20211013Initial Comments.pdf

Joshua Hill
Idaho Solar Owners Network
1625 S. Latah
Boise,ID 83705
P.O. Box 8224
Boise, ID 83707
Telephone: (208) 9l 7-37 57
Email : [e-mail]
Admin copy : toffens@.amsidaho.com
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION TO INITIATE A
MULTI-PHASE COLLABORATIVE PROCESS FOR
THE STUDY OF COSTS, BENEFITS, AND
COMPENSATION OF NET EXCESS ENERGY
ASSOCIATED WITH CUSTOMER ONSITE
GENERATION
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. TPC-E-21-21
IDAHO SOI-AR OWNERS NETWORK
COMMENTS ON CASE
Idaho Solar Owners Network, Intervenor, hereby files comments on Case IPC-E-21-21pursuant
to Rules of Procedure 7l through 75 of the Idaho Public Utilities Commission, ID APA
31.01.01 .071-.075 as follows: The name and address of the intervenor is:
Joshua Hill
Idaho Solar Owners Network
1625 S. Latah
Boise,ID 83705
P.O. Box 8224
Boise, lD 83707
Telephone: [phone]
Email : [e-mail]
Admin copy : tottens@.amsidaho.com
2. Without a comprehensive general rate study to solve the underlying rate issues across all
residential customers, any study of on-site generation customers will result in a discriminatory
analysis. The current rate structure issues prohibit accurate and fair study of on-site generation
customers. On-site generation functions within the largest customer class, and uses that rate
design as its foundation. New rate design for on-site generators cannot be finalized until a new
accurate fixed cost and costs of service to all customers exists within the current rate structure for
all residential customers. We expect that Idaho Power will provide all assumptions and
foundations in this study to be used in future rate studies as we believe that any cost study must
ISON'S COMMENTS - Page I
match the cost for general rates among the larger customer class without on-site generation.
Discriminatory rates must not follow from the outcome of this study. The language of the study
must also be unbiased toward any other customer class.
3. The separate rate class for on-site generation customers is not meant to be discriminatory, and the
study of these customers must properly and fairly assess the benefits of all types of distributed
energy resources @ERs). All DERs should be studied using the same practices that the electric
industry has used to assess the cost effectiveness of long-tenn energy efficiency and demand
response resources. The United States military commonly uses micro-grids and on-site generation
to reduce transmission costs, the current and future value of these type of systems must be
determined. Value must also be provided for all benefits related to on-site generation including
increased resiliency, decreased transmission distance, investment in new generation avoided by
Idaho Power, environmental benefits, land use conservation, economic impact, etc.
4. The value of distributed electricity provided by on-site generators who have also invested in on-
site storage will need to be studied and factored into future rate designs. The study should create
a comprehensive value for access to stored power, specifically values that might be provided in
emergency situations where costs associated with power outages can be avoided. For example -
a network of homes designed with solar and storage could provide power during a blackout to not
only themselves, but potentially a hospital or school to be used as fully micro-grid powered
community center.
5. The cost to serve on-site generation customers due to the value of the kWh's they provide may
be lower than the cost to serve all other customers. There has always been a substantial load and
usage variation among the residential class, even when excluding customers who can self-
generate. For example, usage patterns will be very different for those working at home (a bigger
trend brought on by the pandemic); those working at night; those retired citizens; or stay at home
parents, etc. - but all are classified as residential class. Ifldaho Power undertakes an unbiased
look for groups whose load shapes vary from the class average, rather than singling out solar
customers and searching for a justification to treat them differently, they may find many groups
of users that affect distribution costs even more than solar customers.
6. The utility should distinguish the difference in the lower amount of power a solar customer uses
versus a non-solar customer who has installed energy saving technology, including appliances,
smart devices, increased insulation, etc in order to significantly reduce their power bill.
Justification is needed as to why that form of dropping energy usage should be rated differently
from the lower energy usage caused by solar systems, specifically those that offset only part of
ISON'S PETITION TO INTERVENE - Page 2
customer use, and what effect any forms of energy conservation have on the costs and benefits to
Idaho Power in the transmission and distribution of energy. Lowering peak demand has a value
which should be determined and be applied across all customers.
7. The value of providing electricity to the grid during peak load times for the residential class
should be explored fully. The exports that DG customers deliver to the grid are a generation
service which they provide to the utility, not a service which they receive from the utility. The
utility then delivers those exports to nearby neighboring customers and is fully compensated for
that power even though the costs to distribute to that customer have been drastically reduced,
therefore a true analysis of costs and benefits should recognize that customers farther from any
generation source are more expensive to serve due to distance but are subsidized by those closest
to the source as the rates charged for distribution do not vary by distance. In addition, a solar
customer uses the distribution system less than a regular non-solar customer of comparable size,
and provides the utility with significant benefits by reducing peak loads on the distribution
system. The comprehensive value of infrastructure upgrades by on-site generation customers
must be provided as an outcome of the study.
8. Rates for all customers, including those who install solar should be based on the utility's cost to
deliver power to that customer group. Idaho Power should look at the impact of other rate classes
on overall budget, and other subsidies in other rate classes in a separate general rate case. Ideally,
the outcomes of a general rate case would be used to create a foundational rate for cost of service
to all customer classes and schedules. Any outcome from study of on-site generation customers
should not be used in a general rate case, to avoid discriminatory rates. Customers can install on-
site generation, and these systems can be turned off or removed, either temporarily or
permanently. The basic rates for service therefore cannot vary among these classes.
9. ISON joins the City of Boise comments concerning environmental concerns and processes to
study their impact as listed in their "lnformal Comments on the Proposed Study Design to
Determine the Costs and Benefits of Distributed Generation - IPC-E-21-21". In addition to these
environmental factors, ISON would also like Idaho Power to address impacts on land use -
specifically costs of large scale centralized renewable generation systems versus potentially using
only rooftop surface area to achieve the same goals.
10. The value of Idaho Power capital investments do not expire and customers who have invested in
solar should be given that same consideration and thus. Net metering credits should not expire,
but rather should have a yearly value assigned that customers accumulating them can redeem
rather than having these credits roll forward. The related issue of on-site generation systems being
ISON'S PETITION TO INTERVENE - Page 3
capped, regardless of use, should be eliminated as a result ofthis study. Reasonable values should
be given to "cashing out" credits by customers - as a base, l0% of the value could be taken by
Idaho Power to ensure their profit remains intact, while the remaining value the kWh's were sold
for to other customers is provided to the on-site generation owner.
I l. After completion of the study internally by ldaho Power we suggest that a Technical Advisory
Committee with experts designated by the Company, the Commission, and stakeholders be
convened to select an independent, unbiased third-party to review the conclusions of the study.
Dated this l3th day of October,202l
Joshua Hill, president
ldaho Solar Owners Network
CERTIF'TCATE'- Otr' MAIT,TNG
I HEREBY CERTIFY that on the l3nd day of October 2021,I served a true and correct
copy of the foregoing document(s) upon the following person(s), in the manner indicated:
Joshua Hill
Idaho Solar Owners Network
Electronic mail only (See Order 34781):
IDAHO POWER COMPAI\IY: Lisa D. Nordstrom
@xhibit Nos. 1-100) Idaho Power Company
l22lW. Idaho St. (83702)
PO Box 70
Boise,ID 83707-0070
E-mail: [e-mail]
[e-mail]
Connie Aschenbrenner
Idaho Power Company
l22l W. Idaho St. (83702)
PO Box 70
Boise,ID 83707-0070
E-mail: [e-mail]
ISON'S PETITION TO INTERVENE - Page 4
COMMISSION STAFF: Erick Shaner
(Exhibit Nos. 101-200) Deputy Attorney General
Idaho Public Utilities Commission
I l33l W. Chinden Blvd., Bldg No. 8,
Suite 201-A (83714)
PO Box 83720
Boise, lD 83720-0074
E-mail: [e-mail]
INDUSTRIAL CUSTOMERS OF Peter J. Richardson
IDAIIO POWER: Richardson, Adams, PLLC
(Exhibit Nos. 201-300) 515 N. 27ttr Street
PO Box 7218
Boise, lD 83702
E-mail : [e-mail]
Dr. Don Reading
6070 Hill Road
Boise,ID 83703
E-mail : dreading@m indspring.com
IDAIIYDRO: Tom Arkoosh
(Exhibit Nos.301-400) Arkoosh Law Offices
913 W. River St., Suite 450
P.O. Box 2900
Boise,ID 8370
E-mail : [e-mail]
erin.ceci [e-mail]
IDAHO CONSERVATION LEAGUE: Benjamin J. Otto
(Exhibit Nos. 401-500) Idaho Conservation League
710 N. 6ttr Street
Boise, lD 83702
E-mail: [e-mail]
IDAIIO CLEAN ENERGY ASSOCIATION: Kevin King
(Exhibit Nos.501-600) Idaho Clean Energy Association
POBox2264
Boise, lD 83702
E-mail: [e-mail]
CLEAI\I ENERGY OPPORTUMTIES Michael Heckler
FOR IDAHO: Courtney White
(Exhibit Nos. 601-700) Clean Energy Opportunities for Idaho Inc.
