20201027Comments.pdf

RI.JSSELL SCHIERMEIER
29393 Davis Road
Bruneau, Idaho 83604
Telephone : [phone]
Email [e-mail]
IN TIIE MATTER OF IDAIIO POWER
COMPAI\TY'S APPLICATION FOR
AUTHORITY TO MODIIry SCIIEI}ULE E4'S
METERING REQUIREMENT AND TO
GRANDFATIIER DilSTING CUSTOMERTI
WTTH TWO METERS
':,'r'-Iii.rt.fi'}:at: 'i -- a .d L LJ
". , iii t? Pfi ?t ?9
-.,.-1I:'-1';,:+
; ; ' I :- i*;'l ff. ::-.i. : j'"- ::.: I t rt l.Ia+-ai_-+: *f- t:r; rl tiJti ;
BEFORE THE IDAHO PTIBLIC UTILTNES COMIVilSSION
)
)
)
)
)
))
CASE NO. IPC.E.2O.26
COMMENTS OF INTERVENOR
RUSSELL SCIIIERMEIER
COMES NOW Russell Schiermeier, submits the following comments on Idaho Power's
Application pursuant to the [Notice of Modified Procedure, Order No.34777, issued on
September 4,2020'l and pursuant to the Idaho Public Utilities Commission's Rules of Pmcedure.
1. BACKGROTJND
In the whter of 2008, I had the to purchase an 800-acre farm outside the town of
Bruoearq ldaho. The farm was underperforming production ground with an antiquated irrigation
system with extremely poor soil health and fcrtility. With a limited background in agriculture, I
have worked the last 12 years to focus sa utiliTing resources and effrciently turning the alkali
ground of Owyhee County to highly efficient, highly productive farm ground. One of the most
important resources has been Idaho Power. The consistency and affordability of their product is
pammount to my faming operation. Since I began farming, the energy cost has ranged &om
$165/acre to $188/acre, contributingto25-350/" of the cost of production. Idaho Power's
Production Statrend Field Advisors were crucial in the design and construction of an energy
efficient irrigation system. It focuses on the minimization ofwasted energy with variable
frequency drives, proper pump and pipe sizing, utilization of lrrigation PEAK rewards program
and Energy Efficiency programs. My current operation spans 3200 acres utilizes 21 pumps,
Russell Schiermeier Comments IPC-E-20-26 I 10t27t2020
2890hp,4 variable frequency drives and 36 radio-controlled low-pressure center inigation
pivots. The systern is specifically designed 1s minimize use of water, minimize power
consumption, aod decrease labor costs.
Another important partner in the conversion to energy conservation was the Natural Resource
Conservation Service. Utili-ing conservation practices focused on irrigation advancements and
soil health practices. The net metering is my latest advancement in pursuit of efficiency to
compete on a national scale in ldaho agriculture.
It2017 I met with the ldaho Power's Renewable Energy Speciatist regarding the energy
efficiency project available like the Enerry Efficiency Program and PEAK Rewards. At the
meetin& I leanred thar the Net Metering Program offered to irrigation customers with the
Iimitation of 100-kW dual meter systems that could be aggregated monthly with a l:l kWh
credit. Fortunately, my operation spans 23 meters over 3200 acres of continuous land and met
the requirement to size the system to offset a portion of the lifting and pressurization of the
irrigation system. Due to the 100-kW limitation, the system utilized 8 sites to be aggregated over
the same feeder line to offset approximately 1000 of the 2890 hp. The 100-kW limitation added a
few levels of cornplexity and specific sites were chosen to utilize unproductive or unfarmed land.
After a thorough analysis of feasibility of theNet Metering Prograrn, a system was designed with
a specific criterion: Address madmum production during inigation season, Iongevity of a system
and minimization of impact on agdcultural gound. After visiting solar systems across the United
Slates, I concluded that the use of a dual axis system was the most economical in regard to the
value of solax production, longest lifespan and minimized the fooprint required to accomplish
the design criteria. My system utilizes panels with a 21-year warrantied production life. The solar
system was designed to the specific criteria of the Net Metering Program. It focuses on the
efficiency of my irrigation system and to help minimize my load on the system dwing the
irrigation season. This is very similar the trrigation PEAK Rewards program, supplementing
demaad management and reducing peak load.
One of the essential components to the economic viability of the project was the Federal Tax
Credits from the U.S. Departnrent of Energy Solar Energy Technologies Office and the Rural
Russell Schiermeier Comments IPC-E-20-26 Z ta12712020
Energy for America Program. These proglams "help increase Americao energy independence by
increasing the private sector supply of renewable energy and decreasing the demand of energy
through energy efficiency improvernents. Over time, these investuents can also help Iower the
cost of e,nergy for small businesses and agricultural producers."I Like agriculnral programs from
the Natural Resource Conservation Service and Idaho Power's Energy Efliciency Program, these
programs are established to help promote conservation of energy and encouraging development
of infiastructure to utilize technology or practices in opimizing agricultural practices.
SpecificallR the programs were utilized and directly funded local work to be applied in Idaho
agriculture.
My 800-k\M net metered solar system was completed March of 2019. Later tlat month,
Idaho Power announced 100/o clean energy goal. I was thenpersonally informed ldaho Power
would be filing a case with Public Utility Commission to alter the Schedule 84 Net Metering
Program and suspend Schedule 84 services. On April 56, Case IPC-E-19-15 was filled. After
researching the case and calculating the economics of hiring legal representation, I decided to
intervene and to represent myself and my project due to economic constraints. The timing of the
case was exceedingly difficult to adhere to during my farming season, oflen stopping harvest to
attend the montbly meetings. The Commission Staff and Idaho Power did an excellent job of
accommodating my schedule.
In the case, I learned that Idaho Powers had a l'ew concerns that specifically effected my
operation. One being the concem *[t]hrough conversation with CI&I custometrs, the Company
understands that there are instances where installers have presented customers with payback
periods of as little as five years - when inaccurate assumptions are corrwted, the payback
increases in some cases to over 25 years.":2 Idaho Power also included a parnphlet in the
September 2019 billing statements that addressed customer generation. The pamphlet addressed
cost versus bcnefits and return on investnents, calculating the Approximate Solar Payback Time
TUSDA Rural Developnent Rural Enerry fm America Program Energ5r Systems & Enerry Efficiency Improvement
Guaranteed Loans and Gran* Overview
2 tdaho Power coruncnts IFC -E-19-15 page 9
Russell Schiermeier Comments IPC-E-20-26 3 to/27t2020
rangurg from 16 to 29 years3. The second concern addressed "(iaming of Meter Agglegation."
As stated before, my system was specifically designed with Idaho Power to utilize the allowed
aggregation rules to offset a portion of my annual system loads restricted by the 100-kU/
requirernent. As a system, the project offsets less that 40% of my actual loa4 bd Idaho Power
argued in IPC -E-19-15, "the current criteria of meter aggregation incentivizes these customers to
oversize their systerns in order to generate Excess Net Energy to be transferred to other sites,
rattrer than installing generation that is more aligued with the customer's usage needs."a [n Order
34059, the Public Utility Commission addressed IPC-E-18-15 conceming the grandfathering of
existing customers, and found they'tnake this distinction based on olu finding that customers
who installed on-site generation understood that rates for consumption could change, and
recognized that the value of the l:l monthly kWh offset would change in value along with the
rates for consumption's. Following of the Order for Case IPC-E-18-15, a notice of withdrawal of
application on March 17,2A20 was filed addressing the future of my project and Schedule 84
customers.
2. POSITION/ARGUMEM
In Case IPC-E-20-26, there are 3 concems that directly affect my farming operation and
solar net metering sites:
I. GRA}IDFATHERING EXTSTING CUSTOMERS WITH TWO METERS
As sAted above, my system was specially designed to the design criteria of offseting a
portion of my inigation load on my faruU utiliTing aggregation. The process was very in
depth in physical and economic analysis to detetmine economic viability for my farming
operation, using long standing federal incentives and grants. It was not until weeks after my
project passed county, State of Ldaho Electrical and ldaho Power inspections, did I become
aware ofthe drastic alteration proposed to the New Metering Program. I have encourage
analysis and have offered any dataneeded, production/cost/management wise to Idaho Power
3 Idaho Powen Idaho lrigationNews September 2019
4 ldaho Power comments IPC-E-1915 page I I
5 OrderNo.34509 page 14
Russell Schiermeier Comments IPC-E-2A'26 4 1012712020
and interested parties to create and encourage assessment of the progam and its potential to a
power grid system that is seeing unprecedented growth in the residential sector.Idaho
Power's identification of different desrgn criteria is an appreciated acknowledgment ofthe
difference of proposed singls'mgter changes as well as possible change to non l:l kWh
monthly aggregation. My system is configured with the monthly billing program with the
expectation of a l:l kWh credit. It was sized, designed and consfructed specifically to the
constraints, and would not align with a different progrun, costing our farming operation
financial losses for post design alterations. If a new Net Metering Program is defined and
approvd one could configure to those specifications. To address the time requested of
maximum of l0 years, I would be suffering a drastically different cost recovery if the
approved operational system were forced to conform to a criterion it was not designed for.
Moving to a single meter would not alter the syslerns much, however, the I : I kWh credit
from sites spccifically dcsigned to aggregatc to larger load sitcs (sometimes fcct away) woutd
disnrpt the economic design of those specific systems. The possible implementation of a
different criteria would essentially make approved sites economically unfeasible. My system
was designed specifically for longevity in an agricultural setting, emphasizing quality of
equipment warrantied for 25 years. [n comparison to the residential dirg, our kWh credit
value is approximately 60Ya of that value plus demand charge that is 25-30o/o of the monthly
energy cost resulting in an equivalent payback period of 55.5 years relative to residential in
IPC-E-18-15 treatrrent. A difference of 45.5 years does not align with the treatrnent of Net
Metering customers depending on offsetting residential to agriculture load. As stated before,
Idaho Power has emphasized in testimony and literature of a 16 to 28-year retum.6
2. MODIFICATIONS TO METERING REQUIREMENT
A single-meter conversion does not create any issues with designs going forward. The
system would allow for denrand charges to be possibly offset in operation that do not operate
during sundown periods. In inigation, the demand charge is metered monthly and is
preserved with single or dual-meter configurarions. The movement of l:l kWh credit to an
export rate would drastically change my current design and alter the economics dramatically,
6 ldaho Power comments IPC -E- I 9- I 5 page 9
Russell Schiermeier Comments IPC-E-20-26 5 10t2712020
Due to the larger pump loads associated with agriculture, the l0&kW restriction causes
aggegation to become very imfortant and could be mitigated by allowing pump locations to
be sized for their specific load rather than arbitrary 100-kW requirement. On my project
alone, that would have focused the design and eliminated the need for 3 designed aggregation
sites. Due to the uncertainty of energy credit value, without a complete Net Meteriag
program, an accurate economic analysis is exceedingly difficult to achieve and hence, will be
difficult for inigatom to use. With sunsetting Federal Investnent Tax Credits and
competitive REAP dollars, these opportunities for farmers to invest in infrasfucture in our
state could be squandered.
3. UNDERTAKE A SOLAR COST AND BENEFITS STUDY
Through the development of my farm, I have worked on practices and equipment to
optimize value on my operation. The solar aspect has been another step in the ongoing
advancement As one of the larger self-generation sites in the Schedule 84 sector, I hope to
create data that can be used by farmer and Idaho Power to find a system that benefits both
parties. Until 2018, there was limited data on solar sites in agriculture, I think the
advancement of solar technology can be utilized to benefit the Idaho famrer wtrile helping
Idaho's large influx of residential growttr. In the cases I was involved witb a cost and benefit
study would have allowed for real advancernent in policy. Often, anecdotal e:ramples were
used in public comments or publication that referenced skewed data on payback or cost to
non-solar irrigators- A concrete study would allow for accurate analysis of systems.
3. Conclusion
Idaho Power's rcquest to address the grandfathering of existing customers is the correct way
to approach changing the l8-year-oldNet Metering program. Testimony on October 13th, 2020
indicated farmers have the sailre consems I do. We are looking to control cost of irrigation and
invest in solar under the current design criteria- Just like the residential customers were
addressed in IPC -E-l ll-15, the inigation customers were underthe same understanding and
could have been addressed under the IPC-E- 19- I 5 case. The arbitrary 1 0-year period does not
Russell Schiermeier Comments IPC-E-20-26 6 tu27n020
align return on invesfinent analysis or equipment design tife. Alignment with the Ipc-E-lg-15
ruling should be used.
Agriculture in Idaho has changed since I begm in 2008. The opportunity to build a farm
during the changing period has allowed me to adapt to a new farming system focused on
efficiency of production with a transition to consenation goals. Working with Idatro power has
been an honor and one of my operation's biggest assets. Nationally, ldatro has an agriculfural
advantage over most ofthe county with its reliable power and water infrastructtre. Being able to
utilize unused ground to trarvest the sun's energy at the pump site is a big opportunity for
farmers. The Net Metering progam is a unique opporttmity [o recover investuent in our land
and continue the most effrcient irrigation system possible.
Unfortunately, there has not bc an agricultuml group that has represented my interest, or
other frrmers interested in a solar component to farming. This void in the agricultural
community required me to learn how to protect my invesfinent and voice- The Public Utility
Commission Staff has been an outstanding resouroe and I feel like their interaction has been
balanced to protect interests. The intervenor process has shown to be a process that has atlowed
my concems to be heard and addressed. Moving forward,l would hope experience fromthe farm
field is used to optimize a program that benefits the power gdd and the economy. I am interested
in the advancement of conservation and sustainable farming and look forward to a strong Idaho
agricultural industry.
Respectfully submitted this 27 day of October2020.
Farmer/Owner Schiermeier Farns
Russell Schiermeier Comments IPC-E-20-26 7 rc127n020
CERTIFICATE OF SERVICE
I I{EREBY CERTIIY that I have this day October 27,21zL,served the foregoing IPC-E-2026
upon all parties of record inthis p,rcceeding by email to:
Idaho Power Company:
LisaNordstrom
Timothy E. Tatum
Cornie Aschenbrenner
Regulatory Dockets
Idaho Power Company
l22t West Idaho Street
Boise,Idatro 83702
I nordlirom,,?;i daho rrower. cont
ttatum Q--ti dah opowe r. com
cashenbrenn cf i*.i dahopow er. c otlt
docketst?i idahopr:rt er.com
Commission Stefr:
Edward Jewell
Deputy Attorney General
Idaho Public Utilities Commission
I 1331 W. Chinden Blvd.. Bldg No. 8, Suite 201-A (83714)
PO Box 83720
Boise, ID 83720-0074
Edwardj ewll@puc. idaho.gov
The City of Boise:
Abigail R Germaine
Deputy City Attomey
BOISE CITY ATTORNEYS OFFICE
150 N. Capitol Blvd.
P.O. Box 500 Boise,Idaho 83701 -0500
Email: agermai ne,al )cit]'-oibo isg. org
The Idaho Conseration League:
Benjamin J. Otto
Russell Schiermeier Comments IPC'F-20'26 I 1012712024
Idaho Conseryation League
710 N. 6th Steet
Boise,Idaho 83702
[e-mail]
The Idaho lrrigatton Pumpers Association:
Eric L. Olseir
ECHO HAWK & OLSEN, PLLC
505 Pershing Ave., Ste. 100
P.O. Box 6l 19
Pocatello,Idaho 83205
Email : [e-mail]
Anthony Yenkel
l27OO Lake Avenue, Unit 2505
Lakewood, Ohio 44107
Email: [e-mail]
Idaho Sierra Club
Lisa Young
Mike Heckler
503 W Franklin St
Boise,ID 83702
I isa "younsf4.sierraclub.or g
mickael.p. hecklcr@gmai l.com
Micron Technoloryr lnc:
Jim Swier
8000 South Federal Way
Boise,ID 83707
is*ier,lirmicron.com
Austin Rueschhoff
Thorval A. Nelson
Holland& rlafi, LLP
Dorver, CO 80202
d aru e sc h h o flfg,jho I I andhart. com
tnelsonfrl ho I I andhart.com
ac I ee{4ho I I andhart. c om.
g I garsanoa(nari{Ahollandhard.com t
Russell farmer/owner Schiermeier Farms
Russell Schiermeier Comments IPC-E-20-26 9 10127t202a