20130227Comment.pdf

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ZtH3FEB2G F11 14:1)0
PUIRL C -
UTILIIV_S cOMM
February 19, 2013
Idaho Public Utilities Commission
Attn: Jean D. Jewell, Secretary
472 West Washington Street
Boise, Idaho 83702
RE: Case No. IPC-E-12-27
Proposed Net Metering Changes
Dear Ms. Jewell,
It is my understanding, during December, 2012 that Idaho Power Company (IPC)
petitioned the Idaho Public Utility Commission (IPUC) to change its Net Metering
Agreement with its customers. IPC's proposed Net Metering changes will dramatically
alter all renewable energies within the State of Idaho, now and in the future. Green energy
is in its infancy stages within the State. Nevertheless, renewable energy brings important
and productive jobs into Idaho. Several schools are currently educating its students on the
importance of natural energy sources. Even the State of Idaho plans to incorporated
ecological energy strategies.
If the proposed Net Metering changes go into effect, it will destroy the future for solar,
wind, hydro, bio-mass or cogeneration from ever establishing a foothold within the state. It
also penalizes all of IPC's net metering customers for putting their excess energy back
onto IPC's grid. It will cost these customers dearly for having renewable energy
equipment, which they purchased out of their own pocket and at no cost to IPC. Now IPC
wants to charge these net metering customers based on a daily peak reading but only
documents and reviews those changes twice a year to establish a controlling "Basic
Charge kW'. This reading is displayed by their new AMI meters in kWhs and will only
change when bumped by additional solar energy production or IPC's customer's grid
demand use (adding to the "peak indication value"). This "peak" is a momentary high
amplitude level occurring in the new AM! meters, which is not a true indication of the actual
power being used or even produced. Because the AMI meter cannot differentiate between
energy production or consumption in kWhs. Therefore the AMI meter reading will always
Indicate the same amplitude value unless additional energy is used or produced. With the
resulting error IPC will charge the net metering customer more per day for solar energy
produced plus all grid energy used simultaneously. This error multiplied daily will grossly
inflate costs during this billing cycle enormously!! Remember IPC's intent is to use the
"peak value" ascertained daily by the AMI meters but only reviewed by IPC twice a year.
Nevertheless, IPC does intend to bill and collect its fees monthly. In my opinion, IPC does
not intend to pay its net metering customer one red cent, instead it wants to take their
energy, take their dean renewable energy certificate credits, and then wipe out any energy
benefits their customers may have at the end of the year.
Idaho Power relies heavily on fossil fuel, which according to The Idaho Statesman (PC
claims it is the cheaper means for its customers, in the foreseeable future. Nevertheless,
IPC has a long-standing financial arrangement with a number of other larger electric
utilities. They jointly use and wheel the power produced from several fossil fuel burning
plants in neighboring states. IPC has filed numerous grievances with the IPUC whenever
a large renewable energy company attempts to bring an alternative power source into the
State of Idaho. IPC insists these alternative power companies surrender its Renewable
Energy Certificates (REC). IPC wants these companies to give these RECs to them.
Then IPC use/sell these RECs to other large utilities that also use fossil fuels.
Undoubtedly 'clean RECs" fetch a huge profit on the open market. However the fact
remains that purchasing or owning an REC DOES NOT make the air or water any
cleaner.. In fact,, fossil fuels are to blame for a multitude of gross negligence
consequences with unparalleled predicaments for the earth and all of its
inhabitants. Consider for a moment, China's air quality and its energy demands, it won't
take you long to ask what's wrong with this picture? Renewable energy does not
deteriorate the earth's climate, soil or water.
Interesting enough, on December 1, 2012 IPC petitioned the IPUC to recover the amounts
spent in Custom Efficient projects for its largest energy users. Although according to IPC
this program saved 68 million kWh in 2011, enough to serve the average needs of 5,400
residential customers. Nevertheless, IPC plans to pass 32% of the costs for that program
onto all its residential customers thru the Power Cost Adjustment and Fixed Cost
Adjustment over a period of four years. IPC claims its demand response programs are
intended to reduce summer peak loads in order to minimize or delay the need to build new
supply-side resources. They also claim their energy efficiency programs are designed to
help customers reduce energy use year-round. They clearly realize that energy efficiency
of homes and businesses also reduces power demand. Yet they intend to charge their
net-metering customers for daring to produce green energy. They further claim they
conduct annual analysis of each energy efficient program. I must point out those big-
picture analyses are not verified by any disinterested outside auditing firm on a yearly
bases. Furthermore, IPC has asked the IPUC to suspend two demand response programs
(A/C Cool Credit and Irrigation Peak Rewards). They further claim those programs costs
more to operate than it returns in reduced energy or capacity benefits, even though they
have a large number of customer's utilizing these programs. Without disinterested third
party actually auditing their analyses, it is like the fox guarding the hen house. Moreover,
FERC mandated a distinct split between all of the countries utility's power producers from
its marketers, because of the fox and the hen house scenario. In this author's opinion, IPC
is a cost-motivated company. They want to take the customer's energy, pay them nothing,
while they penalize both the net-metering green energy providers, in addition to those
using the energy efficiency programs and then they have the nerve to ask the IPUC to
pass all the costs onto the backs of all the unsuspecting consumers.
I am in complete agreement with The Idaho Statesman's February 10, 2013 article stating
there needs be real changes in the Country's energy policy. The earth has limited energy
resources, human demand for energy is increasing and access to energy resources
dramatically affects the quality of life for everyone. Otherwise, in a few decades we could
end up without those limited energy resources.
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However, how many times must IPC's customers pay for the distribution lines? They claim
the net-metering clients are not paying their fair share of those costs. Yet all of those
distribution facilities are always oaid for at the time they are constructed!!! Nonetheless
those paying for the facilities don't own them because IPC insist on retaining ownership.
According to IPC's employees, those facilities (when left undisturbed) can last 25-75
years!!! IPC further states that "the IPUC and even some developers agree that the way
prices are set needs to change." Why? Net-metering customers are already paying their
fair share and they contribute green power, of which IPC brags about being as a part of
their mix. How many times and ways does IPC count the same devices again and
again???
I therefore strongly object to IPC's jaded analysis and heavy-duty tactics, resulting in an
unmistakable shocking yet predictable outcome, it is much cheaper for the net-metering
customers to remain on IPC's grid, instead of producing green-energy power which
benefits all of us. It is my opinion, IPC should pay for the much needed additional green
power generated via solar, wind, hydro, bio-mass and geothermal energy methods. I
hereby, respectfully request that IPUC deny IPC's petition to change the net metering
agreement or grandfather the existing net-metering clients. In my opinion, IPUC should
reflect upon IPC's motive and methods along with the dire consequences to the public in
terms of jobs losses, higher utility rates, lost of business opportunities, reduced utility
resources and the future of green energy within the State of Idaho.
Respectfully,
Ji Vanderpool
2746 N. Springtime Way
Meridian, ID 83646
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