3TTSPlantztion River Dr., Suite 102
Boise,ID 83703
E-mail:
m ike@c leanenergyopportunities. com
courtney@c leanenergyopportunities.com
Kelsey Jae
Law for Conscious Leadership
ISON'S PETITION TO INTERVENE - Page 5
920 N. Clover Dr.
Boise,lD 83703
E-mai I : kelse),@kelseyjae.com
IDAIIO SOLAR OWI\IERS NETWORK: Joshua Hill
(Exhibit Nos. 701-800) Idaho Solar Owners Network
1625 S. Latah
Boise,ID 83705
E-mail : [e-mail]
[e-mail]
MICRON TECHNOLOGY,INC: Jim Swier
(Exhibit Nos. 801-900) Micron Technology, Inc.
8000 South FederalWay
Boise, ID 83707
E-mail: [e-mail]
Austin Rueschhoff
Thorvald A. Nelson
Austin W. Jensen
Holland & Hart, LLP
555 l7t Street Suite 3200
Denver, CO 80202
E-mail: [e-mail]
tnelson@hol landhart.com
awj ensen@hol lan dhart. com
[e-mail]
gl garganoam ari@hol landhart. com
CITY OF BOISE: Ed Jewell
(Exhibit Nos.901-1000) Deputy City Attomey
Boise City Attorney's Office
150 N. Capitol Blvd.
PO Box 500
Boise,ID 83701-0500
E-mail: [e-mail]
boi secityattorney@c ityofboise. org
KIKI LESLIE A. TIDWELL,pTo se: Kiki Leslie A. Tidwell,pro se
(Exhibit Nos. 1001-1100) 704 N. River St. #l
Hailey,ID 83333
E-mail: [e-mail]
IDAIIO IRRIGATION PUMPERS Eric L. Olsen
ASSOCIATION,INC: Echo Hawk & Olsen PLLC
(Exhibit Nos. 1101-1200) 505 Pershing Ave., Suite 100
PO Box 6l 19
Pocatello,ID 83205
E-Mail: [e-mail]
RICHARD E. KLUCKHOHN,pTa se AND fuchard E. Kluckhohn, pro se
WESLEY A. KLUCKHOHN,pTa se: Wesley A. Kluckhohn, pro se
ISON'S PETITION TO TNTERVENE - Page 6
@xhibit Nos. 1201-1300)2564 W. Parkstone Dr
Meridian,ID 83646
E-Mail: [e-mail]
[e-mail]
ABC POWER COMPAI\IY, LLC: Ryan Bushland
@xhibit Nos. 1301-1400) ABC Power Company, LLC
184 W. Chrisfield Dr.
Meridian,ID 83646
E-mail: [e-mail]
Comet Energy, LLC: George Stanton
(Exhibit Nos. 1401-1500) Comet Energy, LLC
13601 W. McMillan Rd, Suite 102
PMB 166
Boise,ID 83713
E-mail: [e-mail]
IDAIIOME SOLAR, LLC: Tyler Grange
@xhibit Nos. 1501-1600) Idahome Solar, LLC
2484 N. Stokesberry Pl. #100
Meridian,ID 83646
E-mail: [e-mail]
ISON'S PETITION TO INTERVENE - Page 7