The URL can be used to link to this page

Home My WebLink About20200110Petition for Reconsideration.pdfPreston N. Caner (lSB No. 8462) Givens Pursley LLP 601 W. Bannock St. Boise, ID 83702 Telephone: (208) 388-1200 Facsimile: (208) 388-l 300 Drestoncarter(a nsnurslev.com 14955646_4.docx u1523-ll Attorneys for ldaho Clean Energt Association 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-18-15 IDAHo CLEAN ENERGY AssoclATroN, INc.'s PETrrroN FoR REcoNSIDERATToN RECEIVED JAN IO PH 2: 55 ORIGINAL . il ON BEFORE, THE IDAHO PUBLIC UTILITIES COMMISSION The Idaho Clean Energy Association, Inc. ("ICEA") respectfully requests that the Commission reconsider the portion ofOrder No. 34509 regarding the eligibility date for customers to remain on Schedules 6 and 8. ICEA appreciates the Commission's determination that existing customers are differently situated from flrture customers such that the two groups may be treated differently in terms of rate and rate structure. ICEA also appreciates, and is sensitive to, the Commission's statements that existing customers appear not to have fully understood the type and degree ofchanges that could occur to the net metering program. Finally, ICEA recognizes the importance of, and completely supports, full disclosure to potential customers. ICEA supported passage ofthe Residential Solar Energy System Disclosure Act, Idaho Code $ 48-1805, for this reason. ICEA's sensitivity to these issues motivates this request for reconsideration. ICEA'S PETITIoN FoR RECoNSIDERATIoN - I As the Commission recognized, customers invest significant sums in on-site generation and the investment amount is not spread among the Company's rate base. Order No. 34509 at 3- 4. The payback period for a solar system is an important component ofthe customer's decision, and the payback period is sensitive to program changes. Id. al3, 12. Under Idaho Code $ 48-1805, solar installers must provide several statutory disclosures to customers. ldaho Code $ 48-1805(c). In addition to the statutory disclosures, solar installers must provide any written estimates ofthe projected savings ofthe system; estimated savings over the life of the solar agreement or over the anticipated useful life of the system; any material assumptions used to calculate estimated projected savings; and the source ofthose assumptions. ldaho Code g a8-1805(2)(a) & (b).' An accurate and consistent source for the numbers and assumptions used to make payback calculations is important for purposes ofsolar installers' compliance with the slatute, and to ensure that customer receive information that is as consistent and accurate as possible. Order No. 34509 disapproved the proposed settlement; established a process for a comprehensive study that will form the basis for potential future changes; and grandfathered certain existing customers. Order No. 34509 al 1. However, the Order does not establish a net metering progftrm for the interim period between the date ofthe order and the date of anticipated program changes. Based on conversations that ICEA has had with its members, solar installers understand and respect the Commission's decision. However, there is considerable confusion regarding how to proceed in the interim period. Solar installers simply do not know what numbers and I The Commission noted the statutory disclosures. Order No. 34509 at l3- ICEA agrees that these disclosures are important. ICEA also submits that it is important to provide the most uniform, accurate estimates possible. In ICEA's experience, customers are accustomed to-perhaps even desensitized to a wide variety of wamings and disclosures. Disclosures are important but should be coupled with the most accurate estimates possible. ICEA's Pt r rroN FoR RECoNSIDERATIoN - 2 assumptions to use for anticipated payback calculations. This conlusion is exacerbated by the vast dilference between existing rates and the settlement agreement. A calculation based on existing rates might show an attractive payback while a calculation based on the figures in the settlement agreement might not. Further, the terms of the settlement agreement are complex, and our members would need to invest to build the tools and skills needed to evaluate investments under the settlement agreement. Neither customers nor installers have a clear resource from which to obtain consistent, reasonable numbers and assumptions to calculate payback periods and to otherwise inform customer decision-making. Given the confusion about what numbers and assumptions to use, ICEA anticipates that, through no fault oftheir own, installers will present, and customers will be presented with, payback estimates that vary widely from installer to installer. Many customers and installers might find it easiest to evaluate an investment based on existing rates even while recognizing (and disclosing) that changes are anticipated. ICEA is concemed that in this interim period before those changes are defined, the customer will not have sufficient information to understand or evaluate the impact of future changes. This breeds confusion and, ultimately, customer discontent both now and ifchanges are proposed in the future. ICEA would again like to emphasize the importance of full disclosure and accurate estimates. Both are key to customer satisfaction and the long-term success of the industry in Idaho. ICEA has worked with its members, and will continue to work with its members on these issues. In the cunent situation, however, solar installers simply do not have the ability to provide customers with uniform, accurate estimates or other guidance on key program parameters that dictate the payback period of on-site generation. ICEA's PETITIoN I.oR R-ECoNSIDERATION . 3 Under these circumstances, ICEA submits that the simplest, most straightforward way to alleviate these concems is to allow customers to continue under existing Schedule 6 and Schedule 8 until a replacement progr.rm is implemented. Not only will this provide a basis for solar installers to provide, and customers to receive, accurate information to inform decision- making; it will also foster the Commission's goal ofan open, transparent, and understandable process to implement any changes to the net metering program. Dated: January 10,2020. GIVENS PURSLEY LLP .l/ --: ' -"-' Preston N. Carter Givens Pursley LLP Attorneys for Idaho Clean Energt Associalion ICEA's PETIIToN t oR RECoNSIDER TIoN - 4 CERTIFICATE OF SERVICE I certify that on January 10,2020, a true and correct copy ofthe foregoing comments were served upon all parties ofrecord in this proceeding via the manner indicated below: Commission Staff Diane Hanian, Commission Secretary Idaho Public Utilities Commission 11331 w. Chinden Blvd., Bldg. 8, Ste. 201-A Boise, lD 837 14 Hand Delivery & Electronic Mail Diane.holt@puc .idaho.sov Edward Jewell, Deputy Attomey General Idaho Public Utilities Commission I I 331 W. Chinden Blvd., Bldg. 8, Ste. 201 -A Boise, ID 83714 Edward.Jewell nuc.ldaho.sov Electronic Nlail Via Electronic Mail Lisa D. Nordstrom Regulatory Dockets Idaho Power Company 1221 West Idaho Street (83702) P.O. Box 70 Boise, ID 83707 lnordstrom@.idahoDower.com dockets@idahopower.com Benjamin J. Otro Idaho Conversation League 710 North 6s Street Boise, Idaho 83702 botto@idahoconservation.org Idaho Irrigation Pumpers Association, Inc. c/o Anthony Yankel 12700 Lake Avenue. Unit 2505 Lakewood, Ohio 44107 ton ankel.net ICEA'S PETITION FOR R-TCONSIDERA'IION - 5 Timolhy E. Tatum Connie Aschenbrenner Idaho Power Company 1221 West Idaho Street (83702) P.O. Box 70 Boise, ID 83707 ttatum(@idahopower.com caschenbrenner@idahopower.com Idaho Inigation Pumpers Association, Inc. c/o Eric L. Olsen Echo Hawk & Olsen, PLLC 505 Pershing Avenue, Suite 100 P.O. Box 6119 Pocatello, Idaho 8305 elo@echohawk.com Idahydro c/o C. Tom Arkoosh Arkoosh Law Offices 802 W. Bannock Street, Suite LP 103 P.O. Box 2900 Boise, ID 83701 Tom. arkoosh@arkoosh.com Erin.ceci[@arkoosh.com ICEA'S PI.,I I I'IoN IjoR RE,CONSIDF]RA] lON - 6 Yvonne R. Hogle Rocky Mountain Power 1407 West North Temple, Suite 330 Salt Lake Ci1y, uT 841l6 yvonne.hogl acificom.com David Bender Earthjustice 3916 Nakoma Road Madison, WI 5371 I dbender@earthiustice.or{.r Nick Thorpe nthome@earthi ustice. ors Idaho Sierra Club c/o Kelsey Jae Nunez Kelsey Jae Nunez LLC 920 N. Clover Drive Boise, ID 83703 kelsey@kelsey laenunez.com F. Diego Rivas NW Energy Coalition 1 101 86 Avenue Helena, MT 59601 diego@nwenerqv.ore Ted Weston Rocky Mountain Power 1407 West North Temple, Suite 330 Salt Lake City, UT 84116 ted.weston@oaci fi co{p.com Briana Kober Vote Solar 358 S. 700 8., Suite 8206 salt Lake Ciry, uT 84102 briana@votesolar.orq Al Luna Aluna@earthi ustice.ore Abigail R. Germaine Boise City Attomey's Office 105 N. Capitol Blvd. P.O. Box 500 Boise, ID 83701-0500 agermaine@cityofboise.org Zack Waterman Mike Heckler Idaho Sierra Club 503 W. Franklin Street Boise, ID 83702 zack. walerman@sierracl ub.ore. Michael.p.heckler@smail.com NW Energy Coalition c/o Benjamin J. Otto Idaho Conservation League 710 N. 6e Street Boise, ID 83702 botto@.idahoconservation.ore Micron Technology, Inc. c/o Austin Rueschhoff Thorvald A. Nelson Holland & Hart, LLP 555 Seventeenth Street, Suite 3200 Denver, CO 80202 darueschhoff@hollandhart.com tnelson@hol Iandhart.com Jim Swier Micron Technology, Inc. 8000 S. Federal Way Boise, ID 83707 iswierl@micron.com Industrial Customers of Idaho Power c/o Peter J. Richardson Richardson, Adams, PLLC 5 15 N. 27s Strcet P.O. Box 7218 Boise, Idaho 83702 oeter@richardsonadams. com Industrial Customers of Idaho Power Dr. Don Reading 6070 Hill Road Boise, Idaho 83703 dreadin g@mindspring.com Russell Schiermeier 29393 Davis Road Bruneau, Idaho 83604 bur-hay@smail.com Preston N. Carter ICEA,S PETITIoN FoR RF-CONSIDERATION - 7 r