20191203Comments_(54).pdf

IDAHO PUBTIC
UTILITIES COMMISSION
rPc-E-18-15
Boise, ldaho
Lzlo3lL9
COMMENT FORM
Please use the space below to file a comment in this case. Add extra sheets as needed.
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
htt p s://www. p uc. id a ho.gov/
Click on the "Case Comment Form" link
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Print Name Sign Name
Address zS z.tt yrlrdc/,h (L^) phoneNumber'7o3- 9qS-S/8L
City and State
12/3/19
Uidut ID 8 Zip Code I E*4
ldalro Public Utilities Commission
Offics ol the SocretaryRECEIVED
DEC 0 3 20t9
Boise, ldaho
Good Evening Commissioners,
l'm here to Spgak for putting solar on my home in the next year
and for.y{h'fia..n, when they have homes and wish to add a
solar system.
Renewable energy is our future, and I don't have the crystal ball
to know all the vast changes and improvements we will see in a
very short amount of time.
It is however, reasonable for all of us to want an affordable way
to add a solar system to replaceS electricity bilfi forever.
It also isn't fair to have a utility company or commission
Iimiting solar production credits by the hour or a decreased KW
value or future access fee's to be passed on to me, just because I
have solar.
More specifically, it is not justified to have a completely
different rate structure because I use less power or very little
power compared to the average household due to installing a
solar system.
So changing the net metering system from monthly to hourly is
not the step towards making our utility system better. If all our
meters can instantly track positive and negative electricity usage
The State of Idaho's growth and impact studies may be slightly
close to what actually happens.
But if wisdom prevails to know that just watching what other
states around us have done or not done as effectively, we can all
agree let's not follow their model. Let's be different, let's be
bitter and you can decide to help make us a flation leading State.
there is a complete history generated to know how much energy
is put into the power grid. Solar is not hurting any customer or
the infrastructure down line. Let me repeat...
I believe waiting to see the outcome effect of California's law
for all new construction to have solar and ifother states like
Utah follows suit. It will be important for all of us to understand
how to prevent the Affordable Solar Plan to be passed into law
requiring every meter to have renewable energy installed on its
system.
Can you imagine adding that responsibility to your job duties as
Commissioners, overseeing not just new construction, but all
residential and commercial properties. Ensuring all solar
companies install it correctly, the permit process is followed and
the systems pass inspection. And yes, you are responsible for the
trickle down efflect. Plus preventing a monopoly from taking this
business away from the private solar companies to overcharge
everyone 2 or 3 the current cost, worse yet leasing systems that
you would pay a monthly payment for life.
The wise decision to consider for Net Metering is and knowing
what the next step is after this and how high the rate structure
willjump in 5 or l0 years. But, when Idaho Power wants to be
entirely renewable energy by 2045 and the Cities want that too.
Solar will be added across our state and paid for by you, me and
my children. A wise solution is to have small incentives and
definitely not restrictions to consider adding solar to your home
or business. I will be paying for the cost of my system, not a
utility company, not the State or other home owners. So
covering my return on investment is critical.
Finally, remember if a decision is made, to change net metering
billing to hourly or the KW exchange rate decreases, be wary of
the next move and the impact it has, especially if you can not
unring this bell.
Legally, I see this decision to not be fair, just or reasonable to
single out specific customers based on a specific meter type or
changing a rate structure. Who's next? Commercial businesses,
Cattle and Agriculture, State and Government Municipalities
Thank you.
Sr4r" k*t
Lg"-B -f t2,2d)'' Po-J
wil/e,,/ ZD &EezA
Charles R. Gains
Tuesday, December 3, 2019
ldaho Public Utilities Commission
'1 1331 W. Chinden Blvd Ste. 201-A,
Boise, lD 83714
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 nelmetering 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?
1721 E. Canova Dr Boise, lD 83706 [phone]
Gharles R. Gains
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 net-metering 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 enerqy 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 yourjob, 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 83705 {208) 344-5689
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 contractlo 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
repatriation 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 I would 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 net-metering
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
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 nelmetering 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 net-metering, 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
December3,2019
Thank you for your attention. Are there any questions?
1721 E. Canova Dr Boise, lD 83706 (208) 344-s689
Page 4.
12l3lte
Ref case#: IPC-E-18-15
Comments
My name is Jerry Frederick, 89687 S. Black Cat Rd, Nampa, lD 83687.
This case is about how can ldaho Power make more money similar to how the Government runs the
country always wanting more. I know I am but a small spec on IDP radar but it affects my life now and
into the future.
I invested thousands of dollars for several reasons.
1. ldaho power has for years requested and promoted everyone using electricity to conserve and
make their homes more efficient. Now that many have tried to accomplish just what they asked
for, they are now asking us to pay them for doing just that.
2. lt was my intent to make my home more ecofriendly and that meant adding solar power to
benefit both my family and to benefit ldaho Power. Their intent is to make me pay more for
improving my life.
3. lf I generate power for my use and allow ldaho power to sell to someone else, the power I do
not use, they have to be benefiting at my investment expense. I am sure they are making
money on that power they are selling and investing that money. ln effect I am loaning them my
power generated, and they can sell it at a profit. All I am asking for is my money back (credits at
regular Schedule 6 of 8.7cents) without interest. I know IDP will be raising prices as there
standard practice.
