20191113King Affidavit.pdf

Attorneys for ldaho Clean Energt Association
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
RECEIVED
l3 Pl{ 2:05
IN THE MATTER OF THE PETITION
OF IDAHO POWER COMPANY TO
STUDY COSTS, BENEFITS, AND
COMPENSATION OF NET EXCESS
ENERGY SUPPLIED BY CUSTOMER
ON-SITE GENERATION
Case No. IPC-E-I8-15
Arrroevrt on KEVrN KrNc rN Supponr or
IDAHo CLEAN ENERcY AssocrATroN,
INc.'s BRrEF REcnnorNc TnenrvENr or
ExrsrrNc CusroMERs
OR IGINAL
County ofAda
Kevin King, being first duly swom on oath deposes and stales as follows:
I . I am the owner of several solar energy companies in Idaho, one of which is a
member of the Idaho Clean Energy Association, Inc. ("ICEA"). I have been an active member of
ICEA's Board since January 2013 and started the solar task force in February 2015.
2. I am currently the President of ICEA. In that capacity, I attended and participated
in the settlement conferences and associated activities in this case.
3. ICEA is a 501(c)(3) non-profit organization dedicated to, among other things,
providing a collaborative forum for Idaho's diverse renewable energy and energy efficiency
business community and to pursuing other objectives related to the advancement of clean energy
in Idaho. Members ofICEA include businesses, such as solar installers, engaged in the business
)
)ss
)
AFFtDAvtr oF KEvIN KrNc lN SuppoR I oF ICEA's BRrEF RF:CARDTNC TREATMENT or- ExtsINc CusroMERs - I
Preston N. Carter (ISB No. 8462)
Givens Pursley LLP
601 W. Bannock St.
Boise, ID 83702
Telephone: [phone]
Facsimile: (208) 388-l 300
prestoncarter@ givenspursley.com
14862519_2.docx lll523-31
lr-
-.-r, I r. j .ctarI
STA'I'E OF IDAHO
ofselling, installing, servicing, and undertaking other aclivities related to renewable energy and
on-srte generatlon.
4. I currently own EvenGreen Technology, a design build Solar and Energy
Efficiency Company; Gem State Solar, which designs and installs solar light tubes and attic fans;
and Solar Tools USA, a solar tool manufacturing company. I hold an ldaho electrical contractors
license and am registered as an Idaho building contractor. I am certified with Lithium Chemistry
batteries. I hold a US Patent for tools used in the solar industry.
5. I have been involved with designing and installing solar on-site generation
systems in Idaho since 2009. Through this experience, I have interacted with hundreds. if not
thousands, of customers who have inquired about, and sometimes installed, solar onsite
generation systems. These interactions stem from initial visits, to discussions about the financial
viability of system designs, to designing systems. to installing, servicing, and repairing solar
onsite generation systems.
6. Through my businesses, and through my involvement with ICEA, I stay up to
date on the latest technology for solar onsite generation systems, including technology associated
with energy storage (including batteries), inverters, solar panels, and the related technology that
can be used to fit customers' particular needs in light ofthe goveming rules and regulations.
7 . In addition, during the course ofthe IPC-E-I7-13 case and this case, I have
spoken with many customers that have solar onsite generation systems, and with many other
persons that have installed solar onsite generation systems.
8. Through this personal experience, I am generally familiar with the types ofsolar
onsite generation systems that have been installed in the Treasure Valley and other locations in
Idaho. I am also generally familiar with the factors customers and installers have taken into
AFFTDAVIT oF KEvtN KINC I\ SuppoRT oF tCEA's BRrEr. Rr.GARr)rNG TREATMINT or ExtsING CusroMERs - 2
account in making decisions on what types ofsolar onsite generation systems to install, what
technologies to install, the costs ofvarious systems and technologies, how technology has
evolved over time, and similar issues related to solar onsite generation systems.
9. Through this personal experience, I am generally familiar with the technology and
system configurations that are currently available, and that are expected to be available in the
future, and how customers may choose to use that technology in making choices about the
systems and configurations of solar onsite generation systems.
10. In this affidavit, I use the term "Net Metering Program" to refer to the program
established by the Public Utilities Commission that, until the IPC-E-I7-13 case, was reflected in
Schedule 84. The Commission retained the Net Metering Program but moved it to Schedule 6
and Schedule 8 for certain residential and small general service customers in the IPC-E-17-13
1 l. I use the term "Net Hourly Billing Program" to refer to the program agreed to in
the proposed settlement, which was filed with the Commission on October 17, 2019.
12. I understand that the Net Metering Program has been in place since the early
1980s, and that the key components ofthe Net Metering Program have been in place since the
early 2000s. This understanding comes, in part, from Connie Aschenbrenner's testimony in the
IPC-E-17-13 case.
13. In my experience, the Net Metering Program has several key components. In my
experience, these key components dictated the decisions that customers made regarding the types
of systems to purchase, the size of systems to purchase, the manner in which to configure the
systems, and the technologies to use with the systems. These key components of the Net
AFFIDAvtT ot KEvtN KtNG IN SLrppoRT oF ICEA's BRrEF RIC RDINC TRE^TMENT ot Exls' NG Cust oMFRs - 3
casc.
Metering Program also dictated the decisions that solar installers, such as myself, made when
recommending system size, system design, system configuration
14. The first key component is monthly netting. When considering solar onsite
generation systems on the Net Metering Program, the customer and the installer typically
discussed the customer's monthly energy consumption, the monthly generation of the onsite
generation system, and how sonsumption and generation would match up on a monthly basis.
The customer and installer also typically discussed the customer's consumption and anticipated
generation of the onsite system on an annual basis, but using the monthly data points to frame the
discussion. In my experience, neither customers nor installers discussed or considered y'roarrly
data. Indeed, in my experience, neilher customers nor installers even had hourly data readily
available. In fact, under the Net Metering Program, I never had a sinp,le customer request an
analysis ofhourly data because this was not relevant to the customer's decision under the Net
Metering Program. The customers' decisions, and the installers' recommendations, regarding
system size, system orientation, whether to include storage, and other decisions were made on
the basis of monthly data. These discussions and considerations were dictated by the monthly
netting component of the Net Metering Program.
15. The second key component is the kilowatt-hour-for-kilowatt-hour offset, under
which the customers' exported generation is treated the same, financially, as customers'
consumed generation. My understanding is that some characteristics ofthis have changed over
time, but the key characteristic has remained the same: the financial impact on a customer was
the same whether the generation was consumed on-site or exported. Given this component ofthe
Net Metering Program, customers and installers discussed the optimal system size, orientation,
configuration, and associated technologies ofa system that made the most financial sense when
AFFIDAv] I oF KEvIN KING IN SI]PPORT OF ICEA'S BRII]F RIGARDING TREATMTNT oF ExISTING C(JSToMERS - 4
the customer was neutral as to whether generation was consumed or exported on a net monthly
basis.
16. These two components of the Net Metering Program, which were set by the
Commission and that had remained materially the same (as I understand it) th-roughout the Net
Metering Program's history led customers and installers to make particular choices about system
configuration. Every customer is different, but speaking in generalities. the following
characteristics define common system-related choices made under the Net Metering Program:
Systems were most often (if not always or nearly always) sized using a
customers' annual consumption data and a systems' annual generation data, using
monthly consumption data and a systems' monthly generation data, since the
customer was neutral between generation that was exported and generation that
was consumed, and since net monthly generation was the relevant unit of
measurement.
a
Systems were most often configured to not include storage or other technology
that would enable the customer to control the timing ofgeneration or to reduce
exports. Because energy was netted on a monthly basis. the ability of customers to
align consumption and generation on an hourly basis was not relevant under the
Net Metering Program. Further, because a kWh exported would offset a kWh
consumed, storage was not critical. As such, most systems were not configured to
include storage or associated technologies.
Systems were often sized to generate electricity sufficient to offset the customers'
annual consumption, as measured using monthly data. As discussed separately
below, for customers whose monthly peak consumption occurred in thc
wintertime, systems were designed to generate exports sufficient in the summer to
offset winter consumption.
17. While most (if not all) customers' and installers' decisions were influenced by
these key components of the Net Metering Program, specific subsets of customers were
influenced very strongly by these characteristics. I have personally interacted with many
customers who rely on electric heating. These customers tend to be more rural, and less af{luent,
than customers that rely on natural gas heating. These customers tend to be particularly
concemed with their energy bills during the winter months. Their peak consumption typically
AFFtDAvrr oF KFrvrN KIN-G IN SuppoR I oF tCEA's BRrr.F RF]GARDTNG TREATVENT oF ExtSTNC CusroMERS - 5
a
occurred during winter months. These customers typically sized their system to offset the peak
consumption. However, their peak consumption occuned when generation was [ow. Because
energy was netted on a monthly basis, and because the customer was neutral between exports
and consumption, these systems typically exported large amounts of energy in the summer
months. In my experience, these customers' decisions regarding whether to invest in onsite
generation. the size ofthe system, and the configuration olthe system, depended heavily on
monthly netting and the one-to-one ratio between exports and consumption. It is safe to say that
most, ifnot nearly all, olthese customers would have made different choices about whether to
invest, system size, and system configuration if those components olthe Net Metering Program
were different, or ifthose components of the Net Metering Program had changed throughout the
years.
18. Ifthe Net Hourly Billing Program set forth in the proposed settlement is adopted,
I anticipate that customers and installers will make dillerent choices in how to size their systems,
how to configure their systems, and how to take advantage ofstorage and other technologies.
19. First, because the Net Hourly Billing Program nets on an hourly basis rather than
a monthly basis, customers and installers will have to obtain and rely upon hourly consumption
and generation data rather than monthly consumption and generation data. Based on hourly data
that I have reviewed for potential customers, I anticipate that the net hourly exports will differ
more greatly across customers that net monthly exports. Stated another way, I anticipate that
customers and installers will have to give greater attention to each customers' specific
consumption profile, and more closely tailor particular systems' generation profiles. This will be
a very difficult task and, I anticipate, will lead to more diversity in the types of systems that
AFrr)AVt r oF Kr.vrN KING IN SupPoR I oF ICEA'S BRrEF RTGART)rN(i TREATMINT or- Exrs] rNG CLS roN,r[RS - 6
customers install, as well as more diversity in the conhgurations ofthese systems, the types of
technologies used, and other information.
20, Second, the Net Hourly Billing Program will increase the importance of the
timing of customers' consumption and the systems' generation. I anticipate that customers will
make different choices about syslem size than customers have made under the Net Metering
Program. While, as noted above, I anticipate more diversity, as a general rule I anticipate that
customers will choose smaller systems than they would have under the Net Metering Program.
Whether or not systems are sized smaller, larger, or there is simply more diversity in customers'
choices, customers and installers will make decisions that are influenced more by the timing of
consumption and generation.
21. Third, and relatedly, because the Net Hourly Billing Program increases the
importance of the timing of a customers' consumption and generation, I anticipate that customers
will choose systems that are configured 1o include storage or other associated technologies.
These technologies will enable customers to match generation with consumption on a more
granular basis than was necessaxy under the Net Metering Program.
22. Fourth, the proposed settlement includes a non-export option. I anticipate that
more customers will choose the non-export option, with the associated storage and other
technologies, which was not formalized under the Net Metering Program.
23. The decisions that customers and installers made, based on the key components of
the Net Metering Program, typically cannot easily be undone. For example, it is not financially
feasible for a Net Metering Program customer to decrease their system size. They have already
made the investment and have little reason to incur the additional expense of(for example)
ATT IDAvI I oI, KEVIN KING IN SI]PPoRT oF ICEA,S BRIHF RtjGARDINc TRIATMENT.oF Ex]STINC CUSToMERS - 7
removing panels, reconfiguring wiring, and making the other changes necessary to decrease
system size.
24. In addition, customers that conligured their system to match monthly
consumption and generation can:rot typically economically retrolit their systems to match
consumption and generation on a more granular basis. For example, a customer whose system
did not initially include baftery storage cannot just simply buy batteries. Instead, the customer
would have to completely reconfigure their system.
25. To provide another example, while a new customer could take advantage of
technologies to match consumption with generation by diverting energy for consumption
purposes, such as electric vehicle charging. existing customers whose system was configured
under the Net Metering Program would not likely be able to incorporate these technologies
without completely reconfiguring their systems, which is cost prohibitive.
26. Recently, I have discussed the possibility of incorporating storage or other
technologies with customers who designed and installed their systems under the Net Metering
Program. The cost of reconfiguring the systems was prohibitively expensive lor all ofthese
customers. If these customers had made their decisions based on Net Hourly Billing Program. the
incremental cost ofa system that included storage or other technologies would not be near this
amount-the system would have been designed to incorporate those technologies from the
outsct
27. F-inally, while a new customer has the option to configure their installation to be a
non-export system, customers that configured their systems to meet the components of the Net
Metering Program typically cannot economically alter their systems to take advantage of the
non-export option. Transforming an exporting system to a non-export system would require a
AFFIDAvII. oT. KEvIN KING IN SUPPORT OF ICEA.S BRIEI, RI.CARI)INc TREATMENT oF ExIS,IINC CI]STOMERS - 8
complete reconliguration ofthe system. While I do not have specific figures on what that would
cost, in my experience it would be at least as much, and perhaps more, than reconfiguring a
system to include storage or other technologies.
28. In my experience and opinion, the Net Metering Program and the Net Hourly
Billing Program are two separate programs. The key components of the Net Metering Program
that drove customer decision making-monthly netting and a kilowatt-hour credit for exports-
have changed. This is more than a change in rates. It is a change in programs. Under the Net
Metering Program, customers made decisions regarding the configuration of their systems, and
indeed whether or not to invest in onsite generation, according to the components olthe program
in place at the time. Those decisions cannot be undone.
29. In my opinion, customers that made decisions under the Net Metering Program
are differently situated that customers that will make decisions under the Net Hourly Billing
Program. I urge the Commission to allow existing customers to continue under the Net Metering
Program as specified in the proposal in ICEA's comments.
DATED: November12,2019.
Kevin King
SUBSCRIBED AND SWORN to before me this 121h day of November.20l9.
N tary Publi of ld
Residing at
My Commission Explres:
l(EltlDR l,-EE tlOFFllANcoiluSaloNftltorS
I.IOTARY PUBUC
STATE OF IDA}()
MY cEr fl8stoN EXP|BEE 1tZ2t&A
AFFrDAvtr oF KEvtN KtNC IN SuppoRT oF ICEA's BRIEF RFCARDTNC TRr-Ar Mr-rN r or Exrs'r'rNc CrJsToMFrRs - 9
CERTIFICATE OF SERVICE
I certify that on November 13,2019, a true and correct copy of the foregoing comments
were served upon all parties ofrecord in this proceeding via the manner indicated below:
Commission Staff
Diane Hanian, Commission Secretary
ldaho Public Utilities Commission
I l33l W. Chinden Blvd., Bldg. 8, Ste.201-A
Boise, ID 83714
[e-mail]. eov
Hand Delivery & Electronic Mail
Edward Jewell, Deputy Attomey General
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg. I, Ste. 201-A
Boise, ID 83714
Edward.Jewell puc.idaho.gov
Electronic Mail
Via Electronic Mail
Lisa D. Nordstrom
Regulatory Dockets
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, ID 83707
[e-mail]
[e-mail]
Benjamin J. Otto
Idaho Conversation League
710 North 6th Street
Boise, Idaho 83702
botto@idahoconservation.o
Timothy E. Tatum
Connie Aschenbrenner
ldaho Power Company
l22l West Idaho Street (83702)
P.O. Box 70
Boise, ID 83707
ttatum@idaho power.com
caschenbrenn dahopou.er.com
Idaho Irrigation Pumpers Association, Inc.
c/o Eric L. Olsen
Echo Hawk & Olsen, PLLC
505 Pershing Avenue, Suite 100
P.O. Box 6119
Pocatello, Idaho 8305
[e-mail]
Idahydro
c/o C. Tom Arkoosh
Arkoosh Law Offices
802 W. Bannock Street, Suite LP 103
P.O. Box 2900
Boise, ID 83701
[e-mail]
rg
Erin.ce it oosh.com
AFFIDAvtT oF KEvtN KrNc lN SuppoRT oF ICEA's BRIEI. REGARDTNG TREA'|'MENT oF ExtsING CusroMERs - l0
Idaho Irrigation Pumpers Association, Inc.
c/o Anthony Yankel
12700 Lake Avenue, Unit 2505
Lakewood, Ohio 44107
[e-mail]
Jim Swier
Micron Technology, Inc.
8000 S. Federal Way
Boise, ID 83707
[e-mail]
Industrial Customers of Idaho Power
c/o Peter J. Richardson
Richardson, Adams, PLLC
515 N. 271h Street
P.O. Box 7218
Boise, Idaho 83702
peter@.richardsonadams.com
Ar r I)Avl r oF KEvrN KrNC IN SLJppoRT oF ICEA'S BRIEF RECARDTNG TREATMENT oF ExtstiNc CusroMERs - I I
Ted Weston
Rocky Mountain Power
1407 West North Temple, Suite 330
Salt Lake City, UT 841 l6
ted.weston@pacifi com.com
Briana Kober
Vote Solar
358 S. 700 E., Suire 8206
Salr Lake Ciry, UT 84 102
[e-mail]
Al Luna
Aluna@earthj ustice.org
Abigail R. Germaine
Boise City Attomey's Office
105 N. Capitol Blvd.
P.O. Box 500
Boise, ID 83701-0500
asermaine@cityofboise. ore
Zack Waterman
Mike Heckler
Idaho Sierra Club
503 W. Fmnklin Street
Boise, ID 83702
zack.waterman@sierraclub,org
[e-mail]
NW Energy Coalition
c/o Benjamin J. Otto
Idaho Conservation League
7'10 N. 6th Street
Boise, ID 83702
[e-mail]
Micron Technology, Inc.
c/o Austin Rueschhoff
Thorvald A. Nelson
Holland & Hart, LLP
555 Seventeenth Street, Suite 3200
Denver, CO 80202
[e-mail]
tnel [e-mail]
Yvonne R. Hogle
Rocky Mountain Power
| 407 West North Temple, Suite 330
Salt Lake City, UT 84116
wonne.hosle@Bacifi corp.com
David Bender
Earthj ustice
3916 Nakoma Road
Madison, WI 5371 I
dbender@earthj ustice.ore
Nick Thorpe
nthome@earthj ustice. orq
Idaho Sierra Club
c/o Kelsey Jae Nunez
Kelsey Jae Nunez LLC
920 N. Clover Drive
Boise, ID 83703
kelsey@kelse)'j aenunez.com
F. Diego Rivas
NW Energy Coalition
1 101 8th Avenue
Helena, MT 59601
[e-mail]
Industrial Customers of Idaho Power
Dr. Don Reading
6070 Hill Road
Boise, Idaho 83703
[e-mail]
Russell Schiermeier
29393 Davis Road
Bruneau, Idaho 83604
[e-mail]
F---<--'^=--r"
Prcston N. Cartcr
AFFrDAvrr oF KEvrN KING IN SuppoRT oF ICEA's BRrEF RE0ARDTNG TREAIMENT oF ExrsrrNc CrrsroMERs - l2