20200526Comments.pdf

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EDWARD JEWELL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BARNO. 10446
Steet Address for Express Mail:
I133I W CHINDEN BVLD, BLDG 8, SUITE 201-A
BOISE, TD 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
:" , ;r,',",' i5 Fi-l lr: 53
IN THE MATTER OF THE APPLICATION
OF ROCKY MOIINTAIN POWER TO CLOSE
THE NET METERING PROGRAM TO NEW
SERVICE & IMPLEMENT A NET BILLING
PROGRAM TO COMPENSATE CUSTOMERS
GENERATORS FOR EXPORTED ENERGY
CASE NO. PAC.E.Ig.O8
COMMENTS OF THE
COMMISSION STAFF
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STAFF OF the Idaho Public Utilities Commission, by and through its Attorney of
record, Edward Jewell, Deputy Attorney General, submits the following comments.
BACKGROT'ND
On June 14,2019, Rocky Mountain Power, a division of PacifiCorp ("Rocky Mountain
Power" or'oCompany") filed an application requesting the Commission close Electic Service
Schedule 135 -Net Metering Service ("Schedule 135" or'Net Metering Program") to new
customer participation as of December 3l , 2019, and open Electric Service Schedule 1 36 - Net
Billing Service ("Schedule 136" or'Net Billing Program") to new customer participation as of
February 1,2020.
On July 18,2019, the Commission issued a Notice of Application and Notice of
lntervention Deadline. Order No. 34379. Idaho Irrigation Pumpers Association, lnc., Idaho
Conservation League, and Idaho Clean Energy Association, lnc. intervened.
On December20,2019, the Commission issued a final order in IPC-E-18-15 rejecting a
proposed Settlement Agreement for ldaho Power's net metering program. Order No. 34509.
STAFF COMMENTS MAY 26,2020
On February 5,2020, the Commission issued a final order on reconsideration in IPC-E-
18-15 upholding its decision to reject the proposed Settlement Agreement. Order No . 34546.
On March 10,2020, the Parties met to discuss how to proceed with Rocky Mountain
Power's Application in light of the Commission's directives in Order Nos. 34509 and34546
issued in IPC-E-18-15.
On April 23,2020, Rocky Mountain Power submitted a supplernental application
("Supplemental Application") with updated inputs to the proposed export credit rate and an
updated proposal regarding grandfathering treatment for existing customers.
On April 28,2020, Commission Staffpresented a Decision Memorandum at the
Commission's regularly scheduled Decision Meeting outlining the proposed procedure and
schedule agreed to by the parties.
On May 6,2020, the Commission issued OrderNo. 34661which adopted the "two-
phase" approach the Commission ordered for ldaho Power in Order No. 34509 and
recommended by parties in this case. The two-phase approach consists of a study design phase
and a study review phase, with opportunities for public input during both phases. The study
design phase provides the parties and the public the opportunity to comment on the scope and
parameters of the study. Following the study design phase, the Commission will issue an order
establishing the scope and parameters of the study. The Company then will conduct the study
and file it with the Commission. After the Company files the study, the Commission will issue
an order establishing the procedure and schedule for the study review phase. The study review
phase will allow parties and the public to state whether the study was conducted in a credible and
fair manner and whether the study is sufficiently comprehensive to support a well-informed
decision regarding Rocky Mountain Power's net metering service offerings.
Rocky Mountain Power submitted a Supplemental Application in this docket, which
supersedes the Company's original application.
The Company proposes to close its current Net Metering Program to new participants as
of July 31,2020. The Company proposes that Schedule 135 customers remain on Schedule 135
until July 31,2030, grandfathering existing customers to the terms of Schedule 135 for ten years.
Arguments pertaining to the Company's proposed grandfathering treatment for existing
customers will be considered in the study design phase.
STAFF COMMENTS MAY 26,20202
The Company requests the Commission establish Schedule 136 -Net Billing Program
effective September 1,2020. The Company proposes that customers who apply to interconnect
an onsite generation system after July 31,2020 take service under Schedule 136.
The Company states the only difference between its current Schedule 135 and its
proposed Schedule 136 is that under Schedule 136, energy exported to the gnd by a customer
generator would be compensated at an export credit rate ("Export Credit Rate").
