20160406Comments.pdf

KARL T. KLEIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BARNO. 5156
Street Address for Express Mail:
472W. WASHINGTON
BOISE, IDAHO 83702-5983
Attomey for the Commission Staff
IN THE MATTER OF PACIFICORP DBA
ROCKY MOUNTAIN POWER'S APPLICATION
TO MODIFY ELECTRIC SERVICE SCHEDULE
135 _ NET METERING SERYICE
ftTC E IVED
2016 AI'n -6 AH ll: I 0
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BEFORE THE IDAHO PUBLIC UTILTTIES COMMISSION
CASE NO. PAC.E.16.O7
COMMENTS OF THE
COMMISSION STAFF
The Staff of the Idaho Public Utilities Commission comments as follows on Rocky
Mountain Power' s Application.
BACKGROUND
On February 29,2016, Rocky Mountain Power ("Company") applied to the Commission
for authority to modify Electric Service Schedule No. 135 - Net Metering Service by raising the
current participation cap from 714 kilowatts ("kW") to 2,000 kW. The Company explains that it
began offering net metering service to customers in 2003 pursuant to Commission Order No.
29260, which capped participation in the net metering service at714 kW. The Order also
indicated that the cap should be reviewed when that limit is reached. In its Application, the
Company reports that, as of December 3 I , 2015, participation in the net metering service has
exceeded the 714 kW cap, with 161 customers on the net metering service having 1,049 kW of
interconnected load.
STAFF COMMENTS APRIL 6,2016
The Company explains that it wants to increase the cap, instead of removing the cap,
because the cap is a useful check point for the Company to report to the Commission on the
extent to which the Company and non-participating customers are subsidizingnet metering
customers. The Company states the subsidy currently is a minor part of total Idaho retail
revenue. But the subsidy will need to be addressed in the future. The Company thus proposes to
maintain a cap by modifying Schedule 135 to raise the cap to 2,000 kW. The Company proposes
that the changes take effect on May 1,2016.
STAFF REVIEW
After reviewing the Company's Application and the Commission's prior decision on a
similar issue raised by Idaho Power, Staff recommends that the Commission remove the cap
instead of increasing it. Stafffurther recommends that the Company file an Annual Net
Metering Report, updating Staff and the Commission on the status of net metering service.
Lastly, Staff recommends that the Commission reject the Company's proposal, not discussed in
the body of the Application, to decrease the total maximum connectivity per customer. Staff s
recommendations are further explained below.
Remove the Net Metering Cap
Staff recommends that the Commission remove the cap and require annual reporting
consistent with the Commission decision for Idaho Power's net metering service in order to
reduce investment disruption and provide appraisals of service impact. By way of background,
the Company began offering net metering service in Idaho through Electric Service Schedule No.
135 - Net Metering Service in 2003. See Order No. 29260. At the time, the Company modeled
its Schedule No. 135 after Idaho Power's net metering Schedule 84. See PacifiCorp's Answer
and Request for Approval of Net Metering Schedule, at 4. Case No. PAC-E-03-04.
Subsequently, on November 30,2072,Idaho Power asked the Commission for authority
to increase its net metering cap from 2.9 megawatts ("MW") to 5.8 MW. The Commission
denied Idaho Power's request, however, and removed the net metering cap altogether:
STAFF COMMENTS APRIL 6,2016
We find that a cap may disrupt and have a chilling effect on the investment in and
installation of distributed generation. Accordingly, we decline to adopt a cap at
this time. That said, we find it reasonable and prudent for [Idaho Power] to
closely monitor the net metering service and to provide an annual appraisal of the
service's status and impact on the reliability of [Idaho Power's] system. Further,
we expect [Idaho Power] to promptly notify us of any changes in the net metering
service that materially affect the system.l
Order No. 32846 at 7 (Case No. IPC-E-12-27)
In the present case, the Company proposes to raise its net metering cap, and not just
remove it, because the Company believes 'othe Commission did not intend the cap to be a hard
cap. . .. Instead the cap was implemented to serve as a check point to report the impacts of net
metering to the Commission." See Application at 14.
The Company's proposal to increase the cap is similar to the request by Idaho Power that
the Commission previously rejected. As in the prior case, the Commission should, therefore,
reject the Company's proposal and instead remove the cap and require annual reporting.
