20130510Cardwell DIRECT.pdf

Peter J. Richardson
ISB No. 3195
Richardson & O'Leary
515 N. 27th Street
P.O. Box 7218
Boise, Idaho 83702
Telephone: [phone] Tel
Fax: [phone] Fax
[e-mail]
Attorneys Pioneer Power, LLC
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IDAH(j t]iLtT;ES CMfss;
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF)
IDAHO POWER COMPANY FOR )
AUTHORITY TO MODIFY ITS NET )
METERING SERVICE AND TO INCREASE )
THE GENERATION CAPACITY LIMIT )
)
)
CASE NO. IPC-E-12-27
DIRECT TESTIMONY OF DAWN MARIE CARD WELL
ON BEHALF OF
PIONEER POWER, LLC
May 10, 2013
1
2 I. Introduction and Overview
3 Q. Please state your name and address.
4 A. My name is Dawn Marie Cardwell and I was hired by Pioneer Power, LLC as Project
5 Manager for a net metering project.. My address is 962 N. Glen Aspen Way, Star, Idaho 83669.
6 A copy of my resume is attached as Exhibit "401." I am testifying on behalf of Pioneer Power,
7 LLC.
8 Q. Please describe Pioneer Power.
9 A. Pioneer Power, LLC works with clients seeking to provide services for renewable energy
10 projects, both net metered and contracted applications. In this instance a 40kW wind turbine was
11 installed as a net metered installation to offset electrical expenses associated with operating a 200
12 H.P. irrigation pump. This property is located on a 280 acre ranch in Oreana, Idaho and is
13 owned and operated by John and Loma Steiner. The pump is necessary for the haying
14 operations on the ranch and is a significant expense to the entire ranching operations. The net
15 metered turbine is part of the owner's efforts to provide an economical and environmentally
16 desirable way in which to offset the cost of electricity required to operate this irrigation pump.
17 The owners expect to generate approximately 75,000 kWh on an annual basis which will help
18 offset 400,000 kWh of electrical consumption by the pump. To give you an idea of the nature of
19 this project, I have attached a photograph of the facility as Exhibit 402.
20 Q. What is the purpose of your testimony?
21 A. I testify as to the impact of Idaho Power's proposed changes in the treatment of excess
22 energy under the proposed changes to its net metering program.
23 Q. Have you testified, before a public utilities commission before?
24 A. No. This is the first time I have been a witness before a public utilities commission.
Cardwell, Di
IPC-E- 12-27
1 Q. Do you address any of the other issues in this case, such as rate design?
2 A. No. Idaho Power's request to change rate design does not apply to the irrigation class
3 However the company's proposal to change the treatment of excess energy will apply to the
4 irrigation class as well as all the other net metering customers.
5 Q. What is your understanding of the changes Idaho Power is proposing in the way it
6 treats excess energy?
7 A. The Company is proposing to provide net meter customers with a kWh credit in the
8 amount of excess energy. It will allow that credit to be applied against future bills until the end
9 of the calendar year when any remaining excess credits will automatically expire. Currently
10 excess energy is paid for by Idaho Power at the end of the year.
11 Q. What is Pioneer Power's response to Idaho Power's excess credit proposal?
12 A. I don't like the idea of excess credits expiring because those credits represent real energy
13 that Idaho Power will likely use to serve other customers. In other words, it looks to me like
14 Idaho Power is proposing to take property (in the form of electricity) generated by the owners of
15 net metering projects and at the owners' expense without paying for it. I don't think that is fair.
16 Q. Are there other problems with Idaho Power's proposal?
17 A. The use of a calendar year, when combined with an expiration of the excess credits,
18 essentially deprives Mr. Steiner of the benefits of being a net metering customer for the time
19 frame between the end of the irrigation season and the end of the year. If he irrigates from April
20 through August, all of his generation for the months of September through December will
21 essentially be for naught and will be sold to Idaho Power's other ratepayers without his being
22 paid for it.
Cardwell, Di 2
IPC-E- 12-27
1 Q. If Idaho Power's proposal is adopted by the Commission, is there a fair way to
2 structure the time period over which credits are accumulated and the date on which they
3 expire?
4 A. First off, I don't believe Idaho Power's proposal should be adopted, as I discuss further
5 below. However, if my recommendation is not adopted there is a way to fix this problem.
6 Q. Please explain.
7 A. For irrigation net metering customers, have the year begin at the end of the irrigation
8 season at the beginning of fall, say September first. That way they would be able to use the
9 generation from all twelve months from September through August to offset some of their
10 summer irrigation load.
11 Q. How would you have this Commission address the other issue you raise with respect
12 to giving electrical energy to Idaho Power without being compensated?
