20180307Comments (10).pdf

IDAHO
PUBLIC UTILITIES
GOMMISSION Public Hearing
lPc.E-17-13
Pocatello, ldaho
315118
WHAT DO YOU THINK?
If you cannot or do not want to testify in person at this hearing but want your opinion noted,
please use the space below to write your comments. Add extra sheets as needed.
You may either hand this sheet to a commission staff member or mail it to:
!PUC, PO Box 83720, Boise, lD 83720-0074.
You may also post comments on our web site:
Go to vwwv.puc.idaho.qov and click on the "Case Comment Form" link.
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lPc-E-l7-13
Boise, ldaho
311118
WHAT DO YOU THINK?
lf you cannot or do not want to testify in person at this hearing but want your opinion noted,
please use the space below to write your comments.
Add extra sheets as needed.
You may either hand this sheet to a commission staff member or mai! it to:
IPUC, PO Box 83720, Boise, lD 83720-0074.
You may also post comments on our web site:
Go to wvv\ry.puc.idaho.qov and click on the "Case Comment Form" link.
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IDAHO
PUBLIC UTILITIES
COMMISSION Public Hearing
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Commissioners
Idaho Public Utilities Commission
P.O. Box 83720
Boise, Idaho 83720-0074
March 5,2018
RECEIVED
201$ l{iR -7 A}t B: S0
lli;'riiir PtiijLlCll ll i'' ltSr CCt{lllSSlON
Regarding IPC-E-17-13
Dear Commissioners,
In this written testimony I would like to add four thoughts that I left out of my verbal
testimony March 1.
l) Idaho Power exaggerates when it suggests that net metering customers create a
"wealth transfer" that is "not fair" to Idaho Power non-net metering customers.
In Exhibit No. 5 of Timothy Tatum's testimony in support of Idaho Power's filing, Figure
1 shows a ooNet Metering Subsidy Estimate" of $444 per year or $37 per month.
When this subsidy is spread over 534,534 Idaho Power customers, each non-net metering
customer is subsidizing each net metering customer $0.0000692 per month. This about
one ten-thousanth of a penny per month.
When the subsidy for the whole group of 1,468 net metering customers ($54,316 per
month) is spread over 534,534 Idaho Power customers, each non-net metering customer
is subsidizing the entire class of net metering customers ten cents per month.
Net metering creates no financial burden on any customer.
2) With the increased fees and charges that we can reasonably expect Idaho Power to ask
of net metering customers, I risk paying more with solar than I was before I installed
solar. My Idaho Power bills averaged $42 per month for the twelve months before I
installed solar on my residential rooftop. In Adam Richins' guest opinion published
August 13,2017 in The Idaho Statesman, this Idaho Power vice president of customer
operations wrote, "lt costs...approximately $65 per month in total- for Idaho Power to
supply grid services to the average residential customer." If Idaho Power asked for and
was granted $65 per month from me, a solar net metering customer, I would be paying
$23 more per month after installing solar than I was before I installed solar. This feels
unreasonable to me.
3) In the context of the world in which we live in 2018, a world with ever increasing
greenhouse gases and increased climate mayhem, I would suggest that more incentives
are needed for solar and I propose that net metering customers receive double the
incentives beginning with the conclusion of this case. Instead of being credited one kWh
for each kWh generated in excess of usage, make it two kwh's credit for each kWh
generated in excess ofusage.
4) Many customers want clean, renewable energy, but Idaho Power gives us large
amounts of coal and natural gas energy. Idaho Power's monopoly is not working for us.
Perhaps we need deregulation- like Texans have. They can choose to get 100% of their
electric energy from renewable sources. I would like that choice as well.
Please reject Idaho Power's request in IPC-E-17-13 for a new rate class occupied solely
by net metering customers.
Thank you.
W<Yu,LLc(/-r
Reed Burkholder rburkholder2(g)gmail.com 208 323-8355
6105 Twin Springs Drive
Boise,Idaho 83709
Diane Holt
From:
Sent:
To:
Subiect:
[e-mail]
Wednesday, March 7,2018 1:44 PM
Beverly Barker; Diane Holt; Matthew Evans
Case Comment Form: Rob Hanson
Name: Rob Hanson
Case Number: IPC-E-17-13
Email: [e-mail]
Telephone: [phone]
Address: 2061 E Feldspar Court, Boise
Boise |D,837L2
Name of Utility Company: ldaho Power
Comment: Dear ldaho Public Utilities Commission Thank you for the opportunity to submit our response to Case
Number IPC-E-17-13 (ldaho Powe/s application to establish new schedules for residential and small general service
customers with on-site generation).
