20160406ICL Comments.pdf

Benjamin J. Otto (ISB No. 8292)
710 N 66 Street
Boise,ID 83701
Ph: [phone]x12
Fax [phone]
botto@idahoconservation. org
Attorney for the Idaho Conservation League
IN THE MATTER OF THE
APPLICATION OF ROCKY
MOUNTAIN POWER REQUESTING
AUTHORITY TO MODIFY ELECTRIC
SERVICE SCHEDULE I35 - NET
METERING SERVICE
PAC-E-16-07
ICL Comment
F.ECEIVED
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
COMMENTS
COMES NOW the Idaho Conservation League (ICL) with the following comments regarding
Rocky Mountain Power's (RMP) request to raise the net metering cap. As explained fully below,
ICL encourages the Commission to follow the same logic as applied to Idaho Power's request to
modiff the net metering cap for that utility. Instead of applying a program cap set at an arbitrary
amount of kilowatts, the Commission should find it "reasonable and prudent for the Company to
closely monitor the net metering service and to provide an annual appraisal of the service's status
and impact on the reliability of the Company's system." Order No 32846 at 7.
Net Metering Program Cap
ICL agrees that a possible purpose of capping the net metering capacity is to provide a
check-in point to review the program and make any warranted and reasonable adjustments. ICL
also acknowledges the RMP attempted to calculate a cap that accounted for possible growth in
net metered system until roughly 2018 and proposes a program cap of 2 megawatts. Application
at 7.B:ut, it is system reliability and potential cost impacts that matter, not just a number based
on RMP's vision of potential growth. Two megawatts of net metered systems is simply not a
meaningful number when the eastern portion of RMP's system has 6,910 MW of capacity and
897 MW of reserves, and the westem portion has another 3,221I|l4W of capacity and 4I2 MW of
reserves. PacifiCorp 2015 IRP Update at 31. Even assuming Idaho is 5o/o of PacifiCorp's
system, 2 MW here is de minimus, not a meaningful program cap.
CASE NO. PAC-E-I6-07
IDAHO CONSERVATION LEAGUE
April6,2016
To maintain consistency across Idaho's investor owned utility customers, ICL
recommends the Commission treat RMP just as Idaho Power and decline to set an overall
capacity cap for the net metering program. RMP makes clear in the Company application they
intend to address net metering more fully in 2011, so the Commission already has a time frame
for further check in on the program. Because the program cap is not required to address any
identified reliability issue, and not necessary to ensure a specific time for further program
review, the Commission should not impose an arbitrary limit on the program.
Net Metering Cost Report
As the Commission directed in2003, RMP included along with the request to adjust the
net metering cap a'oreport" on the "differential between the net metering purchase price it pays at
retail sales rates and the wholesale cost of alternative power supplies." Application at 3 - 4.lCL
notes RMP is not requesting any changes to the rates applied to net metering in this case, but
clearly intends to propose changes in the next general rate case. As stakeholders in Idaho prepare
for this next round of net metering debates, ICL submits it is important to make apples-to-apples
comparisons, which comparing retail rates to wholesale power does not achieve.
Retail rates based on cost of service should reflect not just wholesale generation, but all
of the costs to deliver an electron to a specific custorner, properly bill that customer, and
effectively collect said costs. An electron generated by a net-metered system is one that is
immediately useful to the customer, or the next physically closest load. An electron bought on
the wholesale market is not useful to a RMP customer until delivered to the point of use. So,
even if RMP could procure wholesale power as an alternative to net metering, that wholesale
price of generation is just the tip of the cost iceberg. An apples-to-apples comparison would
compare the cost of providing useful electric service to the end user, either from customer sited
generation, excess generation produced at the distribution level, or alternative wholesale
purchases. Comparing the cost of electricity at the point of use to the "average monthly Mid-
Columbia ("Mid-C") wholesale power price is simply not a meaningful or complete comparison.
Further, it is not at all clear that the average monthly Mid-C price has any direct
connection to the value of excess net energy produced and delivered in RMP's Idaho service
territory. There is no showing that RMP has transmission access to deliver this alternate power to
end users in Idaho. There is no attempt to align the timing of excess generation with actual
PAC-E-16-07
ICL Comment
April6,2016
market prices at the same time. To inform stakeholders, ICL recommends the Commission direct
RMP to produce a report that more accurately compares the value of excess net generation
arising from net metering to delivering altemative sources of power to end users in RMP's Idaho
service territory at the same time of the day, month, and year.
Cap on Individual Participation
ICL notes an additional issue that RMP proposes in the tariffs, but not in the Application
- a limit on the total amount of program capacity a single customer may connect, which RMP
proposes to change from 20oh down to 5Yo. First Revision of Tariff Sheet I 3 5. I . In 2003, RMP
explained this provision was intended to "make these schedules available to a wider range of
customers." Order No 29260 qt 3.But RMP offers no explanation for changing this provision in
a manner that will only limit the ability of individual customers to participate in the program. As
ICL explains above, the proposed 2 megawatt program cap is essentially an arbitrary number not
based on any indication of system reliability needs or any meaningful analysis of costs. And the
limit on individual customers to deploy no more than5%o of this total, or 100 kw, is another
arbitrary number untethered to any identified issue. If RMP's goal was truly to "make these
schedules available to a wider range of customers", then the Company would propose a program
cap based on the physical ability of the system to integrate net metered projects and then allow
individual customers to select the size of system best suited to their individual needs.
Instead of layered arbitrary limits on participation, ICL proposes the following as a more
accurate way to facilitate customer participation while preserving the intent of net metering to
allow customers to offset their own loads: each customer may install a system that is no larger
that l20oh of the customer's average monthly load. Applying a cap to individual systems, as
opposed to the program as a whole, allows each customer to design a system that reflects their
use, not adhere to an arbitrary limit. Using this per-system cap will also prevent customers from
building systems intended to generate excess energy. ICL proposes the 120% of average monthly
load cap to account for uncertainty in system performance and growth in household
consumption. Any individual system cap set at less than 100% of energy consumption merely
prohibits individual Idahoans from being self-sufficient. Because an individual system cap is
more equitable, reflects the true purpose of net metering, and still limits the potential for cost
PAC-E-16-07
ICL Comment
April6,2016
shifting issues (if they even exist) ICL recommends the Commission reject RMP's proposal to
limit individual customers to only 100 kw of net metered systems.
Conclusion
ICL recommends the Commission align RMP'S net meter tariff with Idaho Power's by
declining to impose a program wide cap until the utility can demonstrate a meaningful issue with
system reliability. To inform the inevitable debate on rate design, we recofllmend the
Commission order RMP to produce a report that compares the value of excess net generation
arising from net metering to delivering altemative sources of power to end users in RMP's Idaho
service territory at the same time of the day, month, and year. And to make the program available
to the widest set of customers,ICL recommends the Commission impose a per-system cap rather
than cap a customer's share of the program.
Benjamin I. Otto
Idaho Conservation League
CERTIFICATE OF SERVICE
I hereby certifr that on this 6th day of April,2016I delivered true and correct copies of
the foregoing Comments to the following persons via the method of service noted:
Hand delivery:
Iean Jewell
Commission Secretary (Original and seven
copies provided)
Idaho Public Utilities Commission
427 W. Washington St.
Boise,ID 83702-5983
Electronic Mail:
Yvonne R. Hogel
Ted Weston
Rocky Mountain Power
1407 W. North Temple
Salt Lake City, UT 84116
Yvonne.hogle@pacifi corp.com
Ted.weston@pacifi corp.com
PAC-E-16-07
ICL Comment
Benjamin J. Otto
Respectfully submitted,
April6,2016