20250515Comments.pdf

RECEIVED
May 15, 2025
JAYME B. SULLIVAN IDAHO PUBLIC
BOISE CITY ATTORNEY UTILITIES COMMISSION
Jessica Harrison ISB No. 9768
Deputy City Attorney
BOISE CITYATTORNEY'S OFFICE
150 N. Capitol Blvd.
P.O. Box 500
Boise, ID 83701-0500
Telephone: [phone]
Facsimile: [phone]
Email: BoiseCityAttomey�ic,,cityofboise.org
[e-mail]
Attorney for Intervenor
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER'S
APPLICATION FOR ITS FIRST ANNUAL
UPDATE TO THE EXPORT CREDIT RATE FOR Case No. IPC-E-25-15
NON-LEGACY ON-SITE GENERATION
CUSTOMERS FROM JUKE 1, 2025 THROUGH CITY OF BOISE CITY'S
MAY 31, 2026, IN COMPLIANCE WITH FORMAL COMMENTS
ORDER NO. 36048
The City of Boise respectfully submits the following comments in response to Idaho Power
Company's ("Company") Application in Case No. IPC-E-25-15 to revise Export Credit Rates
("ECR") and implement an annual update process. The City intervenes for three reasons:
1. The City has a stake in Idaho Power's approach to solar because it will impact our own
municipal billing. The City is one of Idaho Power's large customers, with over 1,098
unique municipal service accounts on various schedules. The City manages multiple
rooftop solar accounts as well, which generated 109,494 kwh in 2024.
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2. The City also represents through its constituents nearly 139,000 customers—residential as
well as commercial/industrial—as of 2024.As such,the City has a need to ensure that rates
are not just fair, but affordable for its citizens.
3. The City of Boise has adopted a Climate Action Roadmap that outlines its 2050 carbon
neutral goals, which aims to reduce greenhouse gases through energy efficiency and clean
energy, reduce pollution, and enhance the region's climate resilience. Increasing the
percentage of rooftop solar on both municipal buildings and as a percentage of all
community buildings is an explicit goal in the roadmap. Lowering ECR rates, even
temporarily, disincentivizes investment in rooftop solar and increases the payback period
for those who have invested in them.
AFFORDABILITY AND FAIRNESS
The Commission has a duty to ensure that rates are fair, just, and reasonable. The City
agrees with the Commission's stated position that"the fundamental purpose of on-site generation
is to offset a customer's own usage; that on-site generation should not result in cost shifting
between generators and non-generators; and that customers who generate on-site should receive a
fair value for the energy they export". This principle provides a reasonable framework for
balancing individual investment with system-wide equity.
However, the current proposal raises concerns regarding how "fair value" is defined and
calculated. The proposed ECR values—particularly in the non-peak season—are lower than even
the PURPA avoided cost rate, at less than 1 cent per kwh. These changes could result in a rate
design that is technically compliant with a cost-of-service method but results in unfair rates that
are not aligned with long-term affordability and risk reduction mandates.
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While ECR rates should be based on logical cost-of-service principles, there are many
assumptions that go into such a study. Changing any of these assumptions (fuel-price risk,
hydropower availability, etc.) can result in a different ECR. Therefore, it does not seem prudent to
base a customer-facing mechanism on conditions that can change drastically from year to year.
With an eye toward price transparency and fairness for all customers, the City urges the
Commission to review this new ECR holistically, and to evaluate it within the context of the
increased demand Idaho Power sees over the next 20 years and the need for a diversified resource
portfolio.
As Idaho Power's service territory continues to grow, customer-side solutions like rooftop
solar can contribute meaningfully to managing demand, delaying infrastructure investments, and
maintaining affordability. Limiting the growth of distributed energy through restrictive ECRs
could reduce customer participation in energy transition goals and increase long-term system costs
borne by all ratepayers.
IMPACT ON NON-LEGACY CUSTOMERS
Customers who have installed solar under the non-Legacy rate structure incur a significant
financial impact as a result of the new proposed ECR, as well as uncertainty on the payback period
for their rooftop solar systems. These rate changes may dramatically extend payback periods,
ultimately disincentivizing solar investments that provide benefit to the entire grid. In a period of
increasing demand, investments that reduce demand should be incentivized rather than
disincentivized.
