20161019Settlement Comments.pdf

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I_~ .. : •• S~ION
October 18, 2016
Idaho Public Utilities Commission
472 W Washington St
Boise, Idaho 83702
Re: Comments on Idaho Power Company's Application to Approve New Tariff Schedule 63, A
Community Solar Pilot Program IPC-E-16-14
Dear Commissioners,
Thank you for the opportunity to provide comment on the revised proposal for Idaho Power Company 's
Community Solar Pilot Project.
We appreciate Idaho Power Company for working with the Sierra Club and other stakeholders to advance
a pilot project to expand energy choices to customers.
Community solar is taking off as electric utilities seek to address changing customer preferences, gain
experience with operating solar, take advantage o f optimizing the benefits of distributed generation
resources within their service tenitory, improve distribution system resilience and reliability within the
load zone, hedge against fuel price volatility, reduce carbon emissions, and invest more energy dollars
into local economies.
During the recent settlement discussions, diverse stakeholders worked together to improve the initial pilot
offering to (1) expand opportunities for customer participation by lowering the upfront subscription fee
and providing a monthly payment option, and (2) improve the methodology used to value solar
generation.
Sierra Club enthusiastically supports the proposed Community Solar Pilot Project outlined in the
Settlement Stipulation as a launching point for community solar in Jdaho. We believe the revised proposal
is in the public interest as it addresses changing customer preferences and represents a valuable
opportunity for Idaho Power Company to learn about benefits that can offered by clean distributed energy
resources located throughout their service te1Titory. A successful first pilot project will open the door for
additional community solar to be developed strategically and incrementally (as needed) within the service
territory. We believe community solar is a valuable opportunity for utilities to explore how solar, and
other distributed energy resources, can help improve power quality, grid resilience, and defer or eliminate
other investments in the distribution system.
Community Solar Addresses Changing Customer Preferences
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We believe the proposed community solar pilot is in the public interest as it expands customer choice.
Demand for clean energy is rising in Idaho as customers seek to realize the numerous benefits offered by
clean distributed energy resources. Net metering is growing fast and solarize programs in the Treasure
Valley and Blaine have been met with signifi cant interest. Major energy consumers in Idaho Power's
service territory increasingly prioritize clean energy acquisition, including the City of Boise, Boise State
University, Hewlett-Packard (which recently ado pted a 100% clean energy goal), and others.
As demand for clean energy grows, electric utilities aro und the country are increasingly offering
community solar choices to customers. Accord ing to a recent survey conducted by SEPA, 89% of electric
utilities currently or are actively considering/planning for community solar product offerings. Last year
the number of community solar programs in the U.S. increased by 80%, and this year another 79
programs are scheduled to come online.
This pilot project can help meet the growing demand fo r clean energy in the marketplace by providing
additional clean energy choices.
Community Solar Facilitates Valuable Learning
Rapid technology change is transforming the electric utility industry. Community solar is a vehicle to
explore challenges and opportunities presented by the proliferation of cost-competitive distributed energy
resources. Significant uptake in the use of DERs, such as small and medium scale PV solar, warrant
electric utilities expanding their knowledge on how distributed generation can affect grid resilience and
power quality.
As mentioned above, one of the fundamental benefits of solar PV is that it can be sited incrementally and
strategically within the service territory. In the past, traditional large-scale thermal generation was
necessarily site constrained, often located far from the load that generation would serve. This rendered a
vast and expensive network of transmission and distribution wires that today account for the majority of
Idaho Power's rate-based investments. Community solar is an oppo1iunity for Idaho Power to explore
how DERs can help defer, reduce, or eliminate investments in additional poles, wires, and transformers.
The proposed pilot is a valuable opportunity to begin exploring utility-private party arrangements as a
first step in exploring how private capital can be leveraged for public good and utility planning. For
example, additional community solar offerings might be developed on big-box stores at strategic
locations.
These are just a few of the areas that warrant research into how DERs are changing the traditional electric
utility landscape.
Conclusion
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Conclusion
We believe the proposed Community Solar Pilot Project is a win-win for Idaho Power Company,
customers, and our climate/environment, and local economies. The experience !PC will gain from this
pilot project will be a benefit to all customers. We appreciate Idaho Power Company's working with
diverse stakeholders to advance mutual interests.
Thank you for the opportunity to comment on this exce llent proposal.
Sincerely,
Zack Waterman , Director
Idaho Chapter of the Sierra Club
Cc: Michael Heckler
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CERTIFICATE OF SERVICE
I,~......A tf~certify that on this 18th day of October 2016, I delivered true and correct copies of
th~MMENTS 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]
dockets @idahopower.com
[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]
IIPA
Eric L. Olsen
Echo Hawk & Olsen PLLC
505 Pershing Ave., Suite 100
Pocatello, Idaho 83205
[e-mail]
Anthony Yanke!
29814 Lake Road
Bay Village, Ohio 44140
tony@yankel .net
SRA
Ken Miller Snake River Alliance
PO Box 1731
Boise, ID 83701
[e-mail]
ICL
Benjamin Otto
Idaho Conservation League
710 N. 61h St.
Boise, ID 83702
[e-mail]
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