20201222Petition for Reconsideration.pdf

PrestonN. Carter (ISB No. 8462)
Blake W. Ringer (ISB No. 11223)
Givens Pursley LLP
601 W. Bannock St.
Boise,lD 83702
Telephone: [phone]
Facsimile: [phone]
prestonc arter@ givenspursley. com
blakeringer@ givenspursl ey. com
15443329 _).docx [1 5504. l]
Attorneys for Agripower Solar, LLC
BEFORE THE IDAHO PUBLIC UTILITIES COMNtrSSION
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IN THE MATTER OF THE IDAHO
POWER COMPANY'S APPLICATION
FOR AUTHORITY TO MODIFY
SCHEDULE 84'S METERING
REQUIREMENT AND TO
GRANDFATHER EXISTING
CUSTOMERS WruH TWO METERS
Case No.LPC-E-20-26
AcRtpownn SoLaR, LLC's prtnloN r,oR
RBcoNsropRATIoN
Pursuant to Commission Rule of Procedure33L,IDAPA 31.01.01.331, Agripower Solar,
LLC ("Agripower Solar") respectfully requests that the Commission reconsider the portion of
Order No. 34854 regarding the cutoffdate for grandfathering existing Schedule 84 customers.
Specifically, Agripower Solar requests that prospective Schedule 84 customers be afforded
"grandfathered" status so long as applications are received 30 days from the date on which the
order on reconsideration is issued.
In the alternative, and at a minimum, Agripower Solar requests that the five customers
specifically discussed in this Petition be deemed as having submitted timely applications and,
that these five customers therefore be afforded "grandfathered" status under Order No. 34854.
AcRpowER SoLAR's PETrrroN FoR Rscol.rsnrRArroN - I
Agripower Solar did not intervene in Case No. IPC-E-20-26, in part because Idaho
power's Application (the "Application") proposed to change the dual-meter component of
Schedule 84 customers. Agripower Solar did not have significant objections to that proposal, or
to the proposed grandfathering related to the dual-meter systems. Unlike, for example, the
application in IPC-E-19-15,r the Application in this case did not propose substantial
programmatic changes.
Regardless, although Agripower Solar did not intervene, it is a "person interested in a
final order" under Rule of Procedure 331, and is therefore eligible to file this Petition for
Reconsideration. As discussed in more detail below, Agripower Solar and its customers were
severely impacted by the December 1,2020 cutoffdate for grandfathering.
GBNrRl'r, B,c,crcnouND
Agripower Solar is an engineering and design firm that contracts to design, engineer, and
install renewable energy systems that are specifically customized to meet the needs of the
agricultural businesses. For example, Agripower Solar frequently designs, engineers, and installs
solar systems on dual-axis trackers, which enables the agricultural producer to maximize the
amount of energy produced on a given parcel of property. This meets agricultural producers'
desire to self-generate to offset (or, in most cases, to partially offset) their power needs without
reducing agricultural production.2 Agripower Solar favors dual-axis systems because they
produce the most power during the late afternoon and evening, which corresponds to the peak
I Agripower Solar did not independently intervene in IPC-E-19-15 because its interests were represented by the
tCSe. foe Goodman, a representative of Agripower Solar, participated in settlement discussions in IPC-E-19-15.
2 Agricultural businesses often have extremely high power bills. For example, several of Agripower Solar's
,uri=o*"., have electrical bills in excess of one or two million dollars per year. To meaningfirlly offset a customer's
load-the purpose of the net-metering program-with the current 100kw cap, it is necessary to aggregate a large
number of arrays. Under current rules, ,A.gripower Solar is often unable to completely offset customers' loads. It has,
however, been able to partially offset loads and reduce some customers' bills by several hundred thousand dollars
per year.
AGRPOWER SOLAR,S PETITTON TON RTCONSNBREUON - 2
loading hours of utilities. In theory-though the time value of this energy is not fully reflected in
the net metering progam-power provided at these times provides maximum value to the utility
and to the entire grid.
