20200526Comments on Study Design.pdf

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r Dl.r '>. t. o,i.r LO lll uF t.'.,
Preston N. Carter (ISB No. 8462)
Givens Pursley LLP
601 W. Bannock St.
Boise,lD 83702
Telephone: [phone]
Facsimile: [phone]
prestoncarter@givenspursley. com
15142514_3.docx [ 1523-l]
Attorneys for Idaho Clean Energt Association
IN THE MATTER OF ROCKY
MOUNTAIN POWER TO CLOSE THE
NET METERING PROGRAM TO NEW
SERVICE & IMPLEMENT A NET
BILLING PROGRAM TO
COMPENSATE CUSTOMER
GENERATORS FOR EXPORTED
GENERATION
BEFORE THE IDAHO PT]BLIC UTILITIES COMIVISSION
Case No. PAC-E-19-08
Ioaso ClreN ENeRcy AssocrerroN' s
CouunNrs oN SrUDY DesrcN
Idaho Clean Energy Association, Inc. ("[CEA"), respectfully submits the following
Comments on Study Design in response to Rocky Mountain Power's ("Rocky Mountain Power"
or "Company") supplemental application ("Supplemental Application") filed on April23,2020.
ICEA appreciates the opportunity to provide these comments and looks fonvard to engaging with
stakeholders as the case moves forward.
1. General comments
ICEA is an Idaho nonprofit organization dedicated to the advancement of renewable
energy, energy efficiency, and associated technologies in the state of ldaho. lts membership
consists primarily of members involved in the renewable energy industry in Idatro. ICEA hopes
to bring to this case the experience of solar installers and the perspective of customers that are
considering investing in, or have invested in, distributed energy systems.
Ioago Cmat Er.rencv AssocrATroN's CouuENrs oN SruDy DEstcN - I
Overall, ICEA believes that any changes to the Company's net metering program should
be 1) understandable to solar installers and to customers; and2) proportional to the underlying
issue that the changes are trying to address. In the long run, simplicity, and proportionality
should promote understanding and compliance by installers and customers alike.
ICEA agrees with, and adopts, the comments made by Idaho Conservation League in this
case. lnstead of repeating those comments here, ICEA provides the following additional specific
comments.
2. Net hourly billing should be thoroughly studied and explained while building
capacity for customers and installers to understand the financial aspects of on-site
generation under a net hourly billing construct.
ln ICEA's experience, the change from net monthly to net hourly billing causes
significant disruption and confusion to customers and installers alike. To understand the financial
impacts of an on-site generation under net hourly billing, a customer and installer need to obtain,
review, and understand a customer's annual demand information on an hourly basis; obtain,
review, and understand the generation system's annual production information on an hourly
basis; and attempt to compare the two to the utility's tariffed energy rates. This is a time-
consuming and difficult process that reduces the certainty and consistency of installers to predict,
and customers to understand, the financial implications of on-site generation.
For example, in ICEA's experience, different installers have attempted to model the
financial implications of on-site generation under a net hourly billing construct. The models are
difficult to create and vary considerably from installer from installer. Customers are confused
when shown different models with different financial results, and customers are likely to be
confused and upset if the models prove to be inaccurate.
As a whole, in ICEA's experience, net hourly billing is likely to significantly increase
customer confusion, to significantly decrease the predictability of the financial impacts of on-site
IneHo Cr-eeN ENERGy AssocrATroN's CoMMENTS oN STUDy DESIGN - 2
generation, and to significantly decrease customer satisfaction.
These difficulties are inherent in net hourly billing--reither study nor education can fully
remove them. However, in an attempt to address these issues, ICEA suggests the following for
the study design phase.
o Impacts on customers. ICEA suggests that the study should assess how a net hourly
billing progrcm improves or diminishes the customer's ability to evaluate the financial
impact of a potential investment in on-site generation. This information is critical for the
Commission to understand the tradeoffs associated with any move to net hourly billing.
o Impacts on installer's ability to serve customers. ICEA suggests that the study should
assess how a net hourly billing program improves or diminishes an installer's ability to a)
provide evaluations to customers regarding the financial impact of potential investrnents
in on-site generation; and b) to comply with the Residential Solar Energy System
Disclosure Act, Idaho Code $ 48-1805.
o Outreach and education. Although not strictly part of study design, ICEA suggests that
the workshops and other public-outreach activities in this case include a component
designed to explain net hourly billing to customers and installers, including how installers
and customers can access the annual hourly data necessary to evaluate financial impacts
of investing in on-site generation under a net hourly billing construct.
3. Existing customers should be grandfathered according to the terms set forth by the
Commission in Order Nos.34509 and 34546.
Rocky Mountain Power propose to grandfather existing customers for a period of ten
years beginning on July 31,2020 at midnight. Supplemental Application fl21. The Company
does not provide a basis for the ten-year grandfathering period.
In Order No. 34509, the Commission grandfathered existing Idaho Power net metering
IDAHo CLEAN Exencv AssoctATIoN's CoIrausNTs ou Sruov DEstcN - 3
customers starting thirty days after the service date of that decision. Case No. IPC-E-18-15,
OrderNo. 34509 (Dec.20, 2019\ at 10. The Commission's decision was based on the following:
The Commission had legal authority to distinguish between existing and new customers,
Order No. 34509 at ll-12;
a
o The payback period of on-site generation is sensitive to program changes, id. at 12;
. While customers had notice that rates may change, the public believed that fundamentals
of the program structure would not change, id.; and
o Customers had made significant investments in on-site generation systems, id.
ln Order No. 34546, the Commission clarified that grandfathering applied to a particular
system, rather than to a particular customer, and provided guidance as to when a customer can
expand a system without losing grandfathered status. Case No. IPC-E-18-15, Order No. 34546
(Feb. 5, 2020) at 8-9.
Rocky Mountain Power customers share these characteristics. As such, the policies
behind grandfathering Idaho Power customers apply with equal force to Rocky Mountain Power
customers. In addition, grandfathering some customers under conditions different than other
customers is likely to add additional confusion to customers and solar installers, and raise
legitimate questions as to why customer investments in a particular geographical area were
protected to a different degree than investments in a different geographical area. For these
reasons, ICEA submits that Rocky Mountain Power customers should be grandfathered under the
terms set forth in order No. 34509 and 34565.
4. Smart inverters and interconnection.
ICEA notes that the Company does not appear to have proposed any changes to smart
inverter seffings or interconnection requirements. ICEA suggests that the study and any
associated outreach should include an explanation of anypolicies regarding smart inverters and
IneHo Cr-seN ENERGy AssocrATroN's CoMMpNTS oN Sruoy DEsrcN - 4
intenconnection require,ments. If any changes to smart inverters or interconnection requirements
are proposed or anticipated as part of any change to the net metering program, ICEA requests
that these changes be clearly identifie4 their affects included within the scope of any study, and
that the Companyprovide interested parties with notice and the opportunity to meaningfully
comment on the proposals.
Dated: NIay26,2020.
GIVENS PI.JRSLEY LLP
,2 e--b
PrestonN. Carter
Givens PursleyLLP
AttornEts for ldaho Clean Energt Association, Inc.
Ionno CrseNENERGyAssoctATIoN's CourrpNm oN STDYDESIGN - 5
CERTIFICATE OF SERYICE
I certift that on May 26,2020, a true and correct copy of Ioeuo ClpaN ENrRcv
AssocnrtoN's CoMMENTS oN Sruoy DBstcN was served upon all parties of record in this
proceeding via the manner indicated below:
Commission Staff
Diane Hanian, Commission Secretary
Idaho Public Utilities Commission
11331 W. ChindenBlvd., Bldg.8, Ste.20l-A
Boise, lD 83714
Di ane. ho lt (n)puc. idaho. gov
Edward Jewell
Deputy Attorney General
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg. 8, Ste. 201-A
Boise,ID 83714
edward. i ewellGDpuc. idaho. sov
Electronic Mail
Ted Weston
Idaho Regulatory Affairs Manager
PacifiCorp/dba Rocky Mountain Power
1407 West North Temple, Suite 330
Salt Lake City, UT 84116
ted. weston(dpaci fi corp. com
Ajay Kumar (admitted pro hac vice)
825 NE Multnomah, Suite 2000
Portland, OR97232
aj alu. kumar(a),p aci fi corp. com
Data Request Response Center
PacifiCorp
825 NE Multnomah, Suite 2000
Portland, OR97232
datarequest(@paci fi com. com
Electronic Mail
Adam l,owney
McDowell Rackner Gibson PC
419 SW I lft Avenue, Suite 400
Portland, OR 97205
adam(Dmrq-law.com
Emily Wegner (admittedpro hac vice)
PacifiCorp/dba Rocky Mountain Power
1407 West North Temple, Suite 320
salt Lake city, uT 84116
emily. wesener(@paci fi corp. com
Eric L. Olsen
Echo Hawk & Olsen PLLC
505 Pershing Avenue, Suite 100
P.O. Box 6119
Pocatello, ID 83205
elo(rl.echohawk.com
Ioaso ClreN ExeRcv Assocnrrou's CoMrusNrs oN Sruov DESTGN - 6
Anthony Yankel
12700 [,ake Avenue, Unit 2505
Lakewood, OH 44107
[e-mail]
Benjamin J. Otto
Idaho Conservation League
710 N. 6ft Sreet
Boise, D 83702
botto@ idahoconservation. ore
/ ---. 4.- *
Preston N. Caner
Ioeno CrreN Eugncy AssocIATroN's CoutrleNrs oN Sruoy Drsrcn - 7