20250225Comments_8.pdf

The following comment was submitted via PUCWeb:
Name: Richard Craun
Submission Time: Feb 24 2025 7:32PM
Email: [e-mail]
Telephone: [phone]
Address:4219 E 410 N
Rigby, ID 83442
Name of Utility Company: Rocky Mountain Power
Case ID: PAC-E-25-02
Comment: "I am a Rocky Mountain Power customer with a non-legacy on site solar generation system.
The proposed excess generation reimbursement rate change for customers with solar systems from $.08-
$.17 per kilowatt hour (kWh) down to a flat rate of$.04 per kWh is a significant 50%-70% reduction.
Idaho is ranked sixth in the United States for solar sun radiance and our state solar generation capacity is
less than 10%. Idaho has made it a priority to increase on site solar generation with the introduction of a
generous investment tax credits for installing solar systems.This incentive will create many jobs and
opportunities for companies in our state for years to come.Thus,we should establish a rate structure for
excess solar system generation reimbursement that is fair to both the customer and the power
companies.The proposed rate structure by Rocky Mountain Power does not support that goal and will
likely damage the future solar industry growth in Idaho.
Since the on site solar generation capacity is small (less than 10%) compared to the overall generation
capacity of the state, I find it hard to understand the necessity of this proposed change regarding the
financial health of Rocky Mountain Power. Even though Idaho does not currently rely heavily on solar
energy today. We should not penalize it's current and future use.
Since Rock Mountain Power distributes the excess solar energy generation to its other customers, a
potential approach would be to identify that portion of the current energy cost($.08-$.17 per kWh)that
is needed to address energy distribution costs. This cost could be used as a basis to fairly lower the
energy reimbursement rate, e.g., energy reimbursement rate of$.06-$.15 per kWh"
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The following comment was submitted via PUCWeb:
Name: Barry Beutler
Submission Time: Feb 25 2025 9:17AM
Email: [e-mail]
Telephone: [phone]
Address: 8936 S 15th E
Idaho Falls, ID 83404
Name of Utility Company: Rocky Mountain Power
Case ID: PAC-E-25-02
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Comment: "Subject: Opposition to Proposed Reimbursement Reduction in Case No. PAC-E-25-02
Dear IPUC,
I am writing to you regarding Case No. PAC-E-25-02, wherein Rocky Mountain Power is proposing to
reduce reimbursement for residential customers' on-site electricity generation.
I am writing as a Rocky Mountain Power residential customer living in Idaho to plead with you to reject
this change in reimbursement. As a family, we recently chose to purchase a home solar generation
system to help offset our electricity bills. Case No. PAC-E-25-02 would shatter those plans. When we
developed a system with solar generation, we estimated with the current reimbursement rates to recoup
the initial purchase and installation cost within 12 years (even longer if we tried to match what those
initial funds would have paid in dividends had they been invested). At the same time we also recognized
the importance of offsetting our carbon footprint, and helping others in our community by not drawing
as much from the finite electrical supply,thus helping to keep utility costs down for all.
Living in Idaho which receives less direct sunlight than our southern neighbors,the benefit of solar is
already marginal. With a decreased reimbursement rate that is less than 1:1 to the purchased kWh cost,
there is no incentive for families to make the investment, nor could many afford it. There will be a
greater strain on the current grid, and less solar production. Had we known of the proposed rate
decrease, it would have completely changed our plans and we would likely not have a home solar
production system today. For our area, we would see reimbursement drop to just a third of the current
rate.
Rocky Mountain Power already recently increased (more than doubled) their basic monthly charge to
help offset their overhead and collect more from customers who don't use as much electricity, or who
produce their own. To now greatly reduce the reimbursement rate for electricity generation seems
highly disingenuous.
Customers who generate electricity help keep costs down for all customers by reducing the strain on a
limited electrical supply. This behavior should be encouraged and promoted, not disincentivized or
penalized.
