20180810Brief on Reconsideration.pdf

SEAN COSTELLO
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO Box 83720
Boise, ID 83720-0074
Tele: [phone]
FAX: [phone]
ISB NO. 8743
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
AUTHORITY TO ESTABLISH NEW
SCHEDULES FOR RESIDENTIAL AND
SMALL GENERAL SERVICE CUSTOMERS
WITH ON-SITE GENERATION
iiICEIVED
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CASE NO. IPC.E.I7-I3
STAFF'S TECHNICAL BRIEF IN
RESPONSE TO COMMISSION
ORDER NO. 34098
Street Address for Express Mail:
472W Washington
Boise,ID 83702-5983
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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STAFF'S TECHNICAL BRIEF
IN RESPONSE TO COMMISSION ORDER NO. 34098
1
BACKGROUND
In Order No. 34098 the Commission, in response to Vote Solar's Petition for
Reconsideration and related f,rlings, ordered Vote Solar, Idaho Power, Commission Staff, and
any other party with the desire to do so, to file briefs related to whether a customer's ability to
export energy should determine if the customer should be included in new Schedules 6 and 8.
The Commission also stated that it is interested in obtaining "information about export limiting
devices, effects of battery storage, additional information and repercussions of in parallel'
connections, and the masking of usage created by hourly analysis customer and Company energy
exchanges." OrderNo.34098 at2-3. Staff s analysis follows.
SPECIFIC STAFF ANALYSIS AND RECOMMENDATIONS
Staff first reiterates the stance it took in its response to Vote Solar's Petition for
Reconsideration, maintaining that those customers who are wholly incapable of exporting energy
to the grid should be exempt from inclusion in Schedules 6 and 8. Schedules 6 and 8 should only
apply to customers with on-site generation who export. Currently virtually all of the Company's
on-site generation customers have exported energy to the system. However, while the operative
word in Staff s conclusion is incapable, Staff foresees that a certain subset of customers may
desire to maintain a connection to the Company's grid, but utilize a grid tie limiter, grid inverter
with export control, or a similar device to eliminate their ability to export power to the
Company's grid.
Therefore, Staff concludes that if a customer is incapable of exporting she should be able
to remain in Schedules 1 and 7 for purposes of scheduling and rates. Instead of simply removing
customers who choose to limit their export capability from current Schedules 6 and 8 as
proposed by Vote Solar, Staff would instead propose that a voluntary, applied-for, "non-export"
categorrzation be incorporated into Schedules I and7, after reasonable analysis, as one prong of
the pending generic on-site generation case required by Order No. 34046.
The end goal would be to allow a customer with on-site generation to properly apply for
and certify a non-exporting on-site generation system, sized and designed such that the
generator's output is used for the generator's own load, and designed to prevent the transfer of
electrical energy without compensation.l Staff further maintains that addressing the connected,
but non-exporting, customer in the forthcoming generic docket may allow more time for
reasonable standards to be analyzed and put in place to allow formal certification of non-export
devices in order to alleviate Idaho Power's concerns related to improper customer-sided
reconfiguration allowing for export. As well, a consistent statewide standard should apply in
utility on-site generation interconnection and, therefore, the multi-utility generic docket would
allow all utilities to explore this arena without inconsistent application or customer treatment.
Bi-directionali4t
First, generally, in line with the Commission's adopted reasoning in Order No. 34046,
Staff maintains that Company customers who have a physical device that prevents them from
exporting energy to the Company's grid should remain on Schedules I and 7 because these
customers are not bi-directional, meaning they cannot export a meaningful amount of energy
I At least two states, California and Hawaii, have begun to implement non-export and storage program options for
defined portions of their net metering customers. See e.g., http://www.cpuc.ca.gov/Rule21/California (California's
Rule 21 Generating Facility Interconnections) and https://puc.hawaii.gov/wp-content/uploads/20 l7l10/Hawaii-PUC-
Rooftop-Solar-and-Storage-Press-Release-10-20-17-FlNAL.pdf (Hawaii Public Utilities Commission Press Release
related to expanded options for the installation ofrooftop solar and energy storage).