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Average Bill Impact Average
Ave.Monthly Bill Average monthly monthly Dollar
Customer monthly usaU U Percent increa increase U
Category Count Current Proposed 0< 500 kWh 135% $ 15.17
0<500 kWh 3,218 $ 25.30 $ 40.47 500 < 900 kWh 57% $ 19.37
500<900 kWh 4,629 $ 47.70 $ 67.08 900 < 1,300 kWh 37% $ 25.65
900< 1,300 kWh 2,010 $ 75.56 $ 101.21 1,300< 1,700 kWh 33% $ 30.99
1,300< 1,700 kWh 916 $ 107.30 $ 138.29 1,700 kWh+ 23% $ 33.53
1,700 kWh+ 873 $ 199.05 $ 232.59
All Customers 11,646 $ 62.35 $ 83.62 Overall Average Increas 71% $ 21.27
The data shows an average 71% monthly bill increase for Schedule 6 customers'. An
average residential customer with rooftop solar using 900 kWh/month will see a bill increase of
37—57% or approximately $21.2
This is a significant increase for customers who invested in solar PV systems with the
understanding that they would be able to lower their energy bills, reduce demand on the grid, and
offset their own energy usage.
Customers need tools to manage and control their energy bills. Without available options
(and with service charges increasing from$5.00/month to now$15.00/month in 2025), customers'
options to manage their own energy and related billing impacts are more limited than before.Many
will look to solutions that permit them to defect from the grid entirely, which is not a sustainable
outcome.The proposed ECR will incentivize high-income customers to invest in behind-the-meter
batteries and other technologies. Lowering the ECR is not in the spirit of "affordability" and
"fairness"because it will place an unfair burden on those customers without the means to pursue
battery storage.
FUEL PRICE AND OTHER RISKS
In previous filings—including Case No. IPC-E-22-22—the City of Boise recommended
that Idaho Power include fuel price risk in its avoided cost calculations,particularly for natural gas
1 Exhibit 6,ECR Billing Data.
2(K.O'Neil based on Exhibit 6,Taylor DI).
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and coal-fired generation. These resources are subject to price volatility that can impact both
ratepayers and system planning.
Despite this recommendation being supported in multiple comment rounds,the Company's
methodology still does not account for fuel price risk as part of its ECR assumptions.According
to Commission Order 36048,which forms the basis of this application, "At this time the ECR shall
not include any adjustments for environmental costs or fuel cost risk." This omission is
inconsistent with least-cost,least-risk planning principles and underrepresents the long-term value
of customer-generated solar, which has no fuel cost and provides a hedge against fossil fuel
volatility. The Commission should direct the Company to explicitly consider this factor in ECR
filings and updates.
COMMISSION DISCRETION
While prior ECR adjustment methodologies have been approved in the past, the
Commission is not required to continue down the same path indefinitely. Each new proposal
warrants a fresh evaluation, particularly as market conditions, customer expectations, and grid
technologies evolve. The Commission has both the authority and responsibility to ensure that rate
structures support fair and forward-looking energy policies, and the Commission is not bound by
its past decisions if they do not align with forward-looking policies of fairness and affordability.
The Commission has broad authority to set rates that are fair,just, and reasonable. Strict
adherence to a rigid class cost-of-service methodology is not required,nor is it always appropriate.
Like a Class Cost of Service Study, Export Credit Rates are based on myriad assumptions, each
with its own calculation. Unless the Commission prefers to approve each calculation on its own,
the ECR is always going to be one possible outcome of many, depending on the input assumptions.
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The City would like to urge the Commission to use judicious review to adjust the ECR
values post-facto with the aim of allowing rooftop solar generation to be what it is supposed to be
"a way for customers to offset their own usage and receive a fair value for extra energy they
generate".Approving thoughtful ECR rates gives customers a fair and actionable way to manage
their bills without unduly shifting costs to others. This is a solution that lies within the public
interest, and the Commission has both the authority and the responsibility to make it happen.
Based on the foregoing, the City of Boise respectfully requests that the Commission does
not approve the proposed adjustment to the export credit rates and instead ensures that rate design
aligns with the principles of fairness, affordability, and risk management; considers the long-term
impact on customers who have invested in solar under the non-Legacy framework; recognizes the
importance of distributed solar to Idaho's clean energy future and as a generation resource to
address rapidly growing electrical loads; and directs the inclusion of fuel price risk in the avoided
cost methodology for fossil-based resources.
