaho Clean Energy Association Inc. P.O. Box 1212 Boise, ldaho 83701 Snake River Alliance Ken Miller, Clean Energy Program Director Snake River Alliance P.O. Box 1731 Boise, ldaho 83701 Hand Delivered U.S. Mail Overnight Mail FAX Email irh@battfisher.com lisa@fpa-law.com Hand DeliveredX U.S. Mail Overnight Mail FAXX Emai! ioe@mcdevitt-miller.com heather@mcdevitt-m iller. com _Hand DeliveredX U.S. Mail Overnight Mai! FAX Emai! Hand DeliveredX U.S. Mail _Overnight Mail_FAX Emai I kmiller@sna keriveral I iance.orq IDAHO POWER COMPANY'S PETITION FOR CLARIFICATION AND/OR RECONSIDERATION OF ORDER NO. 32846.6