20170816Comment.PDF

Diane Holt
From:Diane Holt
Sent:Wednesday,August 16,2017 11:05 AM
To:Diane Holt
Subject:Comments on idaho Power Case #PC-E-17-13
Case #IPC-E-17-13
First name:Joe
Last Name:Weatherby
Address:3624 S.Midland Blvd.
City:Nampa
State:ID
Zip:83686
Daytime Phone:
E-mail:Joeweatherby(),gmail.com
Name of Utility:Idaho Power Company
My comments below:
I respectfully request a public hearing for the PUC commissioners to hear comments from the public.My
comments are as follows.
General comments:
This request by Idaho Power is unnecessary,ill-advised and punitive toward all customers who,using their
own invested funds,have or will invest in customer owned electrical generation,most commonly,solarpanels.Idaho power asks you to require customers to upgrade at an unknown cost for unspecified andquestionablereasons.They indicate there will be no pricing changes at this time.One must question whynot.If the need for a new and separate group actually exists,then it is irresponsible of the company not torequestsuch.If Idaho Power actually suggests that this class is needed to determine the need then thatsuggestionisfraudulent.It is called,data analysis.They already know what customers are classified,it issimplyamatterofanalyzingthedata.
If Idaho power does not have the capability to analyze the data then I would suggest they do have the expertisetoremainagovernmentsupportedmonopolyandtheenergygridshouldbede-regulated to encourage opencompetitionwhichisthebestwaytokeeprateslow.One would think in such a conservative state as Idaho thatwouldbethedefaultmodeforelectricutilities.This case only emphasizes more reasons why deregulation isthebestwaytoproceed.
Finally,given the fact that this case is so unnecessary and transparent,the commission should insist that IdahoPoweraccumulatethedetailbehindthisratecaseandsubmitthecostdetailforpreparationandargumentofthiscasesothatthosecostscanbebornonlybythestockholdersandbedis-allowed from being reimbursed byIdahopowercustomers.
Page 2 #3
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Idaho Power asks the commission to force an unknown and future burden to R&SGS customers for a vaguebenefitandanunknowncostinaveryshorttimeframe,60 days.This should be denied.There is adequatetimewhenengineeringstandardschangetoevaluatetheimpactofexistingequipmentanditisunreasonable andevenunwisetoforcesucharequirementoncustomerswhohaveinvestedsubstantialcostsintoequipmentonlytofindthemselvespotentiallyunabletoevenfindequipmentwhichmaycomplywithyettobedeterminedrequirementwhichmayormaynotbenecessaryorevenbeneficialforthegrid,or other customers.The shorttimeline(60)days would most certainly impose an unnecessary cost on all of the R&SGC customers given itlikelytakessometimeforhardwaretocatchupwithengineeringstandardsindustrywideandwouldthushave atendencytoreducecompetitionwhichwouldincreasethecoststoretrofitolderequipment,let alone the cost ofnewequipment.This is simply another means for Idaho Power to attempt to kill the expansion of solarinstallationsforunknownreasons.
Page 4 Section 4
Net metering customers are only credited in KWhrs in the billing cycle when they are put back into the grid.Idaho Power also bills their neighbors for those kwhs received from the net-metering customers simultaneouslyandduringthesamebillingperiod.If and when net-metering customers use all of their kWh credit at somefuturedate,they receive no interest on the kwh loan they have provided to Idaho Power who has already soldandcollectedthemoneyfortheloanIdahoPowerreceivedfromthenet-metering customer.Idaho Power hasalreadybeingover-compensated because there was no power generation investment,power transmission norvirtuallyanydistributioncostsinvolvedintakingSolarPowerfromonecustomeranddeliveringittotheirneighborafewfeetawayfromthesolarcustomer.Idaho Power should be required to pay a fair rate of interestonanykwhcreditanetmeteringcustomercarriesover.
Page 5 Section 7
If the existing rate structure creates inequity between net metering customers and standard service customersthenitalsocreatesaninequitybetweencustomersthatinstallnewefficientappliances(like an air conditioner orheatpump)and standard service customers (SSCs).Idaho Power’s so called “wealth transfer”from the poor totherichhappenswhenevera“higher income”customer upgrades heating/cooling,lighting,or other applianceswithamoreefficientmodel.The only time this so called “wealth transfer”doesn’t happen is when a “higherincome”customer buys an electric vehicle that will increase Ms/her household electricity usage.Flow doesIdahoPowerplantoeliminatetheseothersocalled“wealth transfers”to be “fair”?
