20161018Settlement Comments.pdf

Benjamin J. Otto (ISB No. 8292)
710 N 61h Street
Boise, ID 83701
Ph: [phone] x 12
Fax: [phone]
[e-mail]
Attorney for the Idaho Conservation League
:-iECEIV ED
ZO 16 OCT I 8 PH 3: I 3
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER )
COMPANY'S APPLICATION FOR )
APPROVAL OF NEW TARIFF )
SCHEDULE 63, A COMMUNITY )
SOLAR PILOT PROGRAM. )
CASE NO. IPC-E-16-14
THE IDAHO CONSERVATION
LEAGUE COMMENTS ON THE
STIPULATED SETTLEMENT
The Idaho Conservation League (ICL) recommends the Commission approve the
stipulation for the Community Solar pilot project. This agreement represents a collaborative
solution that will provide a voluntary program for some customers to meet their desire for clean
energy while not unduly impacting other customers. In our initial comments in this case ICL
identified two major aspects ofldaho Power's proposal that deserved further attention: the
method for paying the subscription fee and the value of the solar energy credits. After negotiating
with all parties, ICL supports the changes to these issues captured by the settlement stipulation.
These changes work hand in hand to reduce barriers to potential subscribers while continuing to
hold non-subscribers indifferent. Accordingly, ICL wholeheartedly supports the Community
Solar Project and looks forward to encouraging Idaho Power customers to subscribe to the
project.
The first issue ICL was concerned with was Idaho Power's proposal to require upfront,
lump sum payments for subscriptions .. Based on our research into the economic condition of
most Idaho families, we were concerned that requiring subscribers to pay up front $740 for an
asset with a 25-year life would inhibit fully subscribing the project. ICL appreciates the monthly
payment plan devised by the parties though the negotiations. Providing an option for 24 monthly
payments better aligns. with the financial situation of most Idahoans. Because subscribers who
elect the monthly payment plan will cover the financing costs, this provision serves the public
interest by enabling potential subscribers while holding non-subscribers harmless.
IPC-E-16-14 1 October 18, 2016
ICL Comments on Stipulation
ICL was also concerned with Idaho Power's proposed valuation of the solar energy credits
produced by the project. Through negotiation, ICL now supports the methodology used to value
the solar output embodied in the stipulation. We agree the solar energy credits on a subscriber's
bill will reflect the embedded cost of energy. This provides a valuable hedge for subscribers
against rising power costs. We also agree that part of the value of the solar output is rolled
forward and used to reduce the subscription costs. This portion of the value represents the long­
term benefits that accrue from investing today in an alternate resource. Just as investing in
Demand Side Management resources today delivers long-term benefits, investing today in a long­
lived solar subscription delivers long-term benefits to the system.
In sum, ICL supports the Community Solar Project as refined by the stipulation in this
case. We appreciate Idaho Power's initial proposal, and the compromises reached by all parties
though the negotiation process. The public interest is served by the project as improved by the
stipulation, because Community Solar provides some customers an option to meet changing
energy desires without negatively impacting other customers. ICL urges the Commission to
approve the stipulation.
Respectfully submitted this 18th day of October 2016
Benjamin J. Otto
Idaho Conservation League
IPC-E-16-14 2 October 18, 2016
ICL Comments on Stipulation
CERTIFICATE OF SERVICE
I, 1..-tJ::.. ce,;-that on this 18°" day of October, 2016, I delivered true and correct
copies of the foregoing COMMENTS to the following:
Hand delivery:
Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
427 W. Washington St.
Boise, ID 83702-5983
(Original and 7 copies provided)
Electronic Mail:
Idaho Power
Lisa D Nordstrom
Matt Larkin
Peter Pengilly
Idaho Power Company
1221 West Idaho St
PO Box 70
Boise, ID 83707
[e-mail]
[e-mail]
[e-mail]
[e-mail]
ICIP
Peter J. Richardson
Richardson Adams, PLLC
515 N. 27th Street
Boise, ID 83702
[e-mail]
Don Reading
6070 Hill Road
Boise, ID 83703
[e-mail]
IPC-E-16-14
ICL Comments on Stipulation
3
IIPA
Eric L. Olsen
Echo Hawk & Olsen PLLC
505 Pershing Ave., Suite 100
Pocatello, Idaho 83205
[e-mail]
Anthony Yankel
29814 Lake Road
Bay Village, Ohio 44140
[e-mail]
SRA
Ken Miller Snake River Alliance
PO Box 1731
Boise, ID 83701
[e-mail]
Sierra Club
Zack Waterman, Director
Sierra Club
503 Franklin St.
Boise, ID 83702
[e-mail]
Mike Heckler
3606 N. Prospect Way
Garden City, ID 83714
[e-mail]
City of Boise
Elizabeth A. Koeckeritz
Deputy City Attorney
Boise City Attorney's Office
P.O. Box 500
Boise, ID 83701-0500
[e-mail]
October 18, 2016