20250515Comments.pdf

RECEIVED
May 15, 2025
IDAHO PUBLIC
Kevin Dickey UTILITIES COMMISSION
2953 Honey Lane
PO Box 337
Emmett, ID 83617
208.841.5354
[e-mail]
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER )
COMPANY'S APPLICATION FOR ITS ) CASE NO. IPC-E-25-15
FIRST ANNUAL UPDATE TO THE EXPORT )
CREDIT RATE FOR NON-LEGACY ON- ) KEVIN DICKEY'S INITIAL COMMENTS
SITE GENERATION CUSTOMERS FROM )
June 1, 2025 THROUGH MAY 31, 2026 IN )
COMPLIANCE WITH ORDER NO. 36048 )
Kevin Dickey, pro se, hereby submits his initial comments with respect to Idaho Power's ECR Update.
1
KEVIN DICKEY'S INITIAL COMMENTS
IPC-E-25-15

The Mission Statement of the Idaho Public Utilities Commission begins "The Commission serves the
citizens and utilities of Idaho by ensuring that the rates and policies established for utility services are
fair,just, reasonable..." 1 With respect to allowing Idaho Power to unilaterally determine the Export
Credit Rate (ECR) that is used to compensate Idaho's small capacity solar generators, the Commission's
policy is neither fair,just, nor reasonable.
The Commission stated in Order 35284:
"The Commission finds that the Company is best positioned to access and study the extensive
data and issues specific to the Idaho Power system at a reasonable cost. We understand the
argument that third-party evaluators have a different perspective and the results may be believed
to be more credible by some customers. However, third-party studies may be more generic and
not fully reflect the environmental requirements in Idaho or the peculiarities and/or particulars of
the Company's system. Studies conducted in other states provide insight but are not
determinative of what is most reasonable for Idaho Power's customers."2
By effectively stating that no one but Idaho Power can determine the ECR, the Commission put the fox in
charge of the henhouse. The ECR determines the price that Idaho Power pays for the solar energy
produced by Idaho's small capacity generators. It is in Idaho Power's interest to keep costs low, so
naturally they have a preference for minimizing the ECR. But their conflict of interest goes beyond
minimizing costs.
Through its Clean Energy Your Way—Construction offering, Idaho Power stated in a March 22, 2022 news
release that in partnership with Micron, they were "enabling large customers to partner with Idaho
Power on new, dedicated renewable energy resources to meet business sustainability goals, while
simultaneously adding new renewable resources to Idaho Power's system"3 (emphasis mine). This
program established by Idaho Power provides renewable energy to the grid which is in competition with
Idaho's small capacity generators. As the recent blackouts in Spain have shown', all electrical systems
have a limit on how much renewable energy, as a percentage of total energy, a system can safely handle.
A low ECR disincentivizes additional small generator capacity leaving more room for Idaho Power and its
large company partners to monopolize the renewable energy on the grid.
1 IPUC 2024 to 2027 Strategic Plan. Page 2.
z https://If-puc.idaho.gov/WebLink/DocView.aspx?dbid=0&id=71011. Page 11.
3 https://www.idahopower.com/news/idaho-power-and-micron-technology-partner-to-advance-solar-powered-renewable-
energy-in-idaho/
n https://theconversation.com/spain-portugal-blackouts-what-actually-happened-and-what-can-iberia-and-europe-learn-from-
it-255666
2
KEVIN DICKEY'S INITIAL COMMENTS
IPC-E-25-15

As the Chart 1 points out, the only thing that is decreasing under Idaho Power's stewardship is the ECR.
In the last four years, consumer residential rates are up 18%.5 This increase, while large, is less than half
the increase in compensation for Idaho Power's top four executives.' From an average of under $10
million dollars per annum ($2.4 million/executive) in 2021-2022, Idaho Power's top four executives'
compensation increased 39%to an average of$13.5 million dollars per annum ($3.4 million/executive) in
2022-2023. While Idaho Power was increasing residential rates and significantly increasing their
executive compensation, the compensation Idaho Power plans on paying its small capacity generators
will plummet nearly 80% if their proposed ECR Update is allowed to move forward.'
Idacorp (Idaho Power)
Change in Residential Average Power Bill,
1.50 Big4 EO Pay & Idaho Power Determined ECR
Idaho Power Big4 EO total annual $14.37
1.40 compensation in millions of dollars
1.30 $12.72
1.20
1.10 $10.68
1.00
0.90 $8.74
p 0.80
N
0 0.70
0.60
0.50 $Ratio to 2021-Avg Bill,$/mn
0.40 Ratio to 2021-Idaho Power Big4 EO Compensation
0.30 -*-Ratio to 2021-ECR Compensation
0.20
0.10
0.00
2021 2022 2023 2024 2025
Chart 1 Calendar Year
Kevin Dickey's Comments in IPC-E-25-15
5 https://findenergy.com/providers/idaho-power/. 2025 estimate applies the PUC approved pricing increase.
6 Idacorp DEF14A filed 2001-03-30 and Idacorp DEF14A filed 2025-04-01.
https://Puc.idaho.gov/Fileroom/PublicFiles/Press/Workshop/Idaho%20Power%2OWorkshop%2OFinal%2007.pdf. Page 22.
3
KEVIN DICKEY'S INITIAL COMMENTS
IPC-E-25-15

