20121210Comments.pdf

Dec 10 1209:47a Precision Flight !1in 463-4700
Idaho Public Utilities Commission
P.O.Box 83720
Boise, ID 83720-0074
Fax. [phone]
iP-E- i0t-cL'1
10 Dec 2012
SUBJECT: Opposing IPC's proposal to modify the "Net Metering Service" contracts.
Dear Sirs,
I attempted first to use the case comment or question form on line, but I could find no
references to this action by IPC to use (ID. Power Co.), and when I tried to submit a question
about it, the web site failed and gave a white page saying that there was no such address, etc.
Last Friday I received from IPC a letter dated the 5' of Dec. about this subject. A superficial
scan would cause one to think that what they are proposing here is merely a few good
common sense ideas. However, a full review reveals that they are good with soft words and
sophistry. They are instead proposing several things that are very bad for Idaho and also
contradict the Idaho State 2012 Idaho Energy Plan. May I please offer a few specific
comments and references to the afore mentioned Idaho State 2021 Energy plan? Thank you.
COMMENTS:
Idaho Power company has stated in this letter (attached copy for your ease of reference.) in
which they in their first point make it sound as if they are doing a great thing by proposing
more availability of net metering than presently allowed. This is actually patently false in
that they are actually working here to make sure that they kill any possibility that anyone will
ever want to do this in the future. It is a bit sneaky for superficially it sounds so reasonable.
But, immediately in the very next point they demonstrate that they are planning to (even)
reduce any credit given for any energy produced, AND, in the third point, they obviously
plan to cheat anyone out of any power made above what they might personally use.
DETAIL: If this plan were to be accepted by the [PUC, notice please that in the third point
they will then (after having already cut any credit given in point 42) not only renege on
current promise to issue a check at the end of each year, but if there is any extra credit left,
they will pocket it themselves. You really cannot get any lower than this proposal, but that
has not actually been anything too new of a concept for IPC over the past decades in Idaho.
If the IPUC would like to discontinue completely the net metering program in Idaho I simply
cannot recommend a better pathway to do just that than this one that is proposed by the IPC
This action is guaranteed to kill any further growth of the Solar PV in Idaho.
End page 1 of 3, plus attachments.
Dec 1012 09:46a Precision Flight
W
ing •4634700 p.4
Example: I designed, built and completed the installation of a rated 6 KW solar panel
power installation at my home in Nampa Idaho on November of 2011 that cost me about
$46,000. In Idaho, such a system only outputs about 4.5 KW max. In the 13 to 14 months
that it has been operational I have accumulated a credit of $562.00 with IPC.
They have never sent a check to me for I have not formally requested one yet, and in this
proposed plan, they propose to steal all this from me every December.Can you imagine how
you would feel if you were in my place? On top of this, they have regularly disseminated
their propaganda against anyone with a Net Metering System telling all their customers that
they are being unfairly saddled with the costs of over priced power because of people like
myself on Net Metering. It is basically untrue of course, but it has a very small portion of
truth in it. When in the past they have had to buy power from the national power grid, we
in Idaho have had to pay increased rates to reflect those much higher prices paid for outside
power, and the prices we are credited for excess energy produced is marginally different, but
only a very small margin, and the costs to produce this energy are very much higher than any
they are able to produce on their own. As it is even now, it is very nearly impossible to ever
hope to achieve a payback on any system: if the IPUC goes along with this plan, anyone
would be completely discouraged from ever attempting any solar power installation -
effectively killing the program. If I were the people pocketing the money for Idaho Power
Company how could I ever get a better deal? I get to rake it in both ways: I have no costs -
NO REAL COSTS - for this power, and anything extra I get to pocket it and sell it to other
customers: a win, win, & win for Idaho Power Company only.
REFERENCES:
(1)In the 2012 Idaho Energy Plan pages 1 would like to bring up page 9 at the top of the
page for your review. Notice the very first paragraph: items # 1(2) AND 4."Encourage
the development........In my opinion as a professional in. the field, this proposal will
effectively cancel out this directive in the plan by discouraging any or all development of
such production. This proposal contradicts the 2012 Idaho Energy Plan completely.
(2)Center of the page, # E-3. " ........should ensure that their orders and actions are
consistent with the policies and objectives listed......" The current proposal does the
negative of all mentioned in that it will kill all growth of said renewable energies. I do know
that if such a corrupt proposal had been in place before I had contemplated this system, I
would NEVER have built it, and I am sure that I am not alone in this result.
(3)Lower on the page, #E-6. ..........should encourage technologies that minimize
emissions, and harmful pollutants, and consumptive use of water." What I (and others like
myself) have done with the expenditure of significant money is to fully, 100% comply with
the 2012 Idaho Energy Plan as described. Whereas. IPC has only come up with huge sources
of further pollution to meet the growing demand for energy by adding more gas turbines (and
coal) capabilities in direct contradiction to the stated Plan for 2012.
End page 2 of 3, plus attachments.
Dec 10 12 09:45a Precision Flight W ing 0463-4700 p.3
(4) Bottom area of the page 9, RENEWABLE GENERATION SOURCES.
#E-7,"Idaho should encourage........
#E-8,"Idaho should encourage........
As far as "encouraging" anything, this proposal by IPC is the exact opposite. They know all
of this of course, but they have already spent a lot of time and money on propaganda to sell
this proposal, even though it is against the basis of the Energy Plan for this state. For this,
they deserve no encouragement, commendation, nor accolade.
(5) Page 48 of the Idaho Energy Plan 2012, 2.3.7 Solar
In this entire section from page 48 to the top paragraph on page 49 describes solar power in
Idaho, it's potential for growth, it's many benefits to Idaho, and the fact that it is prevented
from growing well right now by the fact that it is cost prohibitive at this time. They believe
that it could play an important role in the future picture of Idaho's overall energy production.
I concur with this, but it is also my conviction that if IPC is allowed by the IPIJC to prevail
that it may never contribute to Idaho in any way in the near future..... all killed by this
proposal. It is a death-nell to the entire Idaho solar PV industry in my professional opinion.
This"proposed plan" would be antithetical to the Idaho Energy Plan 2012.
There are more references that could be cited, but I think that this should provide more than
enough information to help the IPUC to arrive at the conclusion that the current proposal is
NOT compatible with the Idaho Energy Plan for 2012 or likely in any other year to come.
CONCLUSION: I would very much in closing refer you to the bottom of the page 1, from
IPC, the last short paragraph on that page: Because the proposed changes are intended to
=and the availability of net metering service.
My hope is that I have provided to you enough information in this short essay to confirm in
your minds the blatant lie behind that statement above from their letter. IF the IPUC were
to go along with this piaosal the exact opposite would be guaranteed as a result. It is NOT
making anything bigger, better, easier, nor less costly to anyone but themselves in this
proposal. They would have zero investment, they would have zero upkeep costs, they would
steal the output from the producers, and they would sell the stolen output to other customers,
who would then pay them normal rates for all this free energy.Corporate gteed in it's finest
form! Plus, it is a guaranteed way to make sure the IPC never has to "deal with" Net
Metering Services ever again in the future.
Sincerely yours,
ja7(eon, Sr. Idaho State Master Journeyman Electrician
1227 E. Maine Ave Reply is requested. Thank you.
Nampa, II) 83686
[phone]
End page 3 of 3, plus attachments.
Dec 10 1209:45a Precision Flight nin9 04634700 p.2
IHO
POWER®
An IDACORP Company
December 5, 2012
GARY L & DEE E IVERSON
1227 E MAINE AVE
NAMPA ID 83686-7278
Subject: Modification to Net Metering Service
Dear GARY L & DEE E IVERSON:
I am writing to let you know that on November 30, Idaho Power filed a proposal with the Idaho
Public Utilities Commission (IPUC) requesting authority to modify its net metering service
provisions to facilitate continued growth in the service availability. The filing requests authority
to:
• Double the availability of net metering service from the current 2.9 megawatt (MW) cap
to 5.8 MW
• Modify the pricing structure for net metering services provided to Residential Service and
Small General Service customers through the implementation of new, proposed
Schedules 6 and 8 in order to appropriately reflect the costs of providing net metering
service to those customers
• Modify service provisions contained in Schedules 72, Interconnections to Non-Utility
Generation and Schedule 84, Customer Energy Production Net Metering to improve
clarity, and
• Eliminate the practice of providing financial payments to customers who generate more
energy than they use. Instead, the company proposes to provide those customers with a
kilowatt-hour credit in the amount of the excess energy generated during a billing period;
this credit can be carried forward and applied against use in future billing periods.
