HomeMy WebLinkAbout20161025Settlement Reply Comments.pdfLISA D. NORDSTROM
Lead Counsel
lnordstrom@idahopower.com
October 25, 2016
VIA HAND DELIVERY
Jean D. Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington Street
Boise, Idaho 83702
Re: Case No. IPC-E-16-14
New Tariff Schedule 63, A Community Solar Pilot Program
Idaho Power Company's Reply Comments
Dear Ms. Jewell:
An IDACORP company
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Enclosed for filing in the above matter are an original and seven (7) copies of Idaho
Power Company's Reply Comments.
Very truly yours,
~JJ.71_~
Lisa D. Nordstrom
LDN/kkt
Enclosures
LISA D. NORDSTROM (ISB No. 5733)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: (208) 388-5825
Facsimile: (208) 388-6936
lnordstrom@idahopower.com
Attorney for Idaho Power Company
ECEIVED
2016 OCT 25 PM ~: 32
· -! , : . -:~ f-' _; G i..1 C ,., .· 1·.·; :·--r_,Q'.l ~,H SSION
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER )
COMPANY'S APPLICATION TO )
APPROVE NEW TARIFF SCHEDULE 63, )
A COMMUNITY SOLAR PILOT )
PROGRAM. )
)
CASE NO. IPC-E-16-14
IDAHO POWER COMPANY'S
REPLY COMMENTS
Idaho Power Company ("Idaho Power" or "Company") respectfully submits the
following Reply Comments in response to comments filed by the Idaho Public Utilities
Commission ("Commission") Staff ("Staff'), the Idaho Conservation League ("ICL"), the
Snake River Alliance ("SRA"), and Sierra Club on October 18, 2016. In addition, there
were four public comments received. Idaho Power appreciates the comments provided
in this case and notes that all comments recommend that the Commission approve the
Settlement Stipulation submitted in this matter by the parties ("Parties") on September
16, 2016. In these Reply Comments, the Company would like to clarify an issue
IDAHO POWER COMPANY'S REPLY COMMENTS -1
identified in Staffs Comments and respond to the concerns raised in a public comment
by Kyle Nelson.
I. Cost Recovery of the Proiect if it is Not Fully Subscribed
After reviewing Staffs Comments, Idaho Power contacted Staff to ensure both
parties viewed the cost recovery language in the Settlement Stipulation as only
providing for a pass through of the cost of under-subscription resulting from participants
who elect to pay through the 24-month option but do not complete all 24 payments.
Idaho Power discussed the issue with Staff members and understands that Staff is in
agreement with the Company's interpretation of the Settlement Stipulation language.
II. The Participant Will be Able to View Solar Production
Information From a Reliable Source
Through the public comment process, Kyle Nelson expressed concern over the
application of losses and a participant's ability to verify the production from the
community solar array as "the amount of power the solar farm produces is vital in
determining the amount of credit a consumer receives."1 The Company recognizes this
concern and will be providing the array's performance data on the Idaho Power website
at www.idahopower.com/solar. Further, as described in the testimony of Company
witness Dave Angell, on a monthly basis the project's total metered energy will be
reduced by the line loss percent of 3.3 percent.2 Subsequently, each Community Solar
Pilot Program ("Program") participant will receive a proportionate share of the monthly
loss-adjusted energy based on their level of subscription which will be displayed on their
monthly bill.
Public Comment of Kyle Nelson dated 10/03/16.
2 Angell Direct Testimony, p. 12
IDAHO POWER COMPANY'S REPLY COMMENTS - 2
Ill. CONCLUSION
Idaho Power appreciates the opportunity to respond to comments filed in this
case and would like to reiterate its appreciation of the collaborative effort between the
Company, Commission Staff, and other parties to consider and discuss the merits of the
Company's Application and to reach mutually agreeable terms for the Program. Idaho
Power respectfully requests that the Commission issue an order in a timeframe that will
allow the Company to launch its marketing campaign prior to the holiday season.
DATED at Boise, Idaho, this 25th day of October 2016.
~&.~a.,?~ ISAD.NORDSROM
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S REPLY COMMENTS -3
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 25th day of October 2016 I served a true and
correct copy of IDAHO POWER COMPANY'S REPLY COMMENTS upon the following
named parties by the method indicated below, and addressed to the following:
Commission Staff
Daphne Huang
Deputy Attorney General
Idaho Public Utilities Commission
472 West Washington (83702)
P.O. Box 83720
Boise, Idaho 83720-007 4
Idaho Conservation League
Benjamin J . Otto
Idaho Conservation League
710 North Sixth Street
Boise, Idaho 83702
Industrial Customers of Idaho Power
Peter J. Richardson
Gregory M. Adams
RICHARDSON ADAMS, PLLC
515 North 2ih Street (83702)
P.O. Box 7218
Boise, Idaho 83707
Dr. Don Reading
6070 Hill Road
Boise, Idaho 83703
Idaho Irrigation Pumpers Association, Inc.
Eric L. Olsen
ECHO HAWK & OLSEN, PLLC
505 Pershing Avenue, Suite 100
P.O. Box 6119
Pocatello, Idaho 83205
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X Email daphne.huang@puc.idaho.gov
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greg@richardsonadams.com
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IDAHO POWER COMPANY'S REPLY COMMENTS - 4
Anthony Yankel
12_700 Blake Avenue, Unit 2505
Lakewood, Ohio 44107
Snake River Alliance
Ken Miller, Energy Program Director
Snake River Alliance
223 North Sixth Street, Suite 317
P.O. Box 1731
Boise, Idaho 83701
Sierra Club
Zack Waterman
Director, Idaho Sierra Club
503 West Franklin Street
Boise, Idaho 83702
Michael Heckler
3606 North Prospect Way
Garden City, Idaho 83714
City of Boise City
Elizabeth A. Koeckeritz
Deputy City Attorney
Boise City Attorney's Office
150 North Capitol Boulevard
P.O. Box 500
Boise, Idaho 83701-0500
Kyle Nelson
2554 S. Waterbury Lane
Boise, ID 83702
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_x_ Email kmiller@snakeriveralliance.org
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_x_ Email Zack.Waterman@sierraclub.org
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_x_ Email Michael.P.Heckler@gmail.com
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_x_ Email ekoeckeritz@cityofboise.org
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__ Email trucktiva@gmail.com
IDAHO POWER COMPANY'S REPLY COMMENTS -5