4. When I signed up for the solar it was going to take a minimum of 10 years to recover my
investment dollars. ldaho Power is now trying to screw the people that were trying to help IDP
deal with climate change and their need for clean power. lf they win all what they are asking for
then I as a very small customer will have to suffer the consequences of the PUC decision.
5. Since I am well into my retirement age before I decided to go solar, I needed to think about
those people not being able to pay their electric bills. I did not want to be one of them. IDP only
cares about how to Bet more money from those people that did the right thing.
6. lt is not right to change someone's life planning in the middle of the stream. They need to allow
at least a 10 years of no change grandfather option for those who already Invested a larBe part
of their life savings in solar power. ln my case with 100% solar ability per year using credits and
only allowing 4.4 cents credit after 8 years is the same thing as increasing my power bill by 50%
from what it used to be with solar now. This idea of IDP changing to 4.4 cents the rate credit is a
real shaft job to their solar customers. lt will make a maior decrease in the solar business
people. ldaho Power cannot justify that much of increase. lf they want to lower my cost on the
power I use to 4.4 cents from the grid to match my credit sounds good to me.
7. As for their idea of it costing IDP more to deliver power to solar customers, because of
equipment etc., they benefit as well to receive my solar power back to them. lf there is more
cost to them it should only be because of the service they provide. That being the case I would
be willing to increase my current service charge they are now billing me by maybe 10 to 20%.
8. I DO NOT want nor do I think it is right or fair to add this cost increase to my KW usage credits.
I know they are the big Goliath and I am only little David but the PUC needs to support us small
people.
9. I am not sure what their game is regarding the changes for solar people and measuring it on a
hourly bases rather than monthly. I am sure they are thinking of a way to penalize solar
customers for generating power at a time they may not have use for it. lt will be just one more
reason Solar power may get hammered.
The main thinB I am trying to get to is the PUC should recommend and approve IDP to maintain the
current system on credits for KW and allow a 10 year time frame to recoup the cost of installing
solar. This time frame would apply to customers who installed solar systems wior to llt/27.
Maybe allow some change for any new solar investors.
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;daho Public Utilities Commission
'oHg"oL",t?E
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O:C 0 I 2019
Bdse, ldaho
Thank you. ,rL 46
?q;lt'My name is Mark Ottens and I live at TTglgGoodson Rd, Caldwell. *\) ,'
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rate to ldaho Power for approximately 47 years. ldaho X nd- . fo' ,rAl
Power, for longer than that, has established a budget for y
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grid upkeep and charged all residential customers that ? " 4ut pl
rate to fund their grid maintenance budget.
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When a subdivision goes in the developer pays to install / 4P' ,( o
a power grid for that development. lf they have to '/ . t{' \
upsize or expand the system into that development ,then l.gV -.t (
the developer pays to upgrade the system. ldaho Power f *jl
pays nothing.
ldaho Power has established a rate for gird maintenance
for each residential customer to fund this budget. Today
their budget is set at 55.14 per month for all residential
customers but because the local solar generator
I
customer does not write a larger check for power to
ldaho Power they state that we have to pay more for
maintenance upkeep to fund this budget. That is
discrimination.
They get our energy credits.
They do not have to increase generating power for the
3.5% that solar power customers add to their grid. Nor
do they have to pay for the maintenance and upkeep of
that generating plant, which happens to be my solar
panels, which I pay to maintain. Nor do they have to find
excess power outside the grid for that that extra needed
energy, extra personnel costs.
ldaho has been recognized as one of the greatest areas in
the world for solar energy generation. Our energy
production days are some of the highest in the world.
Why not build on that --- and not make it cost
prohibitive?
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I made a business decision based on data provided to me
by ldaho Power and the PUC on the established buy-back
rate versus my generation costs. Now ldaho Power
wants to change the contract to their benefit and to my
loss after the fact.
They established a policy to use my excess power, saving
them from having to build new power generators. ldaho
Power has some of the best statisticians in ldaho. They
are saying they figured it wrong and want to change the
rules. I sure would like an opportunity to have a "do-
over" on some things I may have figured wrong in my
life. I am a small customer who invested a lot in this
system, and these proposed changes will affect my
budget significantly into the red, for-ev-er.
I urge you to deny this request. Thank you
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commcnted [TOzli
Testimony of James and Susan Caswell
Before
ldaho Public Utilities Commission
Net Metering Case Number IPC-E-18-15
7 pm, Tuesday December 3,20L9
IPUC Office
11331W. Chinden Blvd.
Building 8, Suite 201-A
Boise, ldaho 837L4
Mr. Chairman, we want to thank the Commission for holding this hearing, and the
opportunity to present our views regarding the recent ldaho Power Settlement
Agreement requesting changes to the "net-metering" program for customers with
on-site generation.
We have been solar users for a little over a year and did not come to the decision
lightly to invest in rooftop solar. We did our research, evaluated the risks and
benefits both short and long term. We did not make the decision with the
expectation of zeroing out our monthly power bill ($5.00 Service Charge
accepted) nor with the idea of recovering our investment in a specific period of
time.
We came to this decision for three primary reasons (in priority order). Because:
L) We strongly believe that Roof Top Solar is just the "Right Thing to Do." 2) The
availability of IPC current net-metering program, and 3) The availability of the
"Federal lnvestment Tax Credit".
Regarding our number 2 priority, we did research the cases pending before the
Commission and while possible changes did give us pause, the Commission was
clear that a comprehensive study of the costs and benefits of rooftop solar on
IPC's system would be completed before deciding changes. Mr. Chairman, that
promise of a full and comprehensive study was not realized. The proposed
Settlement is in fact a negotiated agreement with many missing important
components. One has to only review the table in Section Vll, Titled, lnitial export
Credit Rates, page 6 of the Settlement to see which components: (Avoided T&D
Capacity, lntegration Cost, Environmental Benefits) are place holders in the
document. lf these components are important enough to be placeholders why
were they not fully developed and included in the export rate? This causes us to
question the changes proposed and raises doubt as to the fairness ofthis new
program for existing solar customers. Solar customers like us satisfied all
requirements imposed by ldaho Power to be accepted into its net-metering
program. We relied on lPCs promise of fair compensation for the production of
our excess energy. lf this settlement agreement is approved as proposed several
thousands of residential solar producers will lose their investments, the growth of
residential solar in ldaho will be negatively impacted, and many hundreds of good
paying jobs will be lost right here in ldaho.
Another significant change is moving from monthly net-metering to hourly net
billing. This is a different program that as I understand it encourages or even
demands a different design of solar systems. Our existing system was designed to
meet the rules of the current net-metering program. lt is not fair for ldaho Power
to propose and the Commission to approve a new program that forces existing
rooftop solar customers onto a new program when our systems were designed
and we invested thousands of dollars based on a monthly netting of consumption
and production.
Mr. Chairman, we respectfully request the Commission direct IPC to hold true to
their word and complete an unbiased study of the costs and benefits of rooftop
solar before making any changes to the net-metering program. In addition, direct
IPC to grandfather-in existing rooftop solar customers to the current net-metering
program. This is a common- sense compromise that allows all parties to keep
prior agreements made in good faith.
An ldaho Power Communications Specialists was recently quoted as saying, "that
the changes will make customer generation more fair. Customers without panels
are effectively subsidizing those with panels." This is sometimes called "cost
shifting" and solar is unfairly being identified as the cause, which is why the
Settlement Agreement is before the Commission. We take exception to Solar
being singled out as it is not necessarily the cause of "cost shifting." Customers
who are frugal and do not use a lot of energy, or households who are
conservation minded also shift costs to other customers.
We find it ironic that ldaho Power aggressively advertises an incentive-based
Energy-Saving Program that also shift costs to other customers. Their incentive
program has ten components and once the improvements are approved they will
mail an incentive check for as much as a 51000. These programs are offered for
one purpose to reduce energy consumption and the cost to the customer. We
burned wood exclusively as our heat source for over 20 years and rarely used our
supplemental electric forced air furnace. All efforts that saves or conserves energy
"shifts Costs" to other rate payers. Costing shifting is not a net-metering or
rooftop solar issue as much as a rate structure problem. ldaho Power recoups
some of their fixed costs through a base charge applied to all rate payers in a
class, but they also recoup some fixed costs through their energy charges. To our
knowledge the rate structure problem has never been examined comprehensively
as a settlement solution.
We do not object to paying our fair share of fixed costs to operate the grid. What
we object to is a Settlement Agreement that fails to comply with the promise the
Commission made to the public "that discriminatory rates would not follow" but
follow they will if this Settlement Agreement is approved.
Thank you, Mr. Chairmen.
Respectfully Submitted
Jim & Susa n Caswell
3005 Windfall Circle
Emmett, ldaho 83617
Re: Docket IPC-E-18-15
ldaho Public Utilitios Commission
Onic€ oI the SocrotarvRECEIVED ,
DEC 0 3 2019
Dear Members of the Public Utilities Commission,Boise, ldaho
I am a new solar energy customer. ln fact, my house is not even finished yet. We started
building in spring of 2019. The panels were installed in October and we just passed our
inspection by ldaho Power on Nov. 25th.
Our preference has always been to install solar panels on our new house but it is not a decision
to be made lightly. Solar panels are almost prohibitively expensive. We looked first to ldaho
Power's website to help us make the decision. ldaho Power encourages people to go all
electric. They Bive a substantial tax credit if you do. But the only way having an all electric
house is financially feasible is to install solar. Given the stated pay off figures which took into
account the monthly Net Metering policies at 10O% exported energy compensation, and ldaho
Power's stated goals for 100% clean electricity generation which includes solar production, we
felt that ldaho Power was fully supportive of private home owners taking this plunge. Thus we
decided to install enough solar panels to provide 100% of our energy needs.
But here we are. ldaho Power, without finishing their own studies, has conducted a bait and
switch to keep their monopoly. lt is a decision that counters their clean energy goal and puts
existing solar owners in a difficult financial situation.
We would ask that, at the very least, the PUC grandfather in existing customers into the old net
metering system. We had an understanding based on the information ldaho Power provided
about net metering and energy export compensation. We invested huge sums of money to
further the goal of clean energy. For most people, this decision was not based on any short-
term cost-savings since the pay off would be upwards of 20 years. But because it seemed that
the investment would at least be revenue neutral in 20 years, we made the commitment to a
better future for all. lf you do not let us continue with the old net-metering system that allows
us to receive full credit for the energy we are generating and measures output over the month,
then many of us will never live to see our investment paid offfinancially. This is unjust. We are
contributingto energy production. lf we produce excess energy, ldaho Power will profit offthat
at our expense. This is an exploitation of current customers, plain and simple.
Furthermore, since we did not learn of this new policy until three weeks ago, well after we
decided to get solar, we ask that "existing" customers be defined as all those with solar panels
installed as of the PUC decision to grandfather in existing solar customers.
Finally, we would like to add that we believe this entire policy of phasing out full credit for
energy production is short sighted and will have unintended consequences. The first, of course,
is that it will dissuade people from converting to solar power in the near future. ldaho Power
should have been working with homeowners to create microgrids as a cheaper means of
obtaining the infrastructure they need to establish their goals. lnstead they will build the
infrastructure on their own and pass those costs onto the consumer. Second, solar panel costs
and battery costs will inevitably decrease. Eventually, this will lead to people decoupling form
the grid entirely. This is not a short term possibility but surely it will be by 2045, the stated year
by which ldaho Power wants to be 100% clean energy only. ldaho Power is joining the ranks of
utility companies all over America that are sacrificing long term goals for short term profits. This
is just sad. I mourn for our planet.
Sincerely,
Nirmala Sandhu @ Ben Schwartzman.
5909 Midsummer St.
Boise, ldaho
83716
Solar installation in our new build at 2115 W. Bannock St., Boise, ldaho 83702
IDAHO PUBLIC
UTILITIES COMMISSION
tPc-E-18-15
Boise, ldaho
L2l03lLs
COMMENT FORM
Please use the space below to file a comment in this case. Add extra sheets as needed
You may either hand this sheet to a commission staff member or mail it to:
IPUC, PO Box 83720, 8oise, lD 83720-0074
You may also post comments on our website:
https://www.puc.ida ho.gov/
Click on the "Case Comment Form" link
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rPc-E-18-15
Boise, ldaho
L2l03lt9
You may also post comments on our website:
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COMMENT FORM
Please use the space below to file a comment in this case. Add extra sheets as needed
You may either hand this sheet to a commission staff member or mail it to:
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Click on the "Case Comment Form" link
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Idaho Power shareholders are being fed enough profit they should not be
hogs. Does ldaho Power need financial help from net-metering solar clients
who are less than 1% of its client base of when the Annual Report stated,
"Last year marked IDACORP's eleventh consecutive year of earnings growth.
Net income increased $14 million from2A77"
Net Income up 6.77Yo
Earnings per share up 6.65%
Dividends per share up7.l4%o
Average Return on Equity has not dipped below 9o/o inthe past 5 years.
Book Value has increased from $38.85 rra2014 to $47.04 that is a2lo/o
tncrease.
As a net metering Idaho Power customers our family invested our own money
in good faith that we would always have the same net metering formula. IDP
must keep our implicit agreement. Even the current Idaho Power website on
their FAQ page and still shows a 17 year payback simple savings back
expectations which uses a rate of approximately 8.3 cents /kwh. That is an
explicit expectation for current investors too. Idaho Power's new scheme
would only pay customers at 4.9cents/l<Wh for summer excess produced
power and then sell it for 8.7cents/kWh. That is outright theft. It will cut our
family's investment by 49o/o during that time. It will also effectively crush the
current ldaho solar industry we enjoy today and end our local efforts to curb
climate change by making net metering solar prohibitively expensive.
Currently there are 558,000 ldaho Power retail customers and only 4800 or
.9%o are net metering clients. Even if all 5500 net metering pending permif
were added it would still only is 1.7%o of the client total. They are not the
threat, Idaho Power greed is.
Their website page says, "Idaho Power welcomes your interest in solar and
renewable generation. To help you research your options, we've developed
the following list:" There are 32 checklist boxes to review to see if "Solar is
right for you;'. After the l2s box there was a note that "net metering is not a
contract and rates could change. Their webpage did not have all this when I
started investing in solar net metering in 201 3 . At the 20ft checklist box it uses
current rates at 8.7lcents/kW for payback estimates & it could go up to 12
cents. After the 2l$ box IDP italics estimates an annual increase of l.3Yo
increase/year for next 18 years. These are currently explicit expectations for
constant or improving rate payback to the prospective solar client. Given these
implicit and explicit agreement examples the rates should stay the same for
new as well as current Net-metering clients.
The annual report section on risks stated that promoting enerry efficiencies
including net metering have mechanisms such as the Fixed Costs Adjustment
to address them. It also lists climate change and significantly increased market
prices during the summer peak as risks. These risks could be mitigated by
distributive net-metering rooftop solar. Since Idaho Power touts a stated goal
of 100% clean energy, positive past and projected returns for stockholders,
there's absolutely no good reason for increased rates for existing or new net
metering clients. Clean energy net metering solar customers are not money
source for greedy stockholders.
Climate change catastrophes are already with us and will get worse for our
children and generations to come. Since Washington politicians have reversed
American progress, our only hope is to do everything we can personally and
locally to slow it. Keeping net metering incentives at full retail pricing is
mandatory. We are expecting that you deny all of IDP requests. We can
predict what Climate Change effects will be; we can't predict how people will
react to those who are irresponsible. Don't let greed win, remember, "Pigs get
fed but Hogs get slaughtered."
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To: Idaho Public Utilities Commission
PO Box 83720
Boise, ID 83720-0074
Case No: [Pe-E-.l4-2,
Name: Keith Woodworth
City: Caldwell
State: Idaho
Zip:83607
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Day time phone: [phone]
Name of Utility Company: Idaho Power
Public disclosure: Acknowledged
I have been an Idaho Power (IP) Net Metering customer with both a PV system and a
Skystream 3.7 wind turbine since the srunmer and fall of2008. To date, I have requested
and received one payment for surplus KWs from Idaho Power. At my request, a buffer
fund was retained by IP for costs not covered during any future billing p€riod by on site
production.
Based on records for the period of July I 9, 201 I to July 19,2012, my turbine produced
1,868 KWs, the PV system produced 5,059 KWs and the residence used 4,370 KWs. In
tum, a surplus of 2,557 KWs were returned to Idaho Power which covered the monthly
$5.00 administrative costs, and contributed to both the buffer and refund amounts. Due to
mechanical problems, the turbine has been "offline" enough to make comments based on
annual production rates approximate BUT, it appears that 72%o of the wind power
production occurs between October and April and about 30% ofthe PV production
occurs during the months of June, July and August. The system does supply power
back to Idaho power during the summer peak rate period.
With a nameplate capacity of 4.940 (5.540 with Skystream @2.4?) my residential system
falls under IP's proposed Schedule 6 as outlined in the testimony of Matthew T. Larkin of
IP.
The following comments follow the outline presented by Mr. Larkin.
History: Staff co ncems, P7,22-29, P8, 1-13. The likelihood of a residential system being
"0" is remote. More than likely, the system has produced a KW surplus which was
distributed and sold by IP at the time of production. As most residential systems are PV,
any surplus produced ollsets IPs dependence on higher cost "non-green" energy sources.
This ignores any cost reduction associated with the voluntary IP "Green Credit" program.
Although the administrative cost is now $5.00 instead of$2.51, the original analysis does
not appear to take into consideration (probably does but I can't see it) the net meter
customers contribution to the grid during peak demand periods at the present rate of
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Proposal Comments
$0.0525 instead ofthe estimated $0.12 cost associated with producing this power at a
newly constructed facility. Presently, power costs from the gas fired New Plymouth
facility may be lower - but, for how long?
P9, 14-20.1 don't understand how the costs to serve net metering customers are
significantly different from that of any other residential customer. We have the same
lines, meters and at least in the past, the same use rate costs. With the new AMI (Smart
Meters?) - the IP cost of service with proper management should decline. (note: our
m€ters are not remotely readable yet)
P10, 9-15. Minor point but as a paying customer I question the 353 customer number.
Once the economics of this proposal are evaluated by the "Applicants", I would think that
at least some will reconsider their application status. As proposed, I know I would!
Capacity Limit: Pl l, Figure L The chart shows that there are roughly applications totaling
250 KWs of nameplate pending. Treating these "Applicants" as "Customers" would
imply that they were notified oflPs pending proposed Net Metering service rates and
requirements.
When proposing such a major change to the existing net metering costs, why would an
increase in the capacity limit be requested or approved before the effects ofany newly
levied rates rir'ere evaluated?
Pricing: Not having access 1o IP's energy costs, this is beyond my review. My records
show that I paid IP $4,653.67 for a third ofthe cost to run an overhead power line to a
point on adjacent property, then $1,506.00 to run underground (trenching and backfilling
were an additional cost) service to a transformer and meter on or adjacent to the
residence. Unless I have missed something, that did put me on equal footing with the cost
of providing service to any other IP residence customer. BUT, with my PV and wind unit,
on a monthly basis I'm not generally buying power produced by IP. On a daily basis, I
recognize that I am using IP produced power (no night or "dead air" power from an on-
site battery storage system). As pointed out by several commenters', I am certainly
producing "green KWs" [which are (sold at a profit?) sold by IP] back into the IP
distribution system during peak demand use periods. It would also appear that my wind
power is mainly produced during the winter period when IPs dam reservoirs are being
recharged. That should be more ofan asset than a liability to the IP system.
Perhaps another approach to residential PV/wind units would be a simplified "admin"
billing system. As an example, on January 1, each residential net metered account would
have a deposit (an amount supported by site specific analysis). At 0:00 AM on June I'r,
for $20.00, IP would take a "Smart Meter" reading and calculate a bill/statement based on
used/produced KWs. At this point the account deposit would be adjusted and IP would
The IP proposal of$20.00/ month to cover "administrative costs" which includes $15.00
of "potential inequity(s)" (what ever they might be) is truly a green energy program 'fatal
blof' for customers having no intentions of being major (MW) energy generators.
send an accounting bill/stalement showing the accoturt balance. Again on August 3l$ at
l2:fi) PM/0:00 AM IP would again read tlle meter for another $20.00, calculate and send
a bill showing an adjusted account deposit. Finally on December 3 l't, IP would read the
meter, then submit a bill to either maintain the account deposit or "Zero"-(cut a check)-
for IPs side ofthe account after of course deducting the third $20.00 admin cost. In this
example, base load is not a consideration.
I don't know how the proposed charge of $1.48 per KW ofBase Load Capacity would
affect me, but assuming that it is also in the "spirif'of the proposed $20.00 per month
administrative fee it could be harsh!
Excess Net Energy: IPs definition of"Excess Net Energy" provides a measure for
accounting purposes but the measure as used by IP is not specific to any particular time
of day. This goes back to PV panels producing KWs during high demand surnmer
periods. On any given day IP would call these "excess" but in reality they should be
viewed as "green" surplus being used to lower IPs use of what appears to be more
expensive carbon based energy sources.
A "Google" search of Avista Corporation failed to show that this system of "Taking"
KWs on December 3l'r is uniformly applied to Avista's customers. Avista customers in
Washington (and Oregon?) are reimbursed on a July 1 - June 30 fiscal year basis. It is
recognized that ldaho and possibly Oregon customers are not eligible for this "... Cost
Recovery/Annual Incentive Payment.. ." program as the Washington State Department of
Revenue is also a program player. Any idea what FERCs position on this existing
payment program might be?
Final Comments: A partial list of the Idaho entities involved in my PV and Wind turbine
project include: IP Company Permitting, Excavation Contractor, Altemate Energy
Contractor, Canyon County Zoning & Planning, Canyon County Building Permit staff
ffield Inspector, Canyon County Electrical Inspector, Idaho State certified Electrician,
Idaho State Electrical Inspector, IP Field Inspector. Concrete, electrical cable, conduit,
wood and locally acquired re-bar would make up most ofthe rest ofthe cost list. The
possible effect of this proposal is far more extensive than just an agreement between a
Net Metering Customer and IP!
Is "Base Load Capacity" a new billing item for all residential power customers or is it
only proposed for Net Meter customers?
Respectfully,
Keith Woodworth
I find it difficult to believe that *FERC" could get really concemed over residential
power generation probably measured at less than I or 2 MWs/year. On the contrary, in
light of the nationwide "greening", I would imagine that they would be happy with a lot
more small residential generalion!
o."" M{* "y7ff**a|,,W 1,V,& r*,,n'P*, r
IDAHO PUBLlC
UTILITIES COMMISSION
lPc-E-18-15
Boise, ldaho
12l03l7s
COMMENT FORM
Please use the space below to file a comment in this case. Add extra sheets as needed.
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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3sllruO POI'IER"
An TDACORP Company
)bu have the power to inve.sl
in a greener energy frtr-rre.
' When you join, you are using a 50/50 blend of
renewafrle solar and wind energy from projects
in ldaho, Oregon or Washington - forjust an
extra penny a kilowatt-hour (kwh).
' Your participation also supports Solar 4R Schools,
which is a great way to teach the next generation
about sustainable energy.
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COMMENT FORM
Please use the space below to file a comment in this case. Add extra sheets as needed.
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IPUC, PO Box 83720, Boise, tD 8372O-OO7 4
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Click on the "Case Comment Form" link
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IPUC, PO Box 83720, Boise, lD 83720-0074
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IPUC, PO Box 83720, Boise, lD 8372O-O07 4
You may also post comments on our website
https://www.puc.ida ho.gov/
Click on the "Case Comment Form" link
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COMMENT FORM
Please use the space below to file a comment in this case. Add extra sheets as needed
You may either hand this sheet to a commission staff member or mail it to:
IPUC, PO Box 83720, Boise, lD 83720-0074
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https://www.puc.ida ho.Bov/
Click on the "Case Comment Form" link
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COMMENT FORM
Please use the space below to file a comment in this case. Add extra sheets as needed
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.ida ho.gov/
Click on the "Case Comment Form" link
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May 2019 - Mauna Loa Observatory in Hawaii - Carbon in the atmosphere was 414 ppm. lt was 280
when the lndustrial Revolution beBan in 1750. There has been a huge uptick in 2019. This is the highest
level of greenhouse gases in our atmosphere in human history, higher than at any point in millions of
years.
Our fossil fuel addiction is altering our atmosphere, endangering life on Earth.
Our denial and failure to address the problem has been a lost opportunity to fix it. We're at a point now
where the best we can do is slow it down.
We need imminent action to reduce Breenhouse gas emissions on all levels: lndividual, corporationsr
government. Many individuals have stepped up to do what we can to reduce greenhouse Bas emissions.
That includes us solarizers. We saw the problem and put our money up to do our little part to solve it.
We should be recognized for that effoG and if not celebrated, at least treated fairly.
But individual action is just not enough.
We need corporations to step up and take action. As our electric utility, ldaho Power is in a unigue
position to take meaningful action.
Most significantly, we need the power of government to understand the gravity of global warming and
adopt effective policies to address it. The talking has been done. We need action NOW.
Solarizing is an effective way to reduce greenhouse gas emissions. Solarizing needs to be incentivized,
not penalized. ldaho Public Utilities Commission, this is your chance to step up for the future by
rejecting ldaho Power's backward plan to hobble solarizing in ldaho. The problem we face is more than
money, than lifestyle, than convenience. lt's about all life on Earth. Do the right thing.
4/rro^ R-r^i H onl,'^_l J57lt4 L: 7 i,^/rzt't<Ld
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Diane Holt
From:
Sent:
To:
Subject:
Attachments:
Rob Conant <[e-mail]>
Wednesday, December 4, 2019 9:25 AM
Diane Holt
Typo Corrected testimony
RConant Solar Testimony 12-4- 19,docx
Hi Diane,
I heard of the online comment deadline yesterday but was at the meeting until early this morning.
I was able to submit my written testimony online after the meeting, but I did not have time to edit.
Here is a typo-corrected copy ifneeded. Ifpossible, please include it instead ofwhat I submitted late last night
online.
Thanks,
Rob
1
My testimony delivered after midnight at the IPC-E-18-15 public hearing 12/3 - 12/4/19
Thank you, commissioners, for your patience to heat us. I am a professional electrical engineer. I
have specialized in system design on this very campus for about a decade. !7e have a lot of
onsite generation perspectives in this toom. I am here to do my duty as a citizen, not rnair y to
represent the solar generatiofl customets, who diligently could be here to speak for themselves. I
have come with a perspective from the undeneptesented 450,000 plus other Idaho power
customen who were failed to be notified ofany of this. They are after all the suggested
beneficiaries of this change.
All my data and calculations are based on Idaho Power's (the company's) fixed cost report.
The company would hke it to be apparent from theit fi-xed cost report that they, ate losing a
large amount of money from on-site generation customef,s. At least when considering the factors
that they wished to indude. They would like it understood that this lost revenue is being bom by
the bulk of the non-generating residential customers. And have since iustified this proposal in
the name of rate faimess.
While multiple scenatios were considered in theit report, the acrual benefit to Idaho non-
generating tesidents (schedule 1) of net houdy billing was not discussed at all in the 91-page
fixed cost study. So, I have been compelled to determine from their own data what this benefit
might be.
As an important aside, the company is using incorrect langrrage in their pubLic correspondence.
The company's letter to the public stated "more accurate measuring" as the issue being
addressed in this case. accurate measuring, who could argue with that? they don't mention. That
accurate hourly measudng is already occuring and has for 5-10 yeats with the distibution of
smart meters and any customet can login online and see accurate hourly measuring, their
utilization and upload to the grid.
I urge the commission to require Idaho power to use the cortect terminology with all the
negative PR it may incur, this is about residential solar carryovers and billing methodology. The
term measuiement is misleading to the public and you will see that is not the terminology the
company chose to use in their report.
As a result of my personal analysis of their repott thete are two points I would like to make to
the commission regarding logical and mathematical problems with the study and the proposed
setdement agreement.
Point 1:
The company is proposing this change in tle name of rate faimess. They would, like those wh<>
incur the costs (at least as they would like to calculate them), to pay the costs. But strangely, ftom
the companies own figure 1, page 15: (the residential generation customers are not the ones you
should be targeting. There exists much vaster misalignment of distribution of fixed cost dollars
There are several othet factots they did not include which more thorough oet-metering study
would have, including numetous defered costs and sola-r benefits they fa.il to assign value to.
Solar mainly generates during the summet, and the company has self-prodaimed "hrgher costing
summer months", on page 32.
qdthin the schedule I residential (non-onsite) customer class itself. Because the company has
fai.led to address the main 6xed cost issues.
Not disorssed by the company is fixed cost report is the large discrepancy between who
payhg for those fixed costs and who is actually incurring those fixed costs. And I'm not talking
about solar generation, I'm talking about the bulk of schedule 1 residential customets not billed
appropriately amongst each other for 6xed costs, per the company's own tepott. The examples
are not hard to consider, someone with a low sca.le constant (high accumulated) electric load is
bearing the 6xed costs, imposed by someone with litde overall energy usage! but pattems which
drives up the real costs of peak load and time of use generation and infrastuctute costs.
Also, thete are also 430 times mote of those regular customets than onsite generation customers.
I would ask the company Y/hy are we not ptoposing properll' assigning the vast majoriqv of fixed
costs within schedule 1?
If we ate tuly putsurng fixed cost faimess amongst schedule 1 @y the way this is the proposed
goal), wouldn't it make sense to address 99.8% of the group impacted by the problem, not only
the 0.27o who are on-site residential customers? Why are you discriminathg against residential
on-site generation, salttng thry haw lo ?E lbir PnPcr shaft lffxed c|rts,but no one else? No other
schedules were included at all.
Point 2:
1'his regards the dollar amounts involved, you have-to follow the money. I examined the
company's rwenue sutplus/deficiency numbers. They are deat. And with the company I must
agtee they ale overcharging residential customers based on theit data, by 19 million pet year,
(page 14), or on average 60 dollars per customer. But who is getdng the benefit of this
overcharging by 19 million? The company makes it sound like it is the residential solar
producets, as this is the only party whom the company is targeting with this regulation.
Yet even accotding to their math, only 2.6o/o (0.5M$) is due to residential solar. If the company is
overcharging residents by 19 million, who is the other 18.5 milLion subsidising if it is not going to
residential solar? It is the Large General, Industrial and Itrigation customers who are not paying
their fair share of costs, burdening the residents in schedule 1, and if you consider the service
charge schedules 06 and 08 pay, perhaps them as well.
Page 14, figure 6, in the report summarizes that this discussion should not metely be about a
minor 0.5N{$. rWe should be addressing the 31 million, 60 times as much as Idaho power is
considering ad&essing, though they have had this data for two years.
If we even achieved billing onsite generators perfectly fairly, based on the company's own
numbets, the commission would save the avetagc schedule 1 customer, over the course of an
entire year, 1$. (fhe math is not hard, - half a nillion $ ftdaPrrohd to dboul ar r ttru t'tstlr en)
I ask the commission, why ale we not discussing saving schedule 01 the full $60 a year?
[.et's have candid discussion about the 20,fi)0 irrigation, latge general, and industrial
customerc who are causing 97.404, almost the entire the schedule l over-charge, totalling
31M$, and get that back to schedule 01 customefs.
This leads to the most blatant issue with the company's study.
The real picture:
In WWII we parachuted rubber dummies into enemy teffitory so they would spend their limited
ammunition fighting a harmless target while we came in under the radar somewhere else.
The company is wasting the commissions and the publics time targeting the wtong group. I
would urge 1'ou, commission to focus youl resources on the actual cost burden to Idaho
residential overbilling. Why are we wasting years targeting residential generation, Individual
homeowners, who account for only 2.67o of the amount you are overchatging other residential
customers?
I'm not surprised that the pubLic l-iews this as predatory by the company, for squashing the
schedules 06 and 08 because they encroached on their power generation monopoly.
IJere today we are discussing how to punish 0.270, or two out of a thousand customets, for
faulty rate stuctures that fail to account for fixed costs propet\ for 1007o of the entire half a
million residential customeG. On yout tate faimess quest, why target initial change towards the
two smallest schedule groups both in numbers and dollar impact? V'hv is the company
drscriminating in this way? Something the commission has forbidden. One of the only
conclusions the consumer can make is they ate targeted because they don't have corporadons
behind them.
Should not they rather be the tatger ofyow slpporl, having fi.rlly cooperated with every
regulation and safety protocol you have issued. In fact, they have bom additional cost to their
solar systems in otder to meet safety and regulation standatds. Are they some sort of law
violators?
,'\nd yct, the companv sent mislcading statements like desiring thc "accurate measuring". 'Ihey
should have been honest and said, "lucrative billing for Idaho Power to the detriment ofprior
green energv competition in Idaho". Idaho Powe/s ptoposal has a clear goal to temove
decades of previously agreed upon gteen energy incentives to a few. While ptomoting
their "pro-green" face to the public, they continue to ovetcharg€ that same public tens of
millions, while subsidising literally power-hungry industrial bottom lines.
Should not hourly billing be marketed as it is, metely a way to target and discourage tesidential
solar customers in an unprccedented waf Why are they not including irrigatron (schedule 24),
Large Geneml Service (schedule 9)? This is discriminatorv.
In this regulation proposal, the company would like to discourage small small installations and
for inappropriate reasons. This is based on data from their oun report. Their own summary
language focuses on classes 06 and 08 (a rnere 2.4oh their ptoblem) as "especially a problem" (pg.
15). I ask why is 2.6% of this billing issue "especially a problem" while 97.47o is not mentioned
at all?
I note among the solar community:
. Alignment with federal and state goals of advancing clean enetgy
r personal investment in the technology of the future
e personal investrnent in the clean future of our wodd
o the lack of taking a single cent of a pay check from their investnent, only fun-rre
deferred costs based on responsible calculations based on..7a u pior poliE,
I agtee that refotm is needed, but if apptoved, you are targeting the wrong gtoup with this
regulation. If power providing parties like Idaho power are guaranteed a rouglrJy 77o profit on
their work, whv are the truly green, proactive, smaller, more risk exposed, and personally
invested homeowners in Idaho not worthy of similar considemtion? Simply because they don't
have millions of stakeholders holding stock certificates or sitting across the board room?
'Ihe company would suggest that solar generators are to be reated as t poner whobsalers, af,d yet
denied that their solar installation is able to pay fot itself, or any profit. Rtasombh would be
guaranteeing the same 6.80/o that the Idaho power is guaranteed and gmnted depreciation and
other tax incentives that all businesses are provided by federal law. This is of course, a ridiculous
proposal. There is an ove y complicated legal mess that would ensue, if we approve this, making
every household a power business. \r('ith future technology, as Idaho power knows, all
households will have low bariers to producing energy in a couple decades in some form, if they
still own the sun that shines on their house. This proposal is further distracting form the real
soutce of fi-red cost inequality in Idaho. I-et's stay focussed, and do our jobs, and force Idaho
power to address the broader faimess issues.
We are years into this discussion, and the company pressudng for quick regulation. It is time we
staft talking about a fair solution. Why would the so-called beneficiaries of this change not be
invited? If they came and actually did the math, this is not the change they would want, because
it does not begin to address theL needs. This begs the question ofwho is this changc targeted to
benefit, ifnot for the schedule 1 customer benefit (of 1$)? At the end ofmy analysis, I can only
conclude this is about Idaho power conrolling the futute of household energy generation,
nothing mote, nothing less. The higher the petcentage of enetgy they contol, the more dollars
of tevenue they receive, at theit guamnteed rate of retum, the larger dollar amount of profit they
accumulate.
To close, ifyou are for clean energy? \X'l-ry punish it? Punishing these 0.294 of the residents does
not wen begin to grant the other 450,000 faimess.
'Ihis is a lie that we are being sold, and the math is dear. If you are for mte faimess then lets
acn:ally pursue it, instead of straining out a 0.5M$ gnat and swallou'ing a 31M$ camel.
Thc only personal comnent that I would make is that My residential solar stakeholders ale ages
,1, 7, and 11, and sit across the dinner table from me. And at some point, I'm also here to
represent them. They ate curtendy excited about clcan energy with open minds and future
cateets defined by pride in our houschold's cadng well for our limited community resources.
They are smart and will hear about and tefetence this moment, as thousands of children wiil.
1'hey are looking to us all to be examples of justice. I also represent you, because you likely also
fall into one of these two categories, schedule 01 or 06.