20130711Iverson Petition for Reconsideration.pdf

Idaho Public Utilities Commission Gary L.Iverson.Sr.
P.O.Box $3720 1227 E.Maine Ave.
Boise,ID 83720-0074 ZC!}L.L.I I ,j;Nampa,Idaho.$3686
Fax:[phone] ..,Ph:208-467-9264
TtL
101uly20l3
SUBJECT:Opposing IPC’s proposal to modify the “Net Metering Service”contracts,and
reconsideration of errors made by current IPUC Order NO.32846.
Dear Sirs,
I would like to submit this response as provided for on page 20 of your “Order NO.32846”as a
Petition for Reconsideration.This order was received by me on 09 July 2013,and this reply will be
within the 21 day time period to do so.
I would like to state that in my professional and reasoned opinion,that the arbitrary action of the
IPUC in disregarding the well researched and thought out responses of not only the public,but even
their own staff in regards to allowing removal of a real value placed on kW hours credited to small
producers was a serious error on the part of the board.Beyond that,it was also a serious failure of
this board to correctly and honestly represent the State of Idaho and it’s people!
Taking the arbitrary words ofthe board,written in the Order NO.32846,1 found numerous onerous
and erroneous arbitrary concepts,ideas,bias towards the Company side,and they have mis-applied
or completely ignored the intentions of the Idaho Energy Plan going back for over 10 years this
all is clearly seen in their words.Examples from just one decision as written:
I.Page 15 of the Order:“Commission Decision:Based on our review ,we find it fair,just
and reasonable for the Company to compensate net metering customers using a kWh
credit instead of a financial credit or payment.”
Comment:This arbitrary statement shows a complete bias towards the Company and they even ignore
their own wise staff recommendations in this matter.It is wrong.It is pandering to the Company
without due cause nor true reasoned thought,and fails the State of Idaho and it’s people.It will
further weaken the future of all solar in general in the State of Idaho as a result.
2.Page 15 of the Order:“Commission Decision:continued “While we want to encourage
net metering,we believe that financial credit or payment may incent potential net metering
customers to overbuild their systems.”
Comment:This demonstrates a complete attitude bias against net metering in reality.This supports
the idea of their arbitrariness in this decision citing “over building”as a supposed reason to ignore
the input of all others.There has never been a true or real concern of over building in solar.This
FACT goes clear back to the beginnings ofthe Idaho Energy Plans for over a decade.Our Energy
Plan has been to do all we can as a State (to begin)to attempt to produce as much non-polluting and
non-water using clean renewable energy as we possibly can.This was also reflected in the most
recent past printings of the Idaho Solar Initiative which cited as it’s goal as being “5000 Solar Roofs
for Idaho”and it never once mentions that anyone might have to worry about some fake “over
building,right-sizing or gaming”oftheir home system as cited by the IPUC.
FACT:To achieve anything close to a zero emissions,fully renewable,home power source,one
Iv1UST produce a bit more than they themselves will use.Then,the extra power is used to pay for
the other non-renewables that we presently cannot do without:things like natural gas for water heat
and oil and gasoline for our cars to get to work.“Over building or right-sizing”when it comes to
solar,net metering,and renewables in general is a fictional word gimmick now used by our own
IPUC against Idaho’s citizens who have been trying to do their part to not pollute and to support
Idaho’s Clean Air initiatives.This too was also a gross failure of this sitting board to correctly and
honestly represent the State of Idaho and the interests of it’s people!
3.Page 15 of the Order:“Commission Decision:continued “We believe that removing the
cash payment takes away this gaming opportunity and encourages customers to right-size
their systems.”
Comment:This foolishness clearly demonstrates their own personal biases towards the Company,and
once again arbitrarily ignores all others whose knowledge and wisdom exceeds their own.The
gaming done was through them on the behalf of the Company the entire Company proposal,
considered all together,was so “out in the nether realms”to begin with,that the Company could
never have thought to get this through.Their only real plan must have ask for 10 get two?This
current plan is an outright theft ofreal value from all those who have invested and followed the “5000
Idaho Solar Roofs Initiative”in good faith!Cormption at it’s best.
4.Page 15 ofthe Order:“Commission Decision:continued “Further,we find it fair,just,and
reasonable for the kWh credit to indefinitely carry forward to offset future bills for so long
as the customer remains on the net metering service at the same generation site.”
Comment:They should have finished that sentence with these true words:“Then the Company will
steal all that credit,take the value for themselves and for their shareholders,though they did not earn
any nor pay for any ofit.”That sort ofevil,and planned collusion,to steal from producers is exactly
the thing the IPUC Board is supposed to protect the people of Idaho from!
5.Page 15 of the Order:“Commission Decision:continued “Allowing the credits to carry
forward ensures customers will be able to use their credits thus receive the benefits
of their systems.”
Comment:Okay,some small credit to the board is due here though very small.At best,most
solar is very expensive compared to hydro-electric dams,natural gas fired turbines,and such.With
this being true,the most anyone could ever have hoped for was that the equipment might actually last
for 20 years (much does not),and that after the 20 years is up that they might have produced enough
energy to pay for the cost of that system.In this small short sentence the board acknowledges that
we citizens have a right to expect to benefit from our system,that was most gracious of them under
the circumstances I guess but they by their overall arrogance and arbitrary decision making,have
made sure that none of us will now actually ever break even.
In my opinion,this too was also a gross failure ofthis sitting board to correctly and honestly represent
the State of Idaho and it’s people!Shame on them all!
To further support my position,I have below cited numerous direct copied portions from the Idaho
Energy Plan 2012,and have added informational “Author’s comments”to each copied portion
supporting my statements above
Recommended Policies and Actions -Idaho Energy Plan 2012
Electricity RESOURCES Policies
1.The State of Idaho should enable robust development of a broad range ofcost-effective energy efficiency and power
generation resources within environmentally sound parameters.
2.Align legislative policies,regulatory policies,and state agency activity to consistenth reinforce and support state
objectives regarding energy efficiency,energy production,and delivery.
4.Encourage the development of customer-owned and community-owned renewable energy and combined heat and
power facilities that meet the Energy Plan objectives of the State of Idaho.(Emphasis added.)
Author’s Comment:The most recent actions of the IPUC Board violated the intent and direct stated plan
to “encourage the development of customer owned renewable energy”which is not in any way limited to
roof top or any other size IPUC actions have NEVER been in any plan as you will see later on below
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E-4.Idaho’s electric utilities should continue evaluating transmission as a resource option in resource planning and
should continue participating in the development of local,sub-regional and regional,national,and international
transmission plans to construct transmission facilities that are needed to provide reliable,low-cost energy service to
their customers.
E-6 The State of Idaho should encourage teclmologies that minimize emissions.harmful pollutants,and consumptive
use of water.(Emphasis added.)
Author’s Comnient:Note that weDO have some problemswith our distribution system being undersized for the current
and future loading any solar generation helps with this need right now!Also,from E-6.with the future of wind
generation in question at times due to many various reasons,we are left with ONLY solar meeting every one ofthese
state’s objectives in the Plan.The current actions ofthe IPUC notv put even this into question for the future in Idaho.
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RENEWABLE GENERATION RESOURCES
Actions
E-7.Idaho should encourage cost-effective investment in renewable generation and combined heat and
power facilities.
E-l 1.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.
AND below
Table 1.1.facts About Energy in Idaho
52%Share of Idaho’s 2009 electric energy supply that
‘as imported from out of state
3$%Share of Idaho’s 2009 electricity fuel mix that came
from coal-fired potver plants
3.4%Share of Idaho’s 2009 electricity supply that came
from non-hydro renewable energy sources
46.5%Share of Idaho’s 2020 electricity supply that is
expected to come from non-hydro renewabLe energy
19th highest sources based on 2011 Idaho utility resource plans
Idaho’s energy intensity as a share of the state
economy compared to other states
Author’s Comment:In E-1 1 and in table 1.1 we see WHY the State of Idaho’s Energy Plan wants to encourage and
NOT to discourage things like solar and net metering!Look how much of our energy is imported!Imported energy
is expensive energy the 0.08%that goes to solar is a mere drop in the bucket,so why single it out for singular
abuse?Notice that we only have 3%of our supply form non-hydro renewables that is ALL forms of non-hydro
renewables no need to wonder why with the failure ofthe WUC to protect the citizens of this state from a greedy
Company and it’s continued failure to support it actively.(The Energy Plan mandates such support.)
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1.4.3.Recommended Policies and Actions
ELECTRICITY
Idaho citizens aiid businesses have benefitted from a stable,reliable and low-costelectricity supply and this
Energy Plan does not recommend major changes to the structure of Idaho’s electricity industry.At the
same time,the Committee recognizes that investments in new generating resources are becoming
increasingly challenging due to volatile fuel costs and increasing environmental concerns and that Idaho’s
current dependence on coal resources for nearly 40%of its electricity supply could leave the state
vulnerable to potential carbon regulation.Enhancing energy conservation and efficiency measures and
continuing to support the further development of cost-effective in-state renewable energy resources in
order to reduce Idaho’s dependence on imported coal-fired power are important aspects of Idaho
policy
ENERGY EFFICIENCY AND CONSERVATION
The Committee finds that energy conservation and energy efficiency measures provide the greatest
economic and environmental benefits for Idaho 1 and enhanced economic competitiveness for our
businesses)and should be one of Idaho’s highest priority energy resources and thus it is a major focus of
the 2012 Idaho Energy Plan.The Committee believes that increasing investments in energy conservation is in
order to reduce Idaho’s dependence on out-of-state energy sources.(Emphasis added.)
NOTE from page 27 of the 2012 Idaho Energy plan
The state produces about 25 percent of the energy it consumes,as shown in Figure 2.3.22 Most of the energy
produced in Idaho comes from hydroelectric dams.The state’s reliance on energy from neighboring states
indicates that infrastructure maintenance and development such as highway,rail,pipeline,and power lines
are critical to support economic development.(Emphasis added.)
Author’s Comment:We see here as fact,that Idaho only produces about 25%ofour own States power and we NEED
more:our demand is NOT decreasing over time either?Coal is one of the worst energy sources (if one can choose
which to use),due to the high carbon emissions output.We should be doing all we reasonably can to support the one
fully clean and renewable that we do have.One that seems to have zero negative impact anywhere or in any way:That
one form is solar!PV.The Idaho Energy Plans have all done that,but IPUC seems to have lost their vision and will.
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2.3.IDAHO RESOURCES
Idaho currently has no commercial coal,oil or natural gas resource extraction operations (although natural
gas exploration and test wells have been drilled and production is anticipated to begin in late 2011.)Idaho
does have a variety of renewabLe resources available for potential development,including wind and small
hydro power,geothermal,biomass,and solar energy.(Emphasis added.)
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2.3.7.Solar IEP page 49
Solar energy is harnessed through a few different technologies.Solar Photovoltaic or PV systems convert
sunlight to electricity.These systems may be small systems on individual homes and businesses or large
central generating utility systems.
Southwest Idaho’s solar potential is very similar to that of the desert southwest,which has the highest solar potential
in the United States.This allows Idaho many opportunities for solar power applications:however,despite its excellent
solar resource potential.Idaho is behind much of the rest ofthe country in solar installations.It is estimated that a total
of 1 to 1.2 MW of solar PV is currently installed in idaho.In 2010 alone,the Solar Energy Industry Association
estimates 1,737 MW ofPV were installed in the US.82 (Emphasis added.)(Q:‘WHY so little in Idaho?)
of 1 to 1.2 MW of solar PV is currenth installed in Idaho.In 2010 alone,the Solar Energ Industry Association
estimates 1.737 MW of PV were installed in the US.82 (Emphasis added.)(Q:WHY so little in Idaho?)
A few of the benefits of solar include utilization of an abundant Idaho resource,no greenhouse gas emissions.
distributed generation.and potential for an additional manufacturing industry in the state.Though solar is an
intermittent resource,its intermittencv is consistent.and in general its production potential lines up well with high
demand (mid-day).As control systems continue to improve,there is good likelihood for solar to play an important role.
Cost is currently the major barrier to installation of photovoltaic (PV)systems,although the price of PV systems
continues to decLine rapidly,making wide-scale use of solar power for electricity generation less prohibitive.
Author’s comment:Here you see that the Idaho State Energy Plan sees the distinct and clear value to Idaho and
it’s people of supporting and encouraging solar PV power,yet our IPUC has just further weakened any hope
of a solar future for the State ofIdaho with their arbitrary and biased move!By ignoring the people’s will and
the true unbiased input of their staff,I believe that they have clearly demonstrated that they have lost the will
to govern rightly without bias,lost the vision ofIdaho’s future in clean renewable energy,and are not following
the Idaho Energy Plan.This is particularly important when considering any future for Solar PV power.
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2.4.6
Idaho’s Conservation Program Funding Charge of 1.5%of customer electricity bills is collected and administered by
Idaho’s electric utilities following a 2002 ruling by the Idaho Public Utilities Commission.Idaho budgeted over $50
million in 2010 to promote energy efficiency and toad management (including residential and low-income programs)
in the state through initiatives administered by Idaho utilities and the Northwest Energy Efficiency Alliance.108
Author’s comment:Here we are already -all of us paying -for this where is it going?Was it used wisely?How
long did what we pay for last?Long term,did we actually accomplish anyihing at all?Even if there were to be found
some small inequity in the current net metering plan,it is obviously a VERY small inequity that does not even come
close to this amount of money taken from everyone by force of law.FACT.Give away $50 million and cheat PV??