Given the size, complexity, and degree of customization required to serve agricultural
businesses, Agripower Solar often works with customers for months to design, plan, and install
solar installations. The planning and design of these systems must necessarily reference the rules
of the existing program-the systems must comply with existing rules, particularly where there
is no basis to predict what a replacement progftrm might look like. As noted, many of these
planned systems are complex. Under current rules, specifically the l00-kilowatt cap and meter
aggregation rules, Agripower Solar often must design up to several dozen solar arrays, on a
dozen or more meters, to materially offset a customer's load. This, in furn, can lead to several
dozen applications for a single customer.
The Commission issued Order No. 35854 on December 1,2020, and Agripower Solar
reviewed it carefully that same day. Two aspects of the Order were surprising to Agripower
Solar and required immediate action. First, to be eligible for grandfathering, customers'
applications and fees must have been received by Decemb er 1,2020, the same day the Order was
issued. Second, the grandfathering did not apply only to the change proposed in the
Application-the change from dual meters to single meters-but rather to programmatic changes
that had not yet been proposed. These two aspects of the Order caused considerable confusion
and, ultimately, placed several customers in unreasonable and inequitable situations.3
3 Agripower Solar is petitioning on its own behalf, but Agripower Solar has reason to believe that customers of other
solar installers were put in a similar position. Unforfunately, not all solar installers or distributed-generation
customers have the time, resources, or regulatory sophistication to petition for reconsideration or to otherwise
channel their interests into well-coordinated regulatory efforts. Agripower Solar seeks reconsideration specifically toallow its customers to be grandfathered, but also respectfully requests that the Commission consider that the
proposed 30-day eligibility period is likely to provide relief to similarly situated customers of other installers.
AGRpowER SoLAR's PETrrroN FoR RrcoNsropnerroN - 3
cusrounns luplcrnD BY THE DpCB*rnBn 1,2020 CUrOrr Dlru
Order No. 34854 was served on Decemb er l,2020,just after 12:00 p.m.a Idaho Power's
offices closed at approximately 6:00 p.m. Because the Order proposed legacy treatment for
existing customers, and the financial impacts of the as-yet-un-proposed programmatic changes
were unknown, it was important for Agripower Solar to ensure that its customers were afforded
legacy treatrnent. Immediately upon receiving and reviewing the Order, Agripower Solar began
reviewing its records and checking with its customers to ensure that applications had been filed
and checks written, such that they would be received by close of business'
It is important to note that Agripower Solar did not altetntptto rush and find entirely new
customers to file applications. Rather, Agripower Solar reviewed its records to ensure that its
existingcustomers-many of whom Agripower Solar had been working with for months to
design a system, and some having already spent hundreds of thousands of dollars on
equipment-had their paperwork in order.
Unfortunately, in the compressed timeline, several customers were unable to ensure that
complete applications were received by December 1. This created what Agripower Solar submits
are distinctions between customers based purely on luck (or lack thereof), geographic location,
innocent mistake, or other arbitrary factors. Agripower Solar submits that it would be reasonable
to provide customers thirty days after the service date of the order on reconsideration to ensure
that applications have been filed. Bn the altemative, and at the very least, Agripower Solar
submits that the following customers should be deemed to have filed timely applications and be
afforded le gacy treatment.
a As already explained, Agripower Solar did not intervene in this case. The press release was issued on December 4,
after the deadline for legaiyireatment had passed. Luckily, Russell Schiermeier received a copy of the Order and
immediately forwardedlt to Agripower Solar. If this had not occurred, Agripower Solar's customers would have
unlcnowinglymissed the grandiatirering deadline, even though several of their systems were partially applied for, or
in some cises, they had placed applications in the mail. This could have resulted in even more unjust outcomes.
AGRTPOWER SOLEN,S PETTTION FOR RECONSDERATION - 4
1. Darrell and Jordan Funk, Double Eagle Dairy. Agripower Solar first met with
the Funks in June of this year. Double Eagle Dairy ultimately agreed to purchase 20, 100-
kilowatt solar systems. Double Eagle Dairy and Agripower Solar eventually formalized their
agreement in eight separate contracts, all signed on Novernber 13,2020. In reliance on these
contracts, Agripower Solar expended considerable funds to build out the system. On or about
July 31, 2020, Agripower Solar made an initial delivery of 300 solar modules, costing
approximately $65,000.s After the initial delivery, and after the confracts were signed,
Agripower Solar delivered an additional2054 modules at a cost of over $450,000. In all, around
half a million dollars' worth of components and equipment were already onsite for this customer
when Order No. 34854 was announced.
