20201027Comments.pdf

JAYME B. SULLTVAN
BOISE CITY ATTORNEY
ABIGAIL R. GERMAINE (ISB No. 9231)
Deputy City Attomey
BOISE CITY ATTORNEY'S OFFICE
150 N. Capitol Blvd.
P.O. Box 500
Boise,ID 83701-0500
Telephone: [phone]
Facsimile: Q08) 384-4454
Email : [e-mail]
Attorney for Intervenor
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR
AUTHORITY TO MODIFY SCHEDULE 84'S
METERING REQUIREMENT AND TO
GRANDFATHER EXISTING CUSTOMERS
WITH TWO METERS
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
Case No. IPC-E-20-26
CITY OF BOISE CITY'S
FORMAL COMMENTS
COMES NOW, the city of Boise City, herein referred to as "Boise City" and pursuant
to Rule 202 of the Rules of Procedure of the Idaho Public Utility Commission (IDAPA
31.01.01.202) and, pursuant to that Notice of Telephonic Public Hearing, Notice of Modified
Procedure, Order No. 34777, filed on September 4, 2020, hereby submits its formal written
comments and states as follows:
l. Idaho Power Company (the "Company") has filed an Application in Case No. IPC-E-
20-26. Boise City has a direct and substantial interest in the outcome of this Application as a
representative of residents and businesses, as the proceeding relates to Boise City's clean energy
CITY OF BOISE CITY'S FORMAL COMMENTS - I
transition plan, Boise's Energy Fufure, which relies on renewable resources including onsite
generation to achieve Boise City's 100% clean electricity goals.
Boise City is also directly impacted by the outcome of these proceedings at four city
facilities (Bown Library!, Foothills Learning Center, Fire Station #9, Twenty Mile South Farm
Administration Building) with onsite generation and net metering under Schedule 84. The short
ten (10) year grandfathering timeline in the proposed Application would impact the financial
considerations that were used to develop the onsite generation at these facilities. The proposed
interconnection requirements would impact at least three of these facilities that currently use a
two-meter interconnection.
Additionally, Boise City owns and operates the Twenty Mile South Farm ("Farm")
where biosolids from our water renewal facilities are land applied. Following land application,
the Farm produces numerous crops that support local and regional grain and feed markets. Crop
production is supported by inigation facilities, including Boise Crty's twenty-four (24) different
Company irrigation service accounts with total usage of 5,614,384 kwh in 2019. Should Boise
City desire to install additional net metered onsite generation facilities, these and other Boise City
accounts are also directly impacted by the proposed changes.
2. On June 19,2020, the Company filed this Application to modiff the metering
Requirement under Schedule 84, Customer Energy Production Net Metering Service ("Schedule
84") to be effective on December l, 2020, or another date as ordered by the Commission
("Effective Date"). The requested modification would remove the two-meter requirement for new
Schedule 84 customers that begin taking service under Schedule 84 on or after the Effective Date.
The Company further requests that simultaneous with the implementation of the single-meter
requirement, the Commission grandfather existing customers and applicants with two-meter
CITY OF BOTSE CITY'S FORMAL COMMENTS - 2
systems under the current one-for-one net metering billing construct provided for in Schedule M,
for a period of no more than ten (10) years. (Application at 1 and 2).
3 . On Decemb er 20, 2019, in Order No. 34509 (IPC-E- I 8- 1 5), the Commission directed
"that the Company shall submit a comprehensive study of the costs and benefits of net metering
to the Commission before any further proposals to change the Company's net-metering
program." Commission Order No. 34509. Boise City believes that the actions proposed herein
with IPC-E-20-26 are premature, considering that this analysis remains incomplete. The
Commission should defer action on the content of this Application until such time that the
analysis ordered by IPC-E-I8-15 is complete and has been fully vetted, analyzedby stakeholders
and the public, and confirmed by the Commission.
4. The proposed modifications in the Application require the implementation of a
single-meter interconnection for all new Schedule 84 customers and that existing customers with
a two-meter interconnection would be grandfathered for a ten-year period (Aschenbrenner Direct
at l4). Boise City recommends that Schedule 84 interconnection requirements remain flexible to
allow customers an option for both a single or two-meter interconnection. While Boise City
acknowledges the Company's comments and preference for a single-meter connection, some
customers may see advantages to a two-meter interconnection, and therefore Boise City supports
the customer's ability to choose the interconnection that best supports their system and the
varying needs of their onsite generation.
5. The proposed modifications in the Application identiff a grandfathering period for
existing and pending schedule 84 customers for a period of ten (10) years with conditions
(Aschenbrenner Direct at20-21). Considering the Commission's decision in Order No. 34509
(IPC-E-18-15) to grandfather residential net metering customers and the substantial investments
made in onsite generation systems by farmers and irrigators, Boise City requests that these
CITY OF BOISE CITY'S FORMAL COMMENTS - 3
Schedule 84 customers be grandfathered indefinitely.
6. Farmers and irrigators play an important role in supporting Demand Side
Management and Peak Load Reduction progftrms and it is important to consider the impacts that
constraints to onsite generation for these customers have on all of ldaho Power's customers and
projected future needs to address peak demand with additional generation. Boise City requests
that the Commission consider these factors in analyzing the requested modifications in the
Application.