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Distributed energy systems can include micro-turbines.photovoltaic installations.combined heat and power,biomass.
wind,and gas turbines,and can be favored due to their relatively low-cost operation,small size,flexibility as well as
many ofdistributed energy technologies being renewable in nature.These systems canbe placed close to customer load.
reducing or eliminating the need for transmission.In some cases a distributed generation unit can even be used as an
alternative to connecting a customer to the grid.In addition,well chosen distributed generation locations can even
reduce grid losses and can provide ancillary services which improve grid stability (such as reactive power.frequency
and/or voltage control).184 (quoted from page 94.)(Emphasis added.)
Author’s coniment:Please do note that there has NEVER been.in any of any of Idaho’s Energy Plans a problem with
size,over size,over-built,or any other arbitrary limit!The desire to reduce our energy dependence,import,and
pollution is the overwhelming thought and intent tvhat happened to this “vision”in the offices of the IPUC??
Where did this bologna about “right-size system &over built”come from?A lunch conference with the “Company”?
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3.7.3.Environmental Impacts and Carbon Regulation2l I
Paragraph 2 his likely that global and national efforts to control C02 will impact Idaho’s econoniy;both
through energy pricing and our overall economic competitiveness.Idaho is among the nation’s largest per
capita energy importing states and many of our energy imports come from coal-fired power plants that are
most susceptible to carbon-based price increases.If pending regulations increase power production costs,
utility regulators in states hosting the power production facilities may act to protect the consumers in their
region.This could further increase the price of power sold on the open market.
Author’s Comment:here we are in beautiful Idaho.yet,we as a state use so much carbon and air polluting sources of
power that we are one of the nation’s largest polluters per capita Let’s see if we can stop our non-polluting
renewables all together,shall we?Our PUC is doing very well right now to further the suppression of Solar Power.
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From page 118,Idaho Energy Plan.
Idaho could take actions to attempt to mitigate potential greenbouse gas emission regulations through:
2.Supporting development of additional low carbon resources such as geothermal,bioelectricity,wind,
solar,distributed hydropower,arid biomethane.(Emphasis added.)
Author’s Comment:An honest question for thought,“How can Idaho actively support these non
polluting,renewable sources best,and what might that support be in the form of?”
In answering that,there is ONE thing for certain the current IPUC Board has proven that it just does not
get it.These people are NOT helping.These people have failed the State of Idaho and it’s people.
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from page 120
f-li.It is Idaho policy to encourage investment in customer-owned generation,therefore the Idaho PUC,utilities,
municipalities and cooperative utilities are encouragedto ensure non-discrimninatorupoliciesfor interconnection and
net metering.
The Committee finds that it is in Idaho’s interest to encourage customer ownership of small-scale
renewable generation such as wind,solar,or micro-hydro in addition to larger facilities that qualify for
PURPA payments.Idaho’s investor owned utilities have established interconnection and ,net metering’
policies for these resources and Idaho’s municipal and cooperative utilities have developed model policies
through the Idaho Consumer-Owned Utilities Association.The Committee urges the PUC and Idaho
utiLities to review these policies to ensure that they encourage investment in small-scale renewable
resources and to fully implement these policies as quickly as possible.(Emphasis added.)
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cf-b.Idaho State Government will:
I.Demonstrate leadership bvpromoting cost-effective energy efficiency,energy efficientproducts,tise ofreneit’able
energy,andfostering emerging technologies by increasing energy efficiency in State government;
iv.Work to identifi,and address barriers and disincentives to increased acquisition of ier,conservation and
efflcienci,;(Emphasis added.)
Author’s Concluding Comments:
Idaho as a State,“Planned and Intended”that the IPUC would actively support all forms of BOTH
large and small renewable energy which includes solar PV at private homes,etc.The recent IPUC
actions do NOT fulfill this plan nor intent,but show a serious lack of understanding,intent,and
compliance with the Idaho Plan in what they do in these areas.Their own words and actions are their
judge.The current WUC action in Order NO.32846,on several other areas I did not cover words
they have used that I did not even include in this,also demonstrate a complete disregard for the Idaho
State Energy Plans past and present.In reality,ALL -in it’s entirety -of the Idaho Power Company
proposal beginning back with Order NO.32715 should have been dismissed with prejudice as being
unreasonable,over bearing,heavy handed,unfair,unequal,and against the State’s Energy Plan
but it was not.In fact,many of the most onerous of the intended newly proposed charges and
monetary penalties were not only -NOT factually dismissed as being wrong and they were just
simply evil wrong but were held off for now,and cleverly worded so that they could be brought
back again for consideration but under a slightly different venue (where they could then quietly be
slipped in when no one was looking).(?)This sort of thing is NOT and should never be,a function
of our PUC!Please DO reconsider your present action in future intentions in this matter.
Iverson,Sr.
Nampa,Idaho 83686