However, any kilowatt-hour credits remaining after the December billing period will
expire and cannot be used.
Because the proposed changes are intended to expand the availability of net metering service, the
rates of standard service customers (those not receiving net metering service) are not affected.
Idaho Power currently has approximately 350 net metering customers that may be impacted by
this proposal. Individual customer impacts will vary depending on how they use energy.
122 W. Idaho St. (83702)
P.O. Box 70
Boise, ID 83707
ec 1012 09:45a Precision Fli9hting •4634700 p.1
Page I of 2
.__PIVER Contact Customer Name: GARY L & DEE E IVERSON
Al JDACORPCOIaP3rS
BOX
Or call [phone] (Treasure Valley). Account Number: - --
rr olease call Billing Date: 12/04/2012
www.idahopower.com Tuesday - Fiday, 7:30 a.m. to 6:30 p.m. Print Date: 121042012
Please Pay Due Date
12/1912012 $0.00
Account Previous Balance .................................................................................... $563.78 CR
Activity Payments Thank You ............................................................................. $0.00
Balance Forward ...................................................................................... $563.78 CR
Current Charges $0.94
Account Balance $562.84 CR
.
Please Note: Any unpaid balances will be assessed a monthly charge of one percent (1%) for Idaho customers. Any credit due to a
rebilling will be applied to future billings or can be refunded upon customer request Returned checks may be resubmitted electronically for
payment. Checks remaining unpaid will be charged a $20 fee.
Consider joining Idaho Power in supporting Project Share, a valuable community service that
uses voluntary contributions to assist individuals and families who need help paying their energy
bills during the winter heating season. To make a pledge, visit our Web site
(www.idahopower.com) or mark the appropriate box on the back of the pay stub.
I y Please detaci and reum the pert on nbw with your payment. Please bring entire bi I when payinLi at a pay station. Y
IIIO P0 BOX 70
PNER BOISE, ID 83707
An IDC.COR'CDlnparlv [phone] (Treasure Valley)
IIhIllhhhllI . IIIIIIllIIIuuIlIlHJIIIIhIIlIIlIIlI
2003 1 AV 0.347 rasi 0O003 10 2003
GARY L & DEE E IVERS0N
1227 E MAINE AVE
NAMPA, ID 83686-7278
ACCOUNT NUMBER DUE DATE PLEASE PAY
- 1211912012 $0.00
Amount Enclosed $
AddresslPhorie Correction.
noted on reverse side.
llILIIIIlI l lullluIIliiliIIllIlIsIIuu.IIlluIIIl.lIlullIIIIlIlIlIla
PROCESSING CENTER
P.O. BOX 34966
SEATTLE, WA 98124-1966
Project Share pledge,
noted on reverse side.
21894282778000056284 000056378 000000000 1204 9

. .
Jean Jewell
From: Ilana Rubel [I [e-mail] ]
Sent: Friday, December 07, 2012 6:16 PM
To: Jean Jewell
Cc: Lou Ann Westerfield; Wayne Hart
Subject: Idaho Power's Net Metering rate increase request
Ms. Jewell, Ms. Westerfield, and Mr. Hart -
I am writing to express my extreme dismay at Idaho Power's November 30, 2012 letter to Commission Secretary Jean
Jewell - it is an "under-the-radar" attempt to crush the budding solar industry in Idaho. Idaho Power has requested a
more than 400% net meter monthly service increase, from $5.00 to $20.92 per month, or $251.00 per year. Having
recently installed solar panels on my own home, I was already flabbergasted by Idaho Power's insertion of obstacles at
every turn. They delayed for months in coming to hook up my meter, then made up a number of flimsy pretexts as to
why they couldn't do it. It took nearly three months to overcome Idaho Power's obstructive tactics - it was as if Idaho
Power had issued explicit instructions to its personnel to do anything possible to stop consumers from being able to get
meter credit for their solar power. If anything, something should be done to reign in Idaho Power's existing sabotage of
consumer efforts to switch to renewable energy. But Idaho Power has stepped up its attacks on clean energy to a
horrific new level with its latest gambit to quadruple rates for solar users. This is nothing but a naked attempt to kill
alternative energy. At the proposed rates, many solar energy users will actually be charged more on their power bills
than if they had no solar panels at all - a ridiculous outcome. The return on investment for solar energy will be so low
under the proposed rate structure that no solar company will have a hope of staying in business (undoubtedly what
Idaho Power hopes will be the result). The fact that Idaho Power is trying to sneak this through without public comment
is also very telling, and should not be tolerated.