13 A. I don't understand all the legal issues behind Idaho Power's excess credit proposal; they
14 say that they won't be able to pay for excess credits without a contract. So, short of signing a
15 contract, I believe the excess credits should be carried forward indefinitely as long as the
16 customer is connected. That way we can keep our property and it is not taken from us without
17 payment.
18 Q. When you say "indefinitely" do you mean to say that excess credits can accumulate
19 forever?
20 A. Not necessarily. They would accumulate for future use as long as that particular
21 customer is connected. Should a new customer take possession of the facility they would begin
22 over as a new net meter customer.
Cardwell, Di 3
IPC-E- 12-27
1 Q. What do you propose would happen to the excess credits when the customer moves
2 or sells the facility associated with the net metering project?
3 A. At that time the customer would sell the excess credits to Idaho Power at the then
4 prevailing avoided cost rate.
5 Q. I thought you said that you understood it to be Idaho Power's position that it cannot
6 buy the excess credits without a contract. How do you reconcile that with your proposal to
7 sell excess credits when the net metering customer moves away or otherwise stops being a
8 net metering customer?
9 A. I think there is an easy way to reconcile this problem. When a net metering customer
10 decides to cease being a net metering customer then that customer enters into a one-time contract
11 to sell any excess credits on a one time basis.
12 Q. What rate would Idaho Power pay for those excess credits?
13 A. The Company could use the then existing avoided cost rate published by the PUC.
14 Q. As a developer of net metering projects, can you help the Commissioners
15 understand the economic impact Idaho Power's application has had on your business?
16 A. Yes, I would like to address the impact this has had on my business model in terms of the
17 economic impact. I worked on this project from the beginning. One of the incentives for me to
18 be involved with this project was that Pioneer Power, LLC and I discussed the potential of using
19 this project as a sort of model project to work out the bugs and be able to show other farmers and
20 ranchers the potential they may have to benefit from a solar or wind net meter property. If
21 IPCo's application is approved as is, we have no reason to even approach others as it would
22 obviously not be cost effective. IPCo's proposal not only hurts existing net metering customers,
23 it hurts Idaho's economy and destroys "Green Jobs" such as mine.
Cardwell, Di 4
IPC-E- 12-27
1 Q. Does this conclude your testimony?
2 A. Yes, it does.
Cardwell, Di 5
IPC-E- 12-27
962 N. Glen Aspen Way
Star, Idaho 83669
Phone [phone]
neCad
July 2008 - present
Pioneer Power, LLC - Owyhee County, Idaho
• Initial planning, production of documentation and submittals for Conditional Use
Permit application for 40WV wind facility.
• Permitting and project management of construction phase thru commissioning.
• Management of application and submittals for Federal "1603 Grant in lieu of
Tax Credir program.
Western Dessert Energy - Owyhee County, Idaho
Initial planning and coordination of documentation for Conditional Use Permit
application for 5 MW wind facility.
Tumbleweed Windfarm - Elmore County, Idaho
• Initial planning and coordination of documentation for Conditional Use Permit
application fcc 10-15 MW wind facility.
• Cost estimates and Financial Projections for 20 year Power Purchase
Agreement.
• Research for Federal "1603 Grant in lieu of Tax Credit" program.
• Research, support for testimony for Idaho legislative renewable energy issues.
The Blackhawk Project, LLC - Boise, Idaho
• Project management and coordination.
• Computer layouts for CNC machining of prototype parts.
• Prototype materials procurement and manufacturing scheduling.
• Coordination of institutional collaborations with Idaho National Lab (INL) and the
Center for Advanced Energy Studies (CAES), Boise State University and
Syracuse University.
• Research on project development for manufacturing design engineering,
certification processes, marketing and distribution.
• Idaho Department of Commerce grants application.
• Application to the Department of Energy collaboration with TBP, LLC,
CAES and Syracuse University.
• Participation in renewable energy conferences, forums and working
groups.
1978 -2004 Architectural Experience
Indudes participation in a full range of services, from design development
stages to the implementation of contract documents, for projects ranging from
single family dwellings to institutional facilities. The fobMng is a partial list,
arranged by type, to provide an overview of my experience and capabilities.
Dawn Marie Cardwell [phone] EXHIBIT 401
IPC-E-1 2-27
• Recreational I Commercial
• Anchorage Clarion Hotel Anchorage, AK
• Kirkwood Resort Clarion Hotel ----- Kirkwood, CA.
• Del Webb Hotels, Marinas, Convention Centers and
Support facilities on Lake Powell
Wahweap, Bullfrog, and Dangling Rope, AZ. and UT.
• Institutional Facilities
• Administration Offices, Minimum Security, Idaho State
Correctional Institution Boise, ID.
