20191203Comments_(10).pdf

IDAHO PUBTIC
UTILITIES COMMISSION
rPc-E-18-15
Boise, ldaho
L2l03lL9
COMMENT FORM
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You may either hand this sheet to a commission staff member or mail it to:
IPUC, PO Box 83720, Boise, lD 83720-0074
You may also post comments on our website
https://www,puc.idaho.gov/
Click on the "Case Comment Form" link
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Robert E. Sojka and Linda Helgeland Sojka
2506 Laurie Lane
Twin Falls, ID 83301
208-420-1472
bobsojka @cableone.net
Let's make one thing perfectly clear. ldaho Power would have never initiated its
original promotion ot-solar and wind on-sit e eneration and net severa I
years ago if it hadn't already done enough math to determine that the terms of
the original net metering compensation plan weren't a good deal for ldaho
Power. ln fact it's a GREAT deal for ldaho power under the original net metering
terms and the changes they propose are aimed at parlaying that into a WILDLY
FANTASTIC dea l-{ar I\te* 1 ei v e s.
To their credit, for several years ldaho Power encouraged homeowners, farmers,
and small businesses to install on site micro-generation for on-site use (mainly
solar and/or wind). l'm uncertain if micro-hydro was also included. Excess power
generation could be fed back to the grid and would be "fairly" compensated (i.e.
via net metering).
ln this arrangement, the homeowner pays the full tab for system design, materials
and installation, bears total responsibility for its maintenance and all liability
regarding impact on future work on or near the system, or problems the system
may cause to the home structure in the future (e.g. roof damage during wind or
whatever).
Furthermore, ldaho Power only compensates homeowner excess power
production on the basis of their "retoil" rates for power delivered via the grid to
the point of use. This is a heck of a deal for ldaho Power since it has to produce
far more power at centralized generation facilities to deliver a net increment of
power to a down line user. This is due to transmission losses. However, excess
power produced by homeowners typically travels short distances across the grid
to the nearest net-user (next door neighbor?), thus suffering nearly no
transmission loss. ln essence, "Net Metering" is already structured to produce a
profit for ldaho power. And it is highly likely the net metering profit per unit
power is more than delivering that same increment of power from a central
Bait and Switch? Welching?
Page2of2(Sojkal
I
generation point. This remains true regardless of the type of centralized
generation (including solar). Even centralized solar installations suffer
transmission loss because they are at great distance from the ultimate power
consumers.
I would like to think that ldaho Power's motivation for initially promoting home
solar installations was formulated in significant part from a sense of
environmental and social responsibility. As the years have passed, however, it is
clear that if there was any altruism or sense of societal obligation whatsoever in
the initial campaign to promote on-site solar etc. that has given way to greed as
the public has embraced and accelerated its willingness to protect our ..---
environment and meet our energy generation needs directly.
lf we were here today arguing about the price of any other commodity or service
that had been initially contracted and paid for in advance and in good faith, and
then within months of signing the agreement the selling party demanded a better
deal, it would be regarded as bait qnd switch or welching on the deal.This is
rticularl true given the clo rential of a statewide entit vs an individual
customer/citizen. ldaho Power has vast more influence with the utility
com m rSsro n than individual citizens and ld hey know it
nd the la ed r e
14 )er iqls t, J,3 +Ll Ovt b.k "l fu?4e 3-
s where public entities regard what theThere have been and are other countrie
public entity owns as theirs but also regards what individualcitizens have as
belonging to that public entity as well. Does ldaho Power believe that what is
theirs is theirs and that what is ours is theirs as well? That system is referred to
variously as communism, socialism, or even totalitarianism. Are we really going to
go down that path in ldaho?
I remind the PUC that times are changing in ldaho. Our citizens have already
successfully vented their frustration over public officials' insensitivity to
reasonable solutions to problems that have already been shown to work in other
states (i.e. Medicaid expansion). When put to a vote in other states net metering
was kept and "jiggered" metering was rejected by voters. ldaho has an initiative
process and I would hope that if ldaho Power has its way with the PUC that this
Iiteral POWER GRAB by ldaho Power would be challenged by voters who don't like
being ignored or treated unfairly.
Linda and I sincerely thank you for the opportunity to present this comment.
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Tracking emissions in the US electricity system
Jacques A. de Chalendar''1, John Taggartb, and Sally M. Bensona
'Energy Retour(es Engineering, Stanford University, stanford, CA 94305-2205; and hManagement Scien(et and Engineering, Stanford University, Stanford,
cA 94:r0s
Edited by Daniel M. Kammen, University of California, Berkeley, CA, and a(cepted by Editorial Board Melhber B. L. Turner ll October 30. 2019 (re<eived for
r€view luly 29, 2019)
Understanding eledri(ity @nsumption and p,odu.tion patterns
i5 a ne.es3ary ri6t 5lep toward redu<ing the health and (li-
mate impacts of associated emissigns. ln this work, the e(onomi(
input-output model is adapted to track emirsionr flows through
ele(tric grids and quantify the pollution embodied in eledri.ity
production, ex(hanges, and, ultimately, (onsumption for the 66
(ontinental US Balan(ing Authorities (BAs). The hourly and 8A-
level dataset we generate and releare leverages multiple publi<ly
available datarets lor the year 20'16, Our analysis demonstratet
the importance of (onsldering lo(ation and temporal eflects a5
well a5 ele(tridty ex.hanger in estimating emissions footprints.
While increa5ing eledri(ity exchanges makes the integration ot
renewable electricity easier, importing eledricity may also run
counter to climate-change goals, and dtizens in regions exporting
ele.tri(ity lrom high-emigsion-generating rources bear a dispro-
portionate air-pollution burden. For example, 40% of the (arbon
emir5ions related to eledri(ity aonsumption in California'5 main
BA were produced in a different region. From 30 to 50% of
the rulfur dioxide and nitrogen oxides rcleased in rome of the
coal-heavy Ro.ky Mountain rcgions were related to electricity
produced that was then exponed. Whether for policymakers
designing energy effi(ien.y and renewable program5, regula-
torS enfor(ing emissions 3tandardr. or large ele(tridty (oniumer5
greening their iupply, greater reiolution i3 needed for electric-
seator emission5 indi(es to evaluate progrers againgt current and
future goals.
Significance
The enviJonmental quality of the electricity llowing through
electri< g.idr varics by location, reason, and time ot day,
Data {rom 3 publi.ly available sour.es have been (ombined
to produce an hourly emi$ions dataret for the 66 balan(ing
authorities in lhe Uniled Stateg. The environmental quality
of electri.ity varies greatly. Eledricity transfe.r are erpe.ially
important In the western United Stater and can be rcipon-
sible for more than 20 to 40% of emissioni. They play a
mu(h Smaller ,ole in the easteh United States. ln a numbea
of regions. a large fradion of pollutant-intensive ele(tricity
is exported, resulting in lo(al communities bearing the pol-
lution burd€n of electricity generaton withoutthe benefits of
<off uming the electririty.
(arbon intensity of elecri(ity renewable energy policy I el€ctricity rystem
emartions factoB I emirsions embodied in electricity ex<hanges
power grids transport elcclrical cnergy hctwcen many differ-f cnt lxarions. oftcn over lar8e dislanccs. As a rcsult, linking
changes in production and consumption at dilferent points of an
eiectric grid is challenging. Accounling for and monitoring pol-
lutants emitted during electricity production and subscquently
embodied in electricity tradc and consumption is cven more
complex, dilficult, and data-intcnsive.
Yet, electricity rcprescnts a largc ftaction of emissions from
fossil-fuel consumption: in the United States.28% of20l6green-
house gas (GHG) cmissions (l). To achicve climate goals (2),
massive electrification will very likely be needed, upping thc
stakes for effcctively decarbonizing the elcctricity sector (3). The
climate and health impacts associated with producing, consum-
ing, and exchanging clectricity should thercfore bc the subject
of close attcntion. Ensuring that cmissions accounting methods
for our electricit) systems accurately capturc when, where. and
why emissions are occurring is especially critical as they becomc
more connected and as the role of rencwablcs grows. Accu-
ratc monitoring will help prevent the outsourcing of pollution
(carbon leakage), and neglecting the consumption-based per-
spcctive may have undesircd consequences for social equity and
environmental justicie.
The cmissions impact of electricity can be mcasured through
Emissions Factors (EFs; mass of pollutant per unit elcctrical
eners/). According to a compilation of life-cycle analysis csti-
matcs lbr carbon EFs (4), coal emits 2 times more carbon dioxidc
(COz) than natural gas, which cmits an order of magnitude more
than electricity from the sun. wind, or water. Recent direct emis-
www.pnae.org/cgydoi/10.1073/pnar.19129501 l6
Author (ontributionr: i.A.d.C., J.I,, .nd 5 M.S. delig.€d rer€.r.h; ,.A.d.C pe.tomed
rccarch; r-Ad.C. an.lyzed d.ta; and r.A.d.C,, J.T., and S.M.B. wrote thc pap€r
The authore d€d,..e no comp€ting inter6t.
Thir arti(l€ i, a PNAS Oir.ct Submi$aon. O.M-K. i5 a gost edno. lNited by the Edito .l
Tnir or.n arc€.6 arude ir dindbuted unds Cr€atNe Commonr Atttibotion-,toncommsel,
NoD€rivariw Lt.€re 4.0 (CC 8Y-NC ND).
Dal. deporition: The code and dn. have been depolited on GatHub .nd arc .vailable at
httpeJ&ithub <onvjdsh.rendar/tradrhg-emiiront.
'To wtm (orelponden(e may b. addr€*€d. EDa : jde.halend.ro.tanlord.edu.
lhir ani(l€ contahr !upponing infomatioi onlirE a! htrp, /,\tr!w. p.at.orgr'boru p6opp,
doi:10. 1073/pnas 1 9129501 l &-/DCSuppleoenlal.
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PNAS Latest Ariicl€s r of 6
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sions cstimatcs (5) show that thc carbon intensity of the US grid
as a whole decreased by 30o/t, from 2001 to 2017 as gas and
renewables displaccd coal.
Capturing heterogcneity matters when considering the climate
and health impacts of the elcctric grid. Previous studies have
compared the use ofavcragc and marginal EFs (6, 7) to estimatc
the impact of policy inlervertions in the short-tcrm; shown how
EFs can vary by l(xation, sca$on, or timc of day (8, 9); and can
use consumption or production of electricity as thc accounting
basis ( l0-13).
The impact of GHG emissions is global and only depends
on time path and total volumc, not on geographic location.
Not so for air pollutants such as sulfur dioxide (SOr), nitro-
gen oxides (NOx), and particulate matter, where damages are
more localized. While distant electricity consumers gct the ben-
e6ts of rcliablc electricity, the associatcd pollutant burden is
bornc by communities near the generating u[it$, Whether their
impact is global or lffal, understanding how clectricily consump-
tion drives the emission of different pollutants is critical and
will be needed by p,olicymakcrs to develop sound and durable
sharcd-responsibility models betwecn producers and consumers.
The need to capture heterogeneity becomes more pressing
as clectric grids ahsorb grcater amounts of renewable energr,
whose availability typically varies in time and spac( (14).In such
grids, demand will need to become more rcsponsive (15). Under-
standing cmbodied emissions flows will be especially important
in networks with high levcls of trade. e.9., in thq US $ystem's
western intercoflnect. As the fraction of renewable generation
increases, greater amounts of trade arc bencficial for rcducing
costs and helping to balanqc exqgss and deficits of elcctricity
supply ( l6).
In this paper. we trace the llow of electricity through the elcc-
tric grid and calculatc hourly embodicd pollutant flows. As in
previous work (l{ll3), we use a fully coupled cconomic multi-
regional input-output modcl (MRIO) of the electricity systcm.
MRIO models havc bcen used to quantiry emissions embodidd
in tradc of goods and scrviccs bctween countries (17, l8). bur
also to asscss other footprints, c.9., water. land, or biodivcrsity
(,!/ -,1l7rcarlA. rct.s. 3-5).
Often constrained by thc lack of appropriatc data, prcvious
asscssmcnts of electricity grids present rcsults that use monthly
rcsolution at best, or do not properly account for the impact
of trade (a more dctailed literaturc revicw can be found in .\/
..lppcnLlir).In this work, we built and solved a lincar system for
each hour of 2016 corresponding to the lull cxchange nctwork
for thc 66 contincntal US balancing arcas. as described in Mate-
rials and Methods. The high spatial and temporal resolution
of the datasct wc gencrated and released represents a signifi-
cant advance and was obtained by solving a fully coupled MRIO
model, This allolvcd us to pcrform an cxhaustive analysis of the
US clectricity system and, in particular, ofthc rolc playcd by clec-
tricity transfcrs in the flow of embodicd pollution through the
clectric grid.
We show why cmissions accounting systems should considcr
liubdaily, Iocal, and exchange data. in that they wauld more
closcly align with thc operation ofmodern clectricity markcts. As
thcse data on the clectric system bccomc routinely available, we
can now compute rnore prccise cmissions frntprints for different
components of lhc electricity systom.
Results
The most reccnt databascs available with appropriate rcsolu-
tion describe the state of the US electricity systcm in 2{)16, and.
accordingly, all results in this paper apply to the ycar 2016. We
computed and reported electric-scctor cmissions for thc 66 bal-
ancing authorities (BAs) in the continental United States by
combining hourly data on BA-levcl elcctricity production, con-
sumption, and trade with hourly data on plant-level emissions
produccd. Exhaustive. BA-by-BA, hourly reports ftom this work
are providcd in .S/,1,t)p.x1r.!, while thc main text focuscs on key
findings and insights.