I would hope that you see your duty at the Public Utilities Commission as including the fostering of an environment in
which sustainable energy providers can survive. Here, Idaho Power is attempting to leverage its monopoly power to
price solar companies out of the market. At the hyper-inflated rates proposed by Idaho Power, consumers will be paying
a severe penalty for using solar energy. This cannot be the incentive structure that your Commission seeks to promote
- if anything you should be incentivizing conversion to solar and other renewable energy.
We in Idaho have a lot to lose in the face of climate change. Our ski industry is suffering terribly, our forests are burning
up as shortened winters allow bark beetles to destroy our trees, and our air quality has been appalling this past year.
The last thing we should be doing is punishing consumers that are willing to invest in solar to try to improve our
environment. Please do not allow Idaho Power to abuse its monopoly status in this egregious manner.
Regards,
Ilana Rubel
IRS Circuflar 23' suu~', :r aur men
ice. in this di tc
VT R,11'11~ 01111111
I S Oe K1v Jua or 't
recipicint you P or 'nt{ th &,v on ti
. .
Jean Jewell
From: [e-mail]
Sent: Monday, December 10, 2012 2:41 AM
To: Jean Jewell; Beverly Barker; Gene Fadness
Subject: PUC Comment Form
A Comment from John Weber follows:
Case Number: IPC-E-12-27
Name: John Weber
Address:
City: Boise
State: Idaho
Zip:
Daytime Telephone:
Contact E-Mail: is weber(hotmail.com
Name of Utility Company: Idaho Power
Acknowledge: acknowledge
Please describe your comment briefly:
Dear PUC Commissioners and Staff,
After further review of the direct testimony of Matthew Larkin I have the following comments:
Page 19- Raising the service charge from $5.00 to $20.92 a month is prohibitively expensive
and would make net metering uneconomical in most cases. The over 400% increase of $15.92
cents is equivalent of 203 kWhs of production @ the current lowest summer rate of $.078424.
Annually this is 2,436 kWhs of production, which for solar PV is a system of 1,575 watts. At
$5.50 per installed watt this system would cost $8,663.
Page 19- A BLC or Basic Load Capacity charge is a good idea and in fairness should be
implemented for all ratepayers not just net metering customers.
Page 23- Time of use billing is possible with Idaho Power's new billing system paired with
NIl meters. At least one Idaho Power employee has told me it would be available to net
metering customers in 2013. Time of use net-metering is the most fair to Idaho Power, net
metering customers and all other ratepayers as Peak Power is more expensive to generate than
Off Peak Power. By using time of use billing, net metering generation would be valued closer
to the true value of other generation sources at the time it is produced.
Page 27- Having kWh credits expire at the end of the December billing period would have
different impacts on net metering customers that use different sources of renewable
generation. Many of the sources are seasonal by nature. The fairest way for all ratepayers
and the net metering customer is for the credits to continue until the service is
disconnected or transferred to a new owner. I do agree that in principal the customer should
not be paid for over production, only credited for the life of the customer's service.
Exhibit #1- Rates should be the same for all customers. Net metering customers should not pay
a lower rate than other customers. Higher rates encourage conservation. The PUC has
encouraged conservation in the past with the tiered rates. The State Energy Plan also
encourages conservation. I believe the reason for conservation is to keep rates down by
reducing the need to build new generation and transmission.
Additional notes:
1
S .
Service charges, BLC charges, and rates should be the same for all customers. 0 & M costs
should be based on usage as the costs vary with usage.
Net metering is good for all customer classes and ratepayers because it reduces the need for
new generation, transmission, and the need to import electricity (or fuel for generation).
Renewable generation installation creates Idaho jobs that can't be out sourced.
If Idaho Power's case were to be approved I can only imagine more customers will choose to
leave the electrical grid entirely or relocate to a more net metering friendly utility. This
would not be to the benefit of all ratepayers or the State of Idaho.
This once again reinforces my long standing avocation for the PUC and/or legislator to create
a state wide net metering law.
Thank you for your consideration.
The form submitted on http://www.puc.idaho.gov/forms/€€€ir)uci/€€`i puc.html
IP address is 69.80.39.77
2