Rocky Mountain Power estimated that the average customer would see an increase of their monthly bill
by 72%. This is significant! Especially for customers who financed their home solar system and depend
on fair kWh reimbursement rates to offset their monthly bills.
Please help protect Idahoans who are trying to do the right thing, contributing positively to the
environment and reducing strain on the grid. Please support policies that incentivize residential solar
electricity generation, rather than discourage it.
Sincerely,
Barry Beutler, Idaho Falls"
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The following comment was submitted via PUCWeb:
Name: Leola Brookhart
Submission Time: Feb 25 2025 1:59PM
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Email: [e-mail]
Telephone: [phone]
Address: 10679 N 38th E
Idaho Falls, ID 83401
Name of Utility Company: Rocky Mountain Power
Case ID: PAC-E-25-02
Comment: "I feel if Rocky Mountain Power is taking my excess generated electricity and selling it to
other customers, I should be given credit at the same rate Rocky Mountain Power pays to any other
business for electricity they buy, ie the retail rate. If the company is concerned about being fair to their
non generating customers,why don't they ask me to pay the same fee as them by asking me to pay a
basic fee for use of the grid, the same basic fee the non generating customers pay and then giving me a
fair credit for the electricity I generate and they turn around and sell. Though I am not sure that basic
fee is fair to all concerned as it is three times as much now as it was when I started with solar 3 years
ago."
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The following comment was submitted via PUCWeb:
Name: Benjamin Harris
Submission Time: Feb 25 2025 2:30PM
Email: [e-mail]
Telephone: [phone]
Address: 5417 N Foothill Rd
Idaho Falls, ID 83401
Name of Utility Company: Rocky Mountain Power
Case ID: PAC-E-25-02
Comment: "I would like to make sure the Commission considers how severely Rocky Mountain Power's
proposal to reduce the credit structure would result would negatively impact customers. Expecting
customers to somehow account for an average increase of 72%to their power bills is unthinkable in any
economic conditions, much less the ones we have been through in recent years. In addition, please
consider how many customers have only recently made large investments in solar for their homes with
the expectation that the power we contribute to the grid would be credited at the current and fair ratio
of 1:1. In fact, my neighbor and I had the wherewithal to ask RMP about potential changes to the credit
rate structure BEFORE going ahead with the$30k+ investment in solar, and the RMP agent at the time
assured us both that we were "grandfathered" into the current 1:1 credit structure with the caveat that
there was a reconciliation that takes place annually where any unused credits on our RMP accounts were
forfeit to RMP.This week, I contacted RMP and was told that I was misinformed and I am actually a
schedule 136 customer and not a schedule 135 customer so I would be affected by this rate change.The
proposed rate change AND misinformation from RMP have been infuriating. Had we been accurately
informed by RMP,we would not have invested our hard earned money in solar. "
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The following comments were submitted via PUCWeb:
Name: George Avery
Submission Time: Feb 25 2025 3:15PM
Email: [e-mail]
Telephone: [phone]
Address: 9324 E. Merrick Rd., POBox36
Lava Hot Springs, ID 83246
Name of Utility Company: RMP
Case ID: PAC-E-25-02
Comment: "72% Increase in a monthly power bill is an absurd request, Non Legacy users are being
punished for the revenue that is lost to the Legacy users."
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Name: Sarah Young
Submission Time: Feb 25 2025 3:22PM
Email: [e-mail]
Telephone:[phone]
Address: 2910 S Ammon Rd
Ammon, ID 83406
Name of Utility Company: Rocky Mountain Power
Case ID: PAC-E-25-02
Comment: "Hello,
I would like to voice my concern and disapproval for the proposed change in compensation structure
regarding RMP customers with solar panel systems.The proposed change will increase our personal cost,
and will deter more people from making the investment to add solar to their homes and businesses. It is
a huge investment for individuals to make, and the current compensation structure is the main reason
why it is worth it. If you want people to continue to invest in solar and all its benefits, you must make it
worth it! At the very least, do not change existing customers compensation for the power we generate
and send to the grid.