7 . On August 21,2002, Order No. 29094 (IPC-E-02-4) established two-meter
interconnection requirements as well as a 100kW cap at each meter point for onsite generation for
Schedule 84 customers. Since that time, Boise City is not aware of any subsequent applications
filed by the Company to address the l00kW cap. Concerns with the 100kW cap were noted in
testimony during the recent public comment sessions held by the Commission in this Case No.
IPC-E-20-26. By contemplating updates to meter interconnection requirements for Schedule 84
customers with onsite generation, the Commission should also evaluate the 100kW cap which
places economic and design constraints on these customers with onsite generation. Boise City
suggests that the issue of the 100kW cap and meter configuration be evaluated in the overall net
metering program analysis that was ordered by the Commission in IPC-E-18-15.
8. Boise City generally supports the comments provided by the Idaho Conservation
Leagoe, Sierra Club, and Idaho Clean Energy Association.
9. In summary, Boise City requests that the Commission defer action on this docket until
the comprehensive study of onsite generation, including the cost and benefits of onsite generation,
rate design, and compensation for net excess energy required by Order No. 34509 (IPC-E- 1 8- I 5),
has been completed. Should the Commission decide not to defer action on this docket, Boise City
CITY OF BOISE CITY'S FORMAL COMMENTS - 4
requests that the Commission: 1) allow customer flexibility for metering and interconnection
requirements; 2) grandfather existing customers indefinitely; and 3) acknowledge the role of onsite
generation towards future generation and peak demand reduction and ensure this Application does
not negatively impact onsite generation customers.
DATED this 27th day of October 2020.
$e
R. Germaine
Deputy City Attomey
CERTIFICATE OT SERVICE
I hereby certiff that I have on this 27th day of October 2020, served the foregoing
documents on all parties of counsel as follows:
JanNoriyuki
Commission Secretary
Idaho Public Utilities Commission
1 133 I West Chinden Boulevard
Building 8, Suite 201-A
PO Box 83720
Boise,lD 83720
i an.norivuki@puc. idaho. gov
g U.S. Mailtr Personal Deliverytr Facsimileg Electronic Means w/ Consenttr Other:
Lisa Nordstrom
Regulatory Dockets
Idaho Power Company
PO Box 70
Boise, D 83707
lnordstrom@ idahopower. com
dockets@ idahopower. com
tr U.S. Mailtr Personal Deliverytr Facsimileg Electronic Means w/ Consenttr Other:
Connie Aschenbrenner
Timothy Tatum
Idaho Power Company
PO Box 70
Boise, lD 83707
caschenbrenner@ idahopower. com
ttatum@ idahopower. com
tr U.S. Mailtr Personal Deliverytr Facsimileg Electronic Means w/ Consenttr Other:
CITY OF BOTSE CITY'S FORMAL COMMENTS - 5
Edward Jewell
Deputy Attomey General
Idaho Public Utilities Commission
11331 West Chinden Boulevard
Building 8, Suite 201-A
PO Box 83720
Boise,ID 83720
edward. i ewell(d.puc. idaho. sov
Eric L. Olsen
ECHO HAWK & OLSEN, PLLC
Attorneys at Law
505 Pershing Avenue Suite 100
PO Box 61 19
Pocatello,ID 83205
[e-mail]
Attorneys for ldaho lrrigation Pumpers
Association, Inc.
Anthony Yankel
12700 Lake Avenue, Unit 2505
Lakewood, OH 44107
[e-mail]
for ldaho lruigation Pumpers Association,
Inc.
Kelsey Jae
Law for Conscious Leadership
920 North Clover Drive
Boise,ID 83703
kelsey@ kelsey.i aenunez. com
Attorneysfor ldaho Sierra Club
Lisa Young
Mike Heckler
503 West Franklin Street
Boise,ID 83702
Li sa. youne (a) s i erraclub. o r g
Michael.p.heckler@ email. com
For Idaho Sierra Club
Benjamin J. Otto
Idaho Conservation League
710 North 6ft Street
Boise,lD 83702
botto (D idahoconservation. ore
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CITY OF BOISE CITY'S FORMAL COMMENTS - 6
Russell Schiermeier
29393 Davis Road
Bruneau,ID 83604
[e-mail]
tr
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U.S. Mail
Personal Delivery
Facsimile
Electronic Means w/ Consent
Other:
Jim Swier
Micron Technology, lnc.
8000 South Federal Way
Boise, D 83707
[e-mail]
U.S. Mail
Personal Delivery
Facsimile
Electronic Means w/ Consent
Other:
Austin Rueschhoff
Thorvald A. Nelson
Attorneys atLaw
Holland & Hart, LLP
555 17ft Street, Suite 3200
Denver, CO 80202
darueschho ff@ hollandhart. com
tnel son@hollandhart. com
aclee@hollandhart. com
el eareanoamari@hollandhart. com
Attorneys for Micron Technologt, Inc.
tr U.S. Mailtr Personal Deliverytr FacsimileV Electronic Means w/ Consenttr Other:
$,tu
Germaine
Deputy City Attomey
CITY OF BOTSE CITY'S FORMAL COMMENTS - 7