Our names are Rob and Annette Hanson and we have a home in Boise, ldaho. We do have solar panels on our roof, so
this proposed action directly affects our family.
ldaho Power (lP) argues that solar power owners through net metering don't pay their fair share of grid costs. However,
lP doesn't credit solar owners for expanding power generation capacity. We expanded the system by 3000 kilowatts at
our cost. ldaho Power's peak demand record occurred between 4 and 5 pm this past July 7. At that time we were not
only producing enough power to meet our needs we were also sending electricity into the grid helping meet that
demand. We did this all summer with the exception of six days. How can ldaho Power argue that we are a net detriment
to other customers?
When we send electricity into the grid it can go to our next door neighbor with negligible grid loss compared to losses
that occur when electricity is transported miles from a dam or power plant. Multiple studies performed by public utility
commissions and others found that net metering is a benefit to all users. Google "Bookings lnstitute net metering" tor a
summary article with links to the studies.
Since we moved to Boise in 1989 we have striven to do everything right by ldaho Power and its energy conservation
programs. We have paid into the Green Power program from its inception until 2013 when we installed our solar
panels. We don't have a clothes dryer, have purchased energy efficient appliances, changed to LED lightbulbs, and have
adopted other practices to reduce our electrical demand. We believe that we are continuing to be good stewards by
installing solar panels. But now ldaho Power is saying we don't pay our fair share.
Adam J. Richins of ldaho Power stated in an August t!,20L7 ldaho Statesman Guest Opinion stated that it costs "-
approximately SSS per month in total - for ldaho Power to supply grid services to the average residential customer."
Our ldaho Power bills before we installed solar panels averaged S31 per month. So apparently we were being subsidized
before we installed our panels. This doesn't make sense to me and raises a numerous questions about electrical rate
pricing.
As brought up by a number of speakers who testified at the hearing, creating a separate class system is not allowed -
not for the poor to give them a break, the rural farmer, or the expensive home in the foothills with huge windows, no
wind breaks, and that needs extensive lines to receive their power.
1
We are relying on the ldaho Public Utilities Commission and its technical staff to sort through ldaho Powe/s claims
about their proposed rate changes. lt seems like ldaho Power should look at home solar power owners as a partner is
supplying a stable supply of electricity to its customers. Pricing and managing a smart grid incorporating renewable
energy is complex and will benefit us all. Counting all costs and benefits will be critical to getting it right.
Thank you for your time and leadership in regulating our utilities for our future
Unique ldentifier: 24.LL7 .L33.249
2
Diane Holt
From:
Sent:
To:
Tutled3'[e-mail]
Wednesday, March 7,2018 1:25 PM
Beverly Barker; Diane Holt; Matthew Evans
Case Comment Form: David TuttleSubiect:
Name: David Tuttle
Case Number: IPC-E-17-13 83201
Email: Tutled3 [e-mail]
Telephone: 208229OLt4
Address:4095 W. Miners Farm Drive
Bise ldaho, 837L4
Name of Utility Company: ldaho Power
Comment: ldaho Power's claims are not valid. The cost benefits to ldaho consumers who use roof top solar are
beneficialto all ldaho citizens.
U niq ue ldentifier: 45.33.220.23
1
Comments to the IPUC
ldaho Power Case IPC-E-17-13
March 7,ZOLB
Hello, my name is Paul Hatab. I have been an ldaho Power customer for more than 30 years.
I would like to thank the IPUC commissioners for holding the public hearing in Boise on Thursday, March
1, 2018. You were all very attentive and respectful. Between the testimonies that night and all the
online comments, you have heard many cogent reasons to reject this proposal from ldaho Power. So I
will not restate those arguments.
But one observation struck me at the public hearings that I would like to share.
Everv sinsle testimonv at the public hearing was passionately against this proposal. I was somewhat
surprised at this as ldaho Power has tried to portray the PV (photovoltaic) home owners as a privileged
subgroup trying to "cost shift" some of their fixed costs to other customers. On August 13, 2017, ldaho
Power Vice President Adam Richins wrote a Guest Opinion in the ldaho Statesman in which cost shifting
was highlighted as the primary motivation for this proposal. He argued that the net-metering customers
were causing higher prices for the other customers. Therefore, I was curious whether any upset ldaho
Power customers would testify in support of the proposal and against the "unfaifl cost shift. But no
public testimony was offered in support of the ldaho Power proposal.
