20250331Comments_4.pdf

From: Norman Shipp<[e-mail]>
Sent:Saturday, March 29, 2025 3:43 PM
To: secretary<[e-mail]>
Subject:Case PAC-E-25-02
My wife and I have written a letter of concern.
It is attached. Please read it.
Thanks,
Norman&Angela Shipp
P.S. Could you let us know what the decision is?
Idaho Public Utilities Commission
CASE PAC-E-25-02
We recently installed a solar panel system into our house electrical system and are concerned that
our investment is turning into a"Pacificorp BDA Rocky Mountain subsidy"where our investment is
being eroded (stolen) by the possible reduction of our credit percent. As senior citizens, having
invested thousands of dollars, are highly concerned about being undercut on our current credit for
supplying electricity to their grid.
The letter we received from PACIFICORP DBA ROCKY MOUNTAIN POWER(RMP)stated that they
are"requesting that the credit for exported energy be reduced from the current 9-10 cents per
kilowatt-hour[for a residential house]to a time-based rate of approximately 4 cents per
kilowatt-hour, subject to annual updates"
That constitutes a 55.6%to 60%reduction!! That is just not fair to the solar customers!
They claim they are being fair to the rest of their customers, but that would be by our expense.
In fact,to really be fair to all their customers (which includes all of those who get credit from their
solar panels) RMP should leave the credit rate at the current retail value. They should pay us
what they charge us.
We,the solar system owners, are the ones who have invested our money to supply ourselves with
the sun's power. We are not in competition with RMP, rather,we are giving our surplus to them.
They don't have to do anything but accept it and give us credit... at the retail value that they
themselves charge us. In the long run,they are getting electricity without an production cost
at all! It's to their advantage to encourage as many solar users as possible.
Here's another point of view from our United States Interior of Energy Secretary,Chris Wright, as
of Wednesday 19 March 2025. He says that the current administration under President Trump's

direction is highly encouraging and working toward"bringing electricity prices down"and making
"more electricity available". So, as citizens,we are doing our part. RMP should actually be
encouraging us and giving us incentives to increase solar energy availability and help drive
prices down.
We believe that the case to leave the retail prices per kilowatt-hour as-is, is clear.
Please reject this proposal.
We and our neighbors,who are supporting our US President,thank you in advance for representing
us the consumer/producer of solar energy by declining RMP's request for the price reduction for our
credits.
Norman P. &Angela B.Shipp
5541 S Old Highway 91
McCammon, Idaho 83250
[e-mail]
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The following comment was submitted via PUCWeb:
Name: Marty Pettingill
Submission Time: Mar 29 2025 5:31 PM
Email: martypl971 @gmail.com
Telephone: [phone]
Address: 1531 so 55 west
Idaho falls, ID 83402
Name of Utility Company: Rocky mountain power
Case ID: PAC-E-25-02
Comment: "Dear I p u c, I am writing to tell you that Im against rocky mountain power wanting to
give us less for the power we solar farms are genratimg. I am new to the solar technology and the
main reason I went solar power is so that I wouldn't have to keep paying the rates that rmp keeps
raising every year. I understand that there is more load on the infrastructure as more people are
moving here but they should be more than enough to cover the added need for power. Plus let alone
pay the extra cost. But not giving us the same rate for the power we generate is not right. It is not
costing them any more for us to generate power and put on there grid..if anything it is costing us. If
they want to buy my solar system and than pay us less that would be fine, but they are not the one
putting up the money to generate the power.This in itself should be enough reason not to let them
give us less credit for it. Please put yourself in our shoes and than make your decision.

Thanks for your time
Marty Pettingill
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The following comment was submitted via PUCWeb:
Name: Kris Perez
Submission Time: Mar 30 2025 8:04PM
Email: kandmperez(@msn.com
Telephone: [phone]
Address: 88 N. Kaylee
Idaho Falls, ID 83402
Name of Utility Company: Rocky Mountain Power
Case ID: PAC-E-25-02
Comment: "I have read and tried to the best of my ability to understand the reasoning behind Rocky
Mountain Power's proposal to reduce the rate at which they will credit customers back for the
energy generated by the customer's solar panels. The proposal fails to clearly state why the
reduction is required. It was not written in away that is easy to understand, but despite that,the
only benefit I was able to find are to the power company. There was reference to benefiting other
non-solar panel owning customers, however,why should the investment that I pay for myself
provide benefit to others who don't make that investment.
In addition, solar energy is a vital part of the renewable energy mix. By making solar investments
less financially attractive,the proposal may slow the adoption of renewable energy sources.This
slowdown conflicts with local, state, and national efforts to increase renewable energy usage and
combat climate change.
Furthermore, public perception of renewable energy initiatives is crucial for their success.
Reducing credit rates for solar-generated power may be perceived as a step backward in the
commitment to renewable energy.This perception can weaken public support and reduce
enthusiasm for future renewable energy projects and policies.
Lastly,there are legal and regulatory considerations that must be addressed when altering the
credit rates for solar power. Customers who have already invested in solar panels based on the
existing credit rates may have grounds to challenge the reduction,citing a breach of implied
agreements and expectations.
In conclusion, Rocky Mountain Power's proposal to reduce the rate used to credit customers for
power generated by their solar panels is a regressive step that threatens the financial viability of

