20130724Woodworth Petition for Reconsideration.pdf

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Case Numb er : lP C -E -12 -27
FirstName: Keith ?.ri,, J,-,,- ?i; ;;i i; ,flg
Last Name: Woodworth
City: Caldwell :': 'i ' '
State: Idaho
Zip:83607
Email: [e-mail] or [e-mail]
Idaho Power Co.
I acknowledge that this comment constitutes a public record under
Idaho Code sec. 9-337(13)
Idaho Public Utilities Commission
P.O. Box 83720
Boise, Idaho 83720-007 4
24luly 2013
Request for Reconsideration of IPUC Order No. 32846
In the Commissions decision the words "fair, just and reasonable" are used to summarize
decision elements based on the commissions' review of information presented by the
various Interveners, Idaho Power, and the public through meetings and comments
submitted to case 12-27. "stable and not to be soon revisited" would be welcomed - but
not likely- additional verbiage!
As a Net Metered Residence affected by this decision, I have the following concems.
Net Metering Pricing Structure and Excess Net Energy. The Commissions decision
roughly agrees with the "Rebuttal Testimony of Gregory W.Said dated 3l May 2013.
In summery this amounts to:
Pg 6. Idaho Power Co. does not recover its fixed costs of distribution etc.
because 66PV" (DG) producers don't purchase kWhs from IPCo
Pg 7. The intent of Net Metering is to only offset all or part of the customers
individual energy needs.
Pg. l2.IPCo has evaluated Solar DG under its "IRP" process.
Pg. 13. We (some Net Metering Customers?) are receiving "free use of equipment
and services".
Pg. 14. "FERC" and "PURPA"!
As I understand the rate process, IPCo. proposes rates based in part on their power source
mixes, seasonal power use patterns, time of day usage, and customer monthly usage -
from power source down to user. This approach does not look at kWh production/values
from the Net Metering generation source upward. For example, because I am not
interested in getting a monthly bill from IPCo., on an annual basis my system is (roughly)
sized to provide about 800 kWhs of power (at roughly $0.075/kwh) to off set $62.
($5.20lmo) worth of administrative costs. As shown on the IPCo. web site, this power
and a large percentage of the summer power produced to offset night time use of IPCo.
generation occurs during IPCo. "Peak Use" periods. (Info based on IPCo. solar array on
their Boise office building). In addition to these 800 kWhs, my system produces enough
power to offset a years worth of IPCo. night and short day light winter useage. I do have
a Sky Stream 3.7 wind turbine which does complement, but can never replace-the PV
system. As an estimate, maybe 600/o of my annual power or 4-5,000 kWhs is produced
during peak demand periods,. This power is fed back through my meter and sold to
neighbors between my residence and the nearest substation. [PCo.s "Time of Day Plan"
states that this power could be worth about $0.12lkwh.or $480.-600. which at some rate
is billed by IPCo. to neighboring users. In tum, I receive $300.-375. worth of credit to
offset my night time or deficit kWh usage, and administrative costs. Any residual is
shown as a credit on my bill.
The power line between our residence and the neighbors was paid for by myself (majority
cost) and two other land owners. Based on experience, it seems reasonable to assume that
the other residences and irrigators also paid for their line hookups. I'm not aware that
IPCo. paid any of the actual local line construction cost. From the "bottom up", this
seems to mean that IPCo. collects revenue for kWhs produced by Net Metering
generators - at a cost to IPCo. of not much more than their administrative costs - during a
large portion of the" Summer Peak Use" period.
Based on the above "concept" of bottom up Net Meter production, I don't understand:
Pg.6. How it can be shown that IPCo. does not receive compensation for Net Metering
customers use of the "system". It appears that we are paying peak load rates for off peak
load power supplied during non or low generation periods.
Pg.7. Why the system cannot accommodate the use of excess power to offset
Administration costs. It appears -based on the above- that I'm paying more than the
existing $5.20lmonth rate through the "peak-off peak" kWh value exchange. It also
appears that customers who build up large summer kWh credits for winter usage ile
paying more than the off peak winter rate for each kWh used.
Pg.l2. As a business it appears that IPCo. makes sound power acquisition decisions. Not
seeing the value of 'oup feed" PV/DG generation should warrant further consideration.
Looking at IPCo.s "Up Close" news releases for July 2'd and 3td, one has to wonder what
it would look like fthe Company had access to 675 MW of solar generation instead of
the same in wind power on the two peak demand days.
Pg.l3. From a top down cost analysis, this might be true, but from the bottom up it's not
supported. I'm guessing that very few (if any) Net Meter PV generated kWhs get to a
IPCo. sub station! Yet, IPCo. collects revenue as though this power was produced and
moved down through their system.
Pg.14. Thirty or more states have systems in place which provide "reasonable
compensation" for excess net metered generation. If this is an issue with FERC, how are
the majority of other states getting away with it? Do they have special "enabling"
legislation designed to foster or shield Net Metering generators?
Finally. why would any residential customer with a nameplate capacity around 7 kWhs -
producing around 10,000 kWh/year (l-2,000kwh above total residential usage), attempt
to meet the requirements of Schedules 86/84 and possibly 72?
As a less than 800 kWh/ month customer, attempting to pay all the IPCo. "side of meter"
costs with excess power I would think that the "Company" would have studied PV
system production values from the generation site upward for at least their average 1,050
kWh residential user. I am not interested, nor could I recoup my generation or hook up
costs through excess generation. kwh production above actual site usage or above usage
and administrative costs can be roughly controlled on site at what is viewed as an
unnecessary loss of revenue to IPCo..
If clarification on any of the above is required, please contact me at either of the above
Email address so that additional arrangements can be made.
Respectfully,
Keith Woodworth