We report both production- and consumption-bascd emis-
sions, taking thc MRIO vicw that pollution is embodied in gen-
crated clectricity and subscquently flows through the eleclricily
network. Produced emissions are defined by thc administrativc
territory in which they are physically cmittcd. Consumption-
based emissions are defincd by the administrative tcrritory in
which elcctricity is consumed, and wc will reli!r to them as 'con-
sumed" emissions. We will similarly rcfcr to "tradcd" cmissions
as thc emissions embodied in hourly clectricity exchanges. [n lhc
remaindcr of the paper. BAs will bc refcrred to as "regions" to
simpli! languagc. A lull table for abbreviations for the differ-
ent regions can bc found in .!/ ,,l/2carlrir. l'ahlc S1; additionally,
Figs. 1 and 2 can be used to providc an indication for location
and a rcfercnce for frcquently used abbrcviations, rcspectively.
Carbon Footprlnt of Ele<trlcity consumpti,on. In 2016. 1.83 Ctons
of CO2 were cmitted in the United Starcs to meet 4 PWh (4
million MWh) of electricity consumption. Tracking emissions at
the BA levcl is natural becauw they corrcspond to the phys-
ical organization of the clectricity system, where conlrol-rq)m
operators must continually monitor the state of thc electric
grid to cnsurc that supply can mect dcmand and line flows
rcmain technically acccptable. Thc consumption-based carbon
intcnsity of elcctricity varics by almost an ordcr of magnitude
across the different rcgions in the US electricity system, as
shown in Fig. 1, In these maps, the size of the circles and
arrows is reprcsentative of annual consumption and trade of
elcctricity (Fig. I, Upper) and, carbon (Irig. l, aon'el), respec-
tively. and color is rcprescntative of coosumption-based carbon
intensilv. Thc flrotprint of the US elcctricity system is domi-
nated by its two largest regions, the Pennsylvania-New Jersey-
Maryland Power Pool (PJM; 20% of electricity and l9a/c ol
emissions) and the Midcontinent Independent Systcm Oper-
ator (MISO: 17% of clectricity, bd 2lq. of emissions). The
Pacific Northwest is a largc exporter of low-emissions-intcnsity
hydroelectric power, while thc Rocky Mountain region is a
Iarge cxporter of carbon. as are somc regions in the coal-heary
Midwest.
Exchanges betwecn regions play an cspecially largc role in
thc western interconncct, where net imports account for 29'l'
of consumption for the 17 net importer rcgions, and net cxports
account for 37olo of production for the 16 nct exportcr regions.
Exchangcs represent a smallcr share of consumption and pro-
duction in thc eastcrn interconncct. while the Electric Rcliability
Council of Texas (ERCO) has few ties to the rest oi thc US
electricity system. In the US systcm as a wholc, carbon trade
rcpresents 5% of total carbon production.
Moving forward, anoual accounting tools will not be enough
to track decarbonization efTorts in thc US clectricity systgm,
because thoy will misstate carbon footprints for rcgions in which
rencwablcs and exchaflges play a largc rolc (19). The hct-
crogeneiry in thc carbon footprint of electricity consumption
and production, both in time and in space, is highlighted in
Fig. 2, wherc we show the 10th, 50th, and 90th pcrcentiles for
hourly data on consumption- and production-based EFs for 20
regions. Thc overall US electric grid carbon intensity of 450 kg(rOr/MWh would accurately match thc carbon embodicd in
elcctricity consumcd only in PJM. ERCO, and th€ southeast-
crn Southern Co. Services. For the others. the annual mcdian
carbon intcnsity can be lower than 100 kgMwh or higher
than 900 ke,/Mwh.
Hourly carbon intensity can fluctuatc equally significantly
around the mediar. In the MISO, consumption EFs swing
by 157r, around the median, from 480 to 660 kg/MWh. For
the ldaho Power Company (IPCO), the carbon content of
-imports (625 kg/MWh) is much highcr than that of lffal gen-
- eration (71 kg/Mwh), and the carbon cmissions per unit of
elcctricity consumcd dcpends sensitivcly on time. While in
the spring, this region gcneratcs almost cnough low-emissions-
intcnsity encrs/ to mcet its dcmand, in other months it
rclies heavily on imports ftom the neighboring Pacilicorp East
(716 kg/Mwh) and Northwestern Energl (765 kg/Mwh). The
Salt River Project (SRP) exports a largc fraction ofits gcneration
and simultaneously imports Iower-emissions-intensity electricity:
Its consumption-based EF is 22% lower than its production-
based EF. Suoh trends cannot bc captured without hourly
exchangc data.
ln California, thc Air Resources Board computcs thc clectric
system's carbon footprint from tcchnolo$/-specific EFs and the
annual generation nrir; including imports. Imports are incorpo-
rated by oonsidering private contracts and market scttlements
(Sl Appendir, rcl,\. 4 and 5). tn 2016, l4ol, of the electric'
iry consumed was reported as imported from an unspecified
source (and given a generic EF). In contrast, our more simplc
and transparcnt approach rclies on publicly availablc physical
observations (clectricity balances bctwecn regions and mea-
surcd emissions) to computc the corresponding cmbodied car-
bon flows, leaving no stranded elcctricity or emissions. Our
results conlirm that the largest carbon imports into the California
Indepcndent Systcm Operator (CISO) originate from the SRP
(654 kg/Mwh) and Los Angcles (Los Angelcs Departmcnt of
Water and Powcr;384 kg/MWh) rcgions. Considering imports to
compute the mcdian EF changcs it by 20%, from 194 kg/Mwh
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Fig. l. Carbon footprint of the US electridty synem. Electri(ity (Uppe.) and (arbon (lori€r) consumption and exdanges and (onrumption'bar€d carbon
intenrity of grld electri(ity luppet and Lower) lor the 65 IJS 8As. The radius of the noder and width of the arrows scale with (onsumption and trade,
retpectively. The (olor of the nodes and arrows scale with (onrumption-b'ased carbon jmentity- The qray nodes and arrows correspond to regionr Ior whi(h
no emirsions were reported. Sl Appendix, tigt. 52 and 53 provide rimilar hapr for SO, and NOx. respedively. S/ Appendlr, Table 51 providet a referen(e Ior
abbreviationr,
E
!j
6
I
I
(production-ba.sed EF) to 233 k8,/Mwh (consumption-based
EF). Our results also demonstrate thc importance of time-
of-ycar effects and that carbon accounting based on annual
data alone is insufficicnt: The mcdia8 hourly EF for imports
into CISO was 216 kg/Mwh betwcen March and June but
394 kg,Mwt bctween August and November. Accounting for
351
soco
120
ERCO
o
o
PNAs l. t6r a.tider 3 ot 6
crso
2016 ELECTRTCTTY COrlSU rPltox (41179 TWh rot l}
I
II
t
I
II
I
Ealtam lnterronnact
2953 twh
o
Wasteft lnteaconnect
7/B Tllrh
C;
o
700
3e
80
IEC
Et€ctrictt coi{mptron (fl vt}3,..ll
Eibcnc*y tr.d. (Iwn)
1@ 200 300 aoo 5@ 6@ 7m 9@*
Con {mpdo n .l(l c.6o. lnt n.ry lrC[.Wh]
2016 CARBON COi{SUMPnOI (1833 t roll! torat)I
III
I
I
II
East€ft lnercoonecl1397llton5 |s EE\
a
l.
ID |!
W6stem lnterconnactta5 tons o
100
Carbon co.rumFtid {rn@.l
+li*src 100 200 300 400 5@ 6l)0 7@ 900
consrT.lontr..d c!6on l.rd.tty (rgllwtr)
."gS
Plo, Ptq Pgo ior hourly c.nrumptloF ..d prodqcn.Fb...d c.rbon l.L..lly {&r'llwh]
flg. 2. The (arbon footprint of electricity (onsumption. National- and annual-level (arbon accounting does nol capture the heterogeneity in rpace and
time of EF . The loth, s0th, and 90th percentiles (P10, P50, and P90, rerpe(ively) ot (on3umption and production'baeed carbon intenrity for sele(ed BAt
these complex carbon flows will be c tical for Calilornia to meet
its ambitious decarbonization targets.
Exhaustivc hourly time-scries data for electricity and carbon
produced. consumed, and traded as well as the corresponding
hourly carbon EFs arc provided in Sl Appendir.lrigs. Sl2-S77
for cach of the regions in the Unitcd States and can be used to
further interyret the trcnds observed in Figs. I and 2.
Balandng Alea-Level a loudy Level Carbon Ac@unting. Both thc
amount of electrical encrs/ consumed and its carbon footprint
vary significantly from region to region, by month and by hour.
Undcrstanding the dynamics ofdemand and supply for elcctricity
will he key to help reduce emissions.
Median daily profilcs for carbon consumption in thc iro
largest eastcrn and western regions arc shown in Fig. 3. [n
the western US grid, it is clcar that capturing thc impacts of
elcctricity exchanges is critical to accuratcly portray pollutant
flows and to dcsign cffective miligation stratcgies, That is lcss
true in the castern US grid. For very large rcgions, such as
PJM and MISO, turther disaggregation of hourly elcctricity
and emissions reporting (e.g., at the Power Control Area lcvel)
will enablc more targcted policics. Whilc basc load represents
a large ponion of demand, electricity and. consequently, car-
bon consumption, is typically greatcst in the late afternoon on
hot summer days and in the carly fall in PJM, MISO, and
CISO. In the other seasons, demand profiles arc much flat-
ter throughout the day (although demand is very oftcn lower
at nigho. ln thc winter, base load is higher in PJM, MISO,
and the Pacific Northwest's Bonnevillc Power Administration
(BPAT). These daily profiles confirm that harsher tcmpcratures
drivc emissions.
As can bc seen in Eq. I, consumption-based carbon inten-
sity is a function of the intensity of generation (largely driven
by technolos/ mix) and ofimports. Generation mix varies signifi-
cantly aqoss the regions in thc US electricity system, and so does
thc carbon intensity of electricity. Further daily and seasonal
data on othcr regions are shown in SI Appendir. Figs. S1-S9,
while SI Appendlt. Fig. Sl presents monthly time series for 8 of
the largest regions in the United Stat€s. Coal and gas dominate
in the MISO and Southwestern Power Pool- High penetrations
of hydropower aod rencwables are responsible for the low-
emissions-intensity electricity consumcd in the 2 major western
regions, CISO and BPAT. Nuclear powers most of the low-
emissions-intensity electricity consumed in the New York rcgion
(New York ISO). Even though they cach reprcsent a relatively
small fraction of elcctricity consumed (3 to 47.) and cmissions
60
8oo
Pzo
=
0
o
2
Mar Jun sep
12
Dec
50
40
20
0
7.5
5.0
2.5
0.0
60
40
20
50
40
20
0
't.5
5.0
2.5
0.0
6 66180
7.5
0
0
5.
2.
0.
7.5
5.0
2.5
0.0612ta
Hour of day
512 18
Hourofday
612 18
Hour of day
512 18
Hour of day
I
6
!
biI
:
Fig,3. Daily (arbon profiles for the two largert balancing areas in both US imerconnection!: the miclwedern MISO and no(heastern PJM in the eastern
interconn€ct, and California'r CISO and Pa(ific Northwett's BPAT inlhe western inter(onnect. Daily profilei are (omputed asthe median valuer for different
months and hourr oftheday. uring localtime zones. The{ull linei represent congumed emigsiont while thedashed lines represenl produced emitsions. The
thaded area between the full and dashed lines (orresponds to net (arbon tranrferr. Trade i9 mu(h more imponant in lhe Wert than in lhe East, as can also
be reen in rig. 4. 5/ Apperd,x, Fiqr. 54-59 rhow similar daily profiles for sele<ted regions in the uS elecrridty system, at well as daily proJiler ror electricity
and consumplion-bared (arbon intenlily, De(, Dec€mberj ,un, June; Mar, Marchj SeO September.
Top 2 Eastern 8As
M
BPAT
4of 6 I www.pnar.orgtgi/doi/10.1073,/pnas.19!2950116
il-+-|iIF,*l- i ila*-
lI*:i'lIF: i',**
I Ef,ports
-Ef-I-Ir
co2 (Mtons)0 510 15 20
50? (Kons)
0
crso
qit
Mlso
NYIS
ERCO
AZPS
50co
5RP
BPAT
ctso
PJl'l
Mlso
FPC
NYIS
ERCO
AZPS
50co
SRP
BPAT
ctso
l,lrso
NYIS
ERCO
tzPs
soco
SRP
APAT
f
t
2
flg. a. Sharing responribility for US electric-rector emissions. Top net importeG and exporteE o{ pollulants are shown. Relative imports and exports are
erpresred ar a fraction of the total embodied pollution ,or a region-i.e., if we (all importr, exports, production, and consumption as ,, f, e and C, the
percentag$ in the graph reprerent ;; for importg and #,. we note that pollutant flows are balancedr For ea.h region, / + P= E+ C and for the regiont
thatalmost only import # = I, while for regions that almorl only export rfo = ,.ln the West, trade is parti(ularly important. 5l Append,r, Fig. SlO provides
further inright into the pollLrtant trading patterns there in the lorm o, Sankey diaya t.Sl Appendix, TableSI provides a reterence for abbreviationr.
(0.75 to 1.870), 20% of the US population lived in these 3
regions in 2016.
Emisrionr Embodied in Electridty Ex(hanges. Pollutiofl traded in
Fig. 4 corresponds to thc emissions embodied in electricity
exchanges for the US electric grid's top net importers and
cxporters. In the same figure, relativc pollution tradcd is
exprcssed as a fraction of the total embodied pollution for
a region (consumption plus exprrts or, equivalently, produc-
tion plus imports). While COe emissions cause global climate
damages, emissions ofSO2 and NOx cause ltralhealth damages.