• Pendyne Remodel and Renovation, Medium Security,
Idaho State Correctional Institution ------- Boise, ID.
• Correctional Industries Facility, Medium Security, Idaho
State Correctional Institution Boise, ID.
• Idaho Army National Guard Tank School and Training
Facility at Gowen Field Boise, ID.
• Nampa Care Center Renovation Nampa, ID.
• The Peregrine Fund Research, Support Facilities and
Interpretive Center ---- Boise, ID.
• Financial I Retail / Space Planning
• Mountain Home Federal Credit Union - Mt Home, ID.
• Idaho Mountain Touring Towne Square Mall
Boise, ID.
• Albertsons Food Centers
Boise, ID., Las Vegas, NV., Wenatchee, WA.
Education • My education has been ongoing in nature. Years of higher
education, with emphasis on design, engineering and architecture.
Extensive informal education and work experience. This education
and experiences have enabled me to gain a well-rounded knowledge
in all areas of the construction industry and also qualify for the
Professional Architectural Registration Examination, administered
under the guidelines set forth by the National Council on Architectural
Accreditation Board, and more recently, my work experience in the
Renewable Energy Industry has greatly expanded my knowledge.
References References available upon request.
Summary of • My experience began with entry level design and drafting and has
Qualifications expanded to include organizing project design teams, training and
working with others, coordinating and communicating with building
officials and governmental agencies, engineers, contractors, clients
and their representatives, code reviews, specifications, bidding,
estimating and job supervision as they relate to the building and
renewable energy industries.
Dawn Marie Cardwell [phone] EXHIBIT 401
IPC-E-1 2-27
Thank you for taking the time to review this document. Please, feel free to contact me for any
additional information you may require.
Sincerely,
Dawn Marie Cardwell
208-761-8658
dmarieblackhawkwindenergy.com
Dawn Marie Cardwell [phone] EXHIBIT 401
IPC-E-1 2-27
IT 402
12-27
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 10th day of May, 2013, a true and correct copy
of the within and foregoing TESTIMONY AND EXHIBITS OF PIONEER POWER,
LLC, IN CASE NO. IPC-E-12-27 was served in the manner shown to:
Jean D. Jewell, Secretary X Hand Delivery
Idaho Public Utilities Commission U.S. Mail, postage pre-paid
472 West Washington Facsimile
Boise, Idaho 83702 ) Electronic Mail
[e-mail]
Karl Klein X Hand Delivery
Deputy Attorney General U.S. Mail, postage pre-paid
Idaho Public Utilities Commission - Facsimile
472 West Washington X Electronic Mail
Boise, ID 83702
Lisa D Nordstrom - Hand Delivery
Regulatory Dockets XU.S. Mail, postage pre-paid
Idaho Power Company - Facsimile
P0 Box 70 X Electronic Mail
Boise, Idaho 83707-0070
[e-mail]
[e-mail]
Matt Larkin - Hand Delivery
Greg Said XU.S. Mail, postage pre-paid
Idaho Power Company - Facsimile
P0 Box 70 X Electronic Mail
Boise, ID 83707-0070
[e-mail]
gsaididahoDower.com
- Hand Delivery
Benjamin J. Otto XU.S. Mail, postage pre-paid
Idaho Conservation League - Facsimile
P0 Box 844 X Electronic Mail
Boise, ID 83702
[e-mail]
Chris Aepelbacher - Hand Delivery
PowerWorks, LLC XU.S. Mail, postage pre-paid
5420 W. Wicher Road - Facsimile
Glenns Ferry, ID 837623 X Electronic Mail
[e-mail]
R. Stephen Rutherford
City of Boise City, Idaho
P0 Box 500
Boise, ID 83701-0500
[e-mail]
John R. Hammond, Jr.
Batt Fisher Pusch & Alderman, LLP
P0 Box 1308
Boise, ID 83701
[e-mail]
Ken Miller
Snake River Alliance
P0 Box 1731
Boise, ID 83701
kmiller(snakerivera1liance.org
Dean J. Miller
McDevitt & Miller LLC
P0 Box 2564
Boise, ID 83701
[e-mail]
Board of Directors
ID Clear Energy Association, Inc.
P0 Box 1212
Boise, ID 83701
- Hand Delivery
XU.S. Mail, postage pre-paid
Facsimile
X Electronic Mail
- Hand Delivery
XU.S. Mail, postage pre-paid
Facsimile
X Electronic Mail
- Hand Delivery
XU.S. Mail, postage pre-paid
Facsimile
X Electronic Mail
- Hand Delivery
XU.S. Mail, postage pre-paid
Facsimile
X Electronic Mail
- Hand Delivery
XU.S. Mail, postage pre-paid
Facsimile
X Electronic Mail
Signed
Nina Curtis