20180810Brief on Reconsideration.pdf

Benjamin J. Otto (ISB No. 8292)
710 N 6th Street
Boise,ID 83701
Ph: [phone] x12
Fax: [phone]
botto@i dahoconservation. org
Attorney for the Idaho Conservation League
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
..iICEIVED
iili0 f,ilil l0 pFi 3: l0
: :':r r^i. i rL;l-J(:
IN THE MATTER OF IDAHO )
POWER COMPANY'S AUTHORITY )
TO ESTABLISH NEW SCHEDULES )
FOR RESIDENTIAL AND SMALL )
GENERAL SERVICE CUSTOMERS )
WITH ON-SITE GENERATION. )
CASE NO.IPC.E.I7-13
IDAHO CONSERVATION LEAGUE
SIERRA CLUB, IDAHO CHAPTER
IDAHO CLEAN ENERGY
ASSOCIATION
NORTHWEST ENERGY
COALITION
RECONSIDERATION BRIEF
The Idaho Conservation League (ICL), the Idaho Chapter of the Sierra Club, the
Idaho Clean Energy Association, and the Northwest Energy Coalition submit the
following brief in response to Order No. 34098. Responding to Vote Solar's Petition for
Reconsideration, the Commission ordered parties to provide:
"[B]riefing related to whether a customer's ability to export energy should
determine if the customer should be included in new Schedules 6 and 8." Order
No. 34098 at 2.
Customer's Ability to Export is the Distinguishing Characteristic
The Commission, in Order 34046, found, "it is time to distinguish a class of
customers that uses the grid for standard energy import and use, from a class of
customers that uses the grid to both import and export energy." Order No. 34046 at 16.
After considering the arguments of the parties, the Commission drew a clear line between
customers who actually export energy to the grid and those that do not. Therefore, we
submit that the ability to export is the distinguishing characteristic to determine a
customer's eligibility for Schedules 6 or 8.
IPC-E-17-13
ICL Reconsideration Brief
I
However, the term "export" is vague in this context. The primary issue is the
appropriate time period to measure whether a customer is exporting or consuming
energy. In this docket, Idaho Power explains they measure customer-owned generation
and consumption hourly. However, the Company currently uses a 15-minute time period
to measure customer demand, and hve-minute intervals at a system level. Anyone can
watch the power meter at home spin instantly.
Because of the uncertainty regarding Idaho Power's metering capabilities, instead
of a specific time period we recommend the Commission adopt a policy that the relevant
period to measure exports is the smallest time interval over which a customer is billed.
This policy aligns with billing practices, places the responsibility for metering on the
entity that has the ability and authority to operate the meters, and incents the utility to
continually improve metering ability.
Use Export Limiting Devices to Determine Eligibility for Rate Schedule
In Order No. 34098, the Commission also asked for "information about export
limiting devices, effects of battery storage, additional information on the meaning and
repercussions of "in parallel" connection, and the masking of usage created by hourly
analysis of customer and Company energy exchanges." Order No. 34098 at 2-3.
We support a policy that uses objective technical specifications regarding the
possibility of energy exports to determine a customer's appropriate rate schedule. Hawaii
has adopted a net metering policy that allows customers to elect a non-export option. The
Hawaii Electric Company Rule 22, Appendix II provides five options for technical
specifications that determine if a customer will not export energy. We recommend
adopting these options that reflect current capabilities and industry standards for
customer-owned generation equipment. The full Appendix II is attached to this brief as
Exhibit 405.
The standards developed by the Hawaii Electric Company are a good model for
this Commission. The utility and stakeholders developed these standards recently so they
reflect current industry capabilities and practices. Because the specifications are based on
system design or technological functions, individuals are extremely unlikely, if not
unable, to evade export limits. And even if a customer did, Idaho Power's metering
IPC-E-17-13
ICL Reconsideration Brief
2
system would alert the company instantly. Finally, because these are objective standards
adopted in a prominent market, compliant equipment is readily available from customer-
owned generation equipment suppliers.
Battery storage:
The distinguishing characteristic the Commission identified is the ability of a
customer to export energy to the grid. Therefore, whether a customer has a battery is not
the issue in this docket; rather the issue is whether that battery is used solely for self-
consumption or exporting to the gird. Hawaii's Rule 22, Appendix II applies to customer
owned batteries as well as customer owned generation to address potential exports. Any
cost or rate issue related to battery storage will be addressed in the next phase of this
docket.
Masking of usage created by hourly analysis:
We submit that customers cannot "mask usage"; rather the utility elects to use a
certain level of granularity in the metering system for recording customer consumption. If
the utility chooses to use an hourly time interval, then customer variation within the hour
is not "masking", it is the normal variation the utility accepts as part of doing business. If
the utility elects to use a more granular time, like 15 minutes, then the customer is not
"masking" usage any more or less; the utility is just measuring consumption better.
Because the utility owns and controls the metering system, we recommend the
Commission acknowledge that customer variation within the time period measured for
billing is a normal part of utility business. This recommendation works in concert with
our recommendation to draw a bright line between customers who elect to limit exports
and those who do not and adopting technical specifications to govern this election.
Recommendation:
The Commission in Order No 34046 and 30498 made clear the distinguishing
characteristic for new Schedules 6 and 8 is the customer's ability to export energy to the
system. We recommend the Commission establish an objective standard to determine if a
customer may export based on industry capabilities and best practices.
IPC-E-17-13
ICL Reconsideration Brief
J
1. Establish the time period for measuring exports is the smallest time interval
over which a customer is billed. This aligns responsibility with the utility who
controls the metering equipment and incents the utility to improve metering
functions.
2. Require Idaho Power to define the eligibility for Schedules 6 and 8 to exclude a
customer who elects to be a non-exporting customer. We recommend adopting the
technical specifications in Hawaii Electric Company Rule 22 Appendix II to
define a non-exporting customer.
We believe the recommendations above are simple, objective standards the
Commission should adopt to clarify the distinction between exporting and non-exporting
customers announced in Order No 34046. We look forward to the next phase of this
docket - a collaborative study of the costs and benefits of customer owned distributed
generation.
Respectfully submitted this 10th day of August 2018,
4 I,u1 bd N/11*b
Benjamin J Otto
Idaho Conservation League
Kelsey Jae Nunez, ISB 7899
Attorney for Sierra Club
Leif Elgethun
Board President, Idaho Clean Energy
Association
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Diego Rivas
NW Energy Coalition
rPC-E-17-13
ICL Reconsideration Brief
4
Benjamin J. Otto (ISB No. 8292)
710 N 6th Street
Boise,ID 83701
Ph: [phone] x t2
Fax: [phone]
[e-mail]
Attomey for the Idaho Conservation League
IN THE MATTER OF IDAHO )
POWER COMPANY'S AUTHORITY )
TO ESTABLISH NEW SCHEDULES )
FOR RESIDENTIAL AND SMALL )
GENERAL SERVICE CUSTOMERS )
wrTH oN-srTE GENERATTON. )
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO.IPC.E.I7-I3
IDAHO CONSERVATION LEAGUE
SIERRA CLUB, IDAHO CHAPTER
IDAHO CLEAN ENERGY
ASSOCIATION
NORTHWEST ENERGY
COALITION
RECONSIDERATION BRIEF
Exhibit 405
Hawaii Electric Company Rule 22, Appendix II
Superseding Sheet No. 448-1 REVISED SHEET NO.44B-l
Effective May 3,2017 Effective February 5,2018
APPENDIX II
TECHNICAL SPECIFICATIONS FOR CUSTOMER SELF-SUPPLY SYSTEMS
The following technical specifications are intended to provide guidelines to facilitate the interconnection and
parallel operation of Self-Supply Systems with the utility's Distribution System. These technical specifications have
been established to maintain safety, reliability, and power quality standards for all utility customers andpersonnel.
Unless otherwise defined herein, capitalized terms shall have the definitions set forth in Rule 14, Paragraph H
("Rule l4H').
Technical Specifications -
Maximum System Size. The Generating Facility shall have a capacity of not more than one hundred
kilowatts (100 kW).
Host Load Only. The Generating Facility shall be sized and designed such that all of the Generating
Facility's output is consumed by the Eligible Customer-Generator's load ("Host Load").
Non-Export Requirements. The Generating Facility shall be designed to minimize the transfer of
electrical energy from the Generating Facility to the utility. The Generating Facility shall not export
electrical energy across the Point oflnterconnection, except to provide Grid Support as described in Option
5, including during emergency conditions where Advanced Inverter functions, including functions that
result in energy export, shall be provided pursuant to Rule l4H and this Agreement. In any situation in
which Rule 22 conflicts with Rule l4H regarding energy export, Rule l4H controls. In order to qualifu as a
Self-Supply System under the Company's Customer Self-Supply tariff, the Generating Facility must utilize
one or more of the following options:
. Option I ("Reverse Power Protection"): To ensure power is never exported across the Point of
Interconnection, a reverse power relay may be provided. The default setting for this protective
function shall be 0.1% (export) of the service transformer's rating, with a maximum 2.0 second
time delay.
. Option 2 ("Minimum Power Protection"): To ensure at least a minimum amount of power is
imported across the Point of Interconnection at all times (and, therefore, that power is not
exported, other than for the short time periods noted), an under-power protective function may be
provided. The default setting for this Minimum Power Protection shall be 5% (import) of
Generating Facility's total gross rating, with a maximum 2.0 second time delay.
. Option 3 (Certified Non-Islanding Protection): To ensure the incidental export ofpower is limited
to acceptable levels, this option requires that all of the following conditions be met: a) the total
gross capacity of the Generating Facility must be no more than25Yo of the nominal ampere rating
of the Customer-Generator's dedicated service equipment; b) the total gross capacity of the
Generating Facility must be no more than 50oh of the Customer-Generator's dedicated service
transformer capacity rating (this capacity requirement does not apply to Eligible Customer-
Generator taking primary service without an intervening transformer); and c) the Generating
Facility must be Certified as Non-Islanding.
The ampere rating of the Eligible Customer-Generator's service equipment to be used in this
evaluation will be that rating for which the Eligible Customer-Generator's utility service was
originally sized or for which an upgrade has been approved. It is not the intent of this provision to
allow increased export simply by increasing the size of the Eligible Customer-Generator's service
panel, without separate approval for the resize.
. Option 4 (Relative Generating Facility Rating): This option, when used, requires the net rating of
the Generating Facility to be small enough in comparison to its host facility's minimum load such
that the use of additional protective functions is not required to ensure that power will notbe
exported to the Company's Distribution System. This option requires the Generating Facility
capacity to be no greater than 50oh of the Eligible Customer-Generator's verifiable minimum Host
Load over the past 12 months. This option only applies to Eligible Customer-Generators with
load profile metering with at least l2 months of historical data.
HAWAIIAN ELECTRIC COMPANY, INC.
Order No. 35266 Dated February 5, 2018, Docket No. 2014-0192
Superseding Sheet No. 44B-2
Effective May 3,2017
REVISED SHEET NO. 448-1
Effective February 5, 2018
a Option 5 (Advanced Inverter Functionality): To prevent the
unpermitted reverse power flow, or Net Export, from the Customer's
Generating Facility across the Point of Interconnection, the use of an
internal transfer relay, Energy Management System, or other
Company approvedCustomer Facility hardware or software
system(s) is required. This option must meet the following
requirements identified below:
l) Inadvertent Export: Inadvertent Export is the unpermitted, unscheduled,
and
uncompensated export or real power generated from a
Customer's Generating Facility and delivered to the
Company. The magnitude of Inadvertent Export shall be less
than
the Generating Facility's Nameplate Rating and the duration
shall be less than 30 seconds for any single event. There are
no limits to the number events.
2) Nameplate Rating: For the purpose of calculating Inadvertent
Export, Nameplate Rating is defined as the lesser of (i) the
Total Inverter Capacity (kW) or (ii) the sum of the Total
Module Capacity and the Total Energy Storage System
Capacity (kW) (i.e. theaggregate of the DC-power
components), as those amounts are stated in Exhibit A
(Description of Generating Facility) of the Customer's
Standard Interconnection Agreement for Self- Supply
Systems, and as depicted on the single-line diagram and
three-line diagram.
3) Net Export Limit: Net Export is the cumulative amount of
Inadvertent Export energy produced by the Customer's
Generating Facility and delivered to the Company. Net
Export shall be less than the limit of the Customer's
Generating Facility's Nameplate Rating multiplied by one
(l) hour per customer billing cycle. The Company will
install an ANSI certified meter or similar device to register
the Net Export produced by the Customer's Generating
Facility per billing cycle.
4) Grid Support: Grid Support is the import and export of real
and/or reactive power in a controlled and specified manner in
order to maintain safety, reliability, and/or power quality.
When permitted by the Company and agreed to by the
Customer, the Generating Facility may provide Grid Support.
Cumulative Grid Support export energy shall be deducted
from the Customer's Net Export Limit per billing cycle, so
as to notcount
towards a Generating Facility's Net Export Limit.
5) Cease to Energize: Any amount of export of real power across
the Point oflnterconnection lasting longer than 30 seconds
for any single event shall result in a tripof the Customer's
Generating Facility within two (2) seconds of exceeding the
30 second duration limit, except to provide Grid Support
when permitted by the Company, including during emergency
conditions where Advanced Inverter functions, including
functions that result in energy export, shall be provided
HAWAIIAN ELECTRIC COMPANY, INC
Order No. 35266 Dated February 5,2018, Docket No. 2014-0192
Superseding Sheet No. 44B-3
Effective May 3,2017
REVISED SHEET NO.44B-I
Effective February 5, 2018
a
pursuant to Rule l4H and this Agreement. In any situation in
which Rule 22 conflicts with Rule 14H regarding energy
export, Rule l4H controls. The event reconnection time limit
will be a minimum offive
(5) minutes, unless otherwise directed by the Company,
pursuant to Rule 14, Paragraph H, Appendix I, Required
Delay on Reconnection.
6) Control System Failure: Where applicable, any failure of the
Customer's Generating Facility control system for thirty
(30) seconds or more, which includes but is not limited to;
the internal transfer relay, Energy Management System, or
other Company approved Customer Facility hardware or
software system(s) intended to prevent the reversepower
flow, shall cause the Customer's Generating Facility to enter
a safe operating mode whereby the production of energy
from the Generating Facility is autonomously limited to an
amount that shall not cause Inadvertent Export to occur until
such time that the Customer has reestablished real power
output control of the Generating Facility.
Advanced Inverter Requirements to Provide Grid Support. The Generating
Facility shall comply with the Advanced Inverter requirements set forth in Rule
14, Paragraph H, Appendix I (Advanced Inverter Generating Facility Design
And Operating Requirements). In any situation in which Rule 22 conflicts
with Rule l4H regarding energy export, Rule l4H controls.
I{AWAIIAN ELECTRIC COMPANY, INC.
Order No. 35266 DatedFebruary 5, 201 8, Docket No. 2014-0192
CERTIFICATE OF SERVICE
I hereby certify that on this 1Oth day of August 2018, I delivered true and correct
copies of the foregoing RECONSIDERATION BRIEF to the following persons via the
method of service noted:
Diane Hanian
Commission Secretary (Original and seven copies provided)
Idaho Public Utilities Commission
427 W. Washington St.
Boise,ID 83702-5983
Electronic Mail
Idaho Power
Lisa D. Nordstrom
Tim Tatum
Connie Aschenbrenner
Idaho Power Company
P.O. Box 70
Boise,Idaho 83707
lnordstrom@idahopower. com
ttatum@idahopower. com
caschenbrenner@idahopower. com
dockets@idahopower. com
Idaho PUC Staff
Sean Costello
Deputy Attorneys General
Idaho Public Utilities Commission
472W. Washington
Boise ID 83702
sean. costello@puc. idaho. gov
Idahohydro
C Tom Arkoosh
Arkoosh Law Offices
802 W Bannock St., Suite 900
PO Box 2900
Boise, ID 83701
tom. arkoosh@arkoosh. com
erin. [e-mail]
Idaho lrrigation Pumpers Association
Eric L. Olsen
Echo Hawk & Olsen PLLC
505 Pershing Ave., Suite 100
PO Box. 6119
Pocatello,ID 83205
[e-mail]
Anthony Yankel
29814 Lake Road
Bay Village, Ohio 44140
Fax: [phone]
[e-mail]
Auric LLC
Elias Bishop
Auric Solar, LLC
2310 s 1300 w.
West Valley City, UT 841l9
elias.bishop@auricsolar. com
Preston N. Carter
Deborah E. Nelson
Givens Pursley LLC
601 WBannockSt.
Boise, ID 83702
prestoncarter@givenspursley. com
den@givenspursley. com
Sierra Club
Kelsey Jae Nunez, LLC
Sierra Club
Hand delivery:
920 N. Clover Drive
Boise,ID 83703
kelsey@kelseyj aenunez. com
Zack Waterman
Idaho Siena Club
503 W. Franklin St.
Boise, ID 83702
zack.waterman@sierrac lub. org
michael.p. heckler@gmail. com
City of Boise
Abigail R. Germaine
Deputy City Attorney
Boise City Attorney's Office
105 N. Capitol Blvd.
PO Box 500
Boise,ID 83701
agermaine @c ity o fbo i se. o rg
Idaho Clean Energ,, Association
C Tom Arkoosh
Arkoosh Law Offices
802 W Bannock St., Suite 900
PO Box 2900
Boise,ID 83701
tom. [e-mail]
[e-mail]
David H. Arkoosh
Law Office of David Arkoosh
PO Box 2817
Boise,ID 83701
[e-mail]
Vote Solar
David Bender
Earthjustice
3916 Nakoma Road
Madison, WI 53711
dbender@earthj ustice. com
Briana Kober
Vote Solar
360 22nd Street, Suite 730
Oakland, CA94612
[e-mail]
J. Kahle Becker
223N.6th St., Suite 325
Boise, lD 83702
[e-mail]
Snake River Alliance and NW Energt
Coalition
John R. Hammond, Jr.
Fischer Pusch, LLP
101 S. Capitol Blvd., Suite 701
PO Box 1308
Boise,ID 83701
[e-mail]
Wendy Wilson
Executive Director, Snake River
Alliance
wwilson@snakeriveralliance. org
Diego Rivas
Policy Associate, NW Energy Coalition
[e-mail]
Intermountain Wind and Solsr, LLC
Ryan B. Frazier
Brian W. Burnett
Kirton McConkie
50 East Temple, Suite 400
PO Box 45120
Salt Lake city, uT 841I
[e-mail]
[e-mail]
Intermountain Wind and Solar, LLC'
1952 West 2425 South
Woods Cross, UT 84087
[e-mail]
[e-mail]
Benjamin J. Otto