A few thoughts about ldaho Powe/s claim of cost shifting.
First, until the cost-benefit analysis is done, I do not accept that anv cost shifting is occurring. lt could
turn out to be a "savings shift''. The PV installations may delay (or eliminate) the need for new capacity.
Has ldaho Power ever built new capacity and not have it cost the ratepayers something? lt is
unfortunate that ldaho Power used this claim (of cost shifting) which promotes divisiveness among
ldaho Power customers.
Second, as several people have noted, if doing something to use less electricity behind the meter is cost
shifting, then it is happening all the time. Let me give you an example to demonstrate. The slide at the
end of this letter estimates the monthly reduction in kWh (kilowatt hours) by the approximately 1400 PV
homes (if each home had a 10 kW system, which is probably larger than average). These are the kWh for
which PV homes no longer pay 9.5 cents. Since approximately 6 cents of the 9.5 cents per kWh goes to
fixed costs, ldaho Power argues that someone else has to pick up that cost. But let's compare this
reduction to the potential reduction created by an ldaho Power program. The ldaho Power "Energy
Savings Kit" is a great program that ldaho Power provides to customers for free. lf only 25% of the
ldaho Power customers took advantage of the 9 free LED bulbs in the kit, and replaced incandescent
bulbs (say 60 watt bulbs), then as the slide shows, the monthly reduction in kWh would be 3 times the
amount generated by all 1400 PV homes! Reduction in consumption should not be considered cost
shifting. lt helps us all! ln either case, if ldaho Power loses any revenue, they have several avenues
available to recover and redistribute this amount.
ldaho .Porer shot*dbe apdffidirlg ttrc PV €ftnts iust as they muld any other co#Een'atiorl effort. We
are some of their most cornmitted and ir'ruohmd crstorRers" t personalfy had a roofbp PV qrstenr
installed in 2O!7. I wotrH have preterred to partftipat€ in the Haho Porrer Communi$ Solar Program if
it had been at least a reasonaHe investrnent. ldaho hwer rc{dd never ask an invests to invest for 25
years with a zero (to possibly negatirrel retum. I am also a mrtlcipant ia the Empowered C-ornmunity
program that provides q$fiorner ffiack to Sdaho Filer. There me rnaoy good peop[e workirg at
tdaho Power wlp rere rery helphd and encor4*rg &rrk€ ee Cornrnunity Solar prolect. I would like
to wornerd ttrecn for their efforts. l hcpe Srat &e tdaho Forer rnanqement can {earn to en&race our
PV homes as partners rather ttran threats. We wodd prefer to work togedrer with trdaho Porrer to
promote clean, reliabh and low-oostenergy!
Thar* you fur your @nsifuation ard I enourile you to denythis request.
Slncerdy,
Pad f&atab
2O0!.,!{. mP*neec
Boise,lddro 83702
208-:143-3731
[e-mail]
Cost Shift by Reduced Usage?
PV Homes
AssunEbns
1) 1{OO homcshrcP't/slncrns
?) Ihe l400horcshrelon *err3B
lGkWsysarns
3i f()"kW slstlrlsterre**q. oar*n3e,
- l20ohWhpermoch
Generat bn { redued usae} per morfi :
14O0 homesx X200 kWh Per morth =
L6m,(m kWrpermonth
--reducedus4e
ldaho Povrer Energy Kit Users
Assunsixrs
1l Cugtomcr gers3 freeL"ED lStrtbube.
2) E rt t.€DrepEera 6(kirrrd€scerrtbut ild
savesSOrperhour
3) E ch bulbisud3hurrsprdey.4! Mor*hly horrrCroE savirgE 9 bubsx S0r/hrx
3 hrs/deyx trdap =rl(}"Sfl)wh ='rxlklffh per
nroerth-
5l lf 25%of ldeho Pqrcr cusrurr(SoQ(X}Q use
thisfreepo6rrm
Reducedusaeper rnmth:
500,000 x -?5 x 40 kWh per momh =
3r!! s,mo,(m rwtrpermonth
reducedus4e
Anna Owsiak
7505 W. Portneuf Rd
Pocatello, lD 83204
I do not support ldaho Power Company's request to charge net metered customers differently than
other customers.
ldaho Power has not shown data that supports the need for their request. I am not against paying my
fair share for use of the infrastructure for energy delivery and use, however, I want to know that it is a
fair share and not an arbitrary one. At the very least IPC needs to do a comprehensive analysis of costs
involved and demonstrate the need based on those costs, and preferably, it should be an independent
analysis and cost determination.