Require an Annual Net Metering Report
While the Company believes a cap serves as a useful check point for the Company to
report to the Commission on the net metering service, Staff prefers an annual net metering report
that guarantees a yearly update of net metering activity. Staff notes that the information
provided by the Company in this case is the first update on net metering the Commission has
received since the inception of Schedule No. 1 3 5 nearly thirteen years ago. Staff further notes
that the Company actually exceeded the cap some time ago with participation at 1,049 kilowatts
at the end of 2015. Consequently, Staff believes that besides ordering the Company to remove
the cap, the Commission should also direct the Company to file an annual report just as it has
directed Idaho Power. The annual report would create transparency in the net metering program,
providing Staff with better information when evaluating possible costs and benefits.
Staff notes that between 2010 and 2015, the number of Schedule 135 customers increased
from 70 to 161 , for a lTYo arrrtual growth rate. Over the same period, name-plate capacity has
increased at a29Yo annual growth rate, from 250 to 1,049 kilowatts, or slightly more than 0.1olo
of the Company's annual Idaho peak load. Staff believes that while the participation level and
I Case No. IPC-E-12-27 Order No. 32846 at7.
STAFF COMMENTS APRIL 6,2016
cost shifting is small, it is sufficiently large to require routine program monitoring to understand
the potential impact on ratepayers.
Therefore, Staff suggests that the net metering annual report discuss the Company's net
metering service, growth in participation, impact on non-net metering customers and potential
impacts to power quality and reliability. The report should include customer count, generator
type, name-plate capacity, total generation and contribution to system peak.
The Company predicts that, by January 1,2018, Schedule 135 participation will grow to
1,800 kilowatts. The Company also plans to ask to modiff its net metering program as part of its
next general rate case. Given that the Company has committed to a general rate case stay-out
with rates effective no sooner than January 1,2018, Staff recommends that the Company's first
report be filed by the end of 2017, or included as part of its next general rate case , whichever is
earlier.
Reject Proposal to Decrease Total Maximum Connectivity per Customer
The Company's Application includes an original copy of Electric Service Schedule No.
135, as well as a modified version showing the proposed changes. The proposed tariff decreases
the total maximum connectivity allowed for each customer from 20Yo to 5Yo of the cumulative
generation nameplate capacity connected under this schedule. The Company's Application does
not discuss the proposed change.
Staff believes that reducing each customer's total maximum connectivity to 5oh conflicts
with the Eligible Generating Plant size listed in the Tariff. Under the tariff s 'Definitions'
section, an "Eligible Generating Plant may not have a generating capacity of more than twenty-
five (25) kilowatts for customers taking service on Schedules 1, 36, 23, or23Aor one hundred
(100) kilowatts for all other customers." Staff notes that, at the current interconnected load of
1,049 kW, a 100 kW Eligible Generating Plant would already exceed 5% of the total load.
According to the tariff, the maximum capacity of a customer's Eligible Generating Plant cannot
be reduced to 5Yo until the cumulative generation nameplate capacity connected under this
schedule reaches 2,000 kW. Staff believes an Annual Net Metering Report would permit the
Company to share any concerns it might have, such as the size of customer systems relative to
the amount of total interconnected load. Staff thus recommends keeping the maximum
cumulative generating capacity per customer at2loh.
STAFF COMMENTS APzuL 6,2016
CONCLUSIONS AND RECOMMENDATIONS
For the above reasons, Staff recommends that the Commission order the Company to: (1)
eliminate rather than increase the net metering cap; (2) file Annual Net Metering Reports
providing information on the status of net metering service with the first filing no later than year
end2017; (3) maintain the limit for cumulative generation nameplate capacity per customer at
20Yo; and (4) file a revised Electric Service Schedule No. 135 that is consistent with the
Commission order.
Respectfully submitted this day of April,2016.
Technical Staff: Michael W. Morrison
Mark Rogers
Umisc/comments/pace I 6.7kkmmmr comments
Deputy Attomey General
STAFF COMMENTS APRIL 6,2016
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 6TH DAY OF APRIL 2016,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NO. PAC-E-16-07, BY MAILING A COPY THEREOF, POSTAGE PREPAID,
TO THE FOLLOWNG:
TED WESTON
ID REG AFFAIRS MANAGER
ROCKY MOUNTAIN POWER
I4O7 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84116
E-MAIL: ted.weston@pacifi com.com
DATA REQUEST RESPONSE CENTER
E.MAIL ONLY:
datarequest@oacifi com.com
YVONNE HOGLE
ASSISTANT GENERAL COI.INSEL
ROCKY MOUNTAIN POWER
1407 WEST NORTH TEMPLE STE 320
SALT LAKE CITY UT 84116
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE