20130930Supplemental Comments.pdf

Benjamin J. Otto (ISB No. 8292)
710 N 6'h Street
Boise,ID 83701
Ph: [phone] xt2
Fax [phone]
[e-mail]
Attorney for the Idaho Conservation Ieague
Dean l. Miller (ISB No. 1968)
Chas. F. McDevitt (ISB No. 835)
Celeste K. Miller (ISB No. 2590)
McDEVITT & MILLER LLP
420 West Bannock Street
P.O. Box 2564-83701
Boise,lD 83702
TeL [phone]
Fax [phone]
joe@mcdevitt- miller.com
[e-mail]
ck@mcdevitt- miller.com
Attorneys for the Idaho Clean EnergyAssociation
IN THE MATTER OF THE
APPTICATION OF IDAHO POWER
COMPANY FOR AUTHORJTY TO
MODIFY ITS NET METERING
SERVICE AND TO INCREASE THE
GENERATION CAPACITY LIMIT.
CASE NO. IPC-E-12-27
SUPPLEMENTAL COMMENTS
OF THE
IDAHO CONSERVATION LEAGUE
AND THE
IDAHO CLEAN ENERGY
ASSOCIATION
BEFOR3 THE IDAHO PUBLIC UTILITIES COMMISSION
The Idaho Conservation League (ICL) and the Idaho Clean Energy Association (ICEA)
respectfully submit the following Supplemental Comments in response to Order No. 32880,
dated August 14,2013.
In Order No. 32880 the Commission stated: "The primary thrust of net metering is to
provide customers the opportunity to offset their own load and energF requirements."r To ensure
the program provides this opportunity the Commission instituted several changes to Idaho
' Order No. 32880 at 3.
ICL/ICEA Supplemental Comments I
rPC-E-t2-27
September 30,2013
Power's net metering program, including most relevant here, replacing cash payments for annual
excess energF with a system of bankable kilowatt-hour credits. Under the cash payment system, a
net metering customer could apply the cash as they wished to offset power bills, including to bills
covering separate accounts and service points. Under the bankable credit system, this ability to
apply credits to multiple accounts is uncertain.
To address several public comments on the issue the Commission requested input on the
following: "If a net metering customer takes service through multiple meters at one or more
premises, should the customer be allowed to apply net metering credits to offset usage on the
other meters? If so, what conditions shoul d apply?"z
For Idaho Conservation League and the Idaho Clean Energy Association, the answer to
the first question is yes. Allowing a customer to apply kwh credits to offset the energy portion of
their power bills is consistent with the primary purpose of net metering.3 Whether the customer's
load and energy requirements is measured at a single meter or multiple meters, the effect is the
same-the customer is using kwh credits to reduce their own power bills, not engaging in a
wholesale power transaction of any sort.
Using a hypothetical monthly power bill will illuminate the issue. Each month a customer
receives a single bill covering three accounts and two locations. Account #1 covers the Boise
ofEce. Account #2 covers the outdoor lighting at the Boise office. Account #3 covers a separate
office in Meridian. Because the accounts cover a single point of service and single customer, the
kwh credits should, at a minimum, be available to offset the energy portion of both Accounts 1
and2. Because the accounts cover a single customer and do not implicate a wholesale power
'Order No. 32880 at 5.
3 Although ICEA previously advocated for a financial credit, ICEA did not seek reconsideration
on this issue and, for the purpose of this proceeding, accepts the use of a kwh credit. ICEA does
not waive the opportunity to advocate for a financial credit in future proceedings, ifjustified by
the circumstances.
ICL/ICEA Supplemental Comments 2
rPC-E-t2-27
September 30,2013
transaction, the kwh credits should also be available to offset the energy portion of Account 3. In
either case, excess kwh credits offset a single customer's energF requirements.
Allowing a single customer to apply kwh credits at multiple locations provides more
opportunities for Idahoans to participate in the program while remaining true to the primary
purpose of net metering. During the public hearing and in written comments the Commission
heard from several current customers who designed their systems to offset their own energy
demands but happen to use multiple meters. Mr. Standal's Petition for Reconsideration explains
how he designed his system to offset his energy loads spread across his five accounts.a Mr. Kelly
Hogan explained at the June 11,20L3 public hearing he separately meters the power
consumption of his commercial buildings and the power production of his net metered system to
simplifr his accounting, but the system is designed to only offset his own load. Ada County
explained they apply credits generated at one meter to offset power bills at a second meter
because this reduced the cost of the installing and interconnecting the system.'Allowing a
customer to apply excess kwh credits to multiple locations provides a full opportunity to offset
their own loads and energy requirements while staying true to the primary purpose of net
metering.
Allowing customers to apply kwh credit across multiple locations will not incent
customers to oversize systems beyond their own energy requirements. Yes, a customer could
install a system at location A designed to produce excess kwh credits at that location. But the
customer would have no incentive to produce more excess kwh credits than the energy they
consume at location B. Even though the system at location A is oversized for that location, using
kwh credits instead of cash payments limits the customer to only offset the energy portion of
their power bills. Utilizing a kwh credit system instead of a financial payment incents systems that
a See Standal Petition at 1 - 2 (ldy 2O,2Ol3).
5 SeeDave Logan/Ada County Comment (September 27,20L3).
ICL/ICEA Supplemental Comments 3
tPC-E-t2-27
September 30,2013
are sized to only offset a customers own energy requirements even when measured at multiple
locations, not engage in wholesale power sales to the utility or other customers.
Applyrrg kwh credits to accounts with differing rate schedules is fair, just, and reasonable.
A single customer may pay for power under differing rate schedules that correspond to the
electric service delivered. But when providing "customers the opportunity to offset their own
load and energy requirements"6 it is the customer's kwh consumption, not the rate schedule, that
matters. Previously a customer accumulated a financial credit calculated by multiplying the
excess kwh by the corresponding energy rate of the customer's rate schedule. Because different
schedules charge different energy rates, applying the financial credit across schedules could
exacerbate cost recovery issues. A kwh credit scheme avoids this issue. Any excess kwh credits
would first reduce the kwh portion of the energy bill, any remaining kwh consumed would be
billed at the correct rate on the corresponding schedule. Applnng credits to different rate
schedules allows a customers the opportunity to offset their load and energy requirements, while
payrng the proper rate for the customer's net energF consumption.
In response to a discovery request, Idaho Power states the Company's billing system "is
not able to net usage across multiple schedules and customer accounts" so a manual system must
be used.T ICL and ICEA submit the Commission should be skeptical of claims that technical
difficulties prevent Idaho Power from doing a thing it does not want to do for poliry reasons.
Instead, the Commission should direct Idaho Power to report back within six months on the
necessary timeline for ensuring the Company's billing system has adequate capability to apply a
kwh credit system for net metering customers.
il
il
6 Order No. 32880 at 3
7 See Exhibit2}6,Idaho Power's Response to StaffRequest No 18.
ICL/ICEA Supplemental Comments
tPC-E-12-27
September 30,2013
In conclusion ICL and ICEA suggest the following conditions apply to excess khw credits:
. Any excess kwh credits will first be applied to the same account the net metered system is
electrically connected to.
A customer may apply any excess kwh credits to another account held by the same
customer.
Kwh credits may not offset the customer charge portion of any account to which they are
applied.
Customers must prospectively designate the additional account or accounts to apply the
kwh credit.
Customers may change the designated account annually.
Repectfully submitted this 30'h day of September 2013,WBenjamin J. Otto
Attorney for the Idaho Conservation
League
Dean J. Miller
MCDEVITT & MILLER, LLP
Attorney for the Idaho Clean
Energy Association
ICLIICEA Supplemental Comments
IPC-E-12-27
September 30,2013
BEFORE THE IDAHO PUBTIC UTITITIES COMMISSION
IN THE MATTER OF THE
APPLICATION OF IDAHO POWER
COMPANY FOR AUTHORITY TO
MODIFY ITS NET METERING
SERVICE AND TO INCRTASE THE
GENERATION CAPACITY LIMIT.
CASE NO. IPC-E-12.27
Idaho Conservation League
Idaho Clean Energy Association
September 30,2013
EXHIBIT 206
IDAHO POWER'S RESPONSE TO STAFF REQUEST NO 18
REOUEBT lrlO. 18: Pl€ese exdaln the capabllit{es of the Oornpanfe nerv billing
syetem wtth regard b net mobnng aggregation. Spedfica[y, fur customert luvhg a
separeb moterfrom the exlsting rdsil load, please explah f the n€u, bllllrq syrtem can
net usags aoroca multlple schedules ard cudomer accountE.
RESFOII3E TO REATEST qp. r8: The Companfs new bllllng system is rnt
ablc b net uaagn acrocs muftipb scheduloa and curtomer acoounta. Manuel blllitrg
prooosoes upuld need to be developed should it be neoessary to net uoag€ acru8o
sdEdulgg, gervloe polnt*, or eo@utt3.
The nsponae to thle Requ€s ls eponeored by Mathar Leftln, Regulelory
Analyst, ldaho Power Company.
Exhibit 206
ICL/ICEA Suuplemental Comments
rPC-E-t2-27
September 30,2013
CERTIFICATE OF SERVICE
I certifr that on the 30th day of September 2013,I delivered true and correct copies of the
foregoing SUPLEMENTAL COMMENTS THE IDAHO CONSERVATION LEAGUE and
IDAHO CLEAN ENERGY ASSOCIATION to the following persons via the method of service
noted:
Hand delivery:
Jean Iewell
Commission Secretary (Original and seven copies)
Idaho Public Utilities Commission
427 W. Washington St.
Boise,ID 83702-5983
Electronic Mail:
Lisa D. Nordstrom
Regulatory Dockets
Matt Larkin
Greg Said
Idaho Power Company
P.O. Box 70
Boise,Idaho 83707
[e-mail]
[e-mail]
[e-mail]
[e-mail]
PowerWorks. LLC
Chris Aepelbacher, Project Engineer
5420W. Wicher Road
Glenns Ferry, Idaho 83623
[e-mail]
Pioneer Power. LLC
Peter I. Richardson
Richardson & O'Leary
51s N. 27 thSt
Boise, Idaho 83702
peter@richardsonandoleary. com
John Steiner
24597 Collett RD
Oreana, Idaho 83650-5070
[e-mail]
Certificate of Service
ICL/ICEA Supplemental Comments
tPC-E-12-27
City of Boise
R. Stephen Rutherford
City of Boise City,Idaho
P.O. Box 500
Boise,ID 83701-0500
BoiseCityAttorney@cityofboise. org
John R. Hammond, Jr.
Batt Fisher Pusch & Alderman, LLP
P.O. Box 500
Boise,lD 83701
[e-mail]
Snake River Alliance
Ken Miller
Clean Energy Program Director
Snake River Alliance
P.O. Box 1731
Boise,ID 83701
[e-mail]
Benjamin I. Otto
September 30,2013