Given the extensive nature of its plans, Double Eagle Dary filed a number of
applications to Idaho Power in the months preceding the Commission's Order. Unfortunately,
because of miscommunication and various changes to the customer's plans, there was confusion
regarding which applications had been filed months earlier and which had yet to be filed. As a
result of this confusion, 7 applications were mistakenly left unsubmitted when the Commission's
December 1 cutoff passed. Notably, the underlying contracts for each of these 7 applications had
already been signed weeks earlier, on November 13. Again, the only reason that the applications
were not submitted was because of miscommunication and confusion regarding which
applications still needed to be submitted. The Funks even called Agripower Solar on December 1
to ensure that all their applications had been submitted. Upon discovering the mistake,
Agripower Solar submitted those 7 applications to Idaho Power on December 2,2020.
Applytng the December I,2020 grandfathering date would leave Double Eagle Dairy
5 Agripower Solar made this initial delivery based on a hand-shake deal---common in the agricultural sector-before
the contracts were signed.
AcRpowrn SoLen's PBurroN FoR REcoNSDeRArroN - 5
with l3 grandfathered systems and 7 non-grandfathered systems.6 Because the replacement
program for the remaining 7 systems is not known---{r even proposed-Double Eagle Dairy is
unable to effectively determine how this split-grandfathered system should be implemented;
whether it makes sense to alter the plans for the grandfathered sites only; or whether to proceed
with the generation program at all.
Double Eagle Dairy has also submitted additional applications to Idaho Power since the
Commission's Order was released; all for the same project. But again, because of the uncertainty
surrounding the replacement program, Double Eagle Dairy is unable to make informed decisions
regarding the overall project. The Commission should grant grandfathered status to all of Double
Eagle Dairy's applications. Ruling otherwise would leave Double Eagle Dairy with a system that
is only part-grandfathered even though Double Eagle Dairy expended hundreds of thousands of
dollars on the system-an inequitable result caused by the simple fact that Double Eagle Dairy's
project was ongoing at the time of the Commission's Order.
2. Craig Giles, Giles & Meyers Farms. Giles & Meyers Farms is another customer
of Agripower Solar that had prepared 19 applications to submit to Idaho Power. On the day
preceding the Commission's Order, Agripower Solar advised Craig Giles to submit his
applications via overnight mail.7 However, Mr. Giles was unable to deliver the applications to
FedEx before its overnight deadline that evening. Instead, Mr. Giles placed the applications in
overnight mail the morning of December l, before the Commission convened to release its
6 Double Eagle Dairy initially ptanned to install 35 systems total: the 20 systems for which contracts had already
been signed, and an additional 15 systems after that. Even when all 35 systems are fully installed, they will only
represent roughly half of Double Eagle Dairy's energy consumption.
7 At the time, Agripower Solar did not know that the Commission's impending order would set the cutoff date at
December l. It recommended submitting the applications via ovemight mail simply as a matter of best business
practice.
AcnpowBn SOLAN,S PETITION FOR RECONSNBNETION - 6
Order.S The applications unfortunately were not received by Idaho Power until December 2.
Thus, as the Order currently stands, Mr. Giles' entire system would not be treated as
grandfathered because the applications arrived late in the mail.
Another customer of Agripower Solar, the Meyers, managed to meet the FedEx deadline
for overnight mail on the evening before the Commission's Order was released. The Meyers'
applications arrived on December 1,2020 while Giles & Meyers Farms' applications arrived the
following day. Both customers placed their applications in the mail before the Commission's
Order was announced, and neither customer, nor Agripower Solar, could have anticipated that
December I would be the cutoff date for legacy treatment. Nevertheless, the Meyers'
applications were accepted and Giles & Meyers Farms' applications were not. From the
customers' perspective, it wasn't attentiveness to the Commission's Order that ultimately
decided whose applications were grandfathered in, but rather, dumb luck.
