20130327Comment.pdf

Jean Jewell
From: puccdagIey.net
Sent: Wednesday, March 27, 2013 6:14 AM
To: Jean Jewell; Beverly Barker; Gene Fadness
Subject: PUC Comment Form
A Comment from Kelley Dagley follows:
Case Number: IPC-E-12-27
Name: Kelley Dagley
Address:
City: Idaho City
State: Idaho
Zip:
Daytime Telephone:
Contact E-Mail: pucdagley.net
Name of Utility Company: Idaho Power
Acknowledge: acknowledge
Please describe your comment briefly:
RE:
Idaho Power's proposed 'Heavy User Discount Plan' aka 'Net Metering Service'
The 2012 Idaho Energy Plan, formally adopted by our elected representatives in the Idaho
Legislature on March 6, 2012, states that:
'It is Idaho policy to encourage investment in customer-owned generation; therefore the
Idaho PUC, utilities, municipalities, and cooperatives are encouraged to ensure non-
discriminatory policies for interconnection and net metering.'
However Idaho Power's application [IPC-E-12-27], to modify its net metering service, stands
in complete opposition to this admirable policy. It all but eliminates true investment in
customer-owned generation and creates overwhelmingly discriminatory policies against genuine
net metering. Consider each of Idaho Power's requests:
Idaho Power's 'Request to Increase Generation Capacity Limit' is a token gesture that
guarantees, by their own projections, the denial of net metering applications in only a few
years. Many states like Montana, Arizona, Arkansas, Oklahoma, and North Dakota specify no
limit at all.
Idaho Power's 'Request to Modify Pricing and Implement New Tariffs' creates far greater
inequities than it claims to mitigate. Careful analysis of the proposed rate and fee
structure reveals that the most energy conservative quarter of residential users would see
their bills rise so much that they could actually lose money on a monthly basis should they
choose to become net meterers. In stark contrast, the heaviest energy using quarter could see
huge savings on their bill by installing even the tiniest of systems. Why should a system
installed by a heavy user be worth more than the same system installed by a moderate user?
This is blatant discrimination against those who have lower power bills.
Idaho Power's 'Request to Modify Billing of Excess Net Energy' undervalues peak supplied
energy and seeks to squeeze the window of net metering time so short that it actually
encourages the wasting of energy. Most energy demands, like heating, cooling, and
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agriculture, occur on an annual cycle that varies with the seasons. The value of this energy
varies similarly based on demand. Systems designed to minimize grid energy usage must account
for the entire annual period with a site specific end date. Anything less would waste
resources, energy, or both. Idaho Power claims that net metering should settle monthly and
arbitrarily cut off in December. They also claim that excess power generated in the peak of
summer demand is worth the same as power used on a fall evening. Both claims are clearly
wrong. This policy would discourage investment in properly sized systems and discriminate
against generators supplying power during peak demand periods.
Idaho Power's 'Request for Tariff Modifications' is a one sided proposal with ill considered
consequences which could negatively impact the adoption of net metering. Interconnection
procedures for net metering should be based on consensus among all concerned parties.
Any proposed obstacle to a simple, safe, and electrical code conforming installation should
be closely scrutinized as a possibly unjustified barrier. Disconnect switches, five minute
reconnect tests, three year recertifications, and high application fees all demand proper
justification. Many states require none of these. The Interstate Renewable Energy Council's
Model Interconnection Procedures are a good place to start. Every barrier to installation
discourages investment in customer owned generation.
State policy demands that Idaho Power's application be denied in every aspect.
Thank you,
Kelley Dagley
The form submitted on http://www.puc.idaho.gov/forms/ipuci/ipuc.html
IP address is 67.41.34.195
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