Submitted this 15th day of May, 2025
J ica Harrison,Attorney for the
Intervenor, City of Boise
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CERTIFICATE OF SERVICE
I hereby certify that I have on this 15th day of May 2025, served the foregoing documents
on all parties of counsel as follows:
Commission Staff ❑ U.S. Mail
Monica Barrios-Sanchez ❑ Personal Delivery
Commission Secretary ❑ Facsimile
Idaho Public Utilities Commission 0 Electronic Means w/Consent
11331 W. Chinden Blvd., Ste. 201-A ❑ Other:
Boise, ID 83714
secretary_kpuc.idaho.gov
Commission Staff ❑ U.S. Mail
Erika K. Melanson ❑ Personal Delivery
Deputy Attorney General ❑ Facsimile
Idaho Public Utilities Commission 0 Electronic Means w/Consent
11331 W. Chinden Blvd., Ste. 201-A ❑ Other:
Boise, ID 83714
Erika.melanson&puc.idaho.gov
Idaho Power Company ❑ U.S. Mail
Megan Goicoechea Allen ❑ Personal Delivery
Donovan Walker ❑ Facsimile
Connie Aschenbrenner 0 Electronic Means w/Consent
Mary Alice Taylor ❑ Other:
Regulatory Dockets
Idaho Power Company
1221 West Idaho Street(83702)
PO Box 70
Boise, ID 83707
mgoicoeacheaallengidahopower.com
dwalker&idahopower.com
[e-mail]
mtgylor&idahopower.com
dockets(&,idahopower.com
Clean Energy Opportunities for Idaho
Courtney White ❑ U.S. Mail
Mike Heckler ❑ Personal Delivery
Clean Energy Opportunities for Idaho Inc. ❑ Facsimile
3778 Plantation River Dr., Suite 102 0 Electronic Means w/Consent
Boise, ID 83703 ❑ Other:
mike(d),cleanenergyopportunities.com
courtney&cleanenerg_yopportunities.com
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Clean Energy Opportunities for Idaho ❑ U.S. Mail
Kelsey Jae ❑ Personal Delivery
920 N Clover Drive ❑ Facsimile
Boise, ID 83703 0 Electronic Means w/Consent
kelsey&kelseyjae.com ❑ Other:
Individual Intervenor ❑ U.S. Mail
Martha Bibb ❑ Personal Delivery
810 CD Olena Dr ❑ Facsimile
Hailey, ID 83333 0 Electronic Means w/Consent
marthasbibb(kgmail.com ❑ Other:
Individual Intervenor ❑ U.S. Mail
Kevin Dickey ❑ Personal Delivery
PO Box 337 ❑ Facsimile
Emmett, ID 83617 0 Electronic Means w/Consent
Bellefourche0l(kgmail.com ❑ Other:
Individual Intervenor ❑ U.S. Mail
Scott Pinizzotto ❑ Personal Delivery
PO Box 6902 ❑ Facsimile
Ketchum, ID 83340 0 Electronic Means w/Consent
spinizzotto(kgmail.com ❑ Other:
Sierra Club and Vote Solar ❑ U.S. Mail
Rose Monahan ❑ Personal Delivery
Sierra Club ❑ Facsimile
2101 Webster Street, Ste 1300 0 Electronic Means w/Consent
Oakland, CA 94612 ❑ Other:
rose.monahangsierraclub.org
Sierra Club and Vote Solar ❑ U.S. Mail
Gregory Adams ❑ Personal Delivery
Richardson Adams LLC ❑ Facsimile
515 N 27t' Street 0 Electronic Means w/Consent
Boise, ID 83702 ❑ Other:
re richardsonadams.com
Vote Solar ❑ U.S. Mail
Kate Bowman ❑ Personal Delivery
Vote Solar ❑ Facsimile
299 S Main Street 0 Electronic Means w/Consent
Suite 1300, PMB 93601 ❑ Other:
Salt Lake City, UT 84111
kbowman(a,votesolar.oriz
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Idahome Energy ❑ U.S. Mail
Tyler Grange ❑ Personal Delivery
6149 Meeker Place ❑ Facsimile
Boise, ID 83713 0 Electronic Means w/Consent
tyler&idahomeenergyy com ❑ Other:
(466 if,
Paralegal, City of Boise
CITY OF BOISE CITY'S FORMAL COMMENTS -9