Giles & Meyers Farms' situation is also a prime example of the discrimination that many
rural applicants have faced as a result of the Commission's December I grandfathering date. If
Giles & Meyers Farms was located in the Treasure Valley, it could have easily hand-delivered
the applications to Idaho Power the day before the Order came out. However, because Giles &
Meyers Farms is located in Hansen, Idaho, it was not able to get the applications to Idaho Power
by mail until December 2.
3. Perry Van Tassell, Hidden Valley Organic. Hidden Valley was originally a
customer of another contractor, Gietzen Electric, which submitted all the necessary applications.
However, while the application fees hadbeenplaced in the mail on December l,2020,they were
not received by Idaho Power until December 4. Idaho Power has since explained that, as a result
8 Enclosed as Exhibit A is the FedEx tracking information for Giles & Meyers Farms' mailed applications. Note
how the applications were placed in the mail at I 0: I 8 a.m. on the morning of December l, 2020, before the
Commission released its Order.
AcRpowrn SoLAR's PBrnroN ronRrcoNsmsRArroN - 7
of the fees' late arrival, Hidden Valley's 14 applications would not be accepted or reviewed.
Hidden Valley has since requested that Agripower Solar install seven, dual-axis tracker systems.
However, under the current Order, Hidden Valley would not be eligible for grandfathering.
Hidden Valley is another example of a customer who, but for its location outside the Treasure
Valley, could have easily hand-delivered its application fees and met the December I cutoff date.
4. Russell Patterson. Upon learning of the deadline, Agripower Solar realized that
to obtain grandfathered status, Idaho Power hadto physically receive checks by 6:00 p.m. on
December l,z}z}.Agripower Solar's employees (and most customers) were located several
hours away from Boise and could not deliver hard copies of checks by the deadline. In near
desperation, Agripower Solar reached out to Russell Schiermeier, a customer and resident of
Bruneau, Idaho, and explained the situation. Mr. Schiermeier dropped everything, rushed to
Idaho Power's office, and began to write physical checks. Mr. Schiermeier graciously
volunteered not only to write checks for his own applications, but also for other customers of
Agripower Solar.e Mr. Schiermeier wrote nearly 100 checks that day, as fast as he could. Despite
the valiant effort, Mr. Schiermeier failed to identify in the "memo" field that any of these checks
were for Russell Patterson's personal installations. Mr. Patterson intended to submit three
applications for three 100-kw systems. Many of the customers for whom the approximately 100
checks were written have since determined to withdraw their applications. However, Idaho
Power has still refused to apply any of these submittedfunds, evenfor withdrawn applicants,
toward Mr. Patterson's system. Because Mr. Schiermeier failed to write a check with Mr.
Patterson's name in the "memo" field, Idaho Power has determined that Mr. Patterson is not
eli gible for grandfathering.
e perhaps demonstrating the remarkable trust and dedication of many engaged in the agricultural sector, Mr.
Schiermeier agreedto personally witechecks not only for himself, but for others, with the understanding that he
would be reimbursed at a later date.
AcRpowER SoteR's PrrnIoN FoR RECoNSnrnertoN - 8
5. Greg Nickell. Agripower Solar had been working with Greg Nickell since early
in the summer of this year. Mr. Nickell intended to arrange five solar installations on property
that he had leased to two farmers. Because the property upon which the installations would be
installed was leased, the applications had to be signed by the lessees, not Mr. Nickell. Upon
learning of the grandfathering deadline on December 1, Mr. Nickell attempted to obtain
signatures from the lessees. The lessee for three of the five installations signed. However, the
lessee for the other two installations could not be reached that afternoon. Under the Order, Mr.
Nickell now has three systems that are grandfathered and two that are not. This result is
predicated not on Mr. Nickell's failure to heed and respond promptly to the Commission,s Order,
but sheer misfortune.
