20180810Comment.pdf

Diane Holt
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Sent:Friday,August 10,2018 2:51 PM
To:BeverlyBarker;Diane Holt;Erik Jorgensen;Matthew Evans
Subject:Case Comment Form:Gordon Sorensen
Name:Gordon Sorensen
Case Number:IPC-E-17-13
Email:[e-mail]
Telephone:[phone]
Address:14001 E Blacks Creek Rd
Boise Idaho,83716
Name of Utility Company:Idaho Power
Comment:Comments on CASE NO.IPC-E-17-13(Vote Solar filed a Petition for Reconsideration of Order No.34046)Short answer,I support the Vote Solar's petition to NOT include net metering customers in the new Schedules 6 and 8(Order No.34046)for R&SGS customers as net metering customers are not net exporters of power into the grid.
The PUC should issue player programs explaining the names and positions of the players.I find it difficult to understandthescopeofthequote"require the Company to revise the new Schedules6 and 8 to apply only to customers who
export electricity".Without a program to explain just who and who is not,an exporter of electricity in this discussion,I
am forced to make assumptions in my attempt to comment on this petition.In reading the petition it appears that theVoteSolarpetitionseekstoexcludethenetmeteringcustomersfrominclusionintothenewSchedules6and8(Order
No.34046)for R&SGS customers.Indeed Idaho Power's rebuttal directly names the net metering customer,"VoteSolar's recommendation would be unenforceable given that Idaho Power does not measure excess generation
separately from consumption when it net meters".Assuming that is the intent of the Vote Solar Petition I agree that net
metering customers should be exempt from inclusion in the Schedules 6 and 8 as net metering customers are not netexportersofpowerintothegrid.The rules for net metering preclude a net export of power.Perhapsthe wording should
be changed to "are net exporters".
With regardsto the statement that Idaho Power does not measure excess generation separately from consumption for anetmeteringcustomer,I am calling bullshit.I can go and view my power bill and the ancillary data to see when my solararrayisgeneratingmorepowerthanweareconsumingforagiveninstanceoftime.The smart meter that was installed
at the time that the system was activated,records consumption and gross excess power generation.Near the bottom of
the power bill is a line item,Net MeteringkWh Credit Balance showing the balance of excess power generated duringthebillingperiod.My bill for last month shows 0 for that amount.
As to "the masking of usage created by the hourly analysis of customer and Company energy exchanges",that sounds
like an administration problem.Apparently it is already a sufficiently accurate count of gross excess power generationforuseinmanaginganetmeteringcustomer.Which begs the question as to why it needs to be more accurate for the
new Schedule6 and 9 customers.One can Improve the granularity(accuracy)of the data,by increasing the samplingfrequency.Add more computers if necessary to handle the extra data.Changethe reporting interval of the smart
meters.I would wager that the smart meter could be programmed to sample more often and store the data if thetransmissionintervalcannotbeshortened.
As to "export limiting devices"there appears to be a number of grid tie inverters on the market capable of limiting the
amount of power being pushed back into the grid.I did not find specifics on how the limits are managed i.e.can thecustomereasilymodifythesevalueorcantheybecontrolledbyIdahoPower?I am also not sure why this is necessarilyimportantasIdahoPowercouldeasilyseewhenaparticulargridtiedsystemispushingpowerintothegrid.Suitable
administrative measures could be implemented to manage and control the amount,though the net metering customer
may want to install the hardware to more easily manage this number.
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With regards to the net metering customer,it is unclear as to why actively limiting this value in real time is necessary.By virtue of Idaho Power's application and approval process Idaho Power has determined that the grid infrastructure iscapableofsupportingthenetmeteringinstallationanditsoperationalbehavior.The effects of batterystorage would be to reduce or eliminate any excess power being fed into the grid.At theeliminatepoint,this would effectively make the customer appear as a non net metering customer who is just using lesselectricity.Power delivery would be one way with none of that pesky excess power running around the grid.It wouldhoweverstillreducetheamountofpowerthatanetmeteringcustomerwouldusewhichwould,from Idaho Powervantage,make the net metering customer guilty of not paying his fair share.This notion comes from Idaho Power's backupinformationassuppliedintherequestforauthoritytoestablishnewschedulesfor"R&SGS"customers,Order No.34046.From Tatum's deposition;"customers with on-site generation may pay less than their fair share for the grid-related services they require".I still do not know what a customer's "fair share"is and this certainly needs to be definedandexplainedbeforeIdahoPowerdoesanychangestotherateschedulesforR&SGS customers.
I do not understand and I would certainly welcome an explanation of the meaning and repercussions of "in parallel"connections,certainly from Idaho Power's view point.If I assume this means managingconsumers and generators ofpower,I can only imagine what is involved in that parallel connection of so many sources of generation and ofconsumption.In the course of matching power generation to consumption,things like the timing of starting andstoppingpeakingstationsduringthecourseofadayisprobablythebasisofadoctoralthesis.Current generations ofgridtieinvertersarenotgridvoltageregulatingdevices.The output of a grid tie inverter is driven by the currentavailablefromthesolarpanel(s),not by the voltage of the grid.Solar power is considered an intermittent power sourceunlikeabaseload,dispatch-able generation,load following,or peaking power plants.The intermittent nature of solarenergymakesitsmanagementsomewhatofaliability.At present the fraction of power generation by solar relative toallothergenerationseemsprettyminuscule.It would useful to know how much it is and if it is even detectable,i.e.acompletesolareclipseoverBoiseandthepeakingstationsnotedariseintheiroutputcorrespondingtothetotaleclipseevent.Still a rapidly moving thunderstorm could significantly cut the output of the solar power being fed into the gridandatsomemuchhigherfractionofthepowergenerationside,could potentiallybe a destabilizing factor.Wind powerhassimilarandgreaterissues,but it appears to be managed,perhaps those techniques could be applied to solar in thefuture,which leads me to an observation.
I would really like to see Idaho Power actually focus their intent to managegrid tie solar systems rather than seeking toexploitthembyneuteringthemorflateliminatingthem.In my scan of the internet I found 3 instances in Maine,Texas,and Nevada where power companies were aggressivelyand successfully trying to cripple or eliminated grid tie solar.While Idaho Power will argue that is not their intent,I find it hard to dismiss this trend by utility companies.I don't recallIdahoPowermentioningthemanagementaspectofnetmeteringortheprosandconsofitintheirargumentsandjustifications.Given those justifications that were presented in the background information for the original newSchedulesapplication,it is difficult to see actual intent to manage net metering customers but to rather to simply toexploitrevenuefromthem.
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