The Company requests the Commission open Schedule 136 for new customers as of
September 1,2020, but initially set the Export Credit Rate equivalent to retail energy charges
until the Commission approves an Export Credit Rate.
The Company proposes three components to determine the Export Credit Rate: an energy
component, an avoided line losses component, and an integration cost component.
The Company proposes using the Surrogate Avoided Resource ("SAR") method, with
on-peak and off-peak pricing, to determine the energy value in the Export Credit Rate. The SAR
method is used by the Commission to calculate published avoided cost prices under the Public
Utility Regulatory Policies Act of 1978. The SAR method reflects the costs the utility would
incur if it were to build, operate, and maintain a natural gas fired combined cycle combustion
turbine. Based on 2019 data and the proposed SAR rates set to take effect on June 1,2020,the
Company calculates the average value of the SAR-based energy component at$22.34 per MWh.
For the value of avoided line losses, the Company proposes a value of $3.36 per MWh.
The Company states it must maintain reserve resources to integrate variable resources.
The Company calculates its integration costs, based on its 2019 lntegrated Resource Plan, as
$0.25 per MWh.
The Company and Commission Staffhave committed to holding public workshops after
preliminary comments are filed and before revised comments are filed. The Company states it
will notiSr all customers when the times, dates, and locations of the workshops are finalized.
Due to COVID-I9, these public workshops will include a telephonic option.
The Company proposes to recover exported energy credits for Schedule 135 and
Schedule 136 through the Company's Energy Cost Adjustment Mechanism ("ECAM").
The Company reports abott 1,262 customers with a total of 9.3 megawatts installed
capacity participate under Schedule 135 as of the end of March2020.
3STAFF COMMENTS MAY 26,2020
The Company proposes a one-time non-refundable application fee of $85 be submitted
with the customer's application for on-site generation.
The Company proposes no changes to retail consumption rates in this docket. On
March 26,2020, Rocky Mountain Power filed a Notice of lntent to File a General Rate case.
In its Supplemental Application, the Company states it intends to file a general rate case on
June 1, 2020. Rate design and cost of service issues for consumption will be addressed in that
docket.
STAFF ANALYSIS
Staff s preliminary comments in this matter recommend that the Commission order the
Company to study the components of its net metering progftrm described in more detail below.
However, Stafflooks forward to soliciting and incorporating feedback from the public on each of
these items and adjusting these recommendations based on that input where appropriate.
Grandfathering Existing Net Meterine Customers
The Company proposes to grandfather existing net metering customers on Schedule 135
for 10 years beginning on July 31, 2020. ln contrast, Staffrecommends that existing net
metering customers be grandfathered for 25 years from the date of the relevant Commission
order at the project location. Staff believes that the logic and conclusions reached by the
Commission in OrderNos. 34509 and34546 apply as much to Rocky Mountain Power
customers as they did to Idaho Power net metering customers and should therefore be adopted in
this case. Rocky Mountain customers likely had an expectation that the essential program
structure under which they were installing net metering equipment would remain intact, though
rates for consumption and bill credit could change.
Staff believes a 25-year grandfathering period is fair to existing net metering customers
because it acknowledges the significant investnent many customers made to meet their energy
needs and it is also fair to other customers because the financial impact to them will likely be
small. Staffbelieves the Commission should order the Company to quantiff the dollar amount
expected to be recovered from all non-net metering customers under a reasonable range of export
credits and grandfathering time periods. The Company should also prepare appropriate
schedules showing class allocations and comparing each option to revenues for all rate schedules
4STAFF COMMENTS MAY 26,2020
In its original Application, the Company proposed an alternative to its l0-year
grandfathering proposal. In that altemative, the Company proposed that no net metering
customers would be grandfathered, but that all net metering customers (existing and new) would
move from the current retail rate compensation to the Export Credit Rate compensation over
three years. Staffdoes not believe that grandfathering existing customers is necessarily mutually
exclusive with a fiansition period for new customers. Because a future Export Credit Rate could
be significantly different from the retail rate, it could be reasonable to adopt both policies to limit
disruption and facilitate an orderly phase-in of the new program structure. The Company should
be required to evaluate phase-in options, calculate the dollar amounts expected to be recovered
under each phase-in period studied, and show class allocations with a comparison to revenues for
all rate schedules.