Rrqursr FoR RECoNSTDERATToN
In Order No. 34854, the Commission decided to provide legacy treatment (or
grandfathering) for "existing Schedule 84 customer-generators." Order No. 34853 at I l. Under
Order No. 34853, the legacy treatment appears to apply not only to the changes proposed in the
Application-a change from a dual-meter to a single-meter configuration-but also to larger
programmatic changes that weren't proposed in the Application. See id. at 10 (suggesting that
legacy treatment approved in this case will apply to "successor program,').
The Order defines 'oexisting Schedule 84 customer-generators" as "those that have
interconnected their system by the service date of this Order, or who have applied for
interconnection under Schedule 84 by the service date of this Order and interconnect their system
within one year." Id. at 12.
AcRrpowBR SoLAR's PernroN non RBcoNsnnnerroN - 9
1. Etigibility for grandfathering status should extend to applications postmarked by
thirty days after the order on reconsideration'
As discussed above, Order No. 34853 was served several hours before its legacy
treatment cutoff took effect. And it granted legacy freatnent not just for the change proposed in
the Application-the change from two meters to one meter-but rather for as-yet-un-proposed
future programmatic changes.
The compressed timeframe, coupled with the heightened importance of grandfathering,
resulted in Agripower Solar's rush to confirm its customers qualified for grandfathering. This
was not a rush for Agripower Solar to recruit entirely new customers; it was a rush to ensure that
Agripower Solar's existingcustomers had properly filled out and submitted their applications
and related fees.
Because Agripower Solar serves customers primarily located outside of the Treasure
Valley, it was not simply a matter of urging customers to visit Idaho Power's headquarters,
submit an application, and fill out a check. Instead, Agripower Solar had to scramble for ways to
hand-deliver applications and checks. These circumstances resulted in several customers being
denied legacy status based on geographical location, bad luck, innocent mistakes, or other
arbitrary factors. For example, Agripower Solar believed it had submitted all applications for
Double Eagle Dairy, but some, although completed, had mistakenly fallen through the cracks. As
a result, the majority of Double Eagle Dairy's locations are eligible for grandfathering, while
some are not. A reasonable period of time to double-check paperwork would avoid this senseless
hardship.
Even more strikingly, Craig Giles and Perry Van Tassell placed applications in the mail
on December 1, before the 6:00 p.m. deadline. Mr. Giles even placed his applications in the mail
before he knew of the December I cutoff. Their applications were not received until after
AcRpowER SoLen's PprIrtoN FoRRECoNSDsnertou - 10
December 1. honically-and unjustly-the fact that they acted earlier in the day on December I
precluded legacy treatrnent. Had these customers lived in the Treasure Valley, they could have
easily submitted their applications and fees by visiting Idaho Power's office in person. But by the
time they learned of the December I cutoff date, it was too late.
In addition, the narow window of time precluded Mr. Nickell from accomplishing the
minor administrative task of obtaining a signature from a second lessee, due to the lessee,s
circumstantial unavailability on that date.
Agripower Solar respectfully submits that the cutofffor legacy treatment should be
governed by more than bad luck, clerical errors, or geographical location. This is particularly
true for rural and agricultural Schedule 84 customers, who tend to have larger and more complex
net metering systems. Agripower Solar submits that it would be fair, just, and reasonable to
provide Schedule 84 customers a reasonable time to ensure that the their applications are
properly filled out and submitted. Accordingly, Agripower Solar submits that Schedule g4
customers should be provided legacy heatrnent so long as their applications are post-marked by
thirty days after the service date of an order on reconsideration in this case.
Agripower Solar would not object to a date of less than thirty days. Its goal is simply to
provide customers and installers with a reasonable period of time to complete their applications
and avoid the unfortunate circumstances illustrated above.
2. In the alternative, the customers discussed in this petition should be deemedgrandfathered.
As discussed above, while Agripower Solar is petitioning for reconsideration on behalf of
itself and its own customers, other customers are likely to have found themselves in similar
situations. Providing a reasonable period of time to qualify for grandfathering should cure this
issue across the board.