I personally know many Idaho Power net metering customers and I do not consider any to be “higher incomecustomers”.All of the net metering customers I know have incomes far less than the average salary of IdahoPoweremployees,even without considering the extravagant bonuses paid to Idaho Power employees and themostextensivebenefitspackageanywhereistheregion.
Is Idaho Power trying to start a class war by this filing?To be “fair”,should customers pay based on theirenergyusageortheirabilitytopay?Will customers have to provide tax returns and bank statements before theyaregivenservice?
Yes,there is a “wealth transfer”going on here.It is from the all the customers to Idaho Power’s Officers,BoardofDirectors,Employees,and shareholders,all of which are compensated beyond any rational yard stick for thisarea.
Page 6 Section 9
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By what method is Idaho Power using to project future net metering customers?Based on past projections of allsortsofdifferentitems,they have likely inflated these numbers to benefit their case.
Page 8 Section 13
It is true that the two-way flow of energy is unique and fundamentally different than a non-net meteringcustomer.In the case of small hydro the power could be generated 24 hours a day and the value of thatelectricitywouldchangeduringthattimeperiod.Wind power could be generated at different times throughouttheday.Solar power will only be generated during the day time and in many cases during peak power time.Thevalueofeachofthesenetmeteringoutputsisdifferentbasedonwhattimeofdayandwhattimeoftheyeartheyaregenerated.Idaho power should compensate the producers for the increased value ofthe power based on thetimeofdelivery.
Page 8 Section 14
The load shape of residential net metering (RNM)compared with residential standard service (RSS)shows thebenefitofgenerationduringpeaktime.It also shows an increase of use in the evening and early morning.Thisislikelyduetothechargingofplug-in vehicle.Many RNM customers own or lease plug-in vehicles.IdahoPowercanandshouldincentivizeplug-in vehicle owners to plug in whenever it will benefit the electrical gridandallcustomers.
Page 9 Section 15
This section would ask the commission to believe that the Idaho Power’s Data analysis it so weak that it cannotanalyzethedifferentkindsofcustomerswithouthavingadifferentcustomerclass.Again,if Idaho Power’s dataanalysisabilitiesaresoweakthenthecommissionshouldimmediatelyde-regulate the electrical utilities inIdahotoallowcompanieswithmorerobustdatafacilitiestocompete.That would quickly eliminate this issue.
If Idaho Power can analyze the data then they should do so,and present that quantitive analysis as reasonedproofofwhattheyprofess.In that manner,the public and the commission could properly consider the case andmakeaninformedandproperdecisionaboutsuch,rather than this thinly veiled attempt to put unreasonable andunwiseoverheadoncustomersfor“doing the right thing”.
The reality of this request is fairly delineated in the sentence,“This is the first step”.I believe the first step is toactuallyanalyzethedataandpresentasthereasontomakechanges,not hiding the actual intent of theapplication,and this alone should be reason enough to deny this application.
If new customer classes are installed for customers with on-site generation to provide data,all types ofgenerationmustbeassignedadifferentclassinorderforthedatatobemeaningfuland“fair”.That wouldnecessitateaclassforhydro,biomass,fuel cells,geothermal,wind,and solar.The value of all of these types ofgenerationvariesgreatly.
To be “fair”time of use metering or better yet real time metering can be used to charge all customers based onthecostofgenerationatthetimeofuse.
Does this also mean in “fairness”there should be rural and urban rate designs?The grid operation andmaintenancecostsaremuchlessinurbanareasthanruralareas.Is there “wealth transfer”going on currentlybetweentheurbancustomertotheruralcustomers?How should this be addressed,in fairness?
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Page 12 Section 21
We are currently,and even in Idaho Power’s future growth estimate nowhere near a “high penetration”of net
metering customers or their nameplate capacity thus this argument is ridiculous and non-sensical.
Page 13 Section 21
The timeline on this section,(60 days),would potentially place an unreasonable and unnecessary burden on
individual producers.Each upgrade of the IEEE change should be handled on an individual bases and not be
provided as an open invitation for Idaho power to unreasonably penalize small producer customers.