Application Fee
The Company proposes implernenting an $85 application fee for customers requesting
service under Schedule 135 and 136. The goal of an application fee is to ensure that the costs the
Company incurs to process an application for net metering customers are not absorbed by other
customers. To study the proposed application fee, Staffrecommends that the Company provide
the costs the Company has incurred in processing applications for these customers historically
and then calculate an average rate per application. Staffproposes to study this fee by auditing
those costs and the calculation to verifu the application fee is accurate. The Company's
proposed fee is less than the $100 other utilities charge for this service. The audit process to
verifu the fee is relatively straightfor"ward.
Recoverine Export Credit Rates in the ECAM
The Company proposes to recover the Export Credit Rate paid to net metering customers
(both Schedule 135 receiving the retail rate and Schedule 136 receiving an Export Credit Rate)
through the ECAM, which is an annual rate adjustrnent through which the Company recovers
power supply costs. Staffnotes that the method the Company uses to recover these expenses can
have a significant effect on which customer classes pay these costs.
In order to study the Company's ECAM proposal, Staffrecommends the Company
explain the method it currently uses to record net metering bill credit costs, the amount of these
costs, and how these costs would change depending on a range of possible Export Credit Rates
5STAFF COMMENTS MAY 26,2020
that may be approved by the Commission. The Company should then analyze how these costs
have been allocated and recovered between rate classes historically and how they would be
allocated and recovered through the proposed ECAM method.
Export Credit Rate
The Company's Supplemental Application proposes an Export Credit Rate of $22 .34 per
MWh for energy generated to the gnd by Schedule 136 net metering customers. The proposed
Export Credit Rate includes three components: 1) avoided energy costs, 2) avoided line losses,
and 3) integration costs. While Staffbelieves these are reasonable components of an Export
Credit Rate, Staffhas concerns about the data and methods the Company used to calculate these
values. [n addition, Staffalso believes that the Company should study the avoided capacity
costs, avoided transmission and distribution costs, and avoided environmental costs provided by
net metering exported energy to determine if these values should be included in the Export
Credit Rate.
Modeled Data as a Proxyfor Actual Customer Export Data
Staffrecommends that the components of the Export Credit Rate be analyzed using
modeled customer export data until at least one year of customer-generator Advanced Metering
lnfrastructure ("AMI") data becomes available. Although Staffbelieves that it is preferable to
conduct this analysis using actual customer export data, sufficient data will not be available for at
least one year after the Company has deployed AMI meters to its Idaho customer-generators.
Given the Company's current implementation plan, Staffdoes not anticipate that AMI meter data
will be available for at least two years. Hourly export data, or a modeled proxy of it, will be
needed to:
o Evaluate the Company's proposal to use time-differentiated Export Credit Rate
prices.
o Evaluate whether or not it is appropriate to include a capacity credit in the
customer-generators' export credit rate, and if it is appropriate to determine the
value of that credit.
o Determine the financial impacts that proposed compensation structures would
have to differently situated customer-generators.
6STAFF COMMENTS MAY 26,2020
In order to serve as a satisfactory proxy for AMI data, the data will need to provide
accurate hourly estimates of each customer's imports and exports. There should also be some
method for checking the accuracy of the model.
ln its response to Staff s Production Request No. 21, the Company provided modeled
hourly import and export data for each of its Idaho solar customer-generators. The Company
modeled each customer's hourly generation using a widely available solar modeling tool (PV
Watts). The Company then scaled a generic, average household consumption profile so that
modeled monthly imports or exports were equal to the actual monthly billing data for each
customer. The modeled hourly estimates of energy imports and exports can then be used as a
proxy for hourly AMI meter data. Because each customer-generator model is constrained to
match actual net monthly billing data, Staffwill be able to estimate an upper limit on the error
that might exist between modeled energy exports and actual energy exports. For the customer-
generator class, it is likely that the deviation between modeled energy imports/exports and actual
energy imports/exports will be relatively small, and less than the typical annual variation in
exported energy. Because the deviation is likely to be small, Staffbelieves using modeled data
to determine the value of exported energy is reasonable.
However, Staffis less certain about the model's ability to provide proxy data that can be
used to estimate exports during system peaking events. This means that modeled data might not
be sufficient for calculating the capacity value of net metering customers' exported energy. This
calculation is particularly sensitive to assumptions about panel orientation, the amount of power
being consumed by each customer-generator during system peaking events, and the exact time
that system peak occurs. Company records include the name-plate capacity of each customer-
generator's system, but not information about solar panel orientation. The Company model
assumes that all panels face southward. Staffperformed a sensitivity analysis, and found that
there is little difference in the peak production of panels with a true south orientation and those
oriented within about 20 degrees of tue south; however, panels with a large westerly orientation
can contribute substantially more at system peak than those with a tue south orientation.
Because total annual energy production is maximized by orienting panels due-south, it is not
unreasonable to assume that the panels of most customer-generators have a southerly orientation;
however, Staff is unable to confirm that this is actually the case.
7STAFF COMMENTS MAY 26,2020
The Company used Idaho Falls weather data to model all of its Idaho customer-
generators. Staffexplains that relevant weather and solar radiation data for ldaho Falls is more
complete than for other cities in the Company's Idaho service territory because Idaho Falls is
used as a gnd point in the National Solar Radiation Database. Staffbelieves it likely that Idaho
Falls weather is reasonably indicative of the weather in other parts of the Company's ldaho
service territory during summer peaking events.
Because sunmer peaking events typically occur during the late afternoon, when the solar
radiation incident on south-facing solar panels is changing rapidly, the Company's estimates of
any individual solar generator's contribution to system peak are extremely sensitive to
assumptions about the exact amount of power being consumed on-site at the time of system
peak. It is likely that any individual customer's consumption will deviate significantly from the
average consumption profile used in the Company's model, therefore, Staffcannot confirm the
accuracy of the model's exports at system peak. Furthennore, given the available information, it
will be difficult for Staffto determine a meaningful upper limit on the error that could result in
modeled estimates of capacity value.
In summary, it is not possible to provide a thorough quantitative analysis of the
Company's proposed Export Credit Rate without accurate, hourly, customer export data. It will
be at least two years before sufficient data from AMI meters becomes available, so Staffbelieves
it is reasonable to use modeled data as a proxy in the meantime. Staffbelieves the model
provided by the Company to be as accurate as possible given the available data, and that energy
credits calculated using this model will be reasonably accurate; however, Staffis less certain that
capacity credits calculated using modeled data will be as accurate. Staffbelieves that the model
is sufficiently accurate for the current case; however, Staffbelieves that the energy and capacity
values obtained from the model should be updated as soon as AMI data becomes available.
Because the modeled data mimics the data that will be obtained from AMI meters, Staffbelieves
that it should be possible to perform this update using the same methodologies used to derive
energy and capacity values from modeled data.
Avoided Energt Value
The Company proposes to calculate the value of avoided energy for the Export Credit
Rate using the Commission's SAR method adjusted for on-peak and off-peak pricing. Although
STAFF COMMENTS MAY 26,20208
Staff believes it reasonable to calculate the energy values according to on-peak and off-peak
pricing, Staffbelieves that the SAR method is problematic because its energy price assumptions
do not align with the energy price assumptions used in the Company's [RP. The SAR method
uses the U.S. Energy lnformation Administration ("EIA") mountain sector energy price forecast
rather than the energy price forecast used in the Company's IRP. Because the energy price
assumptions for the proposed Exported Credit Rate do not relate to the Company's IRP, they are
not likely to be a reasonable assessment of the costs the Company will avoid. Staffrecommends
that the Company analyze the value of its net metering customers' exported energy using the
price assumptions in its most recently acknowledged IRP.
Staff also notes that the Company's proposed method for valuing avoided energy only
includes 85% of the energy price forecast. The Company maintains that this downward
adjustment is appropriate because net metering exported energy is a non-firm resource.
However, the Company did not provide any analysis, workpapers, sources, or supporting
documentation demonstrating how this value was calculated. Staffrecommends that the
Company provide these calculations and sources so they can be analyzed by Staff, stakeholders,
and the public.