solar investments, undermines environmental efforts, and poses legal challenges. Fair
compensation for solar energy producers is essential to promote renewable energy adoption,
support economic growth, and ensure environmental sustainability.Stakeholders must unite to
oppose this proposal and advocate for policies that enhance, rather than diminish,the benefits of
solar energy.
Thank you for your time and consideration Kris Perez
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From: Michael Gardner<[e-mail]>
Sent: Monday, March 31,20251:21 PM
To: secretary<[e-mail]>
Subject: Feedback on Case PAC-E-25-02
Attached is my letter to the PUC regarding the proposed Rocky Mountain Power Export Credit.
Thank you for providing a means for the public to comment on these important proposals.
Sincerely,
Michael Gardner
Michael Gardner
236N4125E
Rigby, ID, 83442
[e-mail]
505-298-3190
30 Mar 2025
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg 8, Suite 201-A
Boise, ID 83714
Subject: Objection to Rocky Mountain Power's Proposed Reduction of Solar Export Credit Rate,
CASE PAC-E-25-02
Dear Commissioners,
I am writing to strongly oppose Rocky Mountain Power's proposal to reduce the solar export
credit rate from current retail rates(approximately 8 cents per kilowatt-hour(kWh))to 4 cents
per kWh.This drastic reduction in compensation for excess solar energy sent to the grid is not only
unfair to existing solar customers but also damaging to Idaho's clean energy future.

Violation of Agreement Terms
When I installed my solar system, I signed a Customer-Generator agreement with Rocky Mountain
Power,which explicitly states:
"By signing the Customer-Generator agreement the Customer acknowledges that this program and
export credit are subject to change and the export credit will be updated routinely to more
accurately reflect the value of the energy exported. The value of the export credit and how often
it is updated will be determined by the Commission."
This clause clearly states that any adjustments to the export credit should reflect the value of
exported energy. But who is setting the value of exported energy? In this case, it appears that the
value is being set by Rocky Mountain Power(RMP),without consideration of the solar generating
customer's investment. In fact, RMP's whole proposal totally ignores the very substantial
investment that solar-generating customers pay in order to partner with the utility company to build
a cleaner energy future.
By artificially lowering the export rate to 4 cents per kWh—well below the retail rate paid by
non-solar customers,which I consider to be the value of the energy exported—Rocky Mountain
Power is violating the intent of this agreement.The proposed reduction does not accurately reflect
the value of exported energy.
This statement from RMP's website bears comment: "The credit is designed to ensure that
customers who don't choose to own their own power generation systems will not subsidize those
who do." How are non-solar customers subsidizing those who choose to generate their own power?
I personally would like to see the data that supports this claim. It seems that the contributions of
solar-generating customers, i.e. providing excess power to RMP to help meet increasing energy
demands without the huge RMP expense required to construct new clean-energy sources, are
completely ignored in their proposal.
Approving this export credit rate change would set a dangerous precedent: utilities recommend
export energy credits at devalued rates,which often get approved by the PUC, discouraging new
installations and robbing homeowners of fair remuneration for the power they generate. It feels
Like I've been jabbed in the throat!
How This Proposal Affects My Solar Investment
Below is a breakdown of my actual solar costs and the projected financial impact on me for the
proposed export credit rate cut. [Note: For the purposes of this illustration, data is taken from Feb
2024 to Feb 2025.] The following scenario, based on my actual costs for the preceding year, is used
to show annual savings due to solar energy production and then show how long it will take,
assuming fixed rates,to pay off my investment.

In order to estimate my savings due to solar energy production, I first had to calculate how much
energy my home would consume if I did not have a solar generating system. This value,the non-
solar consumption value, is the amount of power delivered to my home from RMP plus my home's
internal power consumption. My home's internal consumption is calculated by determining the
total solar-generated power and then subtracting the number of kWh delivered to RMP from my
system. These values were calculated on a separate worksheet, available on request, and were
used to provide the estimates in the following table:
Initial Solar Actual cash benefit Total Out-of-
Installation Cost from Fed and State Pocket solar
(2021) income tax credits. installation cost
$42,599.00 $947.33 $41651.67
Total Annual Net energy Billed Export Rate Energy Credit Additional cost Non-Solar Annual Years to
Energy Charges exported to grid Average for Net solar due to reduced Annual Energy Savings due payoff
(Per RMP Billing) (kwh) export export credit Cost Estimate to Solar
Actual Values $636.14 2319 0.09536 $221.13 NA $1751.58 $1115.44 37.3
Feb 2024-Feb 2025
Future years at $636.14 2319 0.04 $92.76 $128.37 $1751.58 $987.07 42.2
same rate
Assumption:Export credit reduction only affects net energy exported to RMP.
RMP delivered 10,682 kWh to my home and received 8,408 kWh from my home.
My solar panels generated about 13,727 kWh with 4,839 kWh being consumed internally. The total
non-solar consumption for my home was 15,521 kWh. From RMP billing statements, I determined
that 2,319 kWh were actually exported back to the grid and generated export credits.
Using the non-solar consumption value, I estimated the annual energy cost and used that figure to
determine how much my solar system is offsetting the billed energy cost.The table shows an
annual savings, due to solar energy generation, of about$1,115, or about 2/3 of my energy bill.
Now, substituting the proposed export credit rate of.04$/kWh, in place of the current rate(about
.095$/kWh), my annual savings drops to about$987, a 12%decrease.
The pay-off time for my solar energy investment at the current rate is 37.3 years,which is
significantly greater than I was led to believe when I first purchased my system in 2021.At the
proposed 4-cent export credit rate, my system will take an additional 5 years to pay off using solar
savings alone. I will never see a full return on my investment in my lifetime.
Solar generating systems are expensive enough, and this policy essentially destroys any incentive
to me, and likely most energy-conscious residential customers,for any future investment in clean
solar energy. This clearly prioritizes benefiting Rocky Mountain Power at the solar-generating
customer's expense. I know that we, as solar-generating customers, individually do not make a big
impact on Idaho's transition to clean energy, but collectively we can make a big contribution.
Please don't put this huge roadblock in our way and keep us from even wanting and/or trying to
make a difference.

Lessons from California's Mistake
California implemented a similar reduction in solar export rates(NEM 3.0)in April2023, and the
results were disastrous:
80%Drop in Solar Installations:After the implementation of NEM 3.0, California experienced a
significant decline in rooftop solar installations,with reports indicating an 80% reduction. PV
Magazine USA[Dec 20231
17,000 Job Losses in the Solar Industry:The California Solar&Storage Association (CALSSA)
reported that the state's new net energy metering framework, NEM 3.0, led to or was expected to
Lead to a reduction of 17,000 jobs by the end of 2023, accounting for 22%of all solar jobs in the
state. UtilityDive.com [Jan 20241
Increased Reliance on Fossil Fuels:The restructuring under NEM 3.0 aimed to reduce grid
shortfalls and reliance on fossil fuels by introducing high differential time-of-use (TOU) rates;
however,the reduction in export credit rates under NEM 3.0 led to a significant decline in new solar
installations.This decrease in solar adoption could potentially slow the transition to renewable
energy,thereby maintaining or increasing reliance on fossil fuels. Palmetto [Nov 20241
If Idaho follows California's failed path,we will see:
• A major slowdown in new solar adoption, harming Idaho's solar industry.
• Increased reliance on Rocky Mountain Power's fossil-fuel-based grid, leading to higher
rates for everyone overtime.
• Stranded investments for solar customers, leaving many homeowners unable to recover
their solar costs.
• Decreased trust in the PUC regarding its care and concern for the citizens of Idaho and
Idaho's clean energy future..
Why the 4-Cent Rate is Unjustified
Rocky Mountain Power argues that solar customers should only receive about 4 cents per kWh,
aligning with wholesale energy rates.This argument is flawed because it ignores the real benefits
of distributed solar, such as:

• Reducing Peak Demand: Distributed solar energy systems generate electricity during
daylight hours,which often coincide with periods of high electricity demand.This alignment
helps reduce the overall peak demand on the power grid.
Clean Coalition [Dec 2022]
• Avoiding Transmission Costs: By generating electricity at or near the point of
consumption, distributed solar reduces the need for long-distance electricity transmission.
This localization minimizes energy losses that occur during transmission and can defer or
eliminate the need for new transmission infrastructure.
US EPA[Apr 2024]
• Enhancing Grid Resilience: Distributed solar energy systems contribute to grid resilience
by diversifying energy sources and decentralizing power generation.This decentralization
can help maintain power supply during grid disturbances and reduce the impact of
localized outages.
RMI.org[Sep 20171
Rather than acknowledging these benefits, Rocky Mountain Power's proposal transfers value
from homeowners to the utility by buying energy at artificially low rates and selling it at full
retail price to all customers.
My Request to the PUC
I respectfully urge the Idaho PUC to reject Rocky Mountain Power's proposal and instead:
1. Maintain the current retail export rate per kWh to ensure fair compensation for solar
customers.
2. Conduct a full economic analysis on the value of distributed solar, including grid
reliability, peak demand reduction, and avoided infrastructure costs.
3. Hold Rocky Mountain Power accountable to the agreement terms by ensuring the export
credit reflects the true value of exported energy.
4. Encourage Rocky Mountain Power to develop new business models that encourage
distributed clean energy production and meet RMP's power infrastructure development and
maintenance demands.
5. Learn from California's failed policy change and protect Idaho homeowners from a
similar collapse in solar adoption.
6.

The Idaho PUC's decision on this proposal will determine the future of rooftop solar in Idaho. I
urge you to stand with homeowners and the power utilities to determine fair compensation for all,
and ensure Idaho's clean energy progress is not reversed by an unjustified utility-driven policy
change.
Respectfully,
Michael Gardner
P.S. Please acknowledge receipt of this statement to me. I sincerely request a response to my
concerns.
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