20171103Joinder and Motion to Dismiss.pdf

John R. Hammond, Jr.- ISB No. 5470
FrsuBn PuscH LLp
U.S. BANK PLAZA- 7th Floor
101 S. Capitol Blvd., Suite 701
P.O. Box 1308
Boise,ID 83701
Telephone: [phone]
Facsimile: 208.331.2400E-mail: [e-mail]
Attorneys for the Snake River Alliance and NW Energt Coalition
IN THE MATTER OF THE
APPLICATION OF IDAHO POWER
COMPANY FOR AUTHORITY TO
ESTABLISH NEW SCHEDULES FOR
RESIDENTIAL AND SMALL
GENERAL SERVICE CUSTOMERS
WITH ON.SITE GENERATION
Case No. IPC-E-I7-13
REC E IV ED
?0l1NOY -3 Pil 3: 2l
ni'Jr?itloJo,{ffil8t'o*
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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SNAKE RIVER ALLIANCE'S AND NW
ENERGY COALITION'S JOINDER
AND MEMORANDUM IN SUPPORT OF
IDAHO CLEAN ENERGY
ASSOCIATION'S MOTION TO
DISMISS
COMES NOW the Intervenors Snake River Alliance and the NW Energy Coalition
(collectively the "Intervenors" for purposes of this pleading) and file this Joinder and
Memorandum in Support of the Idaho Clean Energy Association's ("ICEA") Motion to Dismiss
and Memorandum in Support of Motion to Dismiss pursuant to the Idaho Public Utilities
Commission Rule of Procedure, IDAPA 31.01.01 .256.04.
The Intervenors also file this pleading to discuss their interests in this case that include,
but are not limited to: l) developing of renewable energy resources, including those from net-
metering customers of regulated utilities; 2) developing incentives to assist regulated utilities and
their customers to integrate renewable energy resources into the electric system; 3) protecting
consumers' interests and demand for renewable energy resources and the businesses and jobs
that have grown from such interests and demand in Idaho; 4) participating in public processes to
determine the costs and benefits of renewable energy resources; 5) working to reduce the chilling
SNAKE RIVER ALLIANCE'S AND NW ENERGY COALITION'S JOINDER AND MEMORANDUM IN
SUPPORT OF IDAHO CLEAN ENERGY ASSOCIATION'S MOTION TO DISMISS - I
impacts that cases like these have on the Intervenors, their members and businesses in the
community that they work with; and 6) ensuring equitable rate design that assigns customer
prices based on real and known costs to the utility.
As is discussed in more detail below, the Intervenors assert, consistent with ICEA's
Motion to Dismiss, that Idaho Power Company's ("Idaho Power" or the "Company")
Application in this case should be dismissed primarily for failing to seek the relief requested in
the proper proceeding, a general rate case, as previously ordered by the Commission in Case No.
IPC-E-12-27, Order No. 32846.
In the alternative to dismissal, the Intervenors respectfully request that the Commission
establish a proceeding in which the Company, the intervening parties in this case, Idaho Power's
customers and any other interested parties may participate to determine the value of net metering
generation, including solar generation on Idaho Power's system.
BACKGROUND
The parties in this case have previously set forth the history of net metering cases before
the Commission. Included within that history, the Commission had established a total nameplate
generation capacity limit of 2.9 MW for net metering customers of Idaho Power in2002. See
Order No. 28951 atp. 12, Case No. IPC-E-01-39. Subsequently, the Commission in Order No.
29094, in Case No. IPC-E-02-04, directed Idaho Power to make a filing with it when the
cumulative nameplate of for net metering customers of 2.9 MW was reached. Order No. 29094
atp.7. In2012,Idaho Power filed an Application in Case No. IPC-E-12-27 wherein it
represented:
In Order No. 29094 issued in Case No. IPC-E-02-04, the Commission directed the
Company to make a filing before the Commission when the cumulative nameplate
generation capacity limit set forth in Order No. 28951 was reached. . . . The
Company is making this filing in accordance with the Commission's directive
SNAKE RIVER ALLIANCE'S AND NW ENERGY COALITION'S JOINDER AND MEMORANDUM IN
SUPPORT OF IDAHO CLEAN ENERGY ASSOCIATION'S MOTION TO DISMISS.2
issued in that case. While the Commission's directive states that the Company is
to provide notification when the cap is reached, the Company believes the timing
of this request is appropriate in order to prevent the refusal of new applications for
net metering service.
Application at pp. 3-4,n 5, Case No. IPC-E-12-21 (emphasis added).
As set forth in ICEA's Memorandum in Support of Motion to Dismiss in Case No. IPC-
E-12-27,ldaho Power sought to modify its net metering service, including a request to create
new rate schedules and rates for its net metering customers. See Commission Order No. 32846
atpp. l-3.
After receiving public testimony and holding a technical hearing in Case No. IPC-E-I2-
27,the Commission entered OrderNo. 32846 which contained the following directive:
IT IS HEREBY ORDERED that the Company's request to double the capacity
cap is denied. Rather. the Company shall file an annual status report with the
Commission discussing the net metering service. The report shall discuss,
without limitation, the net metering service provisions and pricing and how
distributed generation may be impacting system reliability. The Company also
shall promptly file an earlier report if at any time it expects its net metering
service will materially and negatively impact its system. The existing 2.9 MW
capacity cap is removed.
See OrderNo. 32846 at p. 19 (emphasis added). Complying with this requirement, Idaho
Power has filed annual net metering reports in Case No. IPC-E-12-27.
As noted by several intervening parties in this case, in Order No. 32846 the Commission
found that dramatic changes in rates such as those proposed by Idaho Power for its net metering
customers "should not be examined in isolation but should be fully vetted in a general rate
proceeding. If the Company wishes to raise these issues again, then it should do so in the context
of a general rate case." See Order No. 32846 at p. 13. Consistent with the foregoing, the
Commission stated:
IT IS FURTHER ORDERED that the Company's request to change the net
metering pricing structure by modifying Schedule 84 to move residential and
SNAKE RIVER ALLIANCE'S AND NW ENERGY COALITION'S JOINDER AND MEMORANDUM IN
SUPPORT OF IDAHO CLEAN ENERGY ASSOCIATION'S MOTION TO DISMISS - 3
small general service net metering customers to newly created Schedules 6 and 8
is denied. The Company shall continue using Schedule 84 to offer net metering
service to all customers. To the extent the Company wishes to increase the
monthly customelchalge, pr utBlelqea! a BLC for the reudcnltalsld S!@ll
general service customer classes. it shall raise that issue in a general rate case.
Net metering shall not sffselthe suslenter qharge.
See Order 32846 at p. 19.
On July 27,2017,Idaho Power filed its Application in this case, requesting in part: l)
closure of Schedule 84, Customer Energy Production Net Metering ("Schedule 84"), to new
service for residential and small general service customers with on-site generation after
December 31,2017; Application atp.2; and2) approval of two new customer classifications for
new residential and small general service customers who install on-site generation on and after
January 1,2018. Id. The Company also stated it was not currently seeking changes in rates for
new or existing net metering customers despite segregating them between schedules until further
proceedings vetted the costs and benefits of net metering. Id.
ARGUMENT
l. The Company's Application does not comply with Commission Order No. 32846.
The Intervenors agree with ICEA's argument that this case should be dismissed in its
current form. Idaho Power clearly has not complied with the Commission's direction in Order
No. 32846 by filing its Application for the relief requested outside of a general rate case. See
Order No. 32846 at pp. l3 & 19. This noncompliance seems unusual due to the fact Idaho
Power has complied with other Commission directives borne out of net metering proceedings
before it.
2. The Company's Application and associated materials provide insufficient justification
for the relief requested.
A set of factors that should be considered by the Commission in establishing differences
SNAKE RIVER ALLIANCE'S AND NW ENERGY COALITION'S JOINDER AND MEMORANDUM IN
SUPPORT OF IDAHO CLEAN ENERGY ASSOCIATION'S MOTION TO DISMISS.4
between classes of customers and associated rates are set forth in several Idaho Supreme Court
cases. In ldaho State Homebuilders v. Washington Water Power, 107 Idaho 415, 690 P.2d 350,
(1984) held that:
[n]ot all differences in a utility's rates and charges as between different classes of
customers constitute unlawful discrimination or preference under the strictures of
I.C. $ 6l-315. A reasonable classification of utility customers may justify the
setting of different rates and charges for the different classes of customers. Utah-
Idaho Sugar Co. v. Intermountain Gas Co., supra. Any such difference
(discriminatron) in a utilitv and charses must be iustified bv a
correspondine classification of customers that is based upon factors such as cost
of service. quantity of electricity used. differences in conditions of service. or the
time, nature and patteryr qf the use.
Idaho State Homebuilders v. Washington Water Power, 690 P.2d 350, 355, 107 Idaho 415, 420
(1984) (emphasis added). ln Homebuilders, the Court, citing its previous decision in Grindstone
Butte Mut. Canal Co. v. Idaho Public Utilities Commission,l02Idaho 175,181,627 P.2d804,
810 (1981) also found that the Commission may consider other criteria for establishing different
rates, including energy conservation, optimum use, and resource allocation. 1d.
In Grindstone the Court discussed the weight of such criteria
[w]e do not find one criterion to be necessarily more essential than another. Nor
do we find the criteria as listed above as being exclusive. . . . Cost of service is not
a per se essential element without which rate making is invalid. It is an important
qriterion and. in a given case. it mav even be lareqly dispqsilive of th r$uq af
basis for price differentiation.
Grindstone, 102 Idaho 775,180,627 P.2d804,809 (1981) (emphasis added).
ln Grindstone the Court also cited its previous decision in Agricultural Products
Corporarion v. Utah Power & Light Company,98 Idaho 23,557 P.2d 617 (1976) where it had
endorsed the following procedure taken from the New York Public Utilities Commission:
[u]nder the procedure we adopt here. a determination of undue discrimination or
preference must first be made in a rate proceedinq wherein all pertinent factors
are considered. including. amonq others. the provisions of the special contract. the
SNAKE RIVER ALLIANCE'S AND NW ENERGY COALITION'S JOINDER AND MEMORANDUM IN
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the contractin the cost of service the
qaldilqn of the utility. an . In the
rate proceeding, the commission will consider whether some preferential rate may
be appropriate in light of the specific circumstances surrounding each special
contract.... Re Consolidated Edison Co.,4 P.U.R. 4lh 199 Qll.Y.Pub.Ser.Comm'n
1974).
Grindstone, 102 Idaho at 1 80-8 I , 627 P .2d a1809- 10t quoting Agricultural Products
Corporotion v. Utah Power & Light Company, 98 Idaho 23 , 30-31 557 P .2d 611 , 624-25 (197 6)
(emphasis added). Grindstone continues:
Again cost of service is but one criterion to consider. The question then is not
whether one particular type of evidence is present in support of the rate
differentiation. but. rather. whether the evidence as a whole in light of the
circumstances of the particular case supports the differentiation. substantially.
competently and with a just and reasonable result.
Grindstone, 102 Idaho at 180-81 , 627 P.2d at 809-10.
. In support of its requests, Idaho Power asserts net metering customers utilize the grid
differently than similarly situated customers because they can export their excess power
generation onto it. Application atp.8, fl 13. Second, the Company contends that while net
metering customers may have daily power demand requirements similar to other customers
"their net monthly energy as a basis for billing does not reflect their utilization of the grid." Id.
The Intervenors assert that making dramatic changes in customer classifications and
1 ln Grindsto,ne the Court found that the Commission identified three primary objectives of current utility rate de-
sign:
They are (a) the revenue-requirement or financial-need objective, which takes the form of a fair-
return standard with respect to private utiliry companies; (b) the fair-cost-apportionment objective,
which invokes the principle that the burden of meeting total revenue requirements must be distrib-
uted fairly among the beneficiaries of the service; and (c) the optimum-use or consumer-rationing
objective under which the rates are designed to discourage the wasteful use of public utility ser-
vices while promoting all use that is economically justified in view of the relationships between
costs incurred and benefits received. J. Bonbright, Principles of Utility Rates at 292 (1961). Ap-
plication of Utah Power & Light Co., IPUC Order No. 13448 at 39 (Sept. 29,1971).
Grindstone,l02 Idaho at l8l-82, 621P.2d 810-l I
SNAKE RIVER ALLIANCE'S AND NW ENERGY COALITION'S JOINDER AND MEMORANDUM IN
SUPPORT OF IDAHO CLEAN ENERGY ASSOCIATION'S MOTION TO DISM]SS - 6
future rate design based on limited factors can have long term consequences and should not be
considered in a bubble without examination of a greater scope of criteria related to serving all
customers. Many additional relevant factors as set forth in Homebuilders and Grindstone should
be examined in cases like these. Further, the Intervenors contend that the Company's case does
not evaluate the benefits that power generation by net metering customers could provide. Prior
to any new customer classifications being created, such benefits must be evaluated and
quantified, along with considering other factors enumerated in Grindstone and Homebuilders.
See generally, Homebuilders; see also, Grindstone, 102 Idaho at 180-81, 627 P.2d at 809-810
(all pertinent factors should be considered in determining justification for differentiation), see
also, Order No. 32846 at pp. 12-13 (issues arising from Idaho Power's net metering Application
should not be decided in isolation but rather "vetted in a general rate proceeding" where many of
the factors above would be reviewed). See Order No. 32846 at pp. 12-13. Such potential
benefits include, but are not limited to, 1) avoided energy benefits; 2) avoided system losses; 3)
avoided generation capacity benefits; 4) avoided transmission capacity benefits; 4) avoided
distribution capacity benefits; and 5) avoided environmental costs of carbon based generation,
including health costs.
Additionally, Idaho Power's case as currently situated is producing a chilling impact on
consumers who may wish to install renewable generation and the businesses that provide such
products and installation. The uncertainty created by this case has slowed the development of
new generation and negatively impacts consumer choices. Prior to this case being filed, over the
last two (2) years, the Snake River Alliance's "Solarize the Valley Program" helped more than
1,000 families evaluate the practicability of adding rooftop solar panels to their homes. As a
result, over 100 of these families have recently installed rooftop solar panels on their homes or
SNAKE RIVER ALLIANCE'S AND NW ENERGY COALITION'S JOINDER AND MEMORANDUM IN
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are under contract with local installers to do so this winter. These efforts have resulted in over a
$2,000,000.00 consumer investment in the long-term capacity of our community to generate
renewable power. The Intervenors believe that such direct consumer investment at little cost to
the Company helps to provide low-cost, clean energy to all consumers in Idaho Power's service
territory. These consumers who are customers of Idaho Power and who take service under
Schedule 84, believed the Company shares their goals to obtain access to low-cost, clean power.
The Company's Application though seems contrary to these shared goals or at least goals that the
parties should have in common.
The Intervenors believe all electric customers should pay fair prices to access and
maintain the electric grid. However, net metering customers should not be treated differently
than customers that invest in residential conservation measures that reduce energy use. This
filing by Idaho Power singles out net metering customers who are avery small portion of its
customer base with the aim of applying an as of yet unspecified rate hike and charges to them
alone.
In conclusion, based on the foregoing and the content of the previous pleadings filed by
ICEA and Auric Solar, the Intervenors respectfully request that this case be dismissed.
ALTERNATIVE RELIEF
Similar to ICEA, Auric Solar, LLC ("Auric Solar") and the Idaho Conservation League
("ICL"), the Intervenors recognize that the issues raised by Idaho Power in its case must be
considered and resolved along with other factors in order for a just and reasonable result to be
reached. The Intervenors are encouraged and appreciate that Idaho Power has made the request
for the Commission to open a generic docket to determine a compensation structure for
customer-owned distributed energy resources that incorporates the costs and benefits that it
SNAKE RIVER ALLIANCE'S AND NW ENERCY COALITION'S JOINDER AND MEMORANDUM ]N
SUPPORT OF IDAHO CLEAN ENERGY ASSOCIATION'S MOTION TO DISMISS . 8
brings to the electric system.
In the event the Commission declines to dismiss this case, or even if it does, it seems
logical for it to establish a process by which all concemed parties can study and evaluate the
costs and benefits of distributed generation that would potentially lead to a negotiated solution
that benefits the Company, its customers and the collective intervenors' interests.
By way of example, in the state of Oregon, Idaho Power participated actively in a docket
setting the necessary elements to be included in a resource value of solar methodology for each
of Oregon's regulated utilities. Phase I of that docket has concluded. Phase II, whereby each of
Oregon's regulated utilities - including Idaho Power - plugs respective values into the
methodology, has just recently begun. It seems to make sense that Idaho Power simultaneously
use the Oregon methodology or a variant thereof to accommodate any differences between
jurisdictions, to determine resource value of solar figures for its Idaho service territory.
Understandably, the Commission could certainly develop its own methodology for all regulated
utilities in Idaho should it determine that to be most prudent path forward.
Another Idaho neighbor, Montana, has also recently wrestled with the net metering
question. As a result of continued battles to both expand and limit net metering, the legislature
ordered NorthWestem Energy to conduct a cost/benefit study for net-metered systems.
Subsequently, the Montana Public Service Commission initiated a docket to determine the
minimum information requirements, with input from stakeholders, for the cost/benefit study.
NorthWestem Energy has hired a third-party consultant to conduct the study, to be filed with the
Montana Commission by April 1,2018. Based on the foregoing, and in the alternative to
dismissal, the Intervenors respectfully request that the Commission vacate the current case
schedule and order the parties to come together to discuss, as Auric Solar states, "a timeline,
SNAKE RIVER ALLIANCE'S AND NW ENERGY COALITION'S JOINDER AND MEMORANDUM IN
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methodology, source of inputs, and technical group to study the costs and benefits of net
metering and on-site generation, with the results to inform an eventual general rate case." See
Auric Solar, LLC's of ICEA's Motion to Dismiss at p. 8.
DATED thi
FISHER PUSCH LLP
Hammond Jr.
-fo, Intervenors
and NW Energt Coalition
SNAKE RIVER ALLIANCE'S AND NW ENERGY COALITION'S JOINDER AND MEMORANDUM IN
SUPPORT OF IDAHO CLEAN ENERGY ASSOCIATION'S MOTION TO DISMISS - 1O
r Joindel and Memo in Support
, do^rof Novemb er 2017.
River
CERTIFICATE OF SERVICE
i HEREBY CERTIFY that on the 3'd day of November, 2017,1 served a true and correct
copy of the foregoing by delivering the same to each of the following individuals by electronic
mail, addressed as follows:
IDAHO POWER COMPANY:
Lisa Nordstrom
Idaho Power Company
1221 W. Idaho St. (83702)
PO Box 70
Boise, ID $7A7
lnordstrom@idahopower. com
[e-mail]
Timothy E. Tatum
Connie Aschenbrenner
Idaho Power Company
1221 W. Idaho St. (83702)
PO Box 70
Boise, ID 83707
ttatum@idahopower. com
caschenbrenner@idahopower. com
COMMISSION STAFF:
Sean Costello
Deputy Attomey General
Idaho Public Utilities Commission
472 W. Washington (83702)
PO Box 83720
Boise, ID 83720-0074
sean.costel .idaho
IDAHYDRO:
Idahydro
cio C. Tom Arkoosh
Arkoosh Law Offices
802 W. Bannock Street, Suite 900
PO Box 2900
Boise, ID 83701
[e-mail]
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SNAKE RIVER ALLIANCE'S AND NW ENERGY COAL]TION'S JOINDER AND MEMORANDUM IN
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IDAHO IRRIGATION PUMPERS
ASSOCIATION, INC.:
Idaho Irrigation Pumpers Association, Inc
c/o Eric L. Olsen
Echo Flawk & Olsen, PLLC
505 Pershing Avenue, Ste. 100
PO Box 61 19
Pocatello, ID 83205
[e-mail]
Anthony Yankel
12700 Lake Avenue, Unit 2505
Lakewood, OH 44107
[e-mail]
IDAHO CONSERVATION LEAGUE:
Matthew A. Nykiel
Idaho Conservation League
PO Box 2308
102 S. Euclid#207
Sandpoint, ID 83864
mnyki el@idahoconservation. ore
AURIC LLCz
Elias Bishop
Auric Solar, LLC
2310 S. 1300 W.
West Valley City, UT 84119
el i as. b i shop (@auri c sol a1. c om
Preston N. Carter
Deborah E. Nelson
Givens Pursley LLC
601 W. Bannock Street
Boise, lD 83702
prestoncarter@ givenspursley. com
den(@ givenspurs I ey. com
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SNAKE RIVER ALLIANCE'S AND NW ENERGY COALITION'S JOINDER AND MEMORANDUM IN
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SIERRA CLUB:
Kelsey Jae Nunez LLC
Siena Club
920 N. Clover Drive
Boise, ID 83703
kel sey@ ke I seyj aenunez. com
Zack Waterman
Idaho Sierra Club
503 W. Franklin Street
Boise, ID 83702
zack. waterman@ sierracl ub. org
ELECTRONIC SERVICE ONLY
Michael Heckler
michael.p.heckler@ gmail. com
CITY OF BOISE CITY:
Abigail R. Germaine
Deputy City Attomey
Boise City Attomey's Office
150 N. Capitol Blvd.
PO Box 500
Boise,ID 83701-0500
Telephone: [phone]
Facsimile: [phone]
agermaine@cityofboi se. ore
IDAHO CLEAN ENERGY
ASSOCIATION:
C. Tom Arkoosh
Arkoosh Law Offices
802 W. Bannock Street, Suite 900
PO Box 2900
Boise,ID 83701
[e-mail]
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SNAKE RIVER ALLIANCE'S AND NW ENERGY COALITION'S JOINDER AND MEMORANDUM IN
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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.or g
Briana Kober
Vote Solar
360 22"d Street, Suite 730
Oakland, CA 94612
[e-mail]
INTERMOUNTAIN WIND
AND SOLAR, LLC:
Ryan B. Frazier
Brian W. Bumett
Kirton McConkie
50 East Temple, Suite 400
PO Box 45120
salt Lake city, uT 84111
[e-mail]
[e-mail]
Intermountain Wind and Solar, LLC
1952 West 2425 South
Woods Cross, UTG 84087
dou g@ imwindandsolar. com
dal e(@i mwind and so I ar. cot!
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J Hammond, Jr.
SNAKE RIVER ALLIANCE'S AND NW ENERGY COALITION'S JOINDER AND MEMORANDUM IN
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