20170829Comments (2).PDF

Diane Holt
From:[e-mail]
Sent:Friday,August 18,2017 9:40 AM
To:Beverly Barker;Diane Holt;Matthew Evans
Subject:Case Comment Form:Stephen White,CFA
Name:Stephen White,CFA
Case Number:IPCE1713
Email:[e-mail]
Telephone:[phone]
Address:3778 Plantation River Or,Suite 102
Boise ID,83703
Name of Utility Company:Idaho Power
Comment:As a financial advisor who is often contacted for advice on whether to install solar panels,I am deeply
frustrated at Idaho Power’s recent filing.It sheds no light on the value of solar,all it does is sow confusion and
uncertainty.That level of uncertainty is made worse and more permanent by proposing a policy that customers
investing in on-site generation products offered by Idaho Power’s few competitors will be put in a tiny separate class
which will thereafter be vulnerable to discriminatory rates and fees.
Let’s go back to a fundamental principle of investing —the greater the risk,the higher the potential return needs to be to
motivate investment.By proposing a policy that increases the risk of solar investments,Idaho Power is unnecessarily
discouraging investment in solar.To be clear,there is always some level of uncertainty in investment decisions and
specifically with electricity rates,but Idaho Power’s proposal to put net metering customers into their own tiny class
creates a disproportionate level of risk and uncertainty for prospective solar customers and the businesses that serve
them.
For example,a non-profit board asked me to present last night my recommendations regarding the installation of a solar
array to offset a portion of their electric bill.At least half the discussion and the majority of the concerns centered on
the filing before the PUC,including a wide range of speculations on how the economics of the investment might change
in the future.The Board’s readiness to invest in a solar array was markedly affected by the discriminatory tone and cloud
of uncertainty created by this filing.
In this filing,prospective solar customers are being told that installing an array of ANY size will thereafter make them
vulnerable to discriminatory rate structures,that Idaho Power would like to change the economics of the investment the
customer is considering,but that Idaho Power doesn’t have the evidence to propose fair policies.
In terms of credentials,I have an undergraduate degree in finance,an MBA from Harvard,and hold the Chartered
Financial Analyst (CFA)designation -I believe I qualify as an economically logical person,and this filing lacks logic.Idaho
Power’s real concerns are revealed by its focus on “On-Site Generation,”which is not the issue.The Company also uses
the filing to reiterate its long-term concern that it recoups fixed costs via volumetric pricing,which,as I understand it,was a strategic move by the PUC to encourage energy conservation.In any event,it is a concern not specific to IdahoPower,and certainly not specific to net metering.
Net metering customers should remain in their current rate classes.They should be free to buy kWh off the grid and paythesamemonthlyandvolumetricratesasotherstandardcustomers.Concerns over cost shifting should prioritize thebigdollars,and —only if it’s demonstrated as truly material -any concerns over the value of kWh put back on the grid
should focus on determining value,including the benefits of solar and the timing at which it is generated.Discriminatory
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policies like this one before the PUC create disproportionate and unnecessary risk for prospective investments in solar,
and it’s a job killer for this young and vital industry.
Unique Identifier:67.42.72.103
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Diane Holt
From:[e-mail]
Sent:Wednesday,August 23,2017 10:30 PM
To:Beverly Barker;Diane Holt;Matthew Evans
Subject:Case Comment Form:Jedidiah Thomet
Name:Jedidiah Thomet
Case Number:IPC-E-17-13
Email:[e-mail]
Telephone:[phone]
Address:11101 W.Sandhurst Dr.
Boise ID,83709
Name of Utility Company:Idaho Power
Comment:I am writing both to provide my input in this matter,as well as to request a public hearing so that otherconcernedstakeholdersmayexpressopinionstothePublicUtilitiesCommission.
In short,I respectfully request the Commission to deny Idaho Power’s request in its entirety.My reasons for thisrequestareasfollows:
First of all,Idaho Power’s proposal to close existing Schedule 84 to new service (while allowing existing customers toremainonthatrateplanforanindeterminateamountoftime)is a shrewd attempt at incrementally chipping away atdistributedenergyproduction.If Idaho Power wants the public (and the Public Utilities Commission)to agree with thisplan,why can they not be up-front and honest about what the plan (and its timeframe)really is?Before asking theCommissiontoagreetoanyproposal,I believe Idaho Power should present specific details --including a timetable fortheeliminationofexistingrateplans.
Second,the entire question of how long existing customers can remain on Schedule 84 billing is only important becausetheratesproposedinthetwonewrateschedulesareoutrageous!If I had been placed on the proposed Schedule 6whenmyPVsystemwasbroughtonline,my monthly bills would have been 24-26%higher (until we hit peak generationseason,and my solar generation finally caught up with my family’s usage).The proposed Schedule 6 represents anexcessiverateincreaseforthosecustomerswhosePVsystemsareinsufficienttogenerateasmuchpowerastheyuse.
Idaho Power’s application suggests net metering customers need to pay a larger portion of the maintenance costsassociatedwith“the grid”.They further argue that the net metering customer’s failure to pay “their fair share”of thesecostsrepresentsawealthtransfer.To the extent that this is true,it appears that Idaho Power is failing to recognize thattheirproposedratescheduleswillestablishyetanotherwealthtransferwithintheclassofnetmeteringcustomers--from those whose installed PV systems do not cover all of their power consumption to those whose systems do.(Charging more for the power used,while reducing the size of the bottom rung of the tiered plan will only impact thosewhocannotreachanetzerousage.)The entire way the rate plan is structured serves as a disincentive to anyone whoonlyseekstoinstallsolartoreduce(but not eliminate)their power bill.One wonders if the cooling of solar PVinstallationsthroughsucharateincreaseisnottherealintent.
Idaho Power’s intent aside,it does not take much foresight to see the unintended consequence that the proposed rateplanswillhave:they will encourage a “rush to zero”on the part of those who choose to install solar PV systems in ordertoavoidtheconfiscatoryrates.This will further exacerbate Idaho Power’s complaint that net metering customers arenotpayingtheirshareofthegridmaintenancecosts.This is ironic,since last year’s proposed solution was a massiveincreasetothefixedinterconnectfee.While a modest increase to this fee may be justifiable,a fourfold increase hardlyseemsappropriate.If Idaho Power truly wants net metering customers to pay more for the fixed grid costs,it seems
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that a smaller increase to the interconnect fee (possibly phased in over a longer time frame)would do more to address
this issue without completely removing the financial incentive to installing a solar PV system.
Finally,I want to comment on the gap between peak generating and peak demand that Idaho Power’s application
suggests is a key reason to make these changes now.Nobody contends that solar PV systems peak generation leads
peak demand by 2-3 hours,as Figure 2 of Angell’s filing demonstrates.But,there are ways to creatively address that gap
without resorting to discouraging customers from installing on-site generation.For example,Green Mountain Power,autilitiesproviderinVermont,has implemented a plan to subsidize a portion of the customer’s cost of
purchasing/installing a Tesla Powerwall 2 energy storage device with the intent that the distributed storage can be used
to augment the grid’s capability during peak demand times.If Idaho Power sought to partner with the net metering
community,instead of stifling its growth,I’m sure that together we could produce some innovative solutions to the
challenges of tomorrow.
As I said,I urge the Commissioners to reject this application.There are better ways to address some of Idaho Power’s
stated concerns than what they’re proposing.Thank you for your time and consideration.
Unique Identifier:96.19.4.72
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