20191106Comments.pdf

SIERRA CLUB
IDAHO CHAPIER
November 6, 2019
RECEIVED
lClg NCll -5 All ll: l7
Reference: IPC-E-18-15
Sub.iect: october 11, 2019 Settlement A8reement
Dear Commissioners:
Sierra Club submits these comments in support of the Settlement Agreement and requests the
Commission approve the agreement in its entirety.
As is increasingly the case in this period of rapid change within the electric utility space,
customer ownership of on-site generation raises multiple interrelated issues. Under this docket,
a significant number and representative group of interested parties engaged in eight settlement
sessions involving dozens of hours of discussion and negotiation on these complicated and
nuanced matters. Sierra Club believes use ofthis type of settlement process is especially
valuable in these times and took support for continued use of this process into consideGtion
when deciding whether to support or remain neutral on the Settlement Agreement.
The Settlement not only resulted after intensive discussion of matters related to residential and
small commercial customers with on-site generation but also reflects substantial compromises
made by the parties in reaching a settlement. Sierra Club and others agree there are at least
two remaining open issues:
(1) how should existinB residential and small commercial customers with on-site generation
be affected by this new program and
(2) an additional new docket is needed to address the current multiplicity of methods for
calculating "avoided cost" benefits.
Our support for the settlement was premised upon a belief that the Commission will support
separate review of two remaining open issues.
Sincerely,r^
Zack Waterman
ldaho Director, Sierra Club
Cc: Parties to the proceeding via email
dz
Commission Secretary
ldaho Public Utilities Commission
11331 W Chinden Blvd
Building 8, Suite 201-A
Boise, lD 83714
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OIlMISSION