20130725Moore Petition for Reconsideration.pdf

Scott Moore
1840 E. Mary Ln
Meridian, ID 83642
Idaho Public Utilities Commission
4T2Washington Street
Boise,lD 83720-0074
Petition for Reconsideration
Case No. IPC-E-12-27
Order No. 32846
July 242013
Delivered via email to Jean Jewell [[e-mail]]
Issues for reconsideration:
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l. I believe the PUC's decision was erroneous to advanced the date of IPC request to
stop payments for excess power from January 2014 to October lst 2013. As stated in
Idaho Power's request IPC-E-I2-27; "The Company is requesting authorization to
implement this change at the beginning of each customer's January 2014 billing period."
In none of the testimony of hearings was it requested that the proposed effective date be
changed. Advancing the date to Oct. lst will cause additional hardship to some Net
Metering customers that have additional non-net meter services. These customers will
have to expedite the process of rewiring into one meter.
2. I believe the Commissioners decision was erroneous in regards to not addressing the
issue of customers be able to transfer kWh credits from one account to another. This
would have been a fair and equitable way to accommodate Net Metering customers that
have additional non-net meter services.
3. I believe the Commissioners decision was erroneous in stating that a net metering
customer with excess kWh could use schedule 86 to receive financial credit for the excess
power. As stated in order 32846 "Those wishing to be wholesale power providers should
look to Schedule 86 as the vehicle for that type of transaction."
That statement is incorrect in several facts.
l. A customer taking service under net metering schedule 84 can't at the time have
service under schedule 86 PPA on the same meter.
2. It would be impractical for a net metering customer to have a separate service under
schedule 86 and the means to switch their generation system over to that service for only
excess power after their consumption needs where met.
3. Schedule 86 is clearly not intended for very small generation such as 25kW or l00kW
nameplate systems. The cost and time involved in establishing and maintaining a
schedule 86 service exceeds the value ofany excess power.
A fair and equitable solutions would be to allow net metering customers the option to
sign a PPA contract for excess power without the additional requirements of site
certification by a licensed engineer or the requirement for a $lM liability insurance
policy. Another option would be to modifu schedule 86 to accommodate this level of
micro-generation.
Sincerely,
Scott Moore