For rcgional climate policies, accurately measuring and track-
ing the carbon emissions embodied in electricity exchanges will
be kcy to achicving thc desired impact. Imported clcctricity
may run counter to climate goals. Of the 265 Mt of CO,] that
wcre cmitted to the atmosphere when gencrating electricity
in 2016 in the wcstern grid, thc interconnection where trade
is thc most rcle\ant, l1qo wcre emitted to satisfyx clectrical
consumption in a differcnt region. In the CISO, for cxam-
ple, 2016 imports represented 287a of consumption, but 40o/o
of the carbon emissions related to California clectricity con-
sumption wcrc produced in a diffcrent region. Carbon export$
reprcseot 30 to 607d of total embodiod carbon tbr a group of
large wcstern regions in Washington state, the Roclf Moun-
tains, and Arizona (BPAT, Northwestern Corporation, Western
Area Power Administration-Rocky Mountain Region lWACMI,Arizona Public Service Company [AZPS], and SRP). Some of
the same regions act as trade routes for electricity and cmbodied
pollution, simultaneously importing and cxporting large amounts
of carbon (AZPS. SRP, and BPAT). The Tcnnessec Valley is
another region which experiences such transshipments of clec-
tricity and carbon. For a few trade links, elcctricity (and carbon)
can flow both ways during thc year, or even during the day.
Rcverse flows represcnt from 5 to 4O7" of total trade lbr the 6
largest of these bidirectional trade routcs (Sl Appenllx,Fig.Sll).
ln contrast, nct carbol imports represented less than 37., of con-
sumption in the 2largest castern regions (PJM and MISO), and
the Texas electricity grid is almost completely independent.
Citizens in regions cxporting etectricity from higher-intensity-
generating sou.ccs bear a disproportionate local air pollution
burden. For some of the extreme cases in Fig.4, like the CISO
or ldaho's IPCO on thc importer sidc or the Roclf Mountain
WACM and thc Southwestern Power Administration on the
cxporter sidc, almost all ofthc l(rcal pollution caused by electric-
ity gencration is not colocated with the electricity consumption
that caused it, This is particularly lroublesomc for the cxporters:
While the generated electricity physically leaves those rcgions
through the electricity grid, these lrrcal pollutants don't. Our
computation of consumption-based pollutant intcnsity of elec-
tricity can provide an indication as to how embodied pollution
propagates through the 0lestric grid. Fig. 4 also highlights that
levels of pollution for SO2 and NOx (and COz) are not always
corrclated and that each of thcse pollutants necds to be tracked
individually. Higher levcls of SC)2 are typically indicative of
higher sharcs of coal generation, and higher shares of NOx arc
typically indicative of higher shares of gas generation. In the
CISO, SO, imports lepresent 767o of SO2 consumed, while this
number is only 31016 for NOx,
Diicllssion
In this work, we build and analyze a dalaset for pollutant pro-
duction. consumption, and tradc betwccn the 66 continental
US regions, from which localized hourly emissions footprints
can be built. If the damages ftom pollution are priccd, be it
through a price- or a quantity-based approach (20), electric-
it1 gcnerators and consumers will intcrnalize the environmental
costs of clecricity and adapt their bchavior. For instance, large
clectricity consumers could respond to variations in elcctric-
grid carbon intensity by shifting their operations schcdules to
hettcr match the environmental quality of thc grid through
carbon-aware or pollutioo-awarc scheduling. Similarly, devel-
opers of renewable enerry projccts could targct renewable
resources that are available where and when grid elcctricity is
currcntly carbon-intensive. Such cconomic signals will have the
most impact, howcver, whcn emissions data are reported at the
appropriate scalcs in time and space-namely, hourly and at
the BA lcvel.
This work has strong implications for both private and pub-
lic actors at the local, regional, and federal levels, even without
a price on cmissions. Coarsc national- and annual-level car-
bon accounting will not capturq the hcterogen0ity of hourly
production- and consumption-bascd EFs and may misstate cmis-
sions and emissions rcductions. Undcrstanding emissions flows
and their drivers will be key to ensuring that climatc-changc
:
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-
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-
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policies address the bigger picture and to avoid rcsourcc shuf-
fling. Sirnilarly, local environmental and health policies that
ignore how thc responsibility for pollutants ffows from produc-
crs to consumcrs through thc electric grid and that do not result
from the coopemtion of all ofthc partics involved will havc little
cffect in networks whcre trade volumes represent a largc share
of consumption and production. In conrrast. rcgions with fcwer
connections to the rcst of thc US clectric grid and less clectric-
it-v trade, such as in Texas. havc more direct control over thcir
consumcd emissions,
While US power plants reliably report hourly data for ('O2 on
aquartcrlv basis. accurate hourly measuremcnts ofSO2 and NOx
emissions rcmain unreliable in some regions (S/ ,{;4rcrrrlit ). This
study dcmonstrates that it is now possible to track clectricity and
pollutants in real time and lhat doing so will providc valuable
bcnefits for policymakcrs and investors alikc-
Materials and Methods
Difterent publi(ly available Jour(es for emisrion! and eledrici'ty data are
used in this work- The IJS Envjronmental Prote<tion Agency (EPA) tra(kt
emissionr for 3 major pollutantt through iR Continuour Emisrionr Moni-
toring Systemt: CO2, SOr, and NOx lsl Appendix, ref 1). The US Energy
lnformalion Adminirtration Electri( system Operating Data webtite hat
reported hourly (onsumption, produdion, and inter.egional exchanges at
the 8A level sin<e 2015 (Sl Appendix, rcf.21- tinally, plan! 8A, and nalional
statistic at the annual level from the EPAr Emirsionr and Generation lnte-
grated Resource databas€ lsl Appendix, ,et.3) ate ured to adjun emissiont
levelswhen dealinq with misrinq data and forvalidation. Thefull pro(edure
that is used to (lean data from there sources and the underlying arsump,
tion! are detailed in S/AppeDdix. Thisanalyri! does not account for life qcle
emirsions asso(iated wilh building power plantr orextracting luels.
Consumption-bated emi9gion! inventorier are (omputed at hourly,
monthly, and annual relolution for COr, and annual resolution for SO, and
NO)(. To e5timate the pollution emitted on behalf oI electri(ity (onsump-
tion at a certain node, we asrumed that emisrionr ar€ embodied in traded
electri(ity and that weran wrirethe following bBlan.eequation for a gi,en
pollutant (CO,, SO,, or NOx):
nd,= r, -lx1u,'-lla,, tl;
6 ot5 | wwwpnar.org/cgi/doi/10.1073/pnae.19129501 l6
electri(ity and embodied pollurion. All quantitis (and, in parti(ular, trade)
are poiitive- We rearrang€ thir to:
(d,-Iv{,! x1u1 = t,I2t
t4l
W€ (an alto write a balan(e equation for electricity (assuming there are no
transmisrion losler:p+U=d +V, Ir)
where U, y are total impon and expon vertorr and p iJ electricity produ(ed.
We c6n substiture thit to obtain:
xt lpt+ ui) Lxr1,j=fi
Thh equation (an be rewritten in the form Mx=f, wilh M=diag
(P+ U) u. To a<ess the intensity o{conrumption, wesolve a linear syrtem
at ea(h trme rtep, of rize the number of noder.
fo illurtrate and guide intuition, w€ (onsider a simpl€ example with 2
electricgrid regionr, a and a. We call.(,,y, the consumption and production
(arbon intenritiee at node i; D;, P, the.onsumption and producion of ele(-
tri(ity at node i; and ra. s a l-way tranrfer of ele(rkity from node A to node
A. We write the following balance equalions for (arbon:
xaDa- yaPa xaTa.s,
xBDs = yrPo+ x^Ta s{Irl
8y writing that energy is conserved at node A, we obtain:
I xa = v",t -- , _-q t5)lxB h6- "ie
for the erporter-only node, produ(ion and (ontumption intenrity are the
rame. tor the importer only node 8, on the other hand, th€ conrumption
intenrity ir the weighted average o{ its produ(ion intensity and oI node
i4's.ongumption intensity. Weights (orrespond to the fra.tionaltourcing ot
6ode Aj ehctri(ity (onsumption from its own produ(tion and from node A.
ln a network with a more comple)( topology, the fiamework srill appliet,
but (onrumption-based inteneitier may be lers intuitive, in particular for
6odes that simultaneously import and export electri(iry, since all nodes in
the network ere (oupled by Eq. 1.
We have released both the (od€ and data from thii work on GitHub {21).where lor node i, d, ir electricity contumed, xi is the int€nsity oI electri(-
ity (onsumed, , ir pollutant production, u,i h e,€dri(ily imported from Ito i, and vk, is electridty exported from i to k. Thir represen$ the balance
equation for a fully coupled MRIO model, a(counting lor lra nsshipmenls of
ACKNOWLED6MEiITS. Thit work was rupponed at Stantord by the Global
Climate and Enerqy Project and a State Grid Graduate Student Fellowrhip
through the Bi$ & watte initiative.
1. US Enviro.mental P.otedion Agen.y, 'l.ve.tory of U 5. grenhouk 9.r emission!
.nd rinkt: 19902016 Er€cuti@ rLrmm.ry" (ie.h. Rep., Envnonmenul Protection
Agen<y, w.thington, oc, 201E).
2. rntergovemme.tal Panel on Climate change, 'Global w.mi.g of 1.5 'rC Summary
lor policymaker'' V Manon-Delootte et al. Edt. (Te(h Rep , Wond Met@.ologi(a I
Organi.atlorL Ge.eva, Swiuerl.nd, 201E).3 I H. Williams et.l, The lednology path to de€p g.eenhouie gas emilriotu cut5 by
2050rThe pivotalrole olel.<tn(ny s@n(e 33t 53-59{2012).
4. W Moomaw etat, "Annex ll: Methodoloqy'in Aen.w.ble Enetgy Soorcet and Cli-
mate Chahge Mnigation- Sperial Repott of the l.teryotrnnental Panel on Clinate
Cha.ge, O. tdenhofer eta/., tdr. (C.mbridg. Unilenny P.ere, C.mbndge UK,2011),
pp.973-10@.
5. G 5chivl.y, r. Arev.do. C Samarar, Asr.seing the evolution ol porer se(tor carbon
inrenlity in the united Stiter. g,v,ron. aer teft 1!,06401a(2018)
6. A. Hawket Estimating margin.l COr emissio.e.ates lor.allonal ele(ricity syrtem!.
Eneryy Policy $,5977-5941 QO10l.
7. X. sile.tvanr l. L Azevedo, M. G Morgan, M.rginal emirsiont tador9 lor the Us
ele<triclty lyttem. Envr'ron, 5ri. fqhnol. 5, 41424148 .2012),
8. (. sile, Ev.nt, l. L A2e@do, M. G. MorgEo,I Ap! Regional varialionr in th€ he.lth,
envkonme.tal, and climate benefiB ofwi.d and solar qenerarioa. Prcc /vrd.
^<ad.5.r. U.sa. rlO, 11768-ll77l (2013)
9 1.5.G. Zivin, M J. Kotchen, E I Manrur,spalial a.d temporal hererogeneiry ol
ma19i.al em hsions: h pli.ation! tor €leclri( (arl a.d orher eledricity-shihing policiet.
, Econ. Behav Org 107, 2l8 26812014)
10. I Marriott, H 5 Matthews, Environme.ral efleds of rnteBtate poMr t..ding on
eledri.ity .onsu mptioh lnixei. Enircn. S.i feehnol. t9, a584 3590 (2005).
11 E Kodra.S Sheldon.i Oolen, O. Zik, lhe North Ameri@n €le.tri( grid ar an excha.ge
netrcrtr An approach for 4.luating eNrgy resur(e @opBition and g.ee.house
gai mitig.tion Envnon
'ei
re.hnol. 49, 11692-13594 0015).12 5 Ou, S. Liang, M. Xu, CO2 emi$ionr embodied in interprovincial ele<tri(ity
transmieelons in(hina Envto^ 5.i. Technol. a1,1089! 10902 (201n
13. B, Tranberg eta/, Realtime carbon a<counting method tor the European electri(ity
harteB Fffigy srr.teg/ aer 25, 100367 (2019)
14 l. Apt ne(ent retuhro. the integ.ation ol variable r.new.ble electri( power i.to lhe
us yid MR' tne.gy sutt.in 2, E5 <2015)
15 G sttac Denand e.L m.nag€h€nr: Ben.lir and.nalle ge.. Eneey Policy 16,
4419-4426 {2008)!6 A.E. M.<oonald er a/.. tltu,e <o(-.omperitve eled,icit rftemr aodtheir impad on US CO2 enBioni Nat. a/ir. Chang. 6, 526 531
(20r6).
17. G P Petert E G. Hertwi.h, CO2 embodied in i^ternational trade with
implicatiotu for global clim.re Ooli<y. E^vnon. 5(, I€(h.ol, 42, la01 1407
(2008).
18. S l. Davis, K. Caldeira, Coniumplion-ba5ed ac.ounting of (O2 emiriiont Proc &ar/
Acad ,i. U.sa l0r. 5687-5692 (2010).
19. l. A de Chalendar, 5 M senson, why 100% .ehewable ene.gy i5 nor enough. Jorle
3. r38+r39312019)
20. w D Nordhau, Io tix or not to ta!: Altemative approacher lo d@i.g glob.l
w.tring. Aev. Envnoh. Econ, Poltcy 1,264412041).
21 i. A de Chalendar, T.a.kingemBiioni in the Lr5 elern.aty system (rupplement.l (o.b
and d.ta). GitHub. httpt:/&ithub.com4dechalenda/ra<king-emi15io.s. Deporited t7
R
!
!
6t,ItI
SGIP - About the Self-Generatlon lncentive Program
Home i Energy i Consumer Energy Resources : SGIP - About the Self-Generation lncentlve Program
About the Self-Generation lncentive Program
The Self Generation lncentive Program (SGIP) is one of the longest-running and most successful distributed generation
incentive programs in the country. Asof Dec€mber,20'16, SGIP has funded 2,178 completed projects representing over
450 MW of rated capacity. An additional 312 projects representing over 178 MW of rated capacity are in process
towards completion. The program continues to make strides towards a cleaner, distributed-energy future.
The SGIP was initially conceived of as a peak-load reduction program in response to th6 energy crisis of 2001.
Assembly Bill 970 (Ducheny, 2000) designed the Program as a complement to the California Energy Commissions'
Emerging Renewables Program, which locusod on smaller systems than lhe SGIP Since 2001, the SGIP has evolved
significantly. lt no longer supports solar photovoltaic technologies, which were moved under the purview of the
California Solar lnitiative after its launch in 2006. lt has also been modified to include energy storage t€chnologies, to
support larger projects, and to provide an additional 20% bonus for California-supplied products.