Proposed New Schedule 6
Any credits that are given back to Idaho Power should be used to reduce the rates of all customers.They should
not be retained by the company to further engorge their profits.An example would be when a net-metering
customer moves to another state.
Point #6-
It is not currently technically possible for a small generation net metering customer to curtail production.This
paragraph should be removed.
David Angell Testimony
Page 8-Line 17-24
It is true that most on-grid inverters will not function without the grid present.This is by design to protect utilityworkersfrompossibleelectrocution.The inverters will not feed power into the grid when the grid is
down.This does not in anyway show the grid supplies any benefit to customer generator systems,but the
inverse.
Page 9-.
It is misleading to state that most inverters are not sized big enough to run air conditioners,pumps,andhouseholdmotorswithoutbeingconnectedtothegrid.Most modern inverters have the reactive energy to startthesedevices.I have run a whole house heat pump year round with a 4 kW inverter without being connected toIdahoPower’s grid.This testimony,again shows improper and incorrect infonnation supplied improperly tothecommissiontoboostIdahoPower’s case.
Page 12-
The graph shows the contribution the net metering customer makes to power his/her neighbor during the middleofthedaywhichisabenefitsuppliedtoIdahoPowerandisuncompensatedtothenetmeteringcustomer.Thenetmeteringcustomershouldbecompensatedforprovidingsomuchpeakenergy.
Page 13-
The graph shows the contribution the net metering customer makes to power his/her neighbor during the middleoftheday.Idaho power would profess that the use of the distribution system by net-metering customers duringthedayisabenefittothenet-metering customer,the opposite is true,it is a benefit to Idaho Power,and theircustomerduringthehighestpeak.Net metering customers should be compensated for supplying that need high
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cost area.Net metering customers are being cheated out of the true value of the power supplied to Idaho Power
customers.
The smart meter testimony sounds like Idaho Power wants net metering customers’equipment to solve the lowvoltageproblemtheyhavehadwiththegridforyearsattheexpensiveofthenetmeteringcustomers.Idaho
Power should pay the additional cost for a “smart inverter”to fix their low voltage problem if that is the
solution they seek.Having farmed in Owyhee county for years it was a very very common occurrence forpumpstoberesetduringpeakpowertimes.The pump would turn off and likely not be reset till much later intheday.This has been a known practice for many many years.It is unlikely those resets were
accidental.Idaho power should be compensating net metering customers for helping this dirty power problem.
Connie Aschenbrenner Testimony
Page 16-
If there are 1,468 current and pending net metering customers,why was only 830 invitations for the workshopweresentout?
Page 30-
Figure 4 is a good example of the benefit of solar net metering customers.They act as demand side managementduringmostofthepeakhoursintheafternoonreducingtheamountoftimeexpensivegaspeakerplantsareutilized.In most cases Idaho Power pays customers for demand side management.Net meter customers shouldbecompensatedforthatassistancewithdemandsidemanagement.
Page 30-3 1
The vacation home example doesn’t hold water.Both the vacation home and the net metering home are hookeduptothegrid.The wires and distribution system must be maintained regardless of usage.The power poles andwiresdon’t degrade at a different rate depending on the electrons used.Further,much of Idaho Power’s casereliesonthesupposed,yet unsupported,issue surrounding unpredictable usage of the grid.Nothing could belesspredictablethanthepowerusageofavacationhome.This just further illustrates the irrational andunreasonablepositionofIdahoPoweragainstnetmeteringcustomers.
Page 31-
In the case of energy efficiency as compared with net metering solar customers.The solar net meteringcustomerproductionfallsmostlyduringpeakpowertimesavingIdahoPowermoremoneythanenergyefficiencythatfallsthroughouttheday.This peak generation provides Idaho Power much more value than thenetmeteringcustomerisreimbursed,and is not a burden on the system,but a benefit to the system.The powerwhichissuppliedthroughdistributedgenerationreducestheloadonalmostallofthedistributionsystemandallofthetransmissionsystem.The net metering customer is not now,but should be compensated for thatbenefit.The actual situation is exactly the opposite of what Ms.Aschenbrenne tries to promote here.
Page 35-
Idaho Power already profits enough from net metering customers.They have received an interest free kWh loanfromthenetmeteringcustomerinwhichtheyselltoanothercustomer,billing and making a profit instantly.This loan may or may not have to be repaid in the future.If repaid there will be no interest.For solar netmeteringcustomers,they give a loan of peak power in the summer season (expensive generation for IdahoPower)and if they pay that loan back it is normally paid back with non-peak power in the winter season(inexpensive generation for them).It is hard to understand why they want to collect even more profit from theserenewablegenerators.In addition,if Idaho Power would embrace distributed net-metering customers rather
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than try to eliminate it most certainly would substantially reduce the need for expanded transmission and
distribution upgrades as the power produced is used very close to the generation.Net metering customers are
not being compensated for this situation currently,but should be in the futuer.
Page 36-
Regarding the customer comment about his/her $5.27.How much did the customer pay for the system?How
much did this system save Idaho Power from building new generation,new transmission,transmission
upgrades,and distribution upgrades?Idaho Powe?s vision is very short sited indeed and is targeted to push
costs and company investment as high as possible which ultimately results in higher rates.This is exactly theoppositeofwhatisdesiredbyIdahoPowercustomers,and the duty of the Idaho Public Utilities Commission.
Slide show-Shows 526,000 customers and only 1,468 current and pending net metering customers.The netmeteringcustomersareasmallfractionofthetotalcustomers.Future growth is not guaranteed.Why are
customers wanting to net meter?It is not a purely economic decision.If it were,nobody would do it.It is mostlybasedonwantingtoreceive100%renewable power,which Idaho Power doesn’t offer.Net metering would be anon-issue if electric utilities were deregulated in Idaho.Then customers could elect for 100%renewable
generation through the utility company of their choice.A good example of how it works in another conservative
state would be Texas that has literally hundreds of plans a customer can choose from.It appears to be time to
start discussing deregulation in Idaho.
Timothy Tatum Testimony
Page 15-
A case cannot be made without real customer data (including income and wealth of all customers)that the lower
income customers are transferring wealth to the higher income customer.It may actually true that the lowerincomecustomersareinstallingsolarpanelsandbecauseofthattheymaybetransferringwealthtothehigherincomecustomersthatdonotchoosetoinstallsolarpanels.The investments net metering customers makecouldbesavingallofcustomers’money.They should be compensated for this.
If Idaho Power is truly concerned that lower income can’t have solar on their homes they should start a programforthelowerincomecustomerstoreceivedareducedrateloanthatwillbepaidoffaspartoftheirelectricbill.
Page 25-
States that the payback period for a net metering solar system is 15 years.This proves the point customers arenotelectingtodothisforeconomicreasonsbutlikelyforreasonsrelatingtoreducingtheirpersonalcontributiontoglobalgreenhousegasesbecauseIdahoPowerrefusestogivethemthe100%renewable powerwhichtheydemand.
Exhibit 3
Page 2-
Does shows solar’s growth.What was missing from Timothy Tatum’s Testimony was that the majority of thegrowthisfromutilitysolarprojects.It is likely customer’s would not install solar on their roofs if Idaho Powerdeliveredsolarpowertotheirhouses.
Page 4-
Confirms it is most expensive for net metering customers to have solar installed themselves but they have fewotheroptionslivinginIdahoPower’s service area.
Page 5-
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Shows Idaho is not even in the top 10 states for installed solar even though Idaho has excellent potential forgeneration.
Page 7-
Future growth is estimated to come mostly from utility scale solar projects not residential installations.
Exhibit 5
Obviously this article was written for the purpose of electrical utilities being able to unreasonably harm netmeteringcustomers.It even includes an estimate for Idaho Power.It lists no references of where this numbercamefromorhowitwasfigured.This is not a peer review article and should not be allowed as part of thetestimony.
The article does not address the Idaho Power current model for crediting surplus generation by the kWh but bytheretailrateperkWh.This is not comparing apples to apples.
The article does point out,“This time-of-use differentiation would provide rooftop solar owners with a fairercompensationfortheircontributiontothesystemneeds.Unfortunately,such distinctions are almost never madeintheprevailingnetmeteringpricingschemes.”
Exhibit 6-
A big question that did not seem to be addressed is what will happen to the commercial net metering customers,if anything.They are currently using Schedule 84 up to 100 kw of nameplate generation?Will Schedule 84 stillbeusedbythem?
Thank you for the opportunity to comment.!
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