20130508Comment.pdf

May 5, 2013
Idaho Public Utilities Commission
P.O. Box 83720
Boise, ID 83702
2913 MAY -8 AM 8: 32
IDA:-iJ; UTILITIES OOMMISSIO.
Re: Net Metering Case No. IPC-E-12-27
To Whom It May Concern:
On behalf of my family and thousands of other citizens of the State of Idaho, I am writing to you
regarding an issue that requires your attention and urgent intervention. Idaho Power is in the
process of applying with the Idaho Public Utilities Commission (IPUC) to change the rules for
the handling of its solar/wind power producing customers (i.e., Net Metering customers).
The changes requested by Idaho Power are:
1)Increase the current monthly service charge for Net Metering customers by 40(r, from
$5.00 (the standard service charge for residential customers) to $20.92; and from $5.00 to
$22.49 for Small General Service customers.
2)Institute a "Basic Load Capacity" charge of $1.48 per kw for Residential and $1.37 per
kw for Small General Service customers.
3)Cease all year-end payments to its Net Metering customers who have provided Idaho
Power the excess energy they have not used by the end of the year, and
4)They want to re-organize Schedule 72 by changing the "Net Metering application
process" and by adding "a section governing the treatment of unauthorized installations."
Permit me to address the above requested changes. Under items #1 and #2 above, Idaho Power
claims that there is an inequity between Net Metering and standard service customers because "it
allows Net Metering customers to unduly reduce cost recovery associated with non-generation-
related components of revenue requirement." I am not a lawyer or an electrical engineer, but
logic proves that this assertion is not totally true.
Every residential customer is charged a "Service Charge" (i.e., maintenance and non-generation
fee) of $5.00 per month for having Idaho Power connected to their house whether electricity goes
through the line or not. If Net Metering customers generate more energy than they use in any
month, the $5.00 Service Charge is deducted from the credit that was Droduced. This means that
a Net Metering customer is currently giving Idaho Power 69.1037 kw per month to pay for the
Service Charge which the company turns around and sells to a non-solar residential or
commercial customer. So the Net Metering customer is paying the same $5.00 Service Charge
per month that the non-solar residential customer is paying.
As a side note, Idaho Power stated on its website that it currently has 501,104 customers. This
means it collects $2,505,520.00 per month or $30,066,240.00 per year minimum on its "Service
Charge" alone. The Net Metering customers are paying their fair share of that revenue.
Adding insult to injury, Idaho Power not only wants to raise our Service Charge by 400%, but
the $20.92 would be exempt from being paid for by excess electricity generated by a Net
Metering customer.. This means that each Net Metering residential customer would have to
come up with an additional $25104 each year out of their pockets How are we going to pay for
this blatantly unfair and discriminatory rate increase?
Most of the Net Metering customers are senior citizens, retired, and living on a fixed income.
We have to closely budget our expenses and cannot afford any high increases in our monthly
bills. I am retired, my wife is disabled and my youngest daughter who lives with us is disabled
as well. Most, if not all, of the retired Net Metering customers took money from their savings or
borrowed against their homes to pay for their solar generating systems.
We took this action with the expectation that our solar system would offset some of the expense
of our electrical needs as we got older. It is a concept pushed by President Barack Obama and
the Federal Government to make this country energy self-sufficient The State of Idaho and the
Federal Government promote solar power. Yet now, Idaho Power is trying to push policies
which will kill the solar/wind power production in this state
The 400% increase in our monthly Service Charge is nothing compared to their request to
"institute a Basic Load Capacity charge of $1.48 per kw for residential and $1.37 per kw for
Small General Service" customers. Under this policy, Idaho Power would need to know how
much electricity each Net Metering customer uses in their home each month. This is an invasion
of privacy. The energy we generate and use in our homes does not in any possible way go out to
Idaho Power's electrical grid It does not affect the maintenance and up-keep of their equipment
Therefore, Idaho Power should not be allowed to track what we produce and use, then charge us
for that amount
Additionally, under the current system, the meter currently on our homes only tells them how
much power we buy from them (when we are using more than we produce), and how much
energy we give back to them over and above what we use in any one month. They would have
to install a second meter on our homes (which they would charge us for) to record how much we
totally use in any one month. For the second meter to collect total power usage, they would also
have to change parts of their collection and distribution system that feed and collect energy from
our homes This cost would be charged to us. it could run in the tens of thousands of dollars,
depending on what changes they would need to make to their system. This information comes
from a retired Idaho Power employee who currently is a Net Metering customer. I can provide
you with her name and phone number if requested.
Let us say for the sake of argument that they find that my Basic Load Capacity is 25 kw per day.
This means that I would be charged an additional $3700 per month (1.48 x 25 kw) How in the
world do either of the I st and 2K1 policy changes requested by Idaho Power promote solar
production in Idaho? These policies are bad for Idaho, bad for the environment, and contrary to
national interest If approved by the IPUC, these changes would kill the solar industry in Idaho
I have spoken to other Net Metering customers and they have told me that they cannot afford
these additional costs and would be forced to take their systems off-line and dismantle them for
sale out of state. I took out a $60,000 loan on my house to put in my system. Idaho Power .Ijj
not nay for any part of it. If it breaks down or wears out, I have to pay to fix it. Idaho Power
does not and will not help me maintain or repair it In March of this year, for the first time in the
last five months I produced more kilowatts than I used. After Idaho Power deducted the $5.00
Service Charge, I received only $3.27 in credit. Even under the current system, Idaho Power
gains more from us than we do from them. Every kilowatt I produce and use, means one less
kilowatt they have to spend money producing. During the peak summer and winter load months
(July and December) our production means fewer kilowatts that they have to buy from out of
state nroducers at a much higher cost to them. They take none of these facts into consideration
in the current proposals they are trying to push through the IPUC.
If these changes actually go into effect, the ability of a Net Metering customer to sell their home
will be severely affected. What is now a positive selling point will become a huge negative.
Idaho Power is supposed to be following the rules set forth under the Federal Energy Regulatory
Commission (FERC) They were doing Just that until they found they could make a greater
profit by interpreting F.E.R.C.'s regulations in a manner more favorable to them. The serious
nature of the changes has caused the Idaho Conservation League, PowerWorks, L.L.C., Pioneer
Power, L.L.C., the City of Boise, the Snake River Alliance, and the Idaho Clean Energy
Association, Inc. to intervene in the case. They have all retained legal counsel, but the ordinary
residential Net Metering customer cannot afford to hire an attorney. Again, we are left out in the
cold with nowhere to go.
Your help is desperately needed now to speak on behalf of those of us whose voices will be
ignored, if heard at all. We voted for you when you asked for our support Please help us.
Make our voices heard by the LP.U.C.
Sincerely,
fiJd3.
Robert T. Bellew
Cc: Senator Michael Crapo
Senator James Risch
Congressman Michael Simpson
Congressman Raul Labrador
Nathan J. Davis - Federal Energy Regulatory Commission