Avoided Capacity Value
The Company's proposed Export Credit Rate does not include a capacity value, nor does
it include a method for studying the capacity value of energy exported to the Company's system
from net metering customers. Staffrecommends that the Company study the capacity value that
customer-generators, as a class, provide to the system. The Loss of Load Probability (LOLP)
methodology is a standard method for estimating capacity value, but a complete LOLP study
requires considerable time and it can be costly.
Although Staff would not object to a LOLP study, Staffbelieves that the capacity value
of customer-generated exports can be determined using the power that is reliably exported to the
Company during peaking events. Staffrecommends using a reliability threshold of 99.5o/o. If,
for example, the analysis determines that customer-generators provide no less than 1.5 MW of
power during 99.5% of the peaking events, then Staffwould recommend using 1.5 MW as the
basis for determining the capacity avoided by the customer-generator class. Staffbelieves that
9STAFF COMMENTS MAY 26,2020
an accurate estimate of the power reliably exported during peaking events can be obtained using
the top 100 peaking events from each of the past 10 years (1,000 peaking events).
In summary, Staffrecommends that the Company formally study capacity value, either
using the Loss of Load Probability method, or using the method described by Staff.
Avoided Line Losses
Staff has reviewed the Company's proposed methodology and calculations to determine
the value of avoided line losses and believes it is reasonable. Staff believes these sources and
calculations should be included in the Company's study but does not recommend any changes
thus far.
Integration Costs
Staff believes that the integration study used by the Company was inappropriate for
determining the integration costs of net metering exported energy, and recommends that
integration charges be set at zero until the Company develops a methodology that is suitable for
net metering exported energy.
lntegration costs are the costs of managing and maintaining adequate reserves to
compensate for unpredictable fluctuations in the output of generation resources. The Company
only collects monthly netted consumption and production data for its net metering customers;
because it does not have actual export data for these customers, it is not possible to conduct an
integration study for this class.
Because the Company does not have exported energy data for its net metering customers,
the Company used values from the Flexible Reserve Studies ("FRS") performed as part of its
annual [RP, which is conducted to determine the integration costs of energy supplied by
commercial wind and solar farms. Staffnotes that commercial solar and wind farms generate
directly into the grid, and that any fluctuations in power must be managed immediately. Net
metering customers, however, consume some or all of the energy they produce on-site to offset
their own energy requirements, so Staffexpects their generation profile to differ substantially
from that of commercial wind and solar generators, and is therefore not a reasonable proxy.
Whether the generation profile of net metering customers is more stable or less stable than that of
STAFF COMMENTS l0 MAY 26,2020
commercial generators cannot be known without actually looking at the actual energy exports
over short time scales, such as five minutes, fifteen minutes, or one hour.
However, the instability of the Company's proposed integration methodology is evident
in the 60 percent difference between integration charges proposed in the Company's original
Application and its Supplemental Application. In its original application, the Company proposed
a $0.64llvlWh integration charge based on the results of the FRS performed as part of its 2017
IRP. Using the FRS from the Company's 2019 IRP, the Company proposed a much lower
integration charge of $0.25llt4Wh. Staffbelieves this dramatic swing shows that the model is not
stable enough to use for net metering purposes.
Staff does not believe that an adequate integration study can be conducted until the
Company has actual energy export data from its net metering customers. Therefore, Staff
recommends that the Company wait to study the integration charge for net metering customers
until the AMI data becomes available, and in the meantime use a zero placeholder.
Avoided Transmission and Distribution Costs
The Company's proposed Export Credit Rate does not include a value for transmission
and distribution costs that could be avoided by the energy exported to the grid by net metering
customers. Staffrecommends that the Company study the costs of transmission and distribution
that can be avoided by energy exported to the gnd by its net metering customers.
Avoided Environmental Costs
The Company's proposed Export Credit Rate does not include a value for environmental
costs that could be avoided by the energy exported to the gnd by net metering customers. Staff
understands that most, if not all, avoided environmental costs included in rates would be
included in the energy costs. However, Staff believes that it is reasonable for the Company to
study any additional avoided costs and benefits not already in rates, including but not limited to
the possible value of Renewable Energy Credit sales. Stafflooks forward to customer input on
this issue.
STAFF COMMENTS 11 MAY 26,2020
Schedule I 36 Implementation Issues
The Company's proposal includes several aspects related to how it intends to implement
Schedule 136 if approved by the Commission. While not all of these aspects can be
quantitatively studied, Staff believes it is useful to discuss these aspects in detail.
Billing Structure
The Company's original Application proposes that exported energy be measured
instantaneously, which would eliminate the need for netting customer generation with customer
consumption. However, this will not be possible until the Company installs AMI meters. Staff
recommends that the Company more fully explain how it proposes to bill customers until AMI is
implemented throughout its Idaho service territory. Staffalso recommends that the Company
explain how the seasonal and time-of-delivery price differences help align customer generated
exported energy with the Company's system needs.
Export Credit Expiration
The Company proposes that Export Credit Rates generated by customers expire annually.
Staffis concemed that the annual expiration of energy credits may unduly deprive customers of
the significant value generated by their net metering investnents. Staff believes that this issue
should be studied to determine the appropriate time frame for credits to expire, if any.
Staffbelieves that a customer generation system designed to primarily offset
consumption rather than produce exported energy may produce a significantly different amount
of energy from year-to-year based on changes in weather and consumption. For example, if the
customer produces a significant amount of export credits in a sunny year, the customer may not
be able to use all of those credits if the subsequent winter is relatively warm. This could penalize
customers for normal variations in weather that are outside their control.
Staffrecommends that the Company provide evidence showing the magnitude, duration,
and value of accumulated export credits so that parties can recommend a reasonable approach to
studying this issue, which should include analyzing a range of longer expiration periods.
Additionally, the Company should explain the need for credits to expire and show how it does or
does not benefit from the expiration of customer export credits.
STAFF COMMENTS t2 MAY 26,2020
Frequency of Export Credit Rate Updates
The Company proposes to update the Export Credit Rate paid to customers annually.
While Staffagrees that more frequent updates more closely track avoided costs, Staffalso
understands that such frequent updates make it more difficult for current net metering customers
to estimate their bills and more diffrcult for solar installers to provide accurate estimates to
prospective net metering customers analyzing a significant invesftnent. Staffbelieves that
participating customers' need for stability should be balanced with the need for regular updates
to accurately hack avoided costs.
Staffrecommends that the Company study the impact of biannual updates as compared to
annual updates to determine if that would strike a fair balance between the two interests.
Smart Inverter Study
Customer-owned and utility-operated smart inverters provide grid benefits and power
quality services that allow the Company to more effectively integrate customer-generated energy
into the grid and provide ancillary benefits, including reactive power control. The Company has
researched and developed a smart inverter policy and rates for its Utah customers, so Staff
recommends that the Company analyze the benefits of applying that policy in its Idaho service
territory.
ln20l7 Rocky Mountain Power took part in a Smart Inverter Project as part of the Utah
Sustainable Transportation and Energy Plan (STEP, SBI l5 54-20-105-l(h)) to investigate the
capabilities and impacts of smart inverters on the Company's distribution system. Utah Public
Service Commission Docket No. 16-035-36. The Company's project partners included the
Electric Power Research Institute and Utah State University, and resulted in the study of: (1)
IEEE 1547 smart inverter standards and policy, (2) laboratory selection and testing, (3) hosting
capacity results, with and without smart inverters, (4) settings determination, (5) deployment best
practices, and, (6) Technical Policy 138, interconnection standard updates. This research
produced the smart inverter policy that the Company has implemented for its Utah customers.
That policy is currently being considered in a Utah Public Service Commission proceeding to
determine how the value provided by customer smart inverters should be included in the Export
Credit Rate. Utah Docket No. 17-035-61. A review and analysis of the smart inverter policy
STAFF COMMENTS 13 MAY 26,2020
implemented for the Company's Utah customers territory may provide valuable contributions
towards developing a similar policy for its Idaho customers.
CUSTOMER COMMENTS AND NOTICE
Most customer comments received thus far are based on the Company's Original
Application, including the Company letter sent to customers in June 2019.
That letter advised customers that:
o Existing customers would be tansitioned to Schedule 136 over a ten-year period
ending June 1, 2029,
o Compensation for exported energy would be reduced from 12.5 centslkWh to 8.5
centslkWh, and
o The typical payback period would increase from 9.6 years to 14.4 years.
Customer comments indicated that they disagreed with the Company's proposed changes
and argued that the present compensation was less than described in the letter, creating a longer
payback period than the stated 9.6 years. The customers believe that while it may be appropriate
to set new export rates for new customers, the current customers are entitled to retain the current
compensation program for the life of their systems. One customer stated that since the effrciency
of a system is still 80% after 25 years, the existing customer should be kept on Schedule 135 for
25 years. Another customer suggested that customers should be compensated according to the
charges under the Company's time-of-day charges for peak and off-peak power. Other
customers said that the Company needs to consider the avoided energy cost and environmental
benefits. Staffnotes that these comments are similar to the comments expressed by Idaho Power
net metering customers.
ln addition, Staffnotes that the Company's June 2019 letter to customers did not
accurately characterize its proposed changes. The Company's original Application had two
proposals regarding the new Export Credit Rate. The Company's primary recommendation was
to grandfather existing net metering customers for ten years and change the compensation rate
for new metering customers from the retail rate to 2.4 centslkWh immediately. In the event that
the Commission declined to grandfather existing customers, the Company proposed an
alternative: transition all net metering customers from the retail rate for exports to the proposed
STAFF COMMENTS t4 MAY 26,2020
2.4 cents/kWh over three years. tn the first year of the tansition, customers would receive
8.5 centslkWh for exported energy and would decrease significantly each of the next two years.
Neither the Company's June 2019 letter to customers nor its press release disclosed that
the 8.5 cent/kWh credit would decline after the first year, nor did those communications disclose
that the Company's primary proposal was a 2.4 cents/hour export credit for new customers.
Applying a 2.4 cents/hour export credit rather than an 8.5 cents/trour credit rate significantly
affects the payback period for these customer investunents. Staffis deeply concerned that in its
communications, the Company did not accurately represent its filing and its potential impact to
affected customers.
There has been only one customer comment received since the Company filed its
Supplemental Application on April 23, 2020. That customer has been carrying a credit and
would like a refund check from the Company.
Staffexpects that more customers will comment on the Company's Supplemental
Application when it is noticed by the Company and customer letters are distributed. Staff
strongly recommends that the Company carefully examine the content and timing of those
communications to ensure that they fully and accurately represent the Company's filling. Staff
further recommends the Company ensure those communications are received with sufficient time
and instructions for customers to participate in the Commission-ordered public workshops.
Lastly, Staff recommends that the Company distribute notice of its Supplemental Application
and public workshops broadly to all customers so that all interested customers - not just net
metering customers--have the opportunity to be heard on this issue.
STAFF RECOMMEI\IDATION
Staffrecommends that the Company begin constructing its comprehensive net metering
study and customer notice according to specifications laid out in more detail above.
STAFF COMMENTS l5 MAY 26,2020
Respectfrrlly zubmitted this 26th day of May 2020.
P&*L(
EdwardJ. EilAt
Deputy Attoid Geireral
Technical Staff: Stacey Donohue
Rachelle Farnsworth
KevinKeyt
Mke Morrison
Joe Terry
Chris Hecht
irmirc/cornmcnt/nccl9.Scjedrfdmqibh commentg
STAFF COMMENTS l6 N{AY 26,2020
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT T HAVE THIS 26fl' DAY OF MAY 2020,
SERVED THE FOREGOING COMMENTS OF THE COMIVISSION STAFF, IN
CASE NO. PAC-E-I9-08, BY E-MAILING A COPY THEREOF, TO THE
FOLLOWING:
TED WESTON
ROCKY MOUNTAIN POWER
I4O7 WESTNORTH TEMPLE STE 330
SALT LAKE CITY UT 84I 16
E-MAIL: ted.weston(rDpacificorp.com
DATA REQUEST RESPONSE CENTER
E.MAIL ONLY:
datareq uest(dpaci fi co rp. com
ERIC L OLSEN
ECHO HAWK & OLSEN PLLC
PO BOX 6119
POCATELLO ID 83205
E-MAIL: elo(@echohawk.com
BENJAMIN J OTTO
TD CONSERVATION LEAGUE
710 N 6TH ST
BOISE TD 83702
E-MAIL: botto(4idahoconservation.orq
EMILY WEGENER
ROCKY MOUNTAIN POWER
I4O7 WN TEMPLE STE 320
SALT LAKE CITY UT 84116
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