20130425Comment.pdf

P.O. Box 2315
Ketchum, ID 83340
(208) 72(1-3841
FAX: [phone]
April 24, 2013
CITY OF KETCHUM, IDAHO
MAYOR
RANDY BAIL
;.OVNCL MEMBERS
BAflD GOURIAY
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To: Idaho Public Utilities Commission (IPUC)
Subject: Idaho Power Company Filing lPc-E-12-27
The City of Ketchum feels the proposal to change Idaho Power's net metering program
Idaho citizen's ability to generate their own power and unfairly penalizes a very small poi
payers whose on-site solar generation benefits the entire electricity grid during peak den
The City urges the IPUC to eliminate the system wide cap on Idaho Power's net metering program
and to reject the proposed rate changes for net metering customers. The City has, through its own
energy conservation actions (with a grant from Idaho Power), its development and adoption of
mandatory green building codes, sponsorship of public education outreach and classes, and
installation of solar energy projects on City property, promoted energy conservation and generation
of renewable energy in Ketchum. The City would like to make the following observations regarding
Idaho Power's proposal:
• The proposed tariff structure discourages energy efficiency and conservation and is poor
public policy. The City encourages the policy direction from the Idaho PUC that encourages
energy efficiency and conservation. The proposed fee structure disincentives energy
efficiency and conservation and goes against previous Idaho PUC precedents in setting good
public policy.
• The proposed tariff structure is unfair to net metering customers. All customers using the
same amount of electricity from Idaho Power should be billed the same amount. The
proposed changes unfairly place a disproportionate burden upon net metering customers,
who are also providing value to the power grid and to fellow rate payers. It is also unfair to
existing net metering customers who installed systems under the current rules that made
economic sense and risk having their investments in renewable energy by the proposed
change in policy.
• Energy Security and Grid Stability. Moving towards a more distributed energy system versus
building more centralized generation capacity and the necessary transmission capacity will
help create a more stable and secure future for Idaho's energy infrastructure and
communities. Distributed energy generation that a robust net metering policy would
encourage would help move Idaho towards a more secure and stable energy future.
• The proposed net metering changes fail to recognize the benefits of peak load reduction..
Idaho Power's peak load occurs in the summer. In the past, the. company has recognized the
benefit of curbing peak load through load reduction programs affecting air conditioning and
irrigation. Solar power is at a maximum in summer afternoons and matches up well with
peak demand times when irrigators are pumping and air conditioning is in high use. There is
also benefit in that Idaho Power can purchase summer solar through net metering customers
at a fixed known cost per kwh as opposed to buying energy on the unpredictable and volatile
summer spot market or through building expensive new peak time generation facilities. This
is a benefit to all ratepayers, since all class rates go up when Idaho Power builds an
expensive plant or purchases expensive power on the spot market.
In summary, the City urges the Idaho Public Utilities Commission to reject the proposed fee
structure, while eliminating the cap on the net metering program capacity. The City encourages the
Idaho PUC to direct Idaho Power to develop a new robust net metering program proposal that
encourages small scale distributed renewable energy generation, is fair to all customers, and that
doesn't have negative unintended consequences for energy efficiency and conservation efforts.
rtunityto comment.