As an energy consumer, I should have a choice about how and where to spend my energy dollars. I
believe in supporting ldaho and ldaho industry, and the clean energy industry in ldaho is growing.
Currently ldaho imports about half of its power, and I would rather see my dollars go to supporting local
ldaho clean energy industry and increasing its capacity and use, than supporting the importation of coal
produced energy. I also want my dollars used to support clean energy that enhances ldaho's energy
security and does not contribute to greenhouse gas emissions and a changing climate.
As proposed, I feel IPC's request arbitrarily singles out the few clean energy users of the state for
punishment. lnstead of punishing energy users who are trying to make a positive change on multiple
levels, IPC should be looking for ways to enhance and support increased clean energy development in
ldaho.
Thank you for the opportunity to provide testimony
Anna Owsiak
Diane Holt
From:
Sent:
To:
teandreael @yahoo.com
Tuesday, March 6,2018 8:'12 PM
Beverly Barker; Diane Holt; Matthew Evans
Case Comment Form:Tim AndreaeSubiect:
Name: Tim Andreae
Case Number: IPC-E-17-13
Email: [e-mail]
Telephone : [phone]L
Address: 403 OFARRELL ST
Boise lD, 83702
Name of Utility Company: ldaho Power
Comment: ln defense of affordable solar energy in ldaho, ldaho Power should not be allowed to place customers who
use solar, wind or micro-hydro in a separate rate class. Clearly, if they do this the intent is to raise the rates at a later
time. This kind of action that runs contrary to to any kind of sound judgement regarding the bigger picture of our
collective future. Killing solar by making it uneconomic for customers would be a terrible business move. lnstead of
trying to over-control a tiny portion of their solarized customer base (.25%), ldaho Power should embrace distributed
energy - like Green Mountain Power in Vermont - and learn how to profit from it.
U niq ue ldentifier: t7 4.27 .23.249
1
From:
Sent:
To:
geneemcgill@gmai l.com
Tuesday, March 6, 20'18 4:42PM
Beverly Barker; Diane Holt; Matthew Evans
Case Comment Form: Gene McGillSubject:
Name: Gene McGill
Case Number: IPC-E-17-13 83201
Email: [e-mail]
Tele phone : 6L9.248.237 3
Address: 2430 W Cherry lane
Boise |D,83705
Name of Utility Company: ldaho PowerComment:TO: ldaho Public Utilities Commission
FROM: Gene McGill, CPA & CGMA
2430 W. Cherry Lane
Boise, lD 83705
SUBJECT: Comment on IPC-E-17-13 83201DATE: March 6,2Ot8
BACKGROUND
ldaho is developing several solar electric solutions to address the negative impacts of burning fossil fuels. Due to the
robust population growth in Boise, the need for affordable and effective alternative energy solutions is expanding.
Residential solar rooftop panel systems are increasingly attractive investments when coupled with the improved "Tesla
Home Battery" which charges during the day and provides power for appliances when the sun is not available. Solar also
has an advantage over renewable hydro power because it avoids the detrimental impact to native fish species.
SITUATION
ldaho Power contends that the current net metering rate structure for residential and small generation service (R&SGS)
customers with on-site generation does not reflect the cost of servicing those customers, nor does it appropriately
reflect the benefits and costs of interconnecting customer-owned on-site generation to ldaho Power's system. ldaho
Power is requesting that the PUC grant approval for creating a new rate classification for customers who install on-site
generation and interconnect with ldaho Powe/s system.
IMPLICATION
It appears that ldaho Power is applying an incorrect analysis to derive their position that net metering rates are unfair to
other users and do not bear a full cost share of system costs. I would argue that all cost saving projects should only bear
the actual costs of the investment to achieve the new and improved circumstance. ln the case of solar rooftop panel
systems, the customer cost should include the cost of the net metering tool (the device and/or software that allows the
solar customer to adjust external electric flows) as well as their personal investment in panels and batteries. However,
the historicalcapital investment by ldaho Power in system delivery and billing software systems are an unfair burden to
the solar generating customers who are investing in systems reduce fossil fuel emissions and overall use of the existing
delivery system. The fact that all customers may bear a small increase in total existing system costs as a result of
applying the fixed cost (non-variable prior sunk cost) to fewer system outputs is irrelevant to the sub-set of solar rooftop
panel customers. Said another way, it is fair to periodically adjust the rate that all customers (including solar rooftop
panel customers) bear whenever the rate of fixed system delivery costs change due to long term changes in energy
usage. lt is an arbitrary accounting policy for ldaho Power to impose a special cost share of capital expenditures that
were committed long before a selected class of customers created an opportunity for system wide cost reductions.
1
Diane Holt
More specifically, total maintenance costs for the delivery system will be reduced as more solar customers reduce their
use of the system. Lower maintenance costs will offset the higher per capita sunk cost recovery such that a periodic rate
adjustment for all customers may not be warranted.
RECOMMENDATION
ldaho Power's request for a special new classification for customers who install on-site generation and interconnect with
ldaho Powe/s system should be denied. Such a rate class would be unfair and burden the residential solar customers
with a higher share of a capital cost that was incurred based on justifications unrelated to rooftop solar energy systems.
Any per rata historical capital cost increase that ldaho Power documents as a result of the deployment of solar electric
solutions should be attributed to all ldaho Power customers.
OBSERVATION
Based on review of the web site, the ldaho Public Utility Commission has an obligation to ensure to serve
consumers/customers. I would suggest that an important service to ldaho utility consumers is to continue to support the
advancement of renewable solar energy. The proposed new rate classification for customers who install on-site
generation and interconnect with ldaho Powe/s system contradicts the goal to advance renewable solar energy. The
proposed new rate classification is also a policy contradiction with the Federal tax credit and the ldaho state tax
deduction for residential solar investment.
Kind regards,
Unique ldentifier: 159.118.165.136
2
Diane Holt
From:
Sent:
IO:
Subiect:
Name: Darin Letzring
Case Number: IPC-E-17-13
Email: [e-mail]
Te I e p ho ne : 208-7 05-77 L8
Address: 53 Duke St
Pocatello 1D,83201
Name of Utility Company: ldaho Power
Comment: I am writing to comment on net metering with ldaho Power. I am not against fair compensation for ldaho
Power to maintain a grid in our area. I want to establish how this program has changed over the years from my
viewpoint and recommend ways that this program can again become more about a smart future for the state of ldaho
When I installed 5kw of solar on my home in 2010, I was excited to be part of a power solution that didn't include large
infrastructure such as power plants and dams on our beautiful rivers. My conservation efforts have been turned upside-
down by ldaho Power and PUC. When I previously got a check for only approx. SZS per year for excess production of
electricity, it represented a minimal financial return on my investment; I did not install solar to "make money." Several
years ago when PUC approved credits in lieu of cash, a true irony of my efforts came to fruition. Rather than conserving
electricity, my solar panels became a symbol of excess. I can't give my credits to less-fortunate people who can't pay an
electric bill and I can't get cash for the electricity I pay, so I make sure I use the electricity credits. My family now cranks
up the air conditioning in the summer and totally wastes all the benefits of the solar electricity created. lt is an absurd
result of the continuing changes of the program.
My efforts to conserve electricity have become worthless outside of not having to pay an electricity bill each month. I
can't even give my electricity credits to some charitable cause to help people less fortunate than me.
I encourage the PUC to review this whole case that includes the wise use of the electricity created by individual solar
power rather than simply focusing on recouping infrastructure costs from all-size solar projects.
Options include providing a charitable-giving concept for electricity credits (ldaho Power could possibly find cost-savings
with this by off-setting losses in this category), limiting large-scale solar projects that greatly skew the impact of
individual home solar, and providing logical data that sets a cost for individual support for infrastructure.
Let's set a smart course for the future of ldaho by opening the thought process to include creative solutions that "find
money" for ldaho Power in places other than the individual solar owners' bank account.
Thank you,
Darin Letzring
darin.letzri ng@ g mail.com
Wednesday, March 7, 2018 8:30 AM
Beverly Barker; Diane Holt; Matthew Evans
Case Comment Form: Darin Letzring
1
Unique ldentifier: 164.165.193.111