AcRpowER SoLAR's PBrrrroN poR RncoNsmpRarroN - I I
However, even if the Commission is not inclined to reconsider the cutoffdate in general,
Agripower Solar respectfully requests that the customers identified in this petition be afforded
grandfathered status. These customers did not try to game the system; they did not "rush the
door" with a net metering system planned after learning of the grandfathered date; and they
missed the cutofffor legacy treatment by no fault of their own. It would be fair, just, and
reasonable to afford these customers legacy treatment under the terms of Order No. 34854. This
could be accomplished, for example, by deeming these customers as, constructively or in-fact,
having ,'applied for interconnection under Schedule 84 by the service date of this Order." Order
No. 34854 at 12.
Agripower Solar is amenable to other solutions that protect customers from being denied
legacy treatment due to bad luck, geographical location, or clerical elrors.
Colcr.usroN
For these reasons, Agripower Solar respectfully requests that the Commission
1) reconsider the cutoff date for legacy featnent under Order No. 34854; and 2) allow
customers to qualify for legacy treatment so long as an application under Schedule 84 is
postmarked within thirty days after the Commission seryes its order on reconsideration; or 3) as
an alternative, that the Commission afford the customers identified in this petition legacy
treatment under OrderNo. 34854.
Dated: December 22, 2020.
GTVENS PURSLEY LLP
f *.-----: --. L- z-_*
PrestonN. Carter
Blake W. Ringer
Givens Pursley LLP
Attorneys for Agripower Solar, LLC
AoRpowuR SoLeR's PBrIrtou FoR RECoNSDsRertoN - 12
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AcRpowER Soren's prrrnoN FoR REcoNsTDERATToN _ I 3
CERTIFICATE OF SERVICE
I certify that on December 22,2020,a true and correct copy of the foregoing was served
upon all parties of record in this proceeding via the mailler indicated below:
Commission Staff
Jan Noriyuki, Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg. 8, Ste. 201-A
Boise,ID 83714
j an.noriyuki@puc. idaho. gov
Edward Jewell, Deputy Attorney General
Idaho Public Utilities Commission
1 1331 W. Chinden Blvd., Bldg. 8, Ste. 201-A
Boise, lD 83714
Edward. Jewell@Puc. idaho. gov
Electronic Mail
Electronic Mail
TimothyE. 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 lrrigation 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]
Russell Schiermeier
29393 Davis Road
Bruneau, ID 83604
[e-mail]
Via Electronic Mail
Lisa D. Nordstrom
Regulatory Dockets
Idaho Power ComPanY
1221 West Idaho Street (83702)
P.O. Box 70
Boise,ID 83707
lnordstrom@idahoPower. com
dockets@idahoPower' com
Benjamin J. Otto
Idaho Conversation League
710 North 6ft Street
Boise,Idaho 83702
botto@idahoconservation. org
Idaho Irrigation Pumpers Association, Inc.
c/o Anthony Yankel
12700 Lake Avenue, Unit 2505
Lakewood, Ohio 44107
[e-mail]
AcRpowER SoLen's PsurtoN non RrcoNsIonnerIoN - 14
Abigail R. Germaine
Boise City Attorney's Office
105 N. Capitol Blvd.
P.O. Box 500
Boise,ID 83701-0500
agermarne @cityo fboi se. org
Idaho Sierra Club
c/o Kelsey Jae Nunez
Law for Conscious Leadership
920 N. Clover Drive
Boise, ID 83703
kelsey@kelseyj aenunez. com
Lisa Young
Mike Heckler
Idaho Sierra Club
503 W. Franklin Sheet
Boise, lD 83702
lisa. young@sierraclub. org
Michael.p. heckler@gmail. com
Micron Technology, Inc.
c/o Austin Rueschhoff
Thorvald A. Nelson
Holland & Hart, LLP
555 Seventeenth Street, Suite 3200
Denver, CO 80202
darueschho ff@hollandhart. com
tnelson@hollandhart. com
aclee@hollandhart. com
gl garganoam ai@hollandhart. com
Jim Swier
Micron Technology, Inc.
8000 S. Federal Way
Boise, lD 83707
[e-mail]
/ *------:
Preston N. Carter
AcRpowER SoLAR's PrrnroN ron RECoNSDERATToN - 15