Senate Bill 412 (Kehoe, 2009) modified the focus on the Program to include greenhouse gas reductions. Specifically, this
bill directed the Commission, in consultation with the Air Resources Board, to identily distributed energy resources
which will contribute to greenhouse gas reduction goals and to set appropriate incentivg levels to encourage their
adoption- The Commission took this opportunity to expand the porlfolio of eligible technologies, modity the incentive
approach, and to enact other operational requirements including wanantees and performance monitoring to ensure
greenhouse gas reductions.
SGIP was significantly modifi€d by D.16-06-055 to reflect changing conditions and priorities with respect to the
program. The changes made by D.'16-06-055 include the allocation of 75% ot the incentive budget to energy storage
projects, capping each technology developer to no more of 20olo each oI the incentives for large-scale energy storage,
residential energy storage and generation, the creation of a step systom for incentives and the creation of a lottery
system for allocating incentives to projects when a given step is oversubscribed.
The Seliceneration lncentive Program will offer incentivos to energy storage systems based on several factors,
including the kilowatt-hour (kwh) capacity of the system. Tho incentive amount oflered to new storage customers will
decline over time as the market matures to ensure efficient use of these ratepayerjunded incentives. Each incentiv6
level is known as a "step," and a ceftain amount of money is r€served for each step. On a statewide basis,
approximately $40 million has been reserved for onergy storage systems in each step. There will be five steps lor energy
storage systems.
The table below illustrates the planned incentive steps for residential energy storage systems 10 kilowatts (kW) in size or
less. For systems above 1okw plsase refer to the SGIP Handbook available at this webpage for more details on the
incentive levels that apply (the 2017 version of the SGIP Handbook may not be posted until March, 2017).
idsntial Energy Storage Systems less lncentive rate per Watt-hour (sse important
or equal to lokw in sizs disclaimer below)
50 centvwatt-hour
2 45 centvwatt-hour
3
12131'19.1:16 PM
o.IE@Colitornill Pdblic
utilities clnnrf(iof
https://www.cpuc.ca.gov/Generel.aspx?id.11430
40 centvwatt-hour
Page 1 of 2
fr",m F.-TFO
fr ltout Us Safety Transparency Utilities & lndustries Licensing Proceedangs Complaints Public Advocates Office
tep 5 30 centvwatt-hour
SOIP - About the Self-Generation lncentive Program 1213119,1:16 PM
p4 35 centvwatt-hour
Step 1 will commence whon the pmgram reop€ns in spring 2017. Each subsequent step will begin once the previous
step's budget is 6xtinguished.
IMPORTANT DISCLAIMER: The amount ol incentive decrease between steps can accelerate iI a step extinguishes the
entirety of its budget in '10 days or less. ln that event, the decrease between steps is 10 cents/Watt-hour rather than 5
cents/Watt-hour. For example, iI Step 1 extinguishes its budget within 10 days ol its opening date, then the Step 2
incentive rate will be 40 centtwatt-hour rather than 45 cents/Watt-hour.
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Copyright @ffi$t:-et-ts'iror'1l----+
Y f9.oin
Michael G. McBride's comments to PUC case IPC-E-18-15 December 3, 2019
I would like to thank the PUC for giving me the opportunity to make comments on
this proposed settlement agreement.
I think it was great that the parties involved tried to use a collaborative process to
reach a consensus through this settlement agreement.
I think that it is positive that under this process the current service charges of
about 55 per month were retained. Also, underthis agreement if we have any
excess energy credits at the end of the year it seems reasonable to pay a $10
aggregation fee to move the power credits over to our pasture irrigation pump
which is on a different bill and meter.
I do, however, have a number of concerns with the agreement as written. One of
my concerns is that this agreement is written so that it is very confusing for a lay
person to read and understand what it is saying. This is especially troublesome on
page 5 of the agreement where they talk about schedules 5 and 8. Terms like
current blended base energy rate orthe difference between the then current
export credit rate or what 75% of the difference between these (l am thinking to
myself "say what????").
Another thing that bothers me is that I found several places where the parties
seem to agree on the settlement's outline but reserve the right to fight over the
details in a future proceeding. For instance, on page 3 under lll. Avoided
Transmission...(the methodology to determine such a value is not part of this
settlement agreement, but parties retain the right to advocate for a methodology
to determine such a value in a future docket). lt seems to me that in a lot of areas
the parties failed to agree and meet consensus and are just pushing this partially
completed settlement agreement forward even though it doesn't thoroughly
solve the issues.
I have several additional concerns about this agreement. Firstly, ldaho Power
controls the data on which future billings can be based and they don't seem to be
sharing a true cost analysis for the numbers and proposed charges that have been
generated for this settlement despite the fact that they were directed to do so
previously by the PUC. On page 2 of the settlement agreement under A. net-
hourly billing this document proposes a new method of calculating excess power
produced or power imported is introduced- "NET Hourl Billin ". The reason for
this change in accounting method is not explained but must be something that is
done to favor ldaho Power's position. The reasons for and outcomes being
unknown is this perhaps some sort of trojan horse that the power company has
put in for future adj ustments. One outcome mieht be that solar installation
companies will no longer be able !o give prospective customers accurate
Dro ections on how lon it will take to realize Dav back on their investment. Is
would encourage the PUC to change this back to the current monthly net-
metering process not hourly net-metering
We have learned that ldaho Conservation League was part of the negotiations
and they did not sign this settlement agreement at least in part because they felt
it was unfair to current on-site generation customers like ourselves.
I ask now that rather than making us suffer with this agreement that the PUC
exempts the 4,000 or so current on-site generation customers from the new
rules. I think it is only fair. ldaho Power seems to want to stifle future on-site
production so it is up to the PUC to decide if you will permit them to do so
through this agreement. Please make the choice to encourage customer
generated power.
ln closing, this past Sunday I took a walk around our extended neighborhood and
knocked on doors of houses with solar panels to see how the rest of the
neighborhood was reacting to this settlement. Bob our neighbor down the street
agreed to come with us and testify tonight. At two houses no one was at home
and at the remaining two houses I talked with neighbors who were completely
oblivious to what was going on here and kind of looked at me like I was a man
from the moon. A lot of people who have solar also have kids to take care of,
Thanksgiving dinners to cook and lives to live and are really dependent on the
members of the PUC to look out for them.
About a year and a half ago I testified to the PUC about net-metering in Pocatello
at which time ldaho Power had wanted to raise on-site generation customer's
service fees from about 55 to 565 without presenting data to justify this raise. ln
this settlement case from what I can tell ldaho Power is trying to pull another
rabbit out of the hat without presenting the data to back up their request. I am
not opposed to getting credited only for say 80 or 90% kwh for my exported kWh
but cutting it to 50% kWh does not seem fair on the face of it.
Thanks
Michael McBride
2502 Laurie Lane
Twin Falls, lD 83301
Melody Asher's commen
I uto
we are not richffie as a
ts to PUC case IPC-E-18-15flj)7Jo b
n/n'6-
try'-,
els
A-1^.\
family made a substantial investment into solar pan
because we felt it was the right thing to do NOT just to reduce our monthly power
bills but we still feel that we should be able to see our investment pay off
monetarily as well before we are dead I We spent a good portion of the money we
inherited when my parents passed away on our solar panels. We put solar panels
on our roof as our way to contribute less to human-caused global warming or
climate change. We put solar panels on our roof and became on-site generation
or net-metering customers because we hope that we can make a difference
globally by acting locally by producing and using solar power. Through the
currently existing program with ldaho Power I think it will take 12 plus years to
pay back our investment and it will take even longer if ldaho Power is allowed to
give us less kWh credit for our excess power.. Our solar power system was
designed to meet a certain Yo of our usage & it will not do that anymore if ldaho
Power is allowed to credit us for only about% our exported power...
z'We as a society and as power companies need to do this now not in 10 or 20
years. We_ere c_qntributing to ldaho PoweCs !0!70 clean energy by 20_15 gga.l
now. Reviewing what information we could find in local news, mailings, and
internet searches I cannot see that ldaho Power did the comprehensive study of
the costs and benefits of solar power that on-site generation customers send into
the grid like the PUC said would happen before ldaho Power would be allowed to
change the value of credit for our excess electricity. lsn't that something that was
supposed to happen before ldaho Power is allowed to change the net-metering
program. lf they did the comprehensive study then where is it??? I would like to
see it. I would have thought that it would have been included as an attachment
to the settlement agreement. The comprehensive study should have explained
the rational used to develop the new schedule. To me the current kWh credit for
kWh exported is a fair credit for our investment in local clean energy that benefits
us all including ldaho Power. About 50% credit like ldaho Power wants to change
the kWh credit to does not seem reasonable or fair!
ldaho Power must have studied hourly vs monthly metering because they want to
change that also and they must be going to make even more money off our on-
site generation through hourly metering & again we have not seen a study about
this & I would like to stay on monthly net metering as it is now.
ldaho Power Company acts like they support residential solar power generation
and sends out little brochures to that effect with our bills and maintains a
webpage encouraging customer solar power but they seem to want to make it
less and less worthwhile for their customers to actually have solar panels. lnstead
they should support their on-site generation customers because we are making
solar power for them also. I think that ldaho Power makes plenty of money off
our excess power by selling it to our neighbors at full rate. I expect that there is
almost no line loss with the power going to our adjacent neighbors. I do not
believe that ldaho power should not be allowed to change the value of on-site
generation kWh credits. The settlement agreement clearly states that the parties
therein involved leaves it up the the PUC whether the current on-site generation
customers should be grandfathered and remain under the same system that was
in place when the customer installed their solar panels. I think that ldaho Power
should grandfather all current customer on-site generation -schedule 06
customers in at the full credit for kWh and monthly net-metering program that
we are on now. That way current customers would live by the rules that are in
place already and new customers would know up front what energy credits they
would receive and be able to determine h ke to pay back
their investment. This is only fair. (
Please reject ldaho Power's request to es n stru ctu res
the customers already generating power and just leave us under the current
existing rule/schedule.
Thank you.
Melody Asher
2502 Laurie Lane
Twin Falls, lD 83301
Testimony of: Patricia B. Raino
Private Citizen
Address: 4905 W 0utlook Ave
Boise, Id 83703
For: Case no. IPC-E-18-15 as regards to Net Metering
Thank you for holding this hearing.
It is important that ldaho Power not betray the trust ofthe customers that have
invested in solar power here in Idaho. To change the program under which solar
was installed is wrong and will bring hardship to many of ldaho Power customers
that have made the good sense choice to limit their carbon footprint. Further,
moving from net metering will discourage others like me to utilize solar to meet
their enerry needs.
My son has a large solar company in Honolulu that employs more than a 100 people,
and because he grew up in ldaho, has property and family ties to our state he has
also extended his business to Idaho. His business, RevoluSun provides residential
and commercial solar as well as storage systems for solar. Those who have
purchased solar systems using the current ldaho Power poliry of net metering will
find it difficult and costly to adjust their system to the proposal submitted by ldaho
Power. The PUC should be concerned with diversirying and creating redundancy in
our energy system.
I concur with many of the points made by the ldaho Conservation League and also
recommend the PUC adopt the following recommendations as regards Idaho
Power's new Net Billing Program:
1. Set the Net Metering Program availability enrollment dealing to 50 days
following the Commission's order, with eligibility based on application and
system completion within a year.
2. Keep the Net Metering Program open to existing customers indefinitely or at
a minimum 20 years.
3. Existing customers should have the option to transition to the Net Billing
Program.
4. Apply Net Metering Program status to the system, not the customer, allowing
for sale of property.
Solar generation is an important part ofour enerry system and with the PUC'S
encouragement could supply energy to many of our citizen's. It is important to look
at the big picture and ldaho Power has taken a very parochial and limiting view of
solar generation in this state.
Q"r.,i4
4ull-{
My name is Micah Hornback. @ am an Idaho Power
customer. . 11
\rv ( 1. /./'-L .u
VThank you for the opportunity to speak today Commissioners. I am honored
and privileged to be a part of this democratic process.
I've worked for a solar company here in Boise for four years now; however,
am speaking from my own perspective and not on behalf of the company I
work for.
I'd like to start by quoting from the case that we are discussing here today.
On November 9'h, 2018, the PUC released Order No. 34189 in Case No. IPC-
E-18-15. Starting with *re third paragraph of that document, it reads:
) Notice of Petition
YOU ARE HEREBYNOTIFIED that Idaho Power's Petition asks the
Commission, according to Order No. 34046, to "initiate a docket to
comprehensively study the costs and benefits of on site-generation on
Idaho Power's system, as well as the proper rates and rate design,
transitional rates, andrelated issues ofcompensationfor net excess
energ/ as a resource to the Company." Petition at2, citing Order No.
34046 at 31. In that Order, the Commission indicated that the docket
should include all net-metering interests with a focus on Idaho Power's
systems, costs, benefits, resources, and tariffs. Petition at 2; Order No.
34046 at23. I il,ag.cl Q_
I originally interpreted this notice to mean that the "intervention" period was to
ensure that this study was to be fairly conducted by Idaho Power in
conjunction with third parties, in the most objective manner possible.
I believed at the time that engineers, mathematicians, economists, and other
specialists in the field would be drawing diagrams on whiteboards, running
numbers, comparing notes, utilizing other net metering studies, and working
together to determine the most fair solution for properly evaluating customer
generated solar energy on the Idaho Power grid.
Well...it turned out that instead of an analysis by engineers, mathematicians,
and specialists, it was just Idaho Power behind closed doors intimidating these
dintervener's' lawyers with more powerful lawyers and stronger negotiation
tactics.
During these closed door negotiations, not only was there no attempt to
"comprehensively study the costs and benefits of on site-generation on ldaho
Power's system," but there was no consulting with existing net metering
customers, solar installers, and "all net metering interests" were certainly not
accounted for.
