20191001Answer - Redacted.pdf

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An TDACORP Company
LISA D. NORDSTROM
Lead Counsel
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October 1,2019
VIA HAND DELIVERY
Diane Hanian, Secretary
!daho Public Utilities Commission
11331 W. Chinden Boulevard
Building 8, Suite 201-A
Boise, lD 83714
Re Case No. !PC-E-19-28
Jeff Comer vs. ldaho Power Company
ldaho Power Company's Answer
Dear Ms. Hanian
Enclosed for filing in the above matter please find an origina! and seven (7) copies
of Idaho Power Company's REDACTED Answer and CONFIDENTIAL page 4 in the above
matter. lf you have any questions about the enclosed documents, please do not hesitate to
contact me.
Very truly yours,
U.<-l.f-,a*.r-
Lisa D. Nordstrom
LDN:kkt
Enclosures
LISA D. NORDSTROM (lSB No. 5733)
ldaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
I nord strom @ ida hopower. com
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
NECIIVED
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Jeff Comer,
Complainant,
vs.
ldaho Power Company,
Respondent.
Case No. IPC-E-19-28
IDAHO POWER COMPANY'S
REDACTED ANSWER
Respondent, ldaho Power Company ("ldaho Power" or "Company"), hereby
answers the Complaint of Jeff Comerl filed August 6,2019, in the above-entitled case.
ldaho Power believes it has appropriately applied the eligibility criteria for meter
aggregation by using parcel designation to determine the property boundaries and
contiguous properties on which customer meters are located and that applying a broader
definition of "property" as proposed by Mr. Comer is not consistent with conditions set
1 Although signed by Mr. Comer, the Complaint appears to reflect the sentiments of both Jeff Comer
and his net metering project partner/neighbor, Jack Goodman.
IDAHO POWER COMPANY'S REDACTED ANSWER. 1
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forth by the ldaho Public Utilities Commission ("Commission") for meter aggregation in
Order No. 32925.
I. METER AGGREGATION
ldaho Power currently offers net metering service to facilitate the transfer of non-
firm electricity to the Company from customer-owned generation with the intent of
offsetting all or a portion of a customer's energy usage. Generation facilities under
Schedules 6 (Residential) and 8 (Small General Service) must have a total nameplate
capacity rating of 25 kilowatts or less. As of August 31,2019, the Company had 5,200
active and pending net metering systems in its ldaho service atea.
ln Case No. IPC-E-12-27, the Commission issued Order No. 32846 changing how
customers were compensated for excess net energy, effective October 1,2013. Prior to
October 1 ,2013, customers received either a financial credit or a payment for their excess
net energy. After October 1,2013, customers received a kilowatt-hour ("kwh") credit for
their net excess energy. ln Order No. 32925, the Commission went on to establish
conditions under which customers could transfer excess net energy credits from the
designated on-site generation meter to offset consumption at one or more separate
meters - othenrvise known as "meter aggregation":
1. The customer may only apply the excess net energy credits to accounts
held by the customer;
2. The aggregated meters must be located on, or contiguous to, the property
on which the designated meter is located. Contiguous property includes
property that is separated from the premises of the designated meter by
public or railroad rights of way;
3. The designated meter and the aggregated meters must be served by the
same primary feeder; and
4. The electricity recorded by the designated meter and any aggregated
meters must be for the customer generator's requirements.2
2 These criteria were incorporated into ldaho Power's tariff on pages 3-4 of Schedule 8
IDAHO POWER COMPANY'S REDACTED ANSWER - 2
The Commission explained why the location of both meters should be examined
and why energy credits should not offset the consumption of another customer. The
Commission stated:
The intent of net metering is to allow a customer to offset the
customer's usage with self-generation. !t would be
inconsistent with this intent to allow the customer to apply
excess net energy credits to offset another customer's usage.
Further, it would be inappropriate to let the customer apply the
credits to offset the customer's own usage at another delivery
point without considering that delivery point's location. As
discussed in prior comments and testimony, even with one
delivery point, net metering customers may not pay their full
fixed costs given the current rate structure. We find that
allowing customers to apply credits to offset usage on
contiguous meters that are served by the same primary feeder
is a reasonable means by which to limit the potential under-
recovery of fixed costs.3
Prior to the inception of meter aggregation in 2013,4 net metering customers
received a financial crediUpayment for the excess net energy measured in kWh per billing
period. For Residential and Small General Service customers, financial credits were
calculated by applying the full retail energy rate to the total excess net energy
II. ACCOUNT HISTORY
A. Mr. Comer's Accounts
Mr. Comer began taking residential service at 4186 N. 1100 E. in Buhl, ldaho on
June 3, 1991 ; the account remains active to date. The Comer residence is denoted with
a yellow dot on the map provided as Attachment 1. Mr. Comer subsequently began taking
net metering service for a small commercial hydro on-site generation system on May g,
2006. The designated meter for the on-site generation system is denoted with a green
3 Order No. 32925 at 6
4 Order No. 32925.
IDAHO POWER COMPANY'S REDACTED ANSWER - 3
dot in Attachment 1. In his Complaint, Mr. Comer states that he and Jack Goodman are
partners in the net metering projects; however, the Idaho Power account for the hydro
generator is in Mr. Comer's name only.
Prior to the inception of meter aggregation in 2013, Mr. Comer received financial
payments for the excess net energy generated by the small commercial hydro on-site
generation system. Mr. Comer received I in financial payments during 2013, the
last year financial credits were paid to customers for their excess generation. After the
switch to kWh credits in 2013, Mr. Comer began to accumulate a large kWh credit
balance. ln the most recent year, 2018, Mr. Comer was credited tor l kWh credits.
Because there is no load being served by the generation, Mr. Comer relies on meter
aggregation to utilize a portion of his energy credits. The Comer residence consumes
roughly I kWh per year, leaving well over 50 percent of kWh credits unused unless
they are aggregated with other meters, to offset usage elsewhere.
B. Mr. Goodman's Account
Mr. Goodman began taking residential service at4148 N. 1100E. in Buhl, ldaho
on August 6, 1990; subsequently on July 9, 2014, soon after the financial payments for
excess generation were switched to kwh credits, the residential account in Mr.
Goodman's name was closed and service was initiated under the name of Jeff P. Comer
with Mary J. Comer as the co-applicant. The Goodman residence is roughly 0.33 miles
from the Comer residence. As noted in the Complaint filed August 6, 2019: "The meter
on Mr. Goodman's property is in Mr. Comer's name."6
5 Complaint at 1
6 ld.
IDAHO POWER COMPANY'S REDACTED ANSWER - 4
C. Mr. Comer's Requests for Meter Aqqreqation
ln years 2015,2016,2017 , and 2018, Mr. Comer requested to transfer credits from
the designated generation meter to two separate meters: (1) the meter at his own
residence and (2) the meter at Mr. Goodman's residence. ln each of those years, after
believing the criteria for meter aggregation had been achieved, ldaho Power approved
the transfer of credits to both meters, including the transfer from the designated
generation meter to the meter at Mr. Goodman's residence.
The process to review eligibly for meter aggregation is a manual process and in
2015, the Company representative did not consult a map to verify that the properties were
contiguous; instead, the representative, in reviewing the addresses for the two meters
(4186 N 1 100 E and 4148 N 1 100 E), mistakenly thought the addresses were the same
and therefore contiguous. When reviewing the 2016,2017, and 2018 requests for
transfer, the representative erroneously assumed that because the request was approved
previously, the requests did not require further review. The approvals to transfer the
credits in each of the years 2015-2018 to the meter at Mr. Goodman's residence was the
result of human error.
Starting in 2019, the Company utilized a geographic information system ("GlS")-
based tool to confirm contiguous property when evaluating meter aggregation requests.
ln 2019, Mr. Comer again requested to transfer credits from the designated generation
meter to the two separate residential meters. However, upon review, it was determined
that the meter at Mr. Goodman's residence (denoted with a blue dot in Attachment 1) was
not located on a contiguous property to the designated generation meter (denoted with a
green dot in Attachment 1). On February 15,2019, ldaho Power approved the request to
IDAHO POWER COMPANY'S REDACTED ANSWER - 5
transfer credits to the meter at Mr. Comer's residence; however, the Company denied Mr.
Comer's request to transfer credits to the meter at Mr. Goodman's residence.
III. IDAHO POWER'S POSITION
A. "Contiguous"
Order No. 32925 and the provisions of Schedule 8 permit aggregation of meters
for the annual transfer of unused Excess Net Energy when "the meter is located on, or
contiguous to, the property on which the Designated Meter is located. For purposes of
this tariff, contiguous property includes property that is separated from the premises of
the designated meter by public or railroad rights of way."7
The Company determines "contiguous property" under Order No. 32925 based on
a combination of (a) the Company's GIS facility location maps, and (b) the official county
assessor's parcel map. As depicted in Attachment 1, the Company overlays these two
maps in electronic format and determines on which parcels of land the Company's meter
facilities are located. lf the designated generation meter and the meter requested for
transfer are located on the same property or contiguous properties, per the county
assessor's map, ldaho Power approves the meter aggregation request (assuming all
other requirements for meter aggregation are met). lf the designated generation meter
and the meter requested for transfer are located on non-contiguous properties, per the
county assessor's map, meter aggregation is not allowed. The Company believes this
evaluation of contiguous is reasonable, as the information relied upon is the most publicly
available, readily accessible resource to assist with the contiguous properties
determination.
7 Schedule 8, page 3
IDAHO POWER COMPANY'S REDACTED ANSWER - 6
Using this method to determine contiguous property, ldaho Power approved Mr.
Comer's 2019 request to transfer credits from the generation meter (green dot on
Attachment 1) to the residential meter on Mr. Comer's property (yellow dot on Attachment
1); however, ldaho Power denied Mr. Comer's 2019 request to transfer credits from the
generation meter (green dot on Attachment 1) to the residential meter located on Mr.
Goodman's property (blue dot on Attachment 1).
While it had not considered the sale of Mr. Goodman's property to Mr. Comer
(referenced on page 1 of the Complaint) in its determination of contiguous properties, the
Company does not believe this fact changes the outcome of the determination. Because
the property on which the designated generation meter is located continues to be non-
contiguous to the property where the meter on Mr. Goodman's property is located, the
criteria is not met.
B. "Propertv" versus "Parcel"
Mr. Comer states that "lPC has replaced the word 'property'with the word 'parcel"'
in his Complaint.s ln its effort to administer the tariff requirements for meter aggregation,
ldaho Power views property and parcel as synonyms and believes this is reasonable for
administering the evaluation of meter aggregation requests.
From a real estate standpoint, a "parcel" is the basic unit of land ownership in ldaho
and other states. Parcels are created by a formal property deed conveying the parcel to
the landowner, including a definitive legal description of the parcel. The deed is recorded
in the county land records, and the parcel is assigned a unique parcel number by the
county assessor and placed on the county assessor's map.
8 Comer Complaint at 2.
IDAHO POWER COMPANY'S REDACTED ANSWER - 7
ldaho Power interprets the reference to "property" in Schedule 8 to be the "parcel"
of land on which the meter is located. The subject parcel can be reliably and efficiently
identified by ldaho Power through use of the county assessor's map and ldaho Power's
GIS facility location maps, as discussed above. Conversely, Mr. Comer's broader
definition of "property" raises other issues that would need to be resolved. For instance,
what parcels of land would be included in the larger "property" definition suggested by Mr.
Comer - only those parcels held in the customer's name, or would parcels held in different
names or co-owned with other individuals or held under corporate ownership be included
in the larger "property" definition? lf so, ldaho Power could be required to perform an in-
depth title ownership search to determine what parcels should be included or excluded in
the larger "property" envisioned by Mr. Comer, particularly since the county assessor's
map may not show the full ownership of any given parcel.
While the meter aggregation provisions in ldaho Power's tariffs use the word
"property," the Commission recently approved nearly identical meter aggregation
provisions for Rocky Mountain Power using the word "parcel:"
For the purposes of Schedule 135, parcels shall be
considered contiguous if they share a common boundary or
corner, and includes parcels that would otherwise be
considered contiguous but are divided by a public right of way.
The Commission noted that "allowing transfer of excess net energy credits
between meters on contiguous property, as recommended by Staff to include parcels
separated by a public right of way, aligns meter aggregation under Schedule No. 135
IDAHO POWER COMPANY'S REDACTED ANSWER - 8
closely with ldaho Power's Schedule No. 84."s For purposes of meter aggregation tariff
provisions, the Complainants' argument draws a distinction without a difference.
C. The lntent of Net Meterinq Service
Net metering service is offered by the Company to provide for the transfer of
electricity to the Company from customer-owned generation facilities with the intent of
offsetting all or a portion of a customer's own energy usage. ldaho Power does not
believe it was the Commission's intent in Order No. 32925 to allow customers to offset a
non-contiguous neighbor's consumption.
The Company expressed its concern in Case No. IPC-E-12-27 thal meter
aggregation exacerbates the potential under-recovery of fixed costs from net metering
customersl0 and believes that, at a minimum, meter aggregation should be limited to
meters located on contiguous property to reasonably limit the potential for increasing the
magnitude of the under-recovery of fixed costs. When the Commission approved meter
aggregation in Order No. 32925, it discussed the potential for cost shift. The Commission
stated:
[E]ven with one delivery point, net metering customers may
not pay their full fixed costs given the current rate structure.
We find that allowing customers to apply credits to offset
usage on contiguous meters that are served by the same
primary feeder is a reasonable means by which to limit the
potential under-recovery of fixed costs.
!f a customer wishes to offset the energy needs of persons other than himself, or
to make financial gain from the on-site generation system, Net Metering service is not the
e ln the Matter of the Application of Rocky Mountain Power for Authority to Modify Schedule No.
135 - Net Metering Seryice, Case No. PAC-E-19-03, Order No. 34370 at 4 (July 3, 2019) (emphasis
added).
10 ldaho Power Comments in Response to Order No. 32880, p.p. 2-3.
IDAHO POWER COMPANY'S REDACTED ANSWER - 9
appropriate service offering; Schedule 86, Cogeneration and Small Power Production
non-firm Energy, is a more appropriate tariff schedule for which to serve the needs of
such customer.
D. MeterAgoreqationAdministrationChallenqes
ldaho Power believes it has followed the letter and spirit of the Commission's Order
with its application of the eligibility criteria for meter aggregation by using the county
assessor's parcel designations to determine the properties and contiguous properties on
which customer meters are located. However, based on its five years of experience with
meter aggregation, ldaho Power admits that three of the four1l tariff provisions reflecting
the provisions of Order No. 32925 have proven difficult to administer:
1. The customer may only apply the excess net energy credits to accounts
held by the customer.
Challenge: For transfers that include commercial property (Schedules 7, 9,
19, and 24), the customer name may not be associated with the company
name. No method currently exists in the public domain to readily verify
common ownership, particularly regarding limited liability organizations.
2. The aggregated meters must be located on, or contiguous to, the property
on which the designated meter is located. Contiguous property includes
property that is separated from the premises of the designated meter by
public or railroad rights of way;
Challenqe: Verifying contiguous property requires GIS mapping technology
and county data sources that must be reevaluated and updated annually.
3. The electricity recorded by the designated meter and any aggregated
meters must be for the customer generator's requirements.
Challenqe: While ldaho Power can read ily ascertain the customer of record,
it cannot usually substantiate with certainty when indications exist that
customers are assuming responsibility for their neighbor's service to offset
11The provision that requires designated meter and the aggregated meter must be served by the
same primary feeder does not present administrative challenges.
IDAHO POWER COMPANY'S REDACTED ANSWER - 1O
their neighbor's consumption and that the electricity recorded by the
aggregated meters is for the customer generator's requirements.l2
As evidenced by these facts, meter aggregation is a labor-intensive, manual
process that is prone to human error. As net metering service grows and requests for
meter aggregation increase, there may be a need to revisit the meter aggregation tariff
provisions to increase transparency, clarify administration, and ensure consistency with
the Commission's net metering policy.
III. COMMUNICATIONS AND SERVICE OF PLEADINGS
Service of pleadings and communications with reference to this case should be
sent to the following:
Lisa D. Nordstrom
ldaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
I n o rd strom @ ida h ogoyer. som
Kristy Patteson
ldaho Power Company
1221\Nest ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
kpatteson@ id ahopower. com
dockets@ id ahopower. com
IV. CONCLUSION
ldaho Power believes it has followed the letter and spirit of the Commission's Order
No. 32925 with its application of the eligibility criteria as to contiguous property in this
instance. While it had approved Mr. Comer's requests in 2015-2018 to transfer unused
kWh credits to a non-contiguous property, ldaho Power had done so in error. ln its 2019
evaluation, ldaho Power relied on an improved process to evaluate the contiguous
property criteria and determined that Mr. Comer's request to transfer excess kWh credits
to the meter located on Mr. Goodman's property did not meet the criteria in Schedule 8.
12The Complainants'admission to putting the meter on Mr. Goodman's property in Mr. Comer's
name "and therefore qualify for aggregation privileges" is the exception.
IDAHO POWER COMPANY'S REDACTED ANSWER - 11
ldaho Power requests that the Complainant's appeal for aggregation with the meter on
Mr. Goodman's property be denied.
Dated at Boise, ldaho, this 1st day of October 2019.
LI D. NOR
Attorney for ldaho Power Company
IDAHO POWER COMPANY'S REDACTED ANSWER - 12
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the lstday of October 20191 served a true and correct
copy of the within and foregoing IDAHO POWER COMPANY'S REDACTED ANSWER
upon the following named parties by the method indicated below, and addressed to the
following:
Gommission Staff
Edward Jewell
Deputy Attorney General
ldaho Public Utilities Commission
1 1331 W. Chinden Boulevard
Building 8, Suite 201-A
Boise, lD 83714
Jeff Comer
4186 N. 1 100 E.
Buhl, ldaho 83316
X Hand Delivered
_U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
_Hand DeliveredX U.S. Mail
_Overnight Mail
_FAXX Email comerweldi oud.com
berly T Executive Assistant
IDAHO POWER COMPANY'S REDACTED ANSWER - 13
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
GASE NO. IPC-E -19-28
IDAHO POWER COMPANY
ATTACHMENT 1
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