20180126Beach Rebuttal.pdf

Kelsey Jae Nunez,ISB No.7899
KELSEY JAE NUNEZLLC
920 N. Clover Dr.
Boise,ID 83703
Telephone: [phone]
kelsey @ kel seyjaenunez.com
Attorney for Sierra Club
RfiCEIVED
till$ Jf.H 25 Pl{ 3: 3tr
l:ffi,t,li8',0*:T1:: ft;'lllii
BEFORE THB IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY' S APPLICATION TO
ESTABLISH NEW SCHEDULES FOR
RESIDENTIAL AND SMALL GENERAL
SERVICE CUSTOMERS WITH ON-SITE
GENERATION.
CASE NO. IPC-E-17-13
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Sierra Club
Rebuttal Testimony of R. Thomas Beach
January 26,2018
Executive Summary
Idaho Power Company (Idaho Power or IPC) has asked the Commission to take
important initial steps toward changing the compensation for customers who install
renewable distributed generation (DG) under net energy metering (NEM). This includes
placing residential and small commercial customers who install renewable DG into
customer classes distinct from standard customers. The Sierra Club is concerned that
Idaho Power seeks approval of this ratemaking step without actually establishing that
there is a significant economic problem with net metering that needs to be addressed at
this time.
This rebuttal testimony responds to the opening testimony of the Commission staff
(Staf|. Staff proposes to modify IPC's Schedule 84 so that NEM customers are
compensated for the excess energy that they export to the utility, every hour, at an
avoided cost-based rate, while NEM customers would continue to pay for the hourly
energy that they import from the Company based on their current rate schedule. I support
Staff s position that there is no need to establish separate customer classes for NEM
customers. I am not opposed to Staff s proposal for distinct hourly rates for exported
power from NEM customers; however, this structure should be adopted only after a
comprehensive benefit-cost study shows that the costs of NEM exceed the benefits, such
that there is a need to change the present NEM program. My direct testimony described
at length the three key attributes of a benefit-cost study ofNEM:
l. Analyze the benefits and costs from the multiple perspectives of all of the key
stakeholders,
2. Consider a comprehensive list of costs and benefits, and
3. Use a long-term analysis consistent with the economic life of DG facilities.
This rebuttal also discusses my concerns with the Staff s proposal to determine a
NEM customer's imports and exports of electricity on an hourly basis. Today, IPC's
residential and small commercial customers do not have the hourly data that they (or their
solar installer) would need to be able to evaluate the economics of an investment in a
NEM system under the Staffls hourly netting proposal. Without ready access to this data,
the Staff s proposal would create a significant and unfair barrier to new NEM
installations. Ultimately, I would expect Idaho Power to be able to make hourly data
available to all of its customers, as it joins many other utilities in the U.S. in encouraging
demand reduction and the more efficient use of energy through cost-based, time-of-use
(TOU) rates. However, until that time arrives, and all residential and small commercial
customers have access to at least one year of hourly usage data, NEM should continue to
use the monthly netting of imports and exports, as is the practice today.
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Finally, I support the Staff s proposal that the Commission should initiate a docket
in which all interested parties can work together to determine the appropriate avoided
cost methodology to value the benefits of net metered DG. This study should also
examine the costs of NEM. After this study is complete, if the Commission determines
that the costs ofNEM exceed the benefits, this avoided cost methodology can be the basis
for compensating net metering customers for their exports. In this cooperative effort, all
parties should have the chance to provide input into the benefit-cost methodology and
study, and the opportunity to critique the study after it is completed.
Table of Contents
EXECUTIVE SUMMARY I
I. INTRODUCTION
II. RESPONSE TO STAFF 1
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1.I. INTRODUCTION
Please state your name, address, and business affiliation.
My name is R. Thomas Beach. I am principal consultant of the consulting firm
Crossborder Energy. My business address is 2560 Ninth Street, Suite 2134, Berkeley,
California 94710.
Have you previously submitted testimony in this proceeding?
Yes. On December 22,2018, I submitted testimony in this docket on behalf of the Sierra
Club. The interests of the Sierra Club in this case are presented in my opening direct
testimony, and my experience and qualifications are summarized in that testimony.
What is the purpose of this rebuttal testimony?
This rebuttal responds briefly to the direct testimony that the Commission staff (Staff)
filed in this case.
II. RESPONSE TO STAFF
Q:Please summarize the Staffls direct testimony.
The Staff has recommended that the Commission should reject Idaho Power Company's
(ldaho Power or IPC) request to establish two new customer classes applicable to
Residential and Small General Service customers with on-site generation who request to
interconnect to IPC's system on or after January 1, 2018. Instead, Staff proposes to
modifu IPC's Schedule 84, Customer Energy Production Net Metering Service, so that
net energy metering (NEM) customers are compensated for the hourly excess energy that
they export to the utility at an avoided cost-based rate, while continuing to pay for the
hourly energy that they import from the Company according to the rate in their current
rate schedule. Staff asks the Commission to initiate a docket in which all interested
parties can work together to determine the appropriate avoided cost methodology used to
compensate net metering customers for their exports.l
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Staff Direct Testimony (Morrison), at pp.2-3
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Q:Is the staffs proposal a reasonable way to resolve this case and to move forward on
net metering issues on the IPC system?
Yes, it is, but with several caveats that I explain in this rebuttal. The Staff correctly
recognizes that the differences in the electric service that NEM and non-NEM customers
receive from Idaho Power are not significant enough to justifu placing NEM customers
into separate rate classes.2 Staff also properly recognizes that what distinguishes NEM
customers is the fact that they export a portion of their electric production to the grid. As
discussed in my opening testimony, citizens have certain rights under well-established
federal law3 that should be respected in any resolution to this proceeding: (l) to make
private investments to install certain types of renewable distributed generation (DG) on
their premises, (2) to interconnect with the utility provided that this connection is done
safely and in accordance with adopted industry standards, (3) to use a portion of their DG
output to serve their own electric needs behind the meter, and (4) to export the excess to
the grid. Ultimately, the issue for this Commission is how to compensate NEM
customers fairly for those exports.
Q: What are your reservations about the stafPs proposal?
A: The Staff proposal is a reasonable approach, but only after the Commission has
determined that the overall costs of the current net metering program exceed the benefits,
such that compensating NEM exports at the retail rate is unfair for other ratepayers and
the system as a whole. Thus, the first step must be to do a comprehensive benefit-cost
analysis to see if this is true. For example, if the benefits of net metering exceed the costs
(as my analysis in IPC-E-12-27 indicated to be the case five years ago), then non-
participating ratepayers are realizing benefits from NEM. In that case, the Commission
should either (1) do nothing, and maintain the current program, or (2) increase the
compensation for exports to the point where benefits and costs are equal, in order to bring
more clean, renewable generation onto IPC's system at no cost to other ratepayers.
Ibid., at p. 3, and the analyses that Mr. Morrison presents on pp. l0-19
The Public Utilities Regulatory Policies Act of 1978 (PURPA).
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Q:
Without doing such a study, it is simply premature for the Staff to conclude that NEM
customers are being overcompensated today.a
Do you have any concerns with the analysis of the net metering "cost shift" that the
Staff s witness Mr. Morrison presents on pages 11 and 12 of his testimony?
Yes. My first concem is that the Staff s cost analysis uses 2016 DSM avoided cost rates
to value NEM exports.s As set forth in my direct testimony, the benefits of NEM should
be assessed using a comprehensive set of benefits and costs, and a long-term analysis.
The location, diversity, and technologies of DG resources will require the analysis of a
broader set of benefits and costs than, for example, traditional QF facilities installed
under PURPA. Comprehensive lists of the benefits and costs that should be considered
can be found in Table I of my direct testimony, in the Idaho Conservation League's
Exhibit ICL-404, and in the Oregon commission's Resource Value of Solar proc"s.6
Second, Mr. Morrison suggests, but does not analyze, that IPC's revenues from serving
NEM customers' loads (i.e. revenues from NEM customers' imported power) may
actually cover more of IPC's cost of service than do regular residential customers.T Ms.
Kobor's direct testimony for Vote Solar shows that this is indeed the case. IPC's cost of
service, as analyzed by Ms. Kobor, shows that aNEM customer contributes $145 to $175
per customer per year more toward their cost of service than a standard residential
customer. NEM customers more than cover their cost of service (by $a9 to $79 per year),
while non-NEM customers fail to cover their cost of service (by $96 per year).8 This
more than offsets the $ 1 00 per customer per year cost shift that the Staff s analysis
calculates.
As a result, the staff s analysis should be considered to be illustrative rather than
definitive, and I appreciate and support the Staff s recognition that "the exact
Staff Direct Testimony (Morrison), atp.9.
Ibid., at p. ll.
See Oregon Public Utilities Commission Orders No. l7-085 and 17-357.
Ibid., atp. 12.
See Vote Solar Direct Testimony (Kobor), at Table 3 and 4, pp.7l-72.
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methodology for calculating net metering avoided cost rates should be determined in a
separate docket."e
Q:Do you have concerns with the StafPs proposal to determine a NEM customer's
imports and exports of electricity on an hourly basis?
Yes, I do. The Staff is recommending the following:
Staffproposes that Section 1 ofschedule 84 be changed to take advantage ofthe
Company's AMI meters by netting consumption/generation hourly rather than
monthly. Under Staff s proposal, the net metering customer's billed consumption
would be determined by summing the consumption from each hour in which there
is net consumption, and the result applied to applicable Schedule 1 or Schedule 7
rates. The net metering customer's excess energy credit would be determined by
summing the production from each hour in which there is net production and
applying the result to an avoided cost rate. The net metering customer's bill would
then be calculated by subtracting the excess energy credit from the customer's
billed consumption.lo
There are significant practical and fairness issues related to moving to the Staff s
proposed "hourly netting" of imported and exported power, from the current system of
monthly netting. Although Idaho Power's current meters are able to record hourly usage
(in either direction), hourly data are not currently recorded or provided to customers; the
meters are prograrnmed to record only monthly net usage.ll The utility admits that it
would have to re-program its meters and revise its billing system in order to make such
data available.r2 As a result, today customers do not have the hourly data that they (or
their solar installer) would need to be able to evaluate the economics of an investment in
a NEM system under the Staff s hourly netting proposal. It would erect a significant and
unfair barrier to new NEM installations for customers to be required to use hourly netting
without having access to the hourly data on their usage that is necessary to evaluate the
economics of NEM under hourly netting.
' Stuff Direct Testimony (Morrison), at p. I I .ro lbid., at p. 8.rr The only exception to this appears to be residential customers who elect service under IPC's
optional time-of-use (TOU) rate. However, only a fraction of one percent of IPC customers have elected
the TOU rate. See IPC Response to Sierra Club Data Request No. 4, attached as Exhibit 601.tz lbid.
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Ultimately, I would expect and encourage Idaho Power to make hourly data available to
all of its residential and small commercial customers, as part of an efTort to encourage the
more efficient use of energy through the expansion of TOU pricing. Many utilities in the
West and in the U.S. recognize that significant capacity and energy savings can be
achieved through time-dependent rates that are more accurate and more cost-based.l3
The ability to offer time-sensitive rates to all customers is an important reason and
justification for an advanced metering infrastructure (AMI). As part of promoting the use
of time-sensitive rates, utilities with AMI often allow customers to view their hourly
usage on the utility's website and implement a "Green Button" feature that allows
customers to download historical hourly usage data in a format that customers and DER
providers can readily rse.'o
My recommendation is that the use of hourly netting for NEM customers should not be
implemented until Idaho Power's residential customers have had online or Green Button
access to their hourly data for at least one year. This will assure that residential
customers have access to adequate hourly data on their usage to assess the economics of
NEM under hourly netting. Until then, net metering should continue to use monthly
netting, as is in place now, even if the Commission decides in a subsequent proceeding to
change the structure of NEM to provide for distinct import and export rates, as Staff
proposes.
Q:Have other states that have moved to separate pricing of NEM imports and exports
also retained monthly netting?
Yes. As discussed in my opening testimony, both Nevada and New Hampshire have
adopted revised NEM programs that include modest differences between import and
export rates, but have retained monthly netting of imports and exports. New Hampshire,
r3 For example, more than 5Oo/o of the residential customers of Arizona Public Service are on TOU rates,
as a result of that utility's efforts over many years to promote their use. The California investor-owned
utilities are planning in 2019 to move to TOU rates as the "default" rate option for residential customers.t4 The Green Button initiative is an industry-led effort under the auspices of the Department of Energy
designed to provide utility customers with easy and secure access to their energy usage information in a
consumer-friendly and computer-friendly format. To date, a total over 50 utilities and electricity
suppliers have signed on to the initiative, not yet including ldaho Power. See
https ://enerel". eov/data/green-button.
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like Idaho, does not yet have an adequate metering and billing data infrastructure for all
utilities that would allow small customers to access their hourly usage data.r5 Nevada
retained monthly netting in its recent order re-implementing NEM in that state.l6 Aizona
and California are examples of states that have both (1) implemented different import and
export rates and (2) moved to the use of hourly or sub-hourly netting. The utilities in
these states have AMI with full functionality and well-developed programs to encourage
the use of time-dependent rates, including making hourly usage data available to
residential and small commercial customers. They also have far higher penetrations of
solar DG than Idaho.
A
The Staff has proposed that the Commission should initiate a docket in which all
interested parties can work together to determine the appropriate avoided cost
methodolory used to compensate net metering customers for their exports. Do you
support such a cooperative effort?
Yes. As part of such a cooperative effort, I recommend that the Commission retain a
third-party consultant who would either (1) perform a benefit-cost study of net metering
in IPC's service territory, with all parties able to provide input into the study and with an
opportunity to critique the study after it is completed, or (2) would develop a benefit-cost
methodology, producing a straightforward model that any party can use to present their
recommended benefits and costs of net metering. The first approach is the one that was
used by the Nevada commission, as discussed in my direct testimony. The Oregon
commission has used the second approach recently to develop a model for the Resource
Value of Solar that parties are now using in that state.lT
15 In the New Hampshire PUC's Order No. 26,029 (June 23, 2017), at pages 52-53, rejecting a move
from monthly to instantaneous netting, the New Hampshire PUC stated "We are persuaded by the record
evidence that a near-term transition from monthly netting to instantaneous netting is likely to result in
significant customer confusion, project marketing and development complications, and potentially
inefficient customer price signals. For example, instantaneous netting may be confusing to customers who
lack real-time data about their electricity usage."16 See PUCN, Order Granting in Part and Denying in Part Joint Application by NV Energ,, on Assembly
Bill 405 in PUCN DocketNo. l7-07026, atpp. 17-19.
'' See Oregon Public Utilities Commission Docket UM I1716, especially Orders No. l7-085 and 17-
357.
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Does this conclude your rebuttal testimony?
Yes, it does.
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SIERRA CLUB EXHIBIT 601
Beach )Tom
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REQUEST FOR PRODUCTION NO. 4: Please provide the following information
concerning the implementation of time-differentiated rates on the ldaho Power system:
a. Please describe the time-of-use (TOU) or time-differentiated rates that the
Company offers to its residential and small commercial customers. Please provide the
number of residentialand small commercial customers on TOU rates today, in absolute
numbers and as a percentage of the total number of customers in these classes.
b. Does ldaho Power have a customer information and billing system
capable of implementing time-differentiated rates for all of its customers? lf it does not,
please describe the billing and customer service constraints ldaho Power faces in
moving to timedifferentiated rates for all of its customers.
c. Does ldaho Power have an advanced metering infrastructure (AMl)
capable of implernenting time-differentiated rates for all of its customers? lf it does not,
please describe the metering constraints ldaho Power faces in moving to time-
differentiated rates for all of its customers.
d. Does ldaho Power have a customer information and billing system
capable of applying time-differentiated rates for net metering service? Please describe
in further detail the complexity of the calculations to implement time differentiated rates
for net metering customers.
e. Does ldaho Power have 2-channel meters capable of recording separately
(1) the power that ldaho Power supplies to a customer with on-site generation and (2)
the power that such a customer exports to ldaho Power? lf not, why not?
f. Does ldaho Power plan in the future to move to the use of 2-channel
meters for customers with on-site generation? lf not, why not?
]DAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF IDAHO SIERRA CLUB TO IDAHO POWER COMPANY - 7
Sierra Club -IPC-E- l7- 13 l0
RESPONSE TO REQUEST FOR PRODUCTION NO. 4:
a. ldaho Power's Time-of-Day ("TOD") program is offered on an optional,
voluntary basis to residential customers only. The only requirement is that an AMI
meter exists at the customer's residence.
The TOD program includes seasonal pricing with Peak and Off-Peak rates. The
summer season begins on June 1 of each year and ends on August 31 of each year.
The current rates approved for Schedule 5, Residential Service Time-of-Day Pilot
(Optional), are listed below:
Service Charge, per month $5.00
Energy Charge, per kilowatt-hour ('kwh')
SummerPeak 12.9481i,Off-Peak 7.42260,
Non-SumrnerPeak 9.55810Off-Peak 7.4226i,
During the surnmer season, June 1 through August 31, Peak hours are 1:00 p.m.
to 9:00 p.m. on weekdays and all other hours are Off-Peak. During the non-summer
season, September l through May 31, Peak hours are 7:00a.m. to 9:00p.m. on
weekdays, and all other hours are Off-Peak. Holidays, as defined in the tariff, are Off-
Peak.
Of the 439,333 residential customers that ldaho Power serves, there are
currently 1,206 residential customers enrolled in the TOD program. This represents
O.27 percent of residential customers.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF IDAHO SIERRA CLUB TO IDAHO POWER COMPANY - 8
Beach, Tom - DI-REB
Sierra Club -lPC-E-17-13 l1
b. No. ldaho Power's Customer Relationship and Billing ("CR&B") system is
not cunently capable of billing time-differentiated rates for all of ldaho Power's
customers as it is configured today. The current limitations to offering time-
differentiated rates to all customers are due to differences between the way the
metering and CR&B systems are designed and configured. These differences affect the
existing integrations between the two systems and the way metering data is passed to
CR&B including data aggregation, dateltime stamp issues, and timing of meter reads.
ln addition, new validation and estimation processes would need to be identified and
implemented if the Company were to deploy TOD billing on a large scale today, based
upon existing integrations between the billing and metering systems. Further analysis is
needed to determine the metering and CR&B system modifications needed to
accommodate time-variant pricing on a large-scale, all-customer basis.
c. ldaho Power has deployed the Aclara Two-Way Automated
Communications System ("TWACS') for gg percent of its retail customers. The
metering infrastructure in place is capable of providing data necessary for the
implementation of time{ifferentiated rates for those customers, ln order to implement
time-differentiated rates for customers not served by TWACS, ldaho Power would need
to install meters that are capable of recording hourly load profiles that would be read
manually.
d. No. ldaho Power's CR&B system is not capable of billing time-
differentiated rates for customers taking net metering service as it is currently
configured. Modifications to both the metering system and to CR&B would be needed
to accommodate time-variant pricing for customers with on-site generation.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REOUEST OF IDAHO SIERRA CLUB TO IDAHO POWER COMPANY.9
Sierra Club -lPC-E-17-13 12
e. Yes; however, the meters currently installed on residential and small
commercial customer accounts with on-site generation (referred to as "net meters") do
not have that capability. The net meters provide one kWh register read and one hourly
energy channel read, and the meters are configured to record net monthly kWh and net
hourly kwh.
f . Not at this time; however, ldaho Power would explore the implementation
of 2-channel meters if a change in the billing structure required it.
The response to this Request is sponsored by Connie Aschenbrenner, Rate
Design Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF IDAHO SIERRA CLUB TO IDAHO POWER COMPANY.lO
CERTIFICATE OF SERVICE
I hereby certify that on this 26th day of January, 2018, true and correct copies of the above THE DIRECT
TESTIMONY OF R. THOMAS BEACH were sent to the following persons via the methods noted:
Hand delivered and emailed:
Diane Hanian
Commission Secretary
Idaho Public Utilities Commission
472W. Washington St.
Boise, lD 83702
diane.holt @puc.idaho. gov
(original plus nine copies)
Emailed:
Idaho Power Company
Lisa D. Nordstrom
Timothy E. Tatum
Connie Aschenbrenner
l22lW.Idaho St.
PO Box 70
Boise, Idaho 83707
Inordstrom @ idahopower.com
dockets @ idahopower.com
ttatum @ idahooower.com
cashenbren ner @ idahopower.com
Commission Staff
Sean Costello
Deputy Attorney General
Idaho Public Utilities Commission
472W. Washington
Boise,Idaho 83702
sean.costello @ nuc.idaho.pov
Idahydro
C. Tom Arkoosh
Arkoosh Law Offices
802 W. Bannock Street, Suite 900
PO Box 2900
Boise,ID 83701
tom.arkoosh @ arkoosh.com
eri n.ceci I @ arkoosh.com
Idaho Irrigation Pumpers Association, Inc.
Eric L. Olsen
ECHO HAWK & OLSEN, PLLC
505 Pershing Ave., Ste. 100
PO Box 6l l9
Pocatello, Idaho 83205
[e-mail]
Anthony Yankel
12700 Lake Ave. Unit 2505
Lakewood, OH44107
Email : tony @yankel.net
Idaho Conservation League
Matthew A. Nykiel
PO Box 2309
102 S. Euclid f207
Sandpoint, ID 83864
mnykiel @ idahoconservation.org
Ben Otto
Tl0N6thStreet
Boise,ID 83701
Ph: [phone] x 12
Fax: [phone]
botto @ idahoconservation.org
Sierra Club - IPC-E-17-13
Beach, Tom - DI-REB
Certificate of Service - I
Auric Solar, LLC
Elias Bishop
2310 S. 1300 W.
West Valley Ciry, UT 84119
Telephone: (801 ) 878-3363
elias.bishoo @auricsolar.com
Preston N. Carter
Deborah E. Nelson
Givens Pursley LLP
601 W. Bannock St. Boise, ID 83702
prestoncarter @ gi venspursley.com
den @ sivensourslev.com
City of Boise
Abigail R. Germaine
Deputy City Attorney
Boise City Attorney's Office
105 N. Capitol Blvd.
P0 Box 500
Boise,ID 83701-0500
agermai ne @ c i tyofboi se.org
Idaho Clean Energy Association
Preston N. Carter
Deborah E. Nelson
Givens Pursley LLP
601 W. Bannock St. Boise, ID 83702
Drestoncarter@ si vensourslev.com
den @ gi venspursley.com
Vote Solar
David Bender
Earthjustice
3916 Nakoma Road Madison, WI537l I
dbender@ earthjustice.org
Briana Kober
Vote Solar
36022nd Street., Suite 730
Oakland, CA946l2
briana@ votesolar.org
Snake River Alliance and Northwest Energy
Coalition
John R. Hammond, Jr.
Fisher Pusch LLP
101 5. Capitol Blvd., Suite 701
P0 Box 1308
Boise,ID 83701
irh @fisherousch.com
Electronic service only:
Snake River Alliance
wwi lson @ snakeriveral I iance.org
NW Energy Coalition
dieso @ nwenersv.ors
Intermountain Wind and Solar, LLC
Ryan B. Frazier
Brian W. Burnett
Kirton McConkie
50 East Temple, Suite 400
P0 Box 45120
Salt Lake City, UT 841I I
[e-mail]
[e-mail]
Intermountain Wind and Solar, LLC
1952 West 2425 South
Woods Cross, UT 84087
doug @ imwindandsolar.com
dale @ imwindandsolar.com
tr[\tu Nun*a
Kelsey Jae Nunez
Attorney for Sierra Club
Sierra Club - IPC-E-17-13
Beach, Tom - DI-REB
Certificate of Service - 2