STAFF'S TECHNICAL BRIEF
IN RESPONSE TO COMMISSION ORDER NO. 34098
2
back to the grid, and do not "net" their consumption. Secondly, any rate structure predicated on
a bi-directional relationship with the grid will allocate costs to Schedule 6 and 8 customers that
are unique to that bi-directional relationship with the grid, hence, it would be unfair to require
customers who cannot export energy to the grid to bear these additional costs.
Parallel Connection
As noted above, Staff would recommend that the Company's definition of "parallel"2 be
updated, after a full analysis under the prong of the generic docket related to non-export
classification, to include the eventuality of a customer preventing the exportation of energy to the
Company's system. In other words, Staff would recommend that one outcome of the generic
docket be to incorporate a definition of parallel which recognizes a non-export customer option.
Allowing customers the benefit of both a connection to the Company's grid and on-site
generation without export or compensation, would better synchronize with the Commission's
holding in Order No. 34046 related to the key element of new net metering classifications being
based on the bi-directional relationship between customer and Company. Removing overt bi-
directionality through a certified non-export classification removes the need for classification in
new Schedules 6 and 8.
Exoort Limiting Devices
Export limiting devices limit the ability of on-site generators to export electricity to an
electrical grid. Because electrical current flows from higher voltage to lower voltage, most grid
limiting or non-export devices work by regulating voltage on a customer's side of the limiter. In
normal operation, the customer's voltage is slightly less than the Company's, leaving a small
amount of electricity flowing from the Company to the customer, even when the customer's
generating system is operating, but it is occasionally possible for a very small quantity of energy
to flow back to the grid. The quantity that may flow back is negligible.
Although relatively uncommon in the United States, though gaining in prevalence, export
control devices are very common in other parts of the world, where, for example, regulators and
electric providers use limiting devices to discourage self-generating customers from using the
electrical grid as a battery. Under that scenario, meters are configured to charge customers for
all power that passes through the meter, regardless of the direction that it flows. This treatment
2 "Parallel" is defined in Schedules 6 and 8 as "generating electricity from an on-site generation system that is
connected to and receives voltage from ldaho Power's system." See I.P.U.C No. 29, Tariff No. l0l, Sheet 6-2; and
Idaho Power Company's Answer to Vote Solar's Petition for Reconsideration at 3.
STAFF'S TECHNICAL BRIEF
IN RESPONSE TO COMMISSION ORDER NO. 34098
^J
obviously provides an export disincentive to customers, motivating them to purchase grid
limiting, non-export devices so as not to be charged the same rate for both power imported and
power exported.
Staff recommends that export limiting devices be allowed and installed under Idaho
utility on-site generation regimes. Staff would further recommend that non-export customers be
allowed a small threshold for inadvertent or de minimis export amounts of electricity, with no
compensation structure attached to any export. The Company's concerns about its customers
bypassing the export limiting device would thus be greatly alleviated, since no benefit would
accrue from a customer exporting.
Idaho Power has also expressed concern that customers utilizing export limiting devices
would be able to reconfigure "at any time" to allow customer energy export. Idaho Power's
Answer to Vote Solar's Petition for Reconsideration at 4. ln order to combat this outcome Staff
would propose, again, that any limiting device be certified, either by the manufacturer, or, in the
future, using generally recognized standards, or something akin to the UL 1741 Non-Export
Certification Requirement Document ("CRD") depending on applicability and availability. Staff
holds that there are reasonable and safe methods of maintaining a connection to the Company's
system while limiting export.
At base, Staff believes that certain customers may wish to have the option of a relatively
affordable and simple3 method of offsetting consumption without exporting to the Company's
grid. While Idaho Power argues that it would be difficult to monitor and verify that customers
are not exporting power to the grid, the Company has not stated that it is impossible or overly
burdensome, especially in light of the Company's advanced metering infrastructure ("AMI").
While Staff acknowledges that operational costs may increase slightly, Staff does not believe that
the Company would be overly burdened by customers choosing to remain in Schedules I and 7
by utilizing an agreed upon grid limiting or non-export device. Simply put, Staff foresees that
some customers may wish to remain in Schedules I and 7, connected to the Company's system,
but choose to offset their own consumption without exporting or ever receiving any credit for
exporting to the grid. Again, Staff believes this potentiality would be best addressed outside of
3 Staff has found that export limiting devices can cost as little as $85.00, but typically are in the $200-$500 range.
Further, grid limiting options are also a standard feature on many commonly used inverters.
STAFF'S TECHNICAL BRIEF
IN RESPONSE TO COMMISSION ORDER NO. 34098
4
the record available under this Petition for Reconsideration in a prong of the generic case
required under Order No. 34046.
Batteryt Storaqe
Batteries and storage were not, per se, part of the net metering docket now before the
Commission, therefore Staff has received limited data from the Company related to their
presence on the Company's system. However, generally, Staff believes that customers who
choose to generate and store energy on-site are less likely to want to use to the Company's grid
as a battery, and, therefore, would likely attempt to limit export. Therefore, a non-export option
may have the effect of incenting battery storage.
However, as it currently stands, batteries are very expensive. As one example, according
to Tesla's website, a 7 kWh Powerwall costs approximately $6,600 plus installation costs of
$1,000 to $3,000. Summer night time consumption of an Idaho Power self-generating customer
is about 26 kwh, so a typical customer would need four Powerwalls to meet her own needs
without reversion to the Company's grid. There are also currently long wait times for battery
storage systems, for example, depending on the region and availability of Tesla installers, wait
times for Powerwall installation are currently more than a year, with some customers reporting
(in June of 2018) that they have been waiting since 2016.
Intra-Hour Maskins
In its Answer to Vote Solar's Petition for Reconsideration, Idaho Power stated that it
captures net hourly consumption, and therefore, "if the net result at the end of every hour is
greater than or equal to zero; the exported energy, which is less than the amount of energy
consumed, is masked over the course of every hour." See Idaho Power's Answer to Vote Solar's
Petition for Reconsideration at 5. Therefore, at base, intra-hour masking is the problem of
exported energy being hidden by consumption.
While Staff recognizes the potentiality of this problem, it is concerned by the weight the
Company apparently attached to it. The Company's system measures hourly data, so in order to
effectively mask intra-hour consumption, a customer would have to make sure that she never
has a net export in any given hour in the year. Generally speaking, the opportunity for masking
is limited to only those hours in which consumption and production are nearly equal. In practice
this would be the hours during the day when solar production is ramping up and down, or, more
specifically, the hour when production first exceeds consumption and vice versa when
STAFF'S TECHNICAL BRIEF
IN RESPONSE TO COMMISSION ORDER NO. 34098
5
consumption first exceeds production. In other words, a customer would have to carefully
configure her on-site generation site to consume more energy than it produced in each of a
typical year's 8,760 hours. Therefore, Staff concludes the intra-hour masking is a limited
occurrence and would be difficult for most customers to achieve.
While Staff maintains that intra-hour masking would be very difficult to achieve, and the
Company's concerns appear to be disconnected from customer reality on the ground, Staff notes
that intra-hour masking is impossible with a grid tie limiter because it and similar devices
remove the ability for customers to export energy to the grid, which is the only way customers
could mask usage. Further, without any financial or kWh credit, there is no incentive for
customers to export energy.
S afe 4t of Int e r c o nne c t i o ns
As a corollary to Staff s analysis related to the Petition for Reconsideration, Staff also has
an additional safety concern. There may soon be a time when the costs of solar panels are
sufficiently low to make their use economically attractive on a large scale, even without excess
power credit from Idaho Power. If and when that is the case, Staff is concerned, depending on
rate structures, that certain customers may install panels clandestinely to avoid being moved to
and from Schedules 6 and 8. This outcome could make it dangerous and/or impossible for the
Company to fully de-energize power lines for repair. In order to properly analyze safety issues
related to clandestine generation, Staff would also recommend that parties to the generic on-site
generation docket address safety issues related to Company grid interconnection.
RESPECTFULLY submitted tttis /dA day of August,20l8.
Sean Costello
STAFF'S TECHNICAL BRIEF
IN RESPONSE TO COMMISSION ORDER NO. 34098
6
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE ONTHIS]@DAY OF AUGUST,2018,
SERVED THE FOREGOING STAFF'S TECHNICAL BRIEF IN RESPONSE TO
COMMISSIONORDERNO.34O9S, IN CASE NO. IPC-E-17.13, BY MAILING A
COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
LISA D NORDSTROM
REGULATORY DOCKETS
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: [e-mail]
[e-mail]
C TOM ARKOOSH
ARKOOSH LAW OFFICES
802 W BANNOCK ST STE 9OO
PO BOX 2900
BOISE ID 8370I
E-MAIL : [e-mail]
[e-mail]
ELIAS BISHOP
AURIC SOLAR LLC
2310 S 1300 W
W VALLEY CITY UT 84I 19
E-MAIL: [e-mail]
ANTHONY YANKEL
I27OO LAKE AVENUE
UNIT 2505
LAKEWOOD OH 44107
E-MAIL: [e-mail]
TOM BEACH
CROSSBORDER ENERGY
2560 9TH STREET, SUITE 2I3A
BERKELEY CA 94710
E-MAIL: [e-mail]
TIMOTHY E TATUM
CONNIE ASCHENBRENNER
IDAHO POWER COMPANY
PO BOX 70
BOrSE rD 83707-0070
E-MAIL: [e-mail]
caschenbrenner@idahopower. com
MATTHEW A NYKIEL
ID CONSERVATION LEAGUE
102 S EUCLID #207
PO BOX 2308
SANDPOINT ID 83864
E-MAIL: [e-mail]
ERIC L OLSEN
ECHO HAWK & OLSEN PLLC
PO BOX 61 19
POCATELLO ID 83205
E-MAIL: elo@,echohawk.com
KELSEY JAE NUNEZLLC
920 N CLOVER DR
BOISE ID 83703
E-MAIL: [e-mail]
ELECTRONIC ONLY
MICHAEL HECKLER
michael.p.heckler@ gmail.com
ZACK WATERMAN
zack.waterman@,sierraclub. org
STAFF'S TECHNICAL BRIEF
IN RESPONSE TO COMMISSION ORDER NO. 34098
7
ABIGAIL R GERMAINE
DEPUTY CITY ATTORNEY
BOISE CITY ATTORNEY'S
PO BOX s00
BOISE rD 83701-0500
E-MAIL: [e-mail]
DAVID BENDER
EARTHJUSTICE
3916 NAKOMA ROAD
MADISON WI 537I I
E-MAIL: dbender@,earthj ustice.org
JOHN R HAMMOND JR
FISHER PUSCH LLP
PO BOX 1308
BOISE ID 83701
E-MAIL: [e-mail]
RYAN B FRAZIER
BRIAN W BURNETT
KIRTON McCONKIE
PO BOX 45t20
SALT LAKE CITY UT 84111
E-MAIL: [e-mail]
[e-mail]
PRESTON N CARTER
DEBORAH E NELSON
GIVENS PURSLEY LLP
601 W BANNOCK ST
PO BOX2720
BOISE ID 83701
E-MAIL: [e-mail]
den@ givenspurslev. com
BRIANA KOBOR
VOTE SOLAR
986 PRINCETON AVENUE S
SALT LAKE CITY UT 84105
E-MAIL: [e-mail]
ELECTRONIC ONLY
SNAKE RIVER ALLIANCE
wwil son@,snakeriverall iance. or g
NW ENERGY COALITION
diego@,nwenergy.org
DOUG SHIPLEY
INTERMOUNTAIN WIND AND
SOLAR LLC
1953 WEST 2425 SOUTH
WOODS CROSS UT 84087
E-MAIL : dou [e-mail]
fu,\, k.|tdwW
KERI J. HAWKER
Legal Assistant To Sean Costello
STAFF'S TECHNICAL BRIEF
IN RESPONSE TO COMMISSION ORDER NO. 34098
8