The parties who decided to intervene, although well-intentioned, signed onto a
settlement agreement that I venture to say would have been almost
unanimously shot down by existing net metering customers and most solar
installers, myself included.
I am confused at how the vast majority of net metering customers, as well as
solar installers, are being blindsided with this sefflement agreement when we
were instead told that we'd be presented with a comprehensive, objective,
cost/benefit analysis of the import/export value of customer generated power
on the grid.
I disagree that the proposed settlement is 'Just, fair, and reasonable, in the
public interest, or otherwise in accordance with law or regulatory policy," as
stated on page 3, paragraph 3 of Order No. 34460 in Case No. IPC-E-I8-15.
I can say with conviction that I renounce this settlement completely. In fact, I
consider it null and void for having not met the original requirements set forth
in Order No. 34189 in Case No. IPC-E-18-15. I believe that the study should
be completed and that all parties with net metering interests should have ample
time to review the published study prior to implementing net metering
changes. Only after these tasks have been accomplished should we revisit this
hearing.
Lir.nll.+h""'^1 stnc.nll bt a X'vna< . flu "r.,,'^--.^-)'
Thankyouforyourtime. nt'td 'r:+ 0b" n^"1-Q- ' 0It's c' q;'/a-UJ
0
Idaho Public Utilitics Commission
1 1331 W. Chindcn Boulevard
Building 8, Suite 201-A
Boise, Idaho 83714
Re:Casc No. IPC-E-18-15
Study of Costs, Benefits, and Compensation of Nct Excess Energy Supplied bv
Customer On Sitc Gcnctation
I am a residential customer of Idaho Porvcr Co. residing in Nletidian, Idaho. Inthesummcrof 2019
I performed a fmancial analysis of instalLing a solar photor.oltaic system at my l\{eridian home. 'lhis
analysis indicated that thc costs of the $21,450 system would be tecovered in 16 ycats. 'Ihe analysis
was based on the current "monthly net meteting" program, the only onc availablc at the time, and
the only one offeted by Idaho Power.
r\n apphcation rvas made to Idaho Porvct in the fall of2019 and a 23-panel svstem was installcd.
i\'lonths after mv application Idaho Powcr informcd mc of thc proposed program changes. Thc
intention of my system rvas to meet mv family's needs under the monthlv-net metering program.'lhe following is the analysis of thcsc proposed proppam changes on one Idaho famill'.
I have a N'Iaster's degree in Fi,conomics/liconometrics and I am not an expert on Idaho Power, nor
on solat systems, howcvct I am au expert on my family's ftnanccs, solar gcnctation, and electricir,v
consurnption. In ordcr to perform my analvsis of the impact on m1, family I had to model the
clectrical consumption of my homc for cvcry hour of evefl. day of every month. This means I had
to cvaluatc thc consumption bv refrigerators, ftcczcts, HVAC s1,stem, hot tubs, computer systems,
electrical car, and other appliances.
Thc ston' bcgrns rvith my family's acquisition of a solar systcm in fall of 2019. 'l'hc total cost was
$211450, aftct crcdits thc c()st lv,ts approximatelv $14,5C)0. Llntlcr thc systcm of nctrnonthly
mctcting program at thc time of thc purchasc, my systcm had a cost-rccor-erv period of 16 ,vears. In
sirnple tcm.rs, that means in 16 yeam my family rvill tecovcr thc cost of the systen.r, with rro profit
and no return on our inr,cstmctrt. 'Ihis invcstment, under the net-rnonthly program in placc at the
timc of purchasc rvould incrcasc thc valuc of my home and in thc cvent of a salc a largc portion of
thc solar invcstmcnt s,ould bc rccovcrcd. ln addition, Idtho l)orvcr Companr,rvould makc a profit
of $3.600 on thc cxccss powcr my systcm produccs.
LTnder the proposed progmm changcs (Casc No. IPC-E-18-15 - Hourly net-metering & dollar
charge/compensation to thc solar producer) the results the of cconomics analysis of this family's
solar systern drasticalh' changes. 'I'hc cost-rccovcn pcriod <-rf 16 years becomes 36 yeas on
cquipmeut rvith a life expectancy of 25 \'cars. Feu,families rvoulcl make such an investn'lent in a
solar systcm rvhcrc thc fanill, rvill llcvcr rccorfcr thcir initial costs.
7
A Study of the lmpact on an ldaho Family
of
No, IPC-E-18-15 "Net Hourly Metering & Compensation"
The Iirct queotion how is that possible? 'lhc ansrver is simple. Ir{,v sl,stem generatcs thc nraiori6'
of the porver dudng the mid-da,v and dutilg the sumrner months (i.e. rvhen the sun is shining), whilc
thc maiority of thc porvcr consumption is in thc eady mornings and cvenings (i.e. outsidc of thc
time the sun is shining). Thc follorving graph illustrates Idaho l)r'rrvcr's proposed nct-hourlv
consumption and generation ofpowcr (nct powcr usage is red and net gcncration grccn).
Net-Hou rly Power Consumption
5.000
4.000
3.000
2.000
Familv1'ooo pays
,{.$$*$ss*.$s
Idaho Power Profits
Family
pays
$.$.$t-i"$$'F"b'$$$$$$J
(2.000)
I Use Power I Generate Power
2
A Study of the lmpact on an ldaho Family
of
No. IPC-E-18-15 "Net Hourly Metering & Compensation"
A Study of the lmpact on an ldaho Family
of
No. IPC-E-1&15 "Net Hourly Metering & Compensation"
,'\lso, at play, is an annual cyclc, as solar production is srgnificandy higher dr.ning the summcr
months due to longet hours of sunshine and the position of the sun. The following graph illustrates
thc Net-Nfonthly generation and consumptiot't of energy at mv homc (nct powcr usage is rcd zurd nct
gcncration grccn).
Net-Monthly Power Consumption
800
Idaho Power Profits
600
400
0
200 Family
pays
Family
pays
{
.{ J r$ ='". ""' '"s -.",--o "o...{ J,200
-400
-600
'l'hcsc two factors, thc homc's net-hourlv consumption and the annual net-monthly consumption
along with the proposed pricrng undct No. IPC-E-18-15 net-houtlv meteting would create a
situation whcre one economic value is placed on the powcr consumed, but a scparate, much lower,
value is placcd on thc porver generated. I belicve the standatd rate for power consumed is both
ptactical and cconomically justifiable, and I have no disputc with it. However, thc tate now
proposed to bc paid for gcnetated (exported) power is not justificd by any economic or cost-based
analysis, and, if adopted, rvould crcate the situation where this family's solar system rvill ner.cr
recover thc costs. The study of mv svstem and the ptoposed net-hourly pricing structure the cost pf
the systcm will never be tecovered but Idaho Power Company rvill makc a p&Iilat$25J00__to
M0.000 with no invcstment and no risk.
How is that possible? Idaho Powcr's profit is simple, I am paid a few cents for the excess/cxpoted
powct, the power flows out of my home to a ttansfotmer and back down a powerline to my
neighbor's home. N{y neighbor is chatged full market pricc and Idaho Powct iust made 150% off
my expotted clcctricitv with no ptoduction cost, no dsk and no investment by Idaho Powet.
Vho wins? -fhe shareholders of Idaho Powet Company. Not one ratc payet. This study shows
that Idaho Powcr shareholders and exccutivcs win with no investnent and no risk, while my family
loscs.
3
I Use Power lGenerate Power
t
A Study of the lmpact on an ldaho Family
of
No. IPC-E-18-15 "Net Hourly Metering & Compensation"
'l'he ncxt <lucstion for me r',zs rvhcther, uncler this "net hourll program" is there any sizc solar
s\-stetn that makcs ecottotnic sensc to install. A simplc cost-rccovcrl,analysis shorvs that thc ansrvcr
is Nol lf this is truc for sir.nilar lclaho fan.rily soltr systems, that mciurs ferv Iclaho honrc ou,ncrs wi]l
invcst in solar and that nrcafls lorvcr dcmand and thus thc solar industrl,rvill cut back and thc
industr! night cvcn nlovc out oI statc to locations [norc rvclcoming to thc indushr'.
'Ihis event taises two more questions: With the solar industry gone, who thcn rvill prcx'ide thc
waffanties to thc current solru customers? And the more Import^flt qucstion, is elimin^tion of
family owned solar generation systems in the public's interest ot Idaho Power's-/ I suggest that
Idaho l)ower's proposcd ncw ratc structurc, which, if adoptcd, rvould dcstrol, anv rati(mal conccpt
of "nct" in flet metering, will sevcrclv impair, or cvcn climinatc, this important clcmcnt of
distributed electrical gcncration in Idaho and rvould flot bc in the public intcrcst. I believe that a
more divcrsc, distributcd elec[ical generation basc, patticularly onc whosc cnpital costs arc bcirrg
bome by Idaho citizens and not thc power company, is in the public intercst. 'l his is particularlv true
norv, rvhcn global rvarn.rirrg is thteatening our cconomy and our natural rvodd. Idaho l)<xver's
proposed approach hcrc is an xttempt to star.e off needed changes in the electrical utiliry industry,
and I belier.e ultimately rvould not in the (irmpany's ovn interests.'l'he Commission should adopt
policics that cnc()urage thc utility to l>roadcn its rcsourcc basc, not narrow it rvith delibcratc antl
one-sidcd ratc structurc that unfairlv penalizcs r<xrftop solrr.
lrinally, this stucly shorvs that, if thc (lotr'nrission wcrc t() ^dopt Idaho l)orvcr's undcr thc prrposcd
"Ne t-Houd1, mctcting program" it l.ould simplt cor.rstitutc the taking of rny firnrily's propertl bv
Idaho Porver firr their benefit and l,ithor.rt compcnsati()n.
'I'his is because the Compant,rvotrld be rcccir.ing porver fronr nre firr rcsale at retail rntcs on its os,n
account without providing me fair and rcast>nable cornpcnsatitxr. ,\ takiflg also occurs, I subfiit,
undcr thc critcria Idah l)os,cr oscs fr rt n-raintaining cligrbility rvithin this "nct-hourlv program."
lir.en if n.ry systcm wcrc grandfathctcd by a Commission otdcr, my systcm rvould bccomc incligiblc
for this status rvhcn I scll tny homc or pass it to hcirs. At thosc cvcnts the cconornic valuc of nrv
solar svstcm is clinrinatcd becausc lrry st stcm is thcn con\.crtcd to thc ncrv, r'ro-rcasonablc-return-on
investment program.
4
A Study of the lmpact on an ldaho Family
of
No. IPC-E-18-15 "Net Hourly Metering & Compensation"
Conclusions:
The real studv of the cconomics of rooftop solar at a real Idaho home demonstrates a simplc
conclusion: IPC-E-I8-15 is about pto6t, greed, and makrng solar unprofrtablc. lt is about
climinating home solar gcnetation from Idaho Porvct's grid. 'Ihc l'UC's duty is to superr-ise nnd
rcgulate utilities like Idaho Power, to be fair, just, and tcasonable, and to make dccisions in thc
public intetcst. The PUC should tcjcct No. IPC-E-18-15 frrr the following reasons
1. This proposed net-houdy program takes a family's investment and creates a situation whete
the family loscs and Idaho Powct profits by wav of: (1) a rate differential that is unsupported
and unfair; and (2) eliminating thc value of thc famih's invcsthent at thc time of theit home
sale.
2. Idaho l)ower's manufacturcd credit tate for exportcd porver is a fabrication as dcmonstrated
by my analysis of rvho teally consumes thc power my home gencratcs and what thcy pay for
the porvcr I generated. Idaho Pow'et has not shown, and I believc cannot demonstrate, that
tcceiving and reselling electrical energy &om my solar systcm comes at a cost to thc
Oornpany that would justi$ such an extraotdinary pnce differential.
3. 'I'he proposed nct-houtly metering will substantially reducc, if not eliminate altogether, the
solar indusul* in Idaho.
4. My family was not ieprcsented in tlris behrnd the scenes proposcd setdement and rvas not in
anv way represented as it is clear no homework was petformed by anyone tcgardiog a solar
gefleratot of my natu::e.
The PUC should immediatcly ordet Idaho Powet Company to provide evew customer with acccss
to the customer hourly power consumption fot the last ycar, and should requle the Company to
complete a thorough analysis of thc economics of rooftop solar and its true costs and bcnefits to its
customcrs.
fuchard Kluckhohn
N{cridian, Idaho
[phone]
[e-mail]
5
A Study of the lmpact on an ldaho Family
of
No. IPC-E-18-15 "Net Hourly MeterinE & Compensation"
Power Genetation and Usage Graphs
The follorving graph illustratcs porver used & gcnetated by hour and demonstrates that usage in the
early motning and evenings is the hdhest, whilc ptoduction of cnergy is the highcst in the middle of
the day.
Power Usage & Generation
by Hour
u ru tll.r,rlJl,,l J,,l. ltr,
EEEEEAEEEEEEEEEEEEEEEEEEs<t L^ \o r'\ co o' <i J c{ J ^i .it s !^ ro r- qi oi 6 J ^i
-.o"
oou""d."d "" ."N +"" r"e s *-'_..".o
I Usage IGeneration
Thc following graph illustrates power used & gcncrated by month and demonstrates the unique
pattern of usagc of my homc, and the highest is during the summer months.
Power Usage and Generation
by Month
1400
1200
1000
800
600
400
200
0
6
r Ugage lGeneration
^so ^$'
4.5
4
3.5
3
2.5
2
1.5
1
0.5
0
Jeff Fereday and Kay Hummel
420 E. Crestline Drive
Boise. lD 83702
December 2,2019
Idaho Public Utilities Commission
1 l33l W. Chinden Boulevard
Building 8, Suite 201-A
Boise, Idaho 83714
Re Case No. IPC-E-18-15
Study of Costs, Benefits, and Compensation of Net Excess Energy
Supplied by Customer On-Site Generation
Dear Commissioners:
We are residential customers of Idaho Power Company ("IPCo" or the
"Company). Beginning in2016, with additional panels and a nerv inverter in 2018,
we have invested over $28,,000 in a solar photovoltaic system at our Boise home.r
The Company's proposed changes to its net metering program in this proceeding
would substantially undercut our expected retum on this investment and, we
believe, constitute an unjustified windfall to the Company and its shareholders. But
beyond that, and more important as a public policy rnatter, is the fact that the
Company's proposal would have a severe chilling effect on the development in
Idaho of distributed solar and other customer-owned distributed generation C'DG')
resources.