Table 1 summarizes this discrepancy.
Changes in the Last Four Years
Average Idaho Power Small Capacity
Residential Big4 Execs Generators
Power Bill Compensation Compensation
18% it 39% -79% It
Table 1
Kevin Dickey's Comments in IPC-E-25-15
While correlation does not necessarily imply causation, the $4 million/year in increase compensation to
just four Idaho Power executives eats up approximately 50% of the savings Idaho Power would realize
from their 79% decrease in the ECR rates in comparison to the Legacy 1:1 payment structure.
In Order 35631, the Commission stated:
"We want to make clear that our decision in this case is whether to acknowledge that the Study
complied with our previous directives. Our decision is not a determination that a specific
method or value within the Study is superior to another" $(emphasis mine).
So, after admitting that the Commission did not find Idaho Power's ECR establishing VODER study'to be
superior, the Commission still allowed a conflicted party to determine the method for obtaining the ECR
even when there was an alternate study presented that showed, even using Idaho Power's determined
VODER components, that Idaho Power was underestimating the ECR by nearly four times, Table 2.11
s https://If-puc.idaho.gov/WebLink/DocView.aspx?dbid=0&id=71906. Page 28.
s https://puc.idaho.gov/Fileroom/PublicFiles/ELEC/IPC/IPCE2222/CaseFiles/20221026 Voder%20Study Clean.pdf
10 https://puc.idaho.gov/Fileroom/PublicFiles/ELEC/IPC/IPCE2222/Intervenor/ICL/20220921Comments.pdf
Independent Review of the Idaho Power Company's Value of Distributed Energy Resources Study. Beach & McGuire.
September 20, 2021. Page 9.
4
KEVIN DICKEY'S INITIAL COMMENTS
IPC-E-25-15

Critique of the IPC VODER Study Crossborder Energy
September 20. 2022
Table ECR ReColllll end ation.S (S per lUfflo
Component IPC VODER Study Crossborder
Avoided Energy 28.24 47.30
Avoided Generation Capacity 10.60 35.00
T&D Deferral 0.26 49.80
Avoided Line Losses 1.64 9.50
Integration Costs (2.93) (0.64)
Total 37.81 140.96
Table 2
Kevin Dickey's Comments in IPC-E-25-15
In summary, if there was an organization called the Solar Installers of Idaho that had monopoly control on
all solar panel installations in Idaho and they were given the ability to come up with an ECR that
"complied with the (Commission's) previous directives", the ECR would be a very large number. Similarly,
when the Commission gave the monopoly utility the ability to come up with an ECR that "complied with
the (Commission's) previous directives" it should be no surprise that they came up with an ECR that was
minimized. A perfect example of this is that Idaho Power even managed to use negative rates in their
calculation of the 2024 Energy Value as shown in Table 3.1112
"https://Puc.idaho.gov/Fileroom/PublicFiles/Press/Workshop/Idaho%2OPower/`20workshop/`2OFinal%2007.pdf. Page 20.
12 Unfortunately, Idaho Power abrogated it's responsibilities and refused to answer KEVIN DICKEY'S SECOND PRODUCTION
REQUEST TO IDAHO POWER COMPANY. The eight part question was specifically asked to determine the relevance of Idaho
Power's choice of the pricing inputs(including the negative pricing) in Table 3. By refusing to answer the simple request, Idaho
Power is admitting that the pricing used in the Energy Value portion of the VOIDER calculation is not realistic, nor relevant, but
clearly the pricing does help to minimize the calculated ECR,which seems to be the goal.
5
KEVIN DICKEY'S INITIAL COMMENTS
IPC-E-25-15

. • • • • • •
Table l
Nevin Dickey's Comments m tOC•f QS•15
Month Value Energy SAI%%,h Month Value Energy S/MWh
1 S 102,879 3.144 S 32.72 1 S 245.051 3913 S 62.63
2 $ 167.545 6362 S 26.33 2 S 136.706 7,016 S 19.49
S 233,461 8973 $ 26.02 3 S 141.922 12,802 S 11.09
4 S 436204 9977 $ 43.72
5 $ 445,602 11.077 S 40.23 5 S (12,752) 20240 $ (0.63)
6 $ 320,466 10,728 $ 29.87
7 $ 574,323 8,850 S 64.90 7 S 416.881 13,686 S 30.46
8 S 567.746 7,962 S 71.30 8 S 361,978 14,319 S 25.28
9 S 592,657 8.543 S 69.37 9 $ 351.963 13988 S 25.16
10 $ 516,061 9.157 $ 56.36 10 $ 434.150 12,701 $ 34.18
11 $ 332.075 4,809 $ 69.06 II $ 241.687 6,853 $ 35.27
12 S 517.249 2,494 $ 207.40 12 $ 150.126 4.311 S 34.82
S 4,806,268 92.076 $ 52.20 S 2,769,787 145.879 S 18.99
$2,055,192 36,084 S 56.960 $ 1.401.205 59.339 S 23.61
$2.751.076 55.993 S 56.13 $ 1.368.582 86.539 S 15.81
What would be a "fair,just, and reasonable" way to establish the ECR? Neither the fictional "Solar
Installers of Idaho", nor nonfictional Idaho Power should be allowed to establish the ECR. They should
both be conflicted out. An independent firm should be hired to help establish a "fair,just, and
reasonable" solution. Allowing Idaho Power to set the ECR is an abrogation of the Idaho PUC's
responsibilities.
The first question that will be asked is "who will pