20191113Reply Comments on Settlement.pdf

IDAHO
CONSERVATION
LEAGUE
RECEIVED
i0l9t{0Y l3 P}l 2:09
208.345.6933 . PO Box 844, Boise, lD 83702 . www.idahoconservation.org
Diane Hanian
Commission Secretary
Idaho Public Utilities Commission
I 1331 W. Chinden Blvd.
Building 8, Suite 201-A
Boise, ID 83714
Re: IPC-E-18-15
Ms. Hanian,
Please find enclosed two filings submitted on behalfofthe Idaho Consen'ation League
and Vote Solar.
The first filing is ICt, and Vote Solar's Reply Comments on the Settlement. I enclosed an
original and seven copies of this document.
The second filing is ICL and Vote Solar's Brief on Existing Customers. I enclosed an
original and seven copies of this document. This brief includes an attachment with
voluminous excel computer files. I included one cd-rom with these files and will upload
these same files to the FTP site for this docket established bv Idaho Power and used bv
all parties.
Please contact me with an1, questions
Benjamin Otto
Idaho Conservation League
208-345-6933 exr 12
Benjanrin ,|. Otto (lSB No. 8292)
710 N 6th Street
Boise, ID 83701
Ph: [phone] xrZ
Fax: [phone]
[e-mail]
Attorney for the Idaho Conservation League
INTHEMATTEROFTHE )
APPLICATION OF IDAHO POWER )
COMPANYTOSTUDYTHECOSTS, )
BENEFITS, AND COMPENSATION OF )
NETEXCESSENERGYSUPPLIEDBY )
CUSTOMERON-SITEGENERATION )
PH 2:C,
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IDAHO CONSERVATION LEAGUE
AND
VOTESOLAR
REPLY COMMENT ON SETTLEMENT
The Idaho Conservation League ("ICL") and Vote Solar submit the following reply
comments on the proposed Settlement Agreement in this docket. ICL and Vote Solar participated
in all of the negotiations that lead to this settlement. While we did not support the Settlement,
out ofrespect for the process and other stakeholders we lvill address our concerns in future
proceedings. Here we reply only to the comments on the proposed Settlement filed by the Idaho
Irrigation Pumpers Association. On this same day we file a separate brief stating our position on
the Commission's authority to treat existing customer-generators fairly while providing a new
program to address the changing landscape for firture customer-generators.
The PUC Staff state, " [t]he crux of this Settlenrent is the move from retail monthly net
metering to hourly net billing at the Export Credit Rate, with a bright line at the meter to
distinguish imports from exports." Staff Cotnnrcnts at 4.lCL and Vote Solar agree with this
statement and note this framelvork aligns with the Commission Order No. 34046 that set us on
this path. That Order segregated customers r.vith on-site generation from those without based on
the ability to export to the grid, and not on the customer's consumption patterns. "To reiterate,
we recognize the fundamental difference between, as an example, a residential customer with no
on-site generation and one that can both import energy from, and export it to, the Company's
grid using the same infrastructure. 'l'his bi-directionality is distinct from a customer purely
offsetting its own energy usage outside ofthe grid,." Order No. 34046 at 17-18.
The bright line at the meter concept is embedded into the Settlement joined by the
signing parties who agree not to pursue changes to the consumption rates in this docket, rather
lvait for a proceeding "which the Commission determines whether to change rates or rate design
IPC-E-t8-15
ICL and Vote Solar
Reply Comment on Settlement 1 November 12,2019
CASENO. IPC.E-18.I5
for all customer classes." See Senlement Term I.V.F, at page 4. On this subject, the Commission
has ordered a separate docket, IPC-E-18-16, to consider issues offixed cost calculation and
spread across customer classes. Order No. 34190,34466. Second, a proceeding where the
Commission determines whether to change rates of all customers, also known as a General Rate
Case, has key evidence in the record - a cost of service study, a revenue requirement, and facts
showing current rates as they relate to the total revenue requirement for the Company - and
notice to all affected ofpotential rate changes, none ofwhich is present in this docket.
Accordingly, the comments of the Idaho Irrigation Pumpers Association that focus on a solar-
customer's consumption are appropriately studied in docket IPC-E-18-16 and considered in the
next general rate case where consumption rates and cost ofservice are properly notified,
documented, and discussed. The Commission should defer consideration ofthese issues until the
appropriate time and forum.
Respectfully submitted this 13th day of November 2019,
Benjamin J. Otto
Idaho Conservation League
Local Council - Vote Solar
IPC-E-18-15
ICL and Vote Solar
Reply Comment on Settlement 2 November 12.2019
CERTIFICATE OF SERVICE
I hereby certify that on this l3th day ofNovember 2019 I delivered true and corect
copies of the foregoing REPLY COMMENT ON THE SETTLEMENT to the following via the
method of service noted:
Benjamin J. Otto
c Mail
IPUC
Ed Jewell
Deputy Attomey General
Idaho Public Utilities Commission
Edward j ewel l@puc. idaho. gov
Idaho Power
Lisa D. Nordstrom
Timothy E. Tatum
Connie Aschenbrenner
[e-mail]
[e-mail]
[e-mail]
[e-mail]
klafut lrrigation Pumpers Association
Eric L. Olsen
Echo Hawk & Olsen PLLC
[e-mail]
Anthony Yankle
[e-mail]
IDAHYDRO
C. Tom Arkoosh
Arkoosh Law Offices
[e-mail]
[e-mail]
IPC-E-18-15
ICL and Vote Solar
Cerlificate of Service
RoclE Mounlain Power
Yvonne R. Hogle
Ted Weston
Yvonne.hogle@paci fi corp.com
Ted.weston@paci fi corp.com
Vole Solar
Briana Kobor, Vote Solar
[e-mail]
David Bender, Earthjustice
dbender@earthj ustice.org
Al Luna, Earthjustice
al una@earthj ustice.org
Nick Thorpe, Earthjustice
nthorpe@earthj ustice.org
City oJ Boise
Abigail R. Germaine
Deputy City Attorney
Boise City's Attomey's Office
[e-mail]
Idaho Sierra Cluh
Kelsey Jae Nunez
Kelsey Jae Nunez LLC
[e-mail]
Zaok Waterman, Sierra Club
-)Novenrber 12.2019
Hand Delivery Mail:
Diane Hanian
Commission Secretarl' (Original and seven copies provided)
Idaho Public Utilities Commission
427 W. Washington St.
Boise, ID 83702-5983
Mike Heckler, Sierra Club
Zack.waterman@sierracl ub.org
[e-mail]
ldoho Clean Energt Association
Preston N. Carter
Givens Pursley LLP
[e-mail]
Industrial Customers of lduho Power
Pctcr J. Richardson
Richardson Adams. PLLC
[e-mail]
Dr. Don Reading
[e-mail]
il'[i c ron Te c hno I o E),. I nc.
Austin Rueschholf
'l hon'ald A. Nelson
Holland & Hart, LLP
darueschhoffl@hol lardhart.com
[e-mail]
aclee@hollandhart. conl
gi gargano-amari @hollandhart.com
Jim Sr.r'ier, Micron
j srvier@;micron.com
Individual
Russell Schiermeier
[e-mail]
IPC-E-I8-l5
ICL and Vote Solar
Certificate of Service .+Novcmbcr 12.2019