Thank you,
Sarah Young"
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The following comment was submitted via PUCWeb:
Name: Christian Belisle
Submission Time: Feb 25 2025 4:29PM
Email: [e-mail]
Telephone: [phone]
Address: 6098 S 2000 W
Rexburg, ID 83440
Name of Utility Company: Rocky Mountain Power
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Case ID: PAC-E-25-02
Comment: "I received the letter from Rocky Mountain Power in relation to the above case number PAC-
E-25-02 and would like to express my view that I do not want this action to be granted. The purpose for
the solar panels for my house is so that it can pay my power bill. If this proposal is approved it would
effectively wipe out the whole purpose entirely. I am also considering all the other people that this
would effect not only me but everyone. For the good of the Idaho citizens please vote no.Thanks for
your consideration."
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From: Cee Polly<[e-mail]>
Sent:Tuesday, February 25, 2025 12:39 PM
To: secretary
Subject: Fwd: Rocky Mountain Power Rate Scheme Proposal October 1, 2025
February 25, 2025
Honorable Brad Little; Idaho Governor
Idaho State Legislature
Idaho Public Utility Commission
Re: Proposed Rocky Mountain/Pacific Power Rate Scheme for Residential on-site Solar Generation
Systems; Letter to Idaho Residential on-site Solar Generation Systems(Non-Legacy),Dated
February 7,2025.
To Whom It May Concern,
This letter is in regards to said letter and Rocky Mountain/Pacific Powers new proposed rate
scheme for residential on-site solar generating households. Apparently, Rocky Mountain
Power/Pacific Power Company in California is proposing a compensation and rate structure change
for those Residential Idaho based on-site Solar Generation Systems/household.These residential
solar systems cost 10's of thousands of dollars to install, and folks like me view them as protection
to offset our utility bills in order to provide some level of financial security. My wife and I are retired
and on a fixed income.
The letter indicates in Paragraph four on Page one that the purpose of the new rate scheme is to
provide a basis for implementing change to ensure that customers are paid a fair rate for their
export energy and those customers with Residential on-site solar generation system are not being
subsidizing by customers without solar or other self generating customers and therefore as
indicated in Paragraph two on Page two- it will be necessary to increase the onsite residential solar
generators BILL by 72%. This will mandate that all residential on-site solar generators pay more in
order to be more equal to those customers that do not generate their own power at their home
whom have not invested 10"s of thousands of dollars to put a roof top solar system on their home.
This is an outrageous rate scheme proposal by Rocky Mountain/Pacific Power Company out of
California,first to be compared to a billing amount of customers without solar who did not invest
10's of thousands of dollars for some level of future financial security regarding utility bill
expenditures and second that any public utility would be bold enough to believe that a 72%
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immediate increase in each residential solar on-site generators billing amounts would be
acceptable for the Idaho Public Utility Commission to implement as the IPUC is our public steward
charged with protecting their public and thus the utility companies customers.The very purpose of
the IPUC is to prevent a public utility such as Rocky Mountain/Pacific Power Company out of
California,whos business mandate is to find a way to charge its customers more to bring in more
revenue at any cost to Idaho residence. Gaming the system by proposing confusing studies,which
it appears were constructed by identifying the monitory goal first and working in a financial formula
that results in the original monetary profit desired as an illegitimate means of supporting the
financial profit margin rate structure/scheme change. This just means the the IPUC did a good job
with its original standards/regulations in approving an excess power generating purchasing
structure for Residential on-site solar generating households.
I can guaranty the current rate structures were imposed after careful analysis, study and
consideration,which has lead to a valid rate structure, as retail rates go up,the utility company
maintains a relative purchase structure for the excess power generated by the the residential on-
site solar generating systems,which means everyone is relatively compensated fairly under the
current IPUC structure(Current IPUC residential on-site solar generation rate structure schedule;
value of credit for export energy from retail rate that is currently valued between $0.07 and $0.18
per kwh, Paragraph three Bullet point one on Page 1).
