20161019Settlement Comments.pdf

SNAKE RIVER
ALLIANC CEIVED
IDAHD'S NUCLEAR WATCHDOG & C LEAN ENERGY A'2~~~T 19 Mi 9: 03
October 18, 2016
To: Idaho Public Utilities Commission
From: Ken Miller, Clean Energy Program Director, Snake River Alliance
Re: Snake River Alliance Comments In the Matter of Idaho Power Company's Application to
Approve New Tariff Schedule 63, a Community Solar Pilot Program.
Case: IPC-E-16-14
Dear Commissioners,
On behalf of the Snake River Alliance, its Board of Directors, and its members in Idaho Power
Company's service territory, we appreciate this opportunity to comment on the above-referenced
case. These comments are submitted pursuant to the Commission's Notice of Settlement
Stipulation and Notice of Comment Deadline, Order No. 33616.
As a party in this case and a participant in the Settlement Stipulation to modify Schedule 63
(Community Solar Pilot Program) as proposed in the Company's Application, the Alliance
reiterates its support of the Stipulation and offers the following comments:
The Snake River Alliance is a long-standing advocate of solar energy and its adoption by Idaho's
electric utilities and their customers. Our efforts to expand solar power in Idaho include our
successful sponsorship of the "Solarize the Treasure Valley" campaign to facilitate greater solar PV
participation by identifying and introducing potential residential and commercial solar PV clients
to solar PV installers in Southwest Idaho and adding significant amounts of new rooftop solar PV
generation onto Idaho Power's grid.
We believe the Company's proposal is a reasonable beginning for what all acknowledge is a
complex discussion of how to craft a community solar project that is most affordable and
accessible to all eligible Idaho Power customers eager to participate in this pilot project, while
simultaneously advancing the larger goal of greater solar power integration into Idaho Power's
system.
Box 1731 D BOISE, ID 83701 I 208.344.9161 Box 425 I POCATELLO, ID 83204 I 208.233.7212
WWW.SNAKERIVERALLIANCE.ORG
It is clear that those participating in and commenting on this case share the goal of developing a
program accessible to customers who for various reasons cannot or do not avail themselves of
other clean energy resources such as net-metered rooftop solar PV. Judging by the successes
shown by similarly situated utilities nationwide that have already produced community solar
programs, it is also clear that a carefully crafted Idaho Power community solar program should be
attractive to customers who, as Idaho Power states, desire access to clean solar power.
We are pleased that Parties in this case were able to satisfactorily craft a Settlement Stipulation
that address Parties' concerns regarding such issues as calculation of the program's solar energy
credit; its subscription fee and payment terms; and the Company's cost recovery. We commend
Idaho Power for its flexibility and willingness to hear suggestions about the program's design. The
billing and payment options reflect a good compromise of the various proposals presented by
Parties.
As the Alliance asserted in its Sept. 1 comments to the Commission, we remain concerned about
the lack of access to this program by Idaho Power's low and fixed-income customers. We reiterate
here the concerns we raised in those comments:
Inasmuch as the ability to afford participation in a community solar pilot project is central to
this application, we encourage stakeholders to more creatively explore avenues to include
Idaho Power customers on low or fixed incomes to participate in the pilot. Such mechanisms
have been identified in community solar programs elsewhere, and we believe the success of
this program requires a similar effort. Idaho Power should be commended for staking a 15
percent share of this pilot from its shareholders, and that could be one source of funds for a
low-income "carve-out" of sorts to enable certain customers who might not otherwise be able
to participate to do so. For example, Oregon has considered sequestering 10 percent of the
generating capacity from community solar projects to benefit low and fixed-income
customers ....
We also stated in our comments:
The George Washington University Solar Institute explored this issue in depth in 2014
[http://solar.qwu.edu/research/state-policies-increase-low-income­
communities0/0E2y080y099-access-solar-power) and among its key take-aways:
Low-income households in the US spend a higher percentage of household income on energy.
Solar power could reduce the energy burden of low-income households by providing
electricity that is less than what utilities charge.
Low-income households face several barriers to going solar, including: difficulty meeting
credit requirements for financing or leasing, status as a renter, and inability to benefit from
tax credits or other incentive programs.
California has several successful programs and initiatives designed to support solar
deployment to low-income families. The California Solar Initiative [CS) sets aside $216 million
to support the Single-Family Affordable Solar Housing (SASH) and Multifamily Affordable
Housing (MASH) that subsidize solar systems for low-income households. California also used
LI HEAP funds to help support solar installations for LI HEAP eligible families.
Louisiana lacks public support and finance for low-income solar programs, but leasing
company PosiGen has developed a model that leverages state tax credits and secures
financing on community redevelopment terms.
Colorado's 2010 Community Solar Gardens (CSG) Act allow homeowners who without a
suitable roof or space to purchase shares of a solar installation. The Act requires that at least
5 percent of the electricity from the CSG be reserved for low-income families in order to
qualify for solar renewable energy credits [SRECs).
California, Louisiana, and Colorado's low-income solar policies and programs can serve as
models that can be replicated in other states.
We acknowledge the Commission is not bound to address concerns and challenges facing Idaho's
low-income and fixed-income communities, and in today's regulatory framework in Idaho, neither
is Idaho Power. However, we remind the Commission and Idaho Power that most states that have
adopted community solar programs have also identified means to allow all utility customers,
including if not especially those of limited means, to participate in those programs. This pilot
program should be no different, and sequestering the funds for such participation, as identified
anecdotally above, is both achievable and desirable. Otherwise, we continue to run the risk of solar
power, which is sought by all customers, only being available to those in higher income brackets.
The Alliance believes that clean, affordable, and environmentally responsible electricity should be
equally available to all utility customers and not be treated as a "boutique" energy resource. Idaho
has the regulatory authority to ensure equal access to this clean energy resource by all classes of
utility customers and to make such access affordable to all -and we believe such authority should be
exercised in this case and reflected in the Commission's order approving this settlement stipulation.
We urge the Commission to direct in its order that Idaho Power acknowledge and address the needs
and desires of all of its customers, regardless of their income levels, aspiring to participate in this
program.
Conclusion
As stated in our Sept. 1 comments to the Commission, we agree with Idaho Power that utility
customers who choose not to participate in the program should not have undue costs shifted onto
them from those who do participate. However, we do not believe such a cost-shifting threat exists
in this community solar pilot project, and we believe this community solar program has the
potential to deliver real benefits to all customers regardless of their participation in the program.
There are known and provable system-wide benefits that a community solar program delivers to
all customers, including the delivery of capacity-valued power to the system during times of
highest demand and a lowered need for other, marginal, resources.
In addition, we believe that this Settlement Stipulation, as well as the Alliance's recommendations
to the Commission regarding solar power accessibility to varied income groups, furthers the
objectives of the 2007 and 2012 Idaho Energy Plans as adopted by the Idaho Legislature.
The Snake River Alliance appreciates this opportunity to comment on IPC-E-16-14 and the
dedication by all parties to reach this settlement stipulation. We look forward to seeing a
successful completion of this pilot program for all interested in participating.
Respectfully submitted,
Ken Miller
Clean Energy Program Director
Snake River Alliance
P.O. Bo 1731
Boise, ID 83701
[phone]
[e-mail]