20200702Revised Initial Comments.pdf

Benjamin J. otto (ISB No. 8292)
710 N 6ft Street
Boise,ID 83701
Ph: [phone] x 12
Fax: [phone]
botto@idahoconservation. org
Attorney for the Idaho Consenration lrague
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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IN THE MATTER OF THE )
APPLICATION OF ROCKY )
MOUTATN POWER TO CLOSE THE )
NET METERING PROGRAM TO )
NEW SERYICE & IMPLEMENT A )
NET BILLING PROGRAM TO )
COMPENSATE CUSTOMER )
GENERATORS FOR EXPORTED )GENERATION )
PAC-E-19-08
ICL REVISED COMMENT
CASE NO. PAC.E-19-08
IDAHO CONSERVATION LEAGUE
REVISED INITIAL COMMENT ON
STITDY DESIGN
JuJy2,2020
The Commission, in Order No. 34661, provided an opportunity for parties to file Revised
Initial Comments that incorporate public feedback gathered through a PUC Staff hosted
workshop and Commission hosted public hearing. After reviewing the public input provided in
those forums, as well as the written public comment filed since Rocky Mountain Power's
Supplemental Application, the Idaho Conservation League (ICL) stands by our initial comments.
The public input thus far bolsters our position that Rocky Mountain Power's proposal is
inadequate in at least three regards. RMP's analysis lacks supporting data and instead relies on
questionable assumptions. RMP inappropriately compares the value of remote, utility-scale solar
with local customer-owned resources and thereby creates substantial customer confusion. And
RMP's proposal for legacy rate treatrnent does not adequately respect the interests of current net
metering program participants. ICL notes the public input thus far unanimously opposes RMP's
proposals. Accordingly, ICL stands by our initial comments.
I
The public comments raised an additional issue that ICL did not address in our initial
comments - the treatment of a net metering customer's unused energy credits. ICL joins the
public comments that strongly oppose RMP's proposal to extinguish unused credits annually
without compensation. A customer who exports excess provides energy to RMP the Company
then uses to serve, for compensation, neighboring demand. The export customer carries a credit
on their account that represents value to them for providing this product to the utility. If the
Commission were to empower RMP to extinguish this value without compensation, that would
raise a host of legal and equity issues. The far fairer, just, and reasonable approach is to allow
customers to carry credits indefinitely and allow customers to transfer credits to other meters in a
manner akin to the meter aggregation rules applied to Idaho Power. ICL also strongly supports
the idea raised in Mr. Robert Sorensen's Comment of April 30,2020 where he reports asking
RMP to donate the value of his extra energy credits to some other customer who is unable to pay
their bill. We applaud Mr. Sorensen's compassionate idea and urge the Commission to make
clear that no formal rule prohibits RMP from implementing this opportunity.
ICL recognizes that accounting for customer credits may cause accounting headaches for
RMP. But the solution is for RMP to address these accounting issues and not for RMP to ask the
Commission for the power to extinguish customer value without compensation. Thus, ICL
recommends as part of the legacy rate treatment, the Commission reject RMP's proposal to
extinguish credits annually and instead continue to allow customers to carry credits forward,
create a process by which customers can transfer credits to other meters, and implement the
ability for a customer to donate their unused value to other customers who need bill assistance.
Respectfully submitted this 2nd day of July 2020.
/s/Benjamin J. Otto
Idaho Conservation League
PAC-E-19-08
ICL REVISED COMMENT
2
July 2,2020
CERTIFICATE OF SERVICE
I certify that on the 2nd day of July 2020,ldelivered true and correct copies of the foregoing
REVISED INITIAL COMMENTS to the following via the service method noted:
/.s/ Beniamin J. Otto
Idaho Conservation League
Electronic Mail only (OrderNo 34602.)
Idaho Public Utilities Commission
Diane Hanian
Commission Secretary
Idaho Public Utilities Commission
secretary@puc. idaho. gov
Edward Jewell
Deputy Attorney General
Idaho Public Utilities Commission
edward j ewell@puc. idaho. gov
Roclry Mountain Power
EmilyWegener
Ted Weston
Rocky Mountain Power
Emily. we gen er @p acifrc orp. com
ted. weston@pacificorp. com
datarequest@pacifi corp. com
Adam Lowney
McDowell Rackner Gibson PC
[e-mail]
Idaho lrrigation Pumpers Association
Eric L. Olsen
ECHO HAWK & OLSEN, PLLC
[e-mail]
Anthony Yankel
[e-mail]
Idaho Clean Energt Association
Preston N. Carter
Givens Pursley LLP
prestoncarter@givenspursley. com
kendrah@givenspursley. com
PAC-E-19-08
CERTIFICATE OF SERVICE
Monsanto
James R. Smith
[e-mail]
Randall C. Budge
Thomas J. Budge
Racine Olson, PLLP
[e-mail]
[e-mail]
Brian C. Collins
Maurice Brubaker
Katie Iverson
Brubaker & Associates
[e-mail]
[e-mail]
[e-mail]
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July2,2020