Solar on my house uses the the utility companies meter to determine the difference between that
which my system generates and I use on-site and the excess which moves through my weatherhead
and into the grid owned and managed by the utility company,which intern they sell at their inflated
retail rates to my neighbors whom may not have solar.The amount the utility company sells my
power for is more than the utility company credits the value of my excess energy,which my system
has delivered to their grid.
In addition, I could understand a simple measurable and fair way of compensating the utility
company for using the excess energy generated from my system, even though they are making
money off the excess power my residential system generated and is passing though my
weatherhead to the utility companies grid for sale and use by my neighbors.This compensation
could be structured in such a way that the residential solar on-site excess power discharged to the
grid from a weatherhead on a house is credited/purchased by the utility company for resale at 25%
less than the retail rate in which Rocky Mountain Power charges the non residential solar generating
customer and household.This rate structure would allow the utility company to obtain an
instantaneous 25% profit on energy seamlessly integrated into their system by each residential
solar system at the time they deliver the solar generated excess energy through their own utility
infrastructure into the public companies grid. My recommendation is to not approve the Rocky
Mountain/Pacific Power Companies proposal, but if an update is deemed necessary,to implement
the 25%less rate change structure noted above.
I was also troubled to be notified in said February 7, 2025 letter from Rocky Mountain/Pacific Power
Company that a determination of Legacy status(Grandfathering)occurred in 2020 for a 25 year
period regarding schedule 136 and new on-site residential solar generating excess bill rates and
credit values, as proposed by Rocky Mountain Power to be implemented October 1,2025.
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Therefore, if the utility companies rate scheme is approved by the IPUC, it would be justified to grant
all Residential on-site solar generating systems that are in operation as of October 1, 2025"Legacy
Status"thereby grandfathering them into the current rates etc. for a period of 25 years,which is a
reasonable time to realize the benefit of investing 10's of thousands of dollars per residential solar
system installed on homes and protecting those families from an unburden of purchasing solar and
paying close to the average monthly bill of non-solar customers.
Thankyou for your time and consideration,
Richard and Connie
Idaho Falls, Idaho
PS-On another note,when I received this letter, I became really concerned by an encounter I had
with an individual that approached me in my front yard during the summer season of 2024,who I
believe stated theywere affiliated with Rocky Mountain Power.Apparently Rocky Mountain Power
sent them out to talk to me as a Residential Solar Generator. It was my understanding that the
individual stated that Rocky Mountain Power implemented a new rate structure for billing,which
resulted in Residential on-site Solar Generator receiving a bill for a substantial amount no matter
how much excess power I generated. For,this reason, it was my understanding that the individual
told me I needed to buy batteries to put onsite from his company affiliated with Rocky Mountain
Power.
I do not understand how Rocky Mountain Power knows there proposal for implementation on
October 1, 2025 is going to be accepted/approved/implemented by the Idaho Public Utility
Commission (IPUC). This becomes very troubling if the IPUC accepts and implements the proposal
outlined in the February 7, 2025 Rocky Mountain Power letter(Attached), as the IPUC is suppose to
be an impartial body only acting on the merits of the proposal based on publicly available
information through the legal process establish for said action,which did no occur as of the
summer of 2024 and ultimately should not be implemented based on my comments noted above.
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Hello,
As a customer with on-site generation, you are receiving this letter because we want you to be
aware of proposed changes to the compensation structure for on-site generation. This letter is
specific to your non-legacy on-site generation system at 1110010M meter number�.
If you have multiple on-site generation systems,you will receive a letter specific to each system.
Below are details about the proposed changes being considered by the Idaho Public Utilities
Commission(IPUC)with information on how you can participate.
What is this change being proposed?
Rocky Mountain Power is requesting changes to its on-site generation offering as a step towards
ensuring fair prices for all customers. Rocky Mountain Power is seeking approval of a
compensation structure that accurately measures an on-site generator's use of the electrical grid
and an excess export energy credit rate that will result in a fair and accurate valuation of customers'
exported energy. For all customers with non-legacy systems,Rocky Mountain Power is asking to
implement the proposed changes effective October 1,2025:
• A change in the value of credit for exported energy from the retail rate, valued between
$0.07 to$0.18 per kilowatt-hour for residential customers,to a time-differentiated financial
bill credit that would be approximately$0.04 per kilowatt-hour but that would be updated
annually.
• A modification in the eligibility size cap for commercial, industrial and irrigation
customers.
Why is Rocky Mountain Power requesting changes?
The proposed changes follow Rocky Mountain Power's On-Site Generation study in Case No.
PAC-E-23-17, which analyzed the benefits and costs of on-site generation on Rocky Mountain
Power's electrical grid. The study provides a basis for implementing changes to ensure that
customers are paid fair rates for their exports and customers without solar or other on-site
generation systems are not subsidizing the rates for self-generating customers.
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Solar power and other renewable energy sources are an important part of Rocky Mountain Power's
energy mix, and the company supports customers who choose to participate in their own on-site
generation. The company's goal with this request is to modernize the compensation structure for
on-site generation to ensure prices for excess energy are fair and equitable for all customers.
Ho% might my bill be affected?
r For residential customers with nun-legacy systems,Rocky Mountain Power evaluated. 07,3!�0;j
data to assess how customer bills may be affected by the proposed change in compensatiopy
structure. The average monthly bill for residential customers under the current net billingg
compensation structure is about$52.Under the proposed export credit price,the average bill would
increase to $89,resulting in an average increase of approximately$37 per month or about 72%.
A typical Rocky Mountain Power residential customer in Idaho has a bill of$105.48 per month.
The chart helow shows the change in average monthly bills moving from the existing retail rate
credit to an export credit valued at about 4 cents per kWh. The chart is organized by customers'
average net monthly energy consumption.
c: M V401 cc r
Residential Schedule 136 Average Monthly Bill Impact
$326.88
szse.ee
$219.45
E 186.19 -
E E167.71 133.68
$110.66
$59.48 $72.52
A 0 500 kWh B:501-1,000 kWh C:1,001.1,500 kWh D:1,501-2,000 kWh E:2,001 kWh*
(610 customers) (197 customers Moy 20 customer
Averageh o
■Current Monthly Average Bill ■Proposed Monthly Average B+ll
How would non-legacy customer generators be credited for their excess energy under the
proposed changes?
Under the proposed rate structure,customers are charged for all kWh consumed from the grid at
the retail rate,and are credited for all kWh exported to the grid at a time differentiated export credit
rate.
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What is a"non-legacy"system?
As part of previous cases, the IPUC granted legacy status — sometimes referred to as
"grandfathered"—in October of 2020 to existing customers for a 25-year period and established
Schedule 136 for new customers going forward. In these previous cases,the IPUC acknowledged
certain criteria for these systems to maintain legacy status, which allows those systems to retain
the net metering compensation structure for 25 years.
All other systems, including the system referenced in this letter,are"non-legacy"and are subject
to changes in the on-site generation compensation structure,including the changes currently being
considered by the IPUC.
How can I participate?
For more details about the proposed changes to the on-site generation compensation structure,
including the methodologies behind the net billing and excess energy export credit rate changes
customers can review Rocky Mountain Power's proposal, which is subject to approval by the
IPUC.Copies of the application are available to the public at the IPUC offices(1 1331 W.Chinden
Blvd. Building 8, Suite 201-A, Boise, ID 83714), Rocky Mountain Power offices, or at
RockyMountainPower.net/ExportCredit or puc.idaho.gov. Customers also may subscribe to the
IPUC's RSS feed to receive periodic updates via email about the case.
Written comments regarding Rocky Mountain Power's proposal(Case No.PAC-E-25-02)may be
filed with the IPUC(puc.idaho.gov/Form/CaseComment).
You can find more information about Customer Generation, including FAQs, at
RockyMountainPower.net/CustomerGen. If you have additional questions, you can call our
Customer Care team at 888-221-7070.
Sincerely,
Your Rocky Mountain Power Customer Generation Team
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