20200917Comments.pdf

Attomey for the Idaho Conservation League
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
Benjamin J. Otto (ISB No. 8292)
710 N 6ft Street
Boise,ID 83701
Ph: [phone] x 12
Fax: [phone]
botto @idahoconservation. org
IN THE MATTER OF THE
APPLICATION OF ROCKY
MOUTAIN POWER TO CLOSE THE
NET METERING PROGRAM TO
NEW SERVICE & IMPLEMENT A
NET BILLING PROGRAM TO
COMPENSATE CUSTOMER
GENERATORS FOR EXPORTEI)
GENERATION
I Order No. 34752 at7.
PAC-E-19-08
TCL COMMENT ON PROPOSED ORDER
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CASE NO. PAC.E.19.O8
IDAHO CONSERVATION LEAGUE
COMMENT ON PROPOSED ORDER
NO.347s2
The ldaho Conservation League (ICL) submits the following comments on the Proposed
Order No. 34752. ICL supports the Commission's proposal to respect the private investments
made by solar customers who participate in Rocky Mountain Power's net metering program
defined in Schedule 135. A viable and stable net metering program is essential to protecting
Idahoan's rights to invest their own money to meet their own energy needs. The Proposed Order
takes the first step towards this goal by applying the same grandfathering treatment devised in
Idaho Power's net metering docket to Rocky Mountain Power customers. We strongly agree with
the Commission that "there has been no showing of how Rocky Mountain Power customer-
generators are differently situated than Idaho Power customers in their reasonable expectations
of fundamental program stability". I
While we support this overall conclusion ICL does have one concems about the proposed
order. Closing the current net metering program before approving a successor program creates
vast uncertainty in the market for customer-owned solar, to the detriment of tdahoans and benefit
to RMP. This outcome is not fair, just or reasonable. Creating market uncertainty has a huge
negative impact on customers who are considering investing their own money while benefiting
September 16,2020
the utility. The unfairness arises from the fact that the utilities assert, and the Commission
assumes, some amount of cost shifting as the basis for limiting solar growth. But those
assumptions have not actually been rigorously tested by the PUC Staff or other stakeholders by
examining a full cost of service study or completing a full, transparent assessment of the value of
customer exports. Chilling private investment based on assumptions that favor the utility is not
fair to customers. Further, creating this amount of market uncertainty appears to benefit only the
utilities as shown by the sudden lack of urgency to address net metering going forward. ICL
notes both ldaho Power and Rocky Mountain Power initially claimed near-emergency conditions
related to net metering growth. Since closing the Idaho Power program, this emergency
apparently has evaporated. And it seems like a similar dynamic will arise with Rocky Mountain
Power. As RMP clearly states throughout this docket, a primary goal for the utility is to slow the
growth of customer-owned solar and creating market uncertainty achieves this goal about as well
as changing the program rates. Finally, chilling the market for customer-owned solar has a large
impact on Idahoans who may desire to invest in their own energy needs while having no
meaningful impact on RMP's system. In20l9 net metered systems accounted for 0.68Yo of peak
demand in Idaho.2
To protect Idahoan's right to self-supply energy through a viable net metering program,
and to encourage Rocky Mountain Power to complete a full, transparent study of the value of
customer exports ICL recommends the Commission changed the Proposed Order to establish the
eligibility date to remain on Rocky Mountain Power Schedule 135 to be the date the Commission
approves a succor customer-owned solar schedule.
Respectfully submitted this 16th day of September, 2020
/s/BeniaminJ Otto
Idaho Conservation League
2 RI,P 2019 IRP Appendix A at 12 (2017 noncoincident peak of 830 MW in20l7, growing at l.l3o/o equals 848.9
MW in 2019). RMP Application, page 6, states there is a total of 5.8 MW of customer owned solar on their system
in Idaho.
PAC-E-19-08
ICL COMMENT ON PROPOSED ORDER
2
September 16,2020
CERTIFICATE OF SERYICE
I certify that on the 16th day of September 2020,I delivered true and correct copies of the
foregoing COMMENTS ON THE PROPOSED ORDERNO. 34752 to the following via the
service method noted:
/s/ Benjamin J. Otto
Idaho Conservation League
Electronic Mail onlv (Order No 34602)
Idaho Public Utilities Commission
Diane Hanian
Commission Secretary
Idaho Public Utilities Commission
secr etary @puc. id aho. gov
kendrah@givenspurs ley. com
Monsanto
James R. Smith
[e-mail]
Edward Jewell
Deputy Attorney General
Idaho Public Utilities Commission
edward [e-mail]
Randall C. Budge
Thomas J. Budge
Racine Olson, PLLP
r andy @r acineo I son. com
[e-mail]
Roclry Mountain Power
Emily Wegener
Ted Weston
Rocky Mountain Power
Em ily.we gener@pacifi corp.com
ted.weston@pacifi corp. com
datarequest@pac ifi corp.com
Brian C. Collins
Maurice Brubaker
Katie Iverson
Brubaker & Associates
[e-mail]
mbrubaker@consultbai. com
[e-mail]
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
[e-mail]
PAC-E-19-08
ICL COMMENT ON PROPOSED ORDER
J
September 16,2020