20250512Comments_3.pdf

The following comment was submitted via PUCWeb:
Name:Thomas Lillo
Submission Time: May 9 2025 8:44PM
Email: [e-mail]
Telephone: [phone]
Address: 382 E 81 st N
Idaho Falls, ID 83401
Name of Utility Company: Rocky Mountain Power
Case ID: PAC-E-25-02
Comment: "I have reviewed the pending proposal case submitted by Rocky Mountain
Power concerning changes to the export credit for onsite generators. Rocky Mountain
makes the case as to the value to my exports to them. The main factor in their valuation is
the Loss-of-Load probability and they value my exports more only when their generating
capacity may be insufficient to meet demand. Thus the export credit is more during the
summer months and just about nothing during winter months. So in winter months any
exports I make during on-peak demand I will only receive 4.992 cents/kWh while they are
charging 15.8791 cents/kWh for any electricity imported during the same time period. Thus
they are making a profit of approximately 10 cents/kWh on my exports (minus line losses,
which are quite minimal according to the information in their proposal). I understand the
need to make a profit and the difficulties resulting from onsite generation (which can be
highlyvariable, especially in the winter months). However, the difference between export
credits and import costs during winter months are, in my opinion, excessive and too heavily
in favor of Rocky Mountain Power.The use of Loss-of-Load probability in the valuation of my
exports, in my opinion, does not adequatelyvalue my exports.
Furthermore, the proposed changes tend to discourage development of onsite generation -
onsite generation system are quite expensive and all maintenance is the responsibility of
the onsite generator- Rocky Mountain only needs to maintain secondary power lines to use
and profit from my exported energy. Currently, even with tax refunds and rebates, the
payback horizon for a PV solar generation system is in excess of 20 years. This proposal by
Rocky Mountain Power will increase the payback horizon even further- most likely beyond
the life of the PV panels - requiring purchase of new panels and thus never achieving the
break even point.This will discourage development of green generation of electricity.
Delocalized onsite generation over wide geographical area will reduce the inherent
variability associated with solar generation - resulting in a more reliable green source of

electricity. This proposal will discourage development of a wider geographical, delocalized
generating area (which, at the moment, consists of relatively few onsite generators -
according Rocky Mountain Power's testimony) and solar will never become a stable,
reliable source of electricity.
In summary, the proposed export credits for on peak and off peak hours during the summer
months appear reasonable but those proposed for the winter months are extreme and
should be based more on the import cost minus line losses and other maintenance costs. I
fail to see how Loss-of-Load probably should largely dictate the export credit:'
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The following comment was submitted via PUCWeb:
Name: Jeremy Gneiting
Submission Time: May 10 2025 10:07AM
Email: akilleusCcbgmail.com
Telephone: [phone]
Address: 92 N 3500 E
Rigby, ID 83442
Name of Utility Company: Rocky mountain power
Case ID: PAC-E-25-02
Comment: "72% increase is huge. What happens to the credits gained during this summer?
Will they be the current structure of one to one? Or do they change to the new structure if
this takes effect?"
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From: kristine dr-geek.com <[e-mail]>
Sent: Sunday, May 11, 2025 9:31 AM
To: secretary<[e-mail]>
Subject: Case PAC-E-25-02.
Please do not allow a decrease in payments to solar owners.
We signed up to have solar based on the amount of the return which was promised to
supply enough to negate our power bill. We struggle to have this happen due to long cloudy
winter days, and within a short period of time the panels began to degrade in their
performance. Some months we now have to pay both a power bill and a solar bill. We are

already feeling like the solar system was sold to us under false pretense. Should the
reimbursement drop further we will have no choice but to default on this loan.
I have spoken to other solar owners who are in the same boat they, like us, they are seniors
who believed or hoped to cap the ever-increasing price of power by being able to supply
power when moving to a fixed income. Only to find out that it is not turning out to be as
sold. Additionally, the fact was not covered that if you area senior purchasing solar the tax
credit does not turn out as expected since without working income the tax credit is no
Longer available.
Please keep us informed as to any class action that might arise from this as we would be
interested in joining.
Thankyou,
Kristine Summa
Current Solar Owner
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