We respectfully request that the Commission not adopt or approve t}re
October 1l , 2019 Settlement Agreement entered by IPCo and others (the
"Settlement"), not impose the Settlement's proposed new rate structure applicable
to DG resources, and hold the matter in abeyance pending further study. Rooftop
solar in Idaho is in its infancy, and this proposal by Idaho Power Company likely
will throttle it. Rooftop solar today has been adopted by some 5,000 of the
rThe total cost ofthe system, which was paid to AltEnergy, lnc. as supplier and installer, was $28,707.00. With the
federal tax credit and a state tax deduction. the cost to us (after a five-year amonization) will be approximately
$ 18,000. In evaluating the costs of IPCo's proposal, it \,yould appear that tle higher number would be appropriate
because that is what went into ldaho's economy. ln evaluating the cost to our investment posture, the lower number,
adjusted for the timing oftar savings, would be appropriate.
I
Company's customers-about 0.01% of its customer base-and it accounts for a
rniniscule portion of the Company's installed capacity. The effect, financial or
otherwise, of private roollop solar on the other 99.99 percent of ratepayers cannot
be significant. On the other hand, distributed solar is a step in the right direction for
the environment and, we submit, for IPCo's customer base generally; it certainly
carries part of the load toward the Company's "1000% clean energy" aspiration. The
Commission should take no steps to thwart the development of customer-
sponsored rooftop solar in Idaho.
DG's effect on other ratepayers is typically based on the argument that the
revenues they pay for the electricity they still purchase from the utility may not be
covering an adequate share of fixed costs, such as transmission-in other words,
"that net metering customers are not purchasing sufficient kWh to cover fixed
costs," and that "an additional measure is needed to prevent a cost shift from
occurring."2 Presumably, this is IPCo's argument, even though the Company has
not yet made a case for this, much less a convincing one. In any event, studies by
the Brookings Institution and others have concluded that such impacts become
meaningful only when the penetration of rooftop solar approaches an installed
capacity of around ten percent. In Idaho, the current number reportedly is no more
than about 3.5 percent. As stated in an exhaustive analysis ofthis issue by the
economists at Lawrence Berkeley Lab, "for the overwhelming majority of utilities,
current PV penetration levels are far too low to result in any discemible effect on
retail electricity prices, even under the most pessimistic assumptions about the
value of solar and generous assumptions about compensation provided to solar
customers (e.g., ful1 NEM [net rnetering] with volumetric rates)."3
Furthermore, even if DG in the Company's service area were causing
increased costs to other ratepayers, any rate structure change to address this should
compensate these ratepayers for these exact costs, not the Company's shareholders.
There is no indication that the structure proposed here, which plainly would
penalize the solar power generators to the point of being confiscatory of their
investments, would be tailored to compensate for such effects and would not
simply enrich shareholders.
We contend that neither the Company nor the Cornrnission has enough
information yet to make such a momentous decision. IPCo has not completed the
2https://www.infrastructureusa.org/wp-cotrtgnt/up loads/2o14i l2i fte20I4finakeDon- l4I I I 3033 126-conversion-
sate0l - l.odf
lhtplieta-publ ications.lbl. govisitesidefaultifi lesi lbnl- I 007060.pdf
2
study the Commission ordered, and has not released any analysis it may have done
for public review and comment. In sum, there is no need to rush into this decision,
especially absent a thorough cost-benefit study such as the one the Company is
obligated to produce. We believe that any analysis the Company or the
Commission ultimately engages in on this subject should be available for review
and should cover all relevant issues, such as those set forlh below.
To summarize our central requests, we urge the Commission to:
1) reject the proposed Settlement and hold this matter in abeyance;
2) order the Company to complete and make available to the public the
study specified in the Commission's June l, 20i8 Order 34604, Case No.
IPC-E-I7-13, which study is to evaluate the costs and benefits, both to
the Company and to other customers, of net metering relative to DG, and
particularly residential on-site generation;
3) ensure that the study includes, in addition to the above, at least the
following analyses:
a. the value of DG over the next 25 years, to the Company and its
ratepayers, in helping to meet Company's stated goal of achieving
100% "clean energy" by 2045;a
b. the current value of the investment in generating plant represented
by all the DG involved in the Company's net metering plan, and the
Company's cost of replicating this amount of installed capacity
with solar or other energy sources;
c. the actual ransmission and other fixed costs incurred by the
Company or ratepayers arising from DG-produced electricity;
4The Agreement expressly avoids assigning any "environmental benefit" to rooftop solar. This is unacceptable,
panicularly where the Company itself claims to be putting resources into clean energy, presumably to gain their
environmental benefits. Existing DG resources should nol be hamstrung, and future DG resources effectively
blocked, by this proposed new rate schedule while the Company supposedly figures oul how to bring on line cost-
effective clean energy resources. These clean energy resoulces ate here today, delivering an environmental benefit
that the Company, we contend, should be compelled to value in this process.
3
d. the relative firmness, and the relative interruptibility, of DG in the
Company's system as compared to the energy from generation
sources from which IPCo might be able to purchase on the retail or
wholesale markets;
e. the higher costs, if any, borne by non-Dc IPCo customers as a
result of having DG systems producing power for the Company's
grid under the current, one-for-one net metering arangement;
f. the benefit to the Company arising from those DG owners who
annually produce and provide to IPCo more electrical power than
they consume-thus producing excess electrical energy that cannot
be used by the producer and for which, under the present system,
there will be no credit or compensation from IPCo-including an
explanation of whether this benefit will accrue to other ratepayers
or to Company shareholders, and in what amounts;
g. the revenues that will accrue to the Company from reducing the net
metering credit by some fifty percent, including an explanation of
whether these revenues will accrue to the benefit other ratepayers or
to Company shareholders, and in what amounts;
h. an explication of the reasons for, and implications of, calculating
the net metering credit on an hourly basis rather than a monthly
basis;5
losses to investment-backed expectations accruing to existing DG
owners who currently provide net metered electricity to IPCo
should their net meter credits be reduced to approximately 50oh of
what they now are;
5The Agreement catls for "net hourly billing" as follows: "Al the end ofeach hour, consumption and exports within
the hour will be netted and net hourly exports will be compensated at the Export Credit Rate," which is proposed to
be calculated by a method involving such elements as the avoided energy, capacity and transmission and distribulion
costs; avoided line losses. The Export Credit Rate does not factor in environmental benefits or integration costs. The
Agreement also states that "Schedule 6 and Schedule 8 customers will be compensated for net hourly exponed
energy at the Blended Base Energy Rate for their respective customer classes." The Blended Base Energy Rate is
described as "the total revenue to be collected through the base energy charges for each respective class divided by
the total foreca$ed annual er:ergy for each respective class." These calculations are difficult to parse, and we urge
the Commission to insist that they be made clear with specific examples and formulae. And above all, we need to
know how these rates and the hourly billing schedule will affect tie economics ofrooftop solar. IPCo should be
required to answer this question fully and fairly.
4
j. the economic impact, including the loss of commerce and jobs in
the Company's service area, of a diminished solar equipment sales
and installation industry that will result shouid the Company be
permitted to reduce net metering credits by some fifty percent; and
k. the economic impact on home values if the net-metering credit now
in place, and therefore the current value ofa rooftop solar system,
cannot be passed on to a purchaser of the home.
The public, including IPCo's ratepayers, will benefit from any meaningful
effort to reduce carbon emissions and speed the transition to clean energy. The
effort to make this transition is in the public interest, which is another reason the
Commission should not adopt the Settlement and, before making a decision, insist
on a full display of all costs and all benefits of net metering and DG energy
production (including, without limitation, each of the above items). Uncertainties
should be resolved in favor of encouraging development of solar and other carbon-
free energy sources. The current proposal, particularly the idea that lPCo would
begin the process ofsubstantially devaluing credits, is going in the opposite
direction.
While our home's ful1 system has been functioning for just over a yearo it
appears we will be generating and sending into the grid slightly more electricity
than our arutual consumption. We designed it to produce enough to cover all of our
electrical demand, but recent upgrades to our air conditioning system and other
efficiency rneasures have contributed to this situation. In any event, it stands to
reason that at least some residential solar systems that are designed to meet all of
the home's annual electrical demand in fact will, like ours, produce more than
100% every year, thus generating credits we never actually use.
We are not asking the Commission to compensate rooftop system owners for
this unusable, extra energy credit (even though the Company receives this energy
for free, with little or no transmission cost6 and sells it at retail rates); their decision
to aim for a"100% system" was their choice, taking a chance that they would
overshoot somewhat. But we are asking that you address this situation and devise a
way to calculate the revenue IPCo is eaming from this overage represented by
unusable credits. Such a benefit should be factored into the overall analysis of the
6lt is our understanding that electricify pushed to the grid from a home's photovoltaic system is used at the nearest
location needing supply {hat is, the neighboring homes.
5
impact of rooftop solar on the Company and its customers, and its financial benefit
should accrue to other customers.
The Company's approach dodges other important questions, such as the
actual fixed costs (if any) accruing to the Company or other customers involved in
receiving otherwise free electrical supply from private solar systems, the revenues
the Company receives from selling excess power from these systems, and the role
these systems play in reducing both generating and fixed costs associated with
meeting peak summer demand. Idaho Power's answer to whatever problem it
perceives here is to ask this Commission to impose conditions that appear to be a
windfall to IPCo and its shareholders while delivering a crushing blow to future
development of distributed energy sources. There is no fairness or public interest in
this approach. Before entering any order in this matter, the Commission should
ensure there afe answers to such questions.
lPCo began this proceeding by asking the Commission to establish a
separate rate class for net-metered customers, ostensibly to address the question of
unfair cross-subsidy. The Commission obliged, and now we see what the Company
wants to do with this customer class, which is to reduce its relevance essentially to
extinction-to make the installation of rooftop solar so outlandishly expensive that
few, if any, IPCo customers will opt for it in the future. Such a policy is not in the
public interest or the interests of other Idaho Power customers. Nor, of course, is it
consistent with the Company's stated goal to become a 100%:o "clean energy"
enterprise in the next twenty-five years.
We recognize that the Company likely sees this as a simple rate-making
matter, in which a utility is seeking to protect the rate base on which it earns a
refum; private rooftop solar systems are not in its rate base. However, we ask the
Commission to consider the impact that adopting the Company's position will have
on the continued development of solar energy in our state. Here we have customers
making substantial investments that will carry nowhere near the rate of retum on
investment the Company enjoys as a matter of law and IPUC policy. We believe
most of these consumers made these investments in significant part because they
see them as a small but meaningful step in what should, and we hope will, become
a nationwide effort to transition from carbon emitting energy sources. We ask that
the Commission initiate a process to classi! DG in a way that does not discourage
solar power development. It may be that this will entail a new way of structuring
the relationship between the utility and its customers? or a new way of evaluating a
utility's rate base, or its rate of retum. But surely there is a way to allow the utility
6
to remain viable while still encouraging-or at least not undermining-the
emerging energy sector consisting of voluntary, customer-financed rooftop solar.
We ask the Commission to deny the Settlernent and direct IPCo to complete
a rigorous and transparent analysis, which includes input from all stakeholders, to
address the issue ofwhat the Company should pay for excess power from rooftop
solar, and how independently-financed solar can be encouraged to be a part ofthe
Company's energy production portfolio.
Respectfully submitted,
JeflFereday Kay ummel
cc: Covernor Brad Little
7
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An lo oogP cdtEiv
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farnes L Haddock
1738 W Ptzzle Creek Dr
Meridian, ID 836 16-3631
Subject: Modification to Net Metering Service
Dear lames L Haddock
Idaho Power is pleased to offer options to our customers who wish to install on-site
renewable generation at their home or business. We want to let you larow, on fuly 27,
2017, Idaho Power ffled a request with the Idaho Public Utilities Commission (lpUC or
Commission) to modify its net metering service applicable to new on-site renewable
genemtion installations. Ttrese changes are int€nded to hcilitate the expansion of on-site
Seneration in a way that is both scalable and sustainable into the future. A ruling in the case
is expected from the Commission in spring 201$ likely around April 1,2018.
As a customer with an active net metering application, we want to let you licnow about the
request and what it means for you.
Idaho Power is requesting to:r Close the current net metering schedule (Schedule 84) to new residential and small
general service customers.
r Create two new schedules for residential and small general service customers who
wish to install on-site renewable generation
. update inverter requirements on new systems to meet emerging industry
standar-ds.
r Open a separate IPUC proceeding to determine a compensation structure for
customer- owned generation that reflects both the costs and benefits it brings to the
electric grid.
This proposal may affect ]()ur application for interconnection. As part ofthe application
process, Idaho Power requires a System Verification Form, certifying the system has been
installed and has passed all local, state and federal requirements including a city or sate
eleclrical inspection. Under the proposal, customers who submit this form before the
effective date of the new schedules will take service under the edsting net metcring
schedule (Schedule 84); customers who submit this form on or after the effective date of
the new schedules will take service under the new schedules. If the new schedules are
approved, the effective date will be determined by the Commission as part of its ruling in
the case.
NM 2377
?age2 of2 April 2,2018
The company has prloposed the rates under tle new schedules will mirror those of the
residential and small general service customer classes, as do tlle rates under Schedule 84.
However, as part of a future rate proceeding the new schedules will be reviewed and new
pricing stnrctnres may be adoptEd. At this timg no date has been set for a fuhlre rate
proceeding.
We value your business and want to address any questions you have about the proposed
changes to net metering seryice. For your refercnce, I have enclosed a Frequently Asked
Questions document that provides more details.
I invite you to learn more about the proposal. Copies ofthe application are available at the
Commission offices (47ZW.Washington St, Boise) or the IPUC website,
www.puc.idaho.gov. You can also access the application and view additional, related
materials at www.idahopower.com/rates and click on dre link to Idaho Rate Filings,
Ifyou have additiond questions or would like to discuss further, please contact our
Customer Service Center at [phone].
Thank you for aking the time to read this letter. We share you interest in innovation and
look forryard to continuing to provide service options that meet your needs.
Sincerely,
"ltrrrrr*-Dr#.Thercsa Drake
Customer Relatiors and Enerp Efficiency Manager
A
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Charles R. Gains
Tuesday, December 3, 2019
ldaho Public Utilities Commission
11331 W. Chinden Blvd Ste.201-A,
Boise, lD 837'14
Re: Case Number IPC-E-18-15 ldaho Power's filing to change the compensation
structure for residential and small general service customers with on-site generation.
Dear Commissioners Kjellander, Raper, and Anderson:
I have lived in ldaho for nearly 50 years. I consider myself to be a typical ldahoan. I
moved here after the Army and completing college because I wanted the independence
and environment ldaho life has to offer. I love the ldaho people because we put great
emphasis on our values and our ability to make the right choices. ldahoans have a
strong dedication to trust and fairness. We put great meaning in the phrase, "My word
is my bond."
I am here because I am concerned about everyone's right to capture and use clean
and renewable energy - the energy that belongs to everyone. I am also concerned
about the personal investment that I and others have already made in renewable
energy.
Under the net-metering program, promises and incentives were made to those who
wanted to invest in solar energy. Up to and including the present day, the ldaho Public
Utilities Commission (IPUC), with its nelmetering order, has created win-win rules and
utility rates for both ldaho Power customers and the ldaho Power Company (IDPWR).
Clearly, the purpose of the net-metering order was to promote and incentivize the use of
this important energy resource.
Now, along comes IDPWR with its request to change the net-metering agreement and
rates.
My comments are organized into two parts. One is regarding the settlement
agreement itself. And the second is regarding the treatment of existing customers who
have already signed up for the net-metering program.
Part 1. ls the settlement agreement reasonable, just, and fair?
IPUC staff and IDPWR assert this issue is about IDPWR's right to change the
rates. This issue is so much greater than that. lt is about where IDPWR Company, a
monopoly, is taking us in the future.
Let's look into the future through a telescope. Can we see the goal of getting
back to 100% clean-energy getting closer or further away?
L721 E. Canova Dr.Boise, lD 83706 (208) 344-s689
S/"tt
=->
Page 2.
When the IPUC net-metering order was issued, IDPWR customers didn't see this
as a windfall. Rather, it opened the door to energy possibilities. What the IPUC had
created was a clean-energy incubator. The order became popular not because it made
customers rich, but because it allowed customers options and opportunities. Solar
could be installed without having to buy expensive batteries. The order motivated
manufacturers to design and upgrade equipment such that it would meet the IDPWR
standards. The order allowed return enough that the customer could see an eventual
payback. Most important of all, it created opportunity for innovation with clean energy.
Today, IDPWR claims its clean energy generation stands at about 60% - well
below its goal. A goal that is hard to keep when the electricity market demand is
growing. IDPWR complains it is concerned about competition and the rate threat by
clean-energy generators under the nelmetering order. Yet, IDPWR doesn't have to
invest one dime to add this clean-renewable energy generation to its base.
Commissioners, IDPWR is not only turning the telescope around, but in addition
the telescope is now out of focus. The request by IDPWR doesn't appear to be moving
us any closer to the vision of more clean enerqv qeneration. at a time when IDPWR is
experiencing high demand growth. lt does not make any sense at all that IDPWR should
be concerned about such a tiny sector of the total generating market in its service area.
It should welcome the new generation and incorporate this innovation into its own
generating management plan.
It is simply a fool's errand to be wasting all this time and money worrying about
minor generating rates when there is such great demand for clean, reliable energy.
Commissioners, throw out the settlement agreement and move on to more important
matters. Let's grow the total clean energy availability in the IDPWR area.
Part 2. ls it fair or just to change the deal with existing customers?
Commissioners, how would you like it if some power authority suddenly
announced that you would now have to perform youriob, but for half the pay? lsn't that
what IDPWR is asking of those who have already committed to the net-metering
agreement?
We had a deal.
Every Business 101 Law class teaches that a contract must contain the following
"elements:" The parties agree to the deal (IDPWR and I agreed to net-metering.). An
offer and acceptance must be made (The whole net-metering program was presented at
the full electrical rate and we, in good faith, accepted the rate.). An element of
consideration must exist (We pay IDPWR for power and they credit power to us at the
same rate.). The parties have to be capable to enter into agreement (lndeed we were
1721 E. Canova Dr Boise, lD 83706 (208) 344-s689
Charles R. Gains
Charles R. Gains
capable and able to qualify for a loan based on the deal.). And, the agreement has to be
legal (lots of evidence here). ln the words of James Whitcomb Riley:
"When I see a bird that walks like a duck and swims like a duck and quacks like a
duck, I call that bird a duck."
Commissioners, let people call the net-metering deal what they want, but this bird sure
looks like a contract to me! The problem with IDPWR's request is clear. We had a deal
and IDPWR doesn't want to honor it!
When IDPWR informed me about the details and specifications of the net-
metering deal, it was all about the win-win for both parties. First, I could generate and
use my own power. Second, it let IDPWR avoid using its generating capacity and store
the potential energy for later use. Third, if I generated extra power, IDPWR could take it
and provide it to my neighbors at the full retail price and credit my account for
repakiation sometime in the future.
I relied in good faith on the IDPWR assurances. IDPWR did not notify me or
make an obvious statement that it was able to change the rates. Simply by this fact
alone, IDPWR should not be allowed now, after we have inked the deal, to change the
rates I relied on. Note too that DL Evans Bank relied on the dependability of my net-
metering contract to process my loan. Following that, the ldaho Office of Energy relied
on these same assurances in order to accept my application and give me the loan. I
already have much more than $18,000 invested in my PV solar system. From the
beginning, the net-metering deal I signed with IDPWR is how lwould pay off this loan
and ultimately realize a return on my investment in my retirement. lt is not fair, or just,
to let IDPWR back out of the existing deal by citing some hidden excuse that this is
allowed because it is a "rate change." lndeed, my mother would say:
"Lies of omission are often lies of deception. "
IDPWR never made their intention to change the rate a visible condition to me,
the potential solar customer. I never would have accepted the financial decision and
obligation to make the deal had I known what IDPWR was planning. All netmetering
customers should have their deals protected and grandfathered in perpetuity. But
IDPWR seems to hold all the cards. Senator John McCain once said:
''The more powerful you are, the more likely you are to get what you want."
Don't allow this to happen.
There is a great disparity in bargaining power between the small net-metering
customers and ldaho Power Company. The Commission, I think, was formed to provide
some counter-balance to ldaho Power given its obligations, size, and its limited
competition. I am asking the Commission not to allow IDPWR to change the deal.
However, if the Commission does side with IDPWR's request, at least keep those
1721 E. Canova Dr Boise, lD 83706 (208) 344-s689
Page 3.
Charles R. Gains
Page 4
already invested grandfathered in perpetuity. This will give customers like me the dollar
return to maintain, update, and keep their systems operating in compliance.
Conclusion
The IPUC nelmetering order is an infinite-sum (an open) solution. The proposed
IDPWR settlement agreement is a zero-sum solution. The underlying message here is
that small, innovative renewable generators have no freedom to create, control, and
enjoy the benefits of developing and using renewable energy resources.
ln other words, the little guy doesn't have a chance. lf IDPWR's request goes
forward, from now on all IDPWR has to do is identify someone else's new generation
technology, innovation, and/or development idea as a "threat to its rates" and the small
generator business idea is D.O.A!
With the net-metering order as it presently stands, IDPWR is incentivized to
research better, bigger and cheaper clean-energy ideas. Keep the order and it opens
the door to healthy competition. lf the IPUC sends this message to IDPWR, future
projects and innovation will be created on the basis of science, technology and
economy - not on a basis that leads to hearings, rule-making and regulatory
manipulation.
As for those who were motivated to sign up under nelmetering, by what sense of
fairness or ethical thinking is there justification to pull the deal apart? By what
reasoning does it make it okay to allow IDPWR to violate that basic ldahoan tenant -
''My word is my bond."
Sincerely,
lsl
Charles Gains
December 3,2019
Thank you for your attention. Are there any questions?
1721 E. Canova Dr 8oise, lD 83706 (208) 344-s689
12/L/2OLe Boise, ldaho
Honorable PUC Commissioners,
My name is Lisa Hecht. I am an ldaho Power customer who resides at
4920 E. Sagewood Drive, Boise,t0.83716.
Thank you for your service to the ldaho public, for being the body that
ensures ldaho citizens are provided with just and fair treatment by
utilities granted monopolies and regulated under the PUC.
I bring multiple viewpoints to this hearing as:
o an electrical engineer,
r an ldaho Power customer,
r an ldaho Power shareholder,
r an attendee of ldaho Power's IRP sessions since 2015,
. as a net-metering customer, and the first person to install a solar
PV system on my roof through Snake River Alliance's "Solarize the
Valley" program in 20t6,
o as the mother of two young adults, and,
. as someone who has read the IPCC reports, the Fourth National
Climate Assessment, halved her personal carbon footprint, and
who holds great concern for our children, and all of us.
First, the positive. To the signers of the proposed settlement: thank
you for keeping demand charges the same, since that will continue to
align cost with usage, incenting efficiency, benefiting all customers.
I also support a non-export option with reduced connecti on costs.
,tct siib ec*-1c e*r,o
-l€ r t,r S e+h er I,l
Cr.wp r.s&[C}\
My testimony regards the proposed settlement for case IPC-E-18-15,
whose title is, "\tudy of Costs, Benefits, ond Compensotion of Net
Excess Energy Supplied by Customer On-Site Generotion". The very
title implies that the value of that customer generation was the
purpose in opening this case. So, what was the conclusion of the costs
and especially, the benefits of that net excess energy supplied by us
net-metering customers? Some of the values of those benefits have
been assigned values of zero. How then, can the compensation values
possibly be calculated?
My first ask, therefore, is that the PUC direct the signing parties to
complete the settlement by assigning mutually agreed-to values on
three missing benefits of solar net-metering. Those values may be
to
tv ue, stnce
ldaho Pow sses T&D co 2/3'd of i f providing
, txne{ik
electricity.
er +ise
ffiis
ts -atW
.)hese missing values of net-metering could concurrent ly
with the next IRP cycle, and those Updates to Export Credit Rate in
with a
o
Given that the foundation for identi n8 va lu of solar exists; it should
be possible to include all values.
ldaho Power has been party to an Oregon PUC Resource Value
of Solar (RVOS) study for years. On January 22,2019,Lhe
Commission issued orders completing Phase ll of the resource
value of solar (RVOS) proceeding and adopting final
methodologies that utilities will use to produce their initial sets of
Section C should be determined
i ntervenors.,, Si-,r,tr:4_ 5{&Ll@
jointly
Ptr.uv
t the current
d-b*LvJPPpnuw
a
ICLoa
significant and include Avoided and
.L
-+o ftrtAvoided T&D
a
RVOS values.
OPUC staff will provide a
presentation at the December 3, 2019 public meeting
summarizing the compliance filings, addressing the status of the
compliance filings, and outlining next steps.
ln 2OL7,28 valuation studies were proposed, pending or decided
an 21 states and DC, according to the
(NCCETC) 20L7 solar policy review.
Secondly, the issue of grandfathering was not addressed in the
settlement. My guess is that, considering what happened in Nevada
with net-metering, that was what you'd call an ldaho "hot potato!".
As a net-metering customer since 2Ot6,l urge you in the strongest
terms to grandfather existing net-meterinB customers under the
program which drove the designs and installations of their systems.
Around the U.S., in other states, 20 years from installation has been a
typical grandfathering period, which coincides with the expected
lifetime of solar PV panel generation. That grandfathering should
follow our accounts, if not our addresses.
Existing customers MUST be grandfathered, and it is all about fairness:
o We who installed solar on our homes don't praeticallv have the
option of a contract with ldaho Power, because a PPA would be
far too expensive for homeowners and small business owners.
Therefore, only the ldaho PUC can protect the value of our
investment, to ensure that it is "fair, just, and reasonable" to
families and small businesses who invested their hard-earned
dollars in cleaner energy, for themselves, their neighborhood,
a
and ultimately, all ldaho Power customers. I wanted to do my
part for my daughters, community, and the world, since we have
under 10 years to massively reduce our carbon output, and
electric generation is America's #2 source of carbon emissions at
about 28%.
Our investment will continue to benefit other customers for the
lifetime of the panels, estimated generally at 20-25 years. Those
benefits include avoided generation, significant avoided T&D
losses (since generation and load are co-located), and lower
demand for much of peak, since peak demand largely coincides
with peak solar generation, and since peak load drives ldaho
Power generation investments.
The Break-Even Time (BET) of the solar investment depends in
part on ; what happens to resale,val.y."jh*"
can't grandfather? On average, across the country,ft-raisei'value
bV 4.1%, but if net-metering compensation rules change
frequently, uncertainty destroys that value.
Re. precedents, a determined in 2015 that
fairness meant respecting the rights of those who invested their
personal money in solar PV energy systems that benefitted the
entire system.
after the
PUC's decision to lower net-metering rates and not grandfather
existing customers, and was replaced by Gov. Sandoval, because
Nevadans expressed their feeling that it was profoundly unjust.
Net-metering is a program, and our solar PV designs are built on
the premise and rules, especially the economics, of monthly net-
metering.
I support the motion to grandfather new customers until or after
January of 2020.
a
a
a
a
a
. I have accrued nearly 2200 kWh in accumulated credits under the
existing rules, worth S176 at S.o8/kwh, to ldaho Power. This is
another value l'd like to have the possibility of recouping through
grandfathering.
Finally, I invite you to join me in my perspective as a mother of two,
and concerned citizen who has read the IPCC and NCA reports with
great concern and determination to get us all to safe harbor by cleaning
upourerectricenersyA;;. Lr1 IpUr**- (r.-', ;ti;fi )60'1"
r Per IPCC models to achieve carbon neutrality, by 2050 we must
eliminate coal-burning, and reduce natural gas by 80%. Solar must
grow significantly to replace them (along with wind, battery and
other storage). Do we want that solar on existing rooftops and
built space, or covering ldaho's precious farmland or wild places?
How will ldaho Power achieve its goal of 100% clean electricity by
2045, without the help of rooftop generation?
o Vermont's Green Mountain Power, a B-corporation, entered into
a cooperative agreement with customers to use batteries to shave
peak load. What value might such a program hold for ldahoans?
ldaho Power wants to see electric vehicle adoption grow; EVs also
have batteries which could be used cooperatively to meet load.
r When we don't put a financial value on all the benefits of solar
and other forms of customer net-metering, this discourages its
use at a time when we must ramp it up. We can only determine
what is fair to all customers by establishing a full and fair, agreed-
upon valuation among all parties to the case.
o lf we thereby discourage solar now, by punishing those who tried
to do right, many according to their highest values, what recourse
will we have to achieve the required clean energy balance
mandated by physics as laid out by the IPCC and NCA scientists?
With gratitude for the opportunity to provide testimony on this case,
Lisa Hecht
Sources:
Oregon PUC RVOS Order UML91L re. ldoho Power ond RVOS
a
a
a
a
ln summary, we all have the most to gain through a cooperative
relationship between ldaho Power and net-generation customers
in accelerating a clean-energy future, by fully valuing not only
what ldaho Power provides, but also what net-generation
customers provide, now and in the future, and incentivizing that.
Nevodo Regulotors Restore Net Metering for Existing Solor
Customers, GTM, September 16, 2016
t Nevodo utility regulotor Poul Thomsen resigns
o 50 Stotes of Solor: Q4 2077 Annuol Report ond 2077 Quarterly
Report Executive Summary, NC Clean Energy Technology Center
Here's how much odding solor ponels will boost your home's
value, Money Magozine
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Idaho Public Utilities Commission previous Order regarding Accumulated Net Excess Energy
Credit Balances and potentially grandfathering:
ln Order No. 32846, the Commission stated, "we find it fair, just, and reasonable for the kWh
credit to indefinitely carry for*ard to offset l'uture bills for so long as the customer remains on
the net metering service at the same generation site. Allowing the credits to carry forward
indefinitely ensures that customers will be able to use their credits when they need them and thus
receive the benefits oftheir systems."
IPC-E- l7-13 - IDP - New schedules for customers with on-site generation
IT IS HEREBY ORDERED that Idaho Power shall close Schedule 84 and create new Schedule
6: Residential Service On-Site Generation and new Schedule 8: Small General Service On-Site
Generation.
IT IS FURTHER ORDERED that Idaho Power shall initiate a docket to comprehensively study
the costs and benefits ofon-site generation on ldaho Power's system, as well as proper rates and
rate design, transitional rates, and related issues ofcompensation for net excess energy provided
as a resource to the Company.
IT IS FURTHER ORDERED that Idaho Power shall file a study with the Commission exploring
fixed-cost recovery in basic charges and other rate design options prior to its next general rate
case.
When Customers go solar, they are paying for the generation, not Idaho Pow'er. Savings and
cost-shift from solar when compared to energy efficiency is very similar to the grid. In many
ways solar is more beneficial.
From Idaho Power's 2018 Annual report:
"ln 2018, 2017, and 2016, Idaho Power expended approximately $44 million, $48 million, and
$43 million, respectively, on both energy elficiency and demand response programs."
IDP STAF F-: "Demand-Side Nlanagement Marketing ExDenses versus Tolal Program Expcnses
Pages l9-20 olthe Demand-Side [Vlanaqemcnt 2018 Annual Report breaks out the markeling
expenses ol$1,270,112 fiom the portfolio total spend of $44,262,080."
That means the Company spends around 2.870lo on marketing to customers encouraging energy
etliciency.
"ln 2018, Idaho Power's energy efficiency programs reduced energy usage by approximately
173,000 MWh."
IMAGINE 2 IDENTICAL RESIDENTIAL CIRCUITS
Circuit 2-SavedtO%
KWH/Month by
changing nothing in
the way they used
energy, but by 10%
of the homes going
SOLAR
Circuit 1 - Saved
10% KWH/Month
by being more
energy efficient
like smart thermostats
and space heaters
BOTTOM LINE - SAME NET
EFFECT ON BOTH SIDES
173,000 MW or $14,878,000 (at $0.086 per kWh, which is less than the actual retail value) of
revenue was lost in 2018 due to customers becoming more efficient.
On-site generation customers can function exactly the same as energy efficient customers. Solar
is simply one way to be energy efficient AND provide the benefits ofdistributed energy to the
grid.
$14,878,000 + $1,270,112 = $16,148,112 in total cost ofenergy efficiency.
Quote from Idaho Power's 2018 Annual Net metering report:
"There are roughly 650 electrical distribution circuits in the Company's service area.
As of March 31, 2018, there werc 2,068 active net metering systems totaling
approximately 16 MW on 377 distribution circuits."
16r MW of generation which costs ldaho Power $0 to irstall and maintain. The value of
distributed generation is VERY SIGNIFICANT.
"The Company had accumulated approximately 0.5 million, 1.3 million, 2.3 million, and 2.6
million unused excess net energy credits by the end of years 2014, 2015,2016, and2017,
respectively."
2,600,000 * $0.086 : $223,600.00+ in FREE ELECTRICITY in20l7.
PUC STAFF: "Distributed energy is every bit as valuable as energy efficiency."
The Energy Information Administration estimates that national electricity transmission and
distribution losses average about 6% of the total electricity generated in the United States each
year. (40- Independent Statistic & Analysis-U.S. Energy Information Administration.
Accessed April 2,2015: http:/i rvw iv.eia.sovi toolsi lirqsi laq.ctln'li,.i- 10.5&t l.)
COMPANY STAFF: "Regarding the 70Vo fixed cost claim - the Company filed a cost of service
study. looking at overall costs. A "class cost ofservice study" was uploaded as work papers in
IPC-E-18-16 docket." (This study looks at Idaho Power's Overall cost ofoperating).
JSH: "When is our peak pricing?"
COMPANY STAFF: "lt depends, but power system peaks in late afternoor/evening in
summertime."
JSH: "What solar benefits were set aside?"
COMPANY STAFF: "Th,ree components - avoided transmission and distribution capacity,
integration costs, environmental benefits."
Distributed Generation lowers the transmission cost to the erid.
Provides an overview and explains how came to numbers.
(15:45) open case filed "fixed cost report" - case 18-16
lhe circuits that conlain the greatest number ofnet metcring systems are largely located in
northeast Boise and in theWood River Valley area, while the circuits that contain thc greatest
amount ofconnected net metering capacity tend to be located in mostly agricultural and rural
areas. The greatest number ofactive net metering systcms that cunently exist on a single
distribution circuit is 30 totaling approximately 139 kW. On another distribution circuit, from a
capacity' perspectivc, seven generators (all solar) rated at approximately 606 kW arc located on
that single distribution circuit. That circuit serves mostly rural customers with a calculated
summer peak load olapproximately 1,900 kW. The net metering penetration on the circuit is
approximately 32 percent. The net metered connected kW capacity on the Company's
distribution system continues to remain small and the Company has not yet experienced
significant operational impacts on these circuits.
...This revie*'may include determining if there is adequate translbrmation and conductor
capacity, as well as a phasing (single- versus three-phase) match. The Company has not denied
any net metcring applications due to systcm limitations, but continues to carefully monitor
requests for connection to ensure ongoing sal'e and reliable sen'ice is availablc to both existing
and new customers.
...As net metering s-vstem penetration increases. the Companl u'ill keep the Commission
apprised ofexperienced or anticipated system reliability impacts and will propose mitigation as
needed. This may include additional invcrter requirements such as smart inverter tcchnology.
which can mitigate many high penetratitrn issues.
20180423 ANNUAL NET METERING REPORT
II. SYSTEM RELIABILITY CONSIDERATIONS
The circuits that contain the greatest number ol'net metering systems continue to bc located
primarily in northeast and east Boise and in the Wood River Vallcy. Horvever, greatest net
metering connection capacity tends tti be on mostly agricultural and rural serving circuits. For
example, the largest number ofnet metering systems connected on a single distribution circuit
are 47 which total approximately 244 kilowatts ('kW). The distribution circuit that leads in
connected capacity has only eight solar PV system that are rated at approximately 667 kW. This
circuit serves mostly rural customers with a calculated summer peak load of approximately 2,100
kW. During minimum load conditions, lhe 550 kW of power flows from the circuit into the
substation and on to other circuits. Although growing quickly, the net metered connected kW
capacity on the Company's distribution system continues to remain small relative to the total load
and the Company has been able to manage the minimal operational impacts on these circuits.
...Although some service transformer upgrades have been required, and further study has been
necessary, the Company has not denied any net metering applications due to system limitations
...The use of smart inverter technology, with reactive support capability enabled, may mitigate
many high penetration issues and provide additional distributed generation hosting capacity.
Idaho Power's Annual Net metering report quotes:
201 7O428ANNUAI, NET METERING REPORT
VII. SYSTEM RELIABILITY CONSIDERATIONS
RE:FW ANY SOLAR DICISIONSI
.@- -
,Gf own| rh. D'or.d .arr F1r5rt6 T.yLr), ,.ffiM })tw x 53 3 rartrr-. l.rar tr6 dr6 ur$r.d p.i.lt dl n a .. mnd.ffr a *fu. trh ufdr..rd per.ndm1(tud.d'j1t0olrdbr !flrrd.l w.i thF.r?rdd by thl
Above graphic shows one ofmany projects where a customer and/or the solar provider fully
funded a $2,000 - $3,000 transformer upgrade. Upgraded transtbrmers allow the utility
company's system to be more efficient as well as recover more revenue due to added capacity on
the upgraded circuit (more potential customers).
Idaho power company's comments in support of settlement -
pc-7
"The Signing Parties agreed that other costs and benefits (avoided T&D [Transmission &
Distribution] capacity, integration costs, and environmental benefits) may be measurable, but
agreed not to include those costs or benefits as part of the Settlement Agreement."
COMPANY STAFF: "What are we trying to solve?...n'hats the problem? Well the problem is,
while the majority ofour underlying cost structure is fixed, the way that we collect those costs is
tluough volumetric rates. And when customers reduce their usage for any reason, that creates
under-recovery for the utility and what we're left to do is collect that from other customers, and
fbr the residential class that happens through the FCA (Fixed Cosl Adjustment).
I $'ould lell you that... the company's position is that isn't a solar problem, that's a rate design
problem. And rve have repeatedly stated that in these cases, and what w'e've tried to do in the 18-
16 report is lay that out, that this needs to be addressed for all ofour customers. We are not
trying to single out solar."
"When customers reduce their usage for any reason, that creates under-recovery for the
utility and what we're left to do is collect that from other customers. The company's
position is that isnt a solar problem, that's a rate design problem. And we have repeatedly
stated that in these cases,"
"and what we've tried to do in the I 8- 16 report, is lay that out. That this needs to be addressed
for ALL of our customers, we're not trying to single out solar."
ln Order No. 34046, the Commission closed Schedule 84 to R&SGS customers with on-site
generation and created new tariff Schedule 6, Residential Service On-Site Generation, and new
tariff Schedule 8, Small General Service On-Site Generation. The Commission also ordered
ldaho Power to initiate a docket to comprehensively shrdy the costs and benefits of on-site
generation on ldaho Power's system, as well as proper rates and rate design, transitional rates,
e-:-
and related issues of compensation for net excess energy provided as a resource to the Company.
OrderNo.34046at3l.
So I ask you, as a solar professional, a local business owner, and a concemed citizen: how can
the PUC pass any settlement without inclusion ofall the benefits ofsolar, when they ordered a
comprehensive study of costs and benefits of on-site generation customers?
Environmental benefit ofland use, grandpa hill used to say, they aren't making any more of
it...use our rooftops!
Time ofuse across all rate schedules is a fair,just and reasonable solution.
Incentivizing West facing solar is a fair, just and reasonable solution.
Incentivizing battery storage with solar, allowing Idaho power access to a percentage of stored
kWh's during peak loads is a fair, just and reasonable solution.
Please find below two programs implemented by Utah and Nevada power companies:
6 a.m.iprn. O 8pln (5 a.m.All Day
Utah:
Pricing
With Time of Day. your basic service rates still apply. You also pa1
1.6334 cents less than your basic setvice rate (Schedule I or Schedule 3) tbr each
kilowatt-hour (kwh) of electricity used during oft'-peak hours
,1.3560 cents more than thc basic service rate for each kwh ol electricity used
during on-peak hours
'Weekends and
Holldays
a
May - September
Weekdays
.a I
I t
$
Ofr-PeakOff-Peak Ofr-Peak
Nevada:
Nct i\lctering
Net metering (NEM) allows you to receive a credit for the energy generated by your renewable
energy system, which you can use to offset your monthly energy bill. All customers with
renewable energy systems may be eligible for NEM.
See below for more information if you are intetested in applying for net metering.
Ratc Tr pcs
Net Metering Rider-405 (NMR405)
Customers who installed or had an active application for a rooftop solar system of25 KW or less
on or after June 15,2017 are automatically placed on this rate and in the applicable tier.
iltEllflrrallTt
Net Metering Rider-G (NMR-G)
Customers who installed or had an active application for a rooftop solar system of 1,000 KW or
less as ofDecember 31, 2015 are grandfathered into original NEM rules and rates.
ililTttl[ltrllt
Net Metering Rider-A (NMR-A)
Southern Nevada customers who installed or had an active application for a rooftop solar system
of 1,000 KW or less between January l, 2016 and June 14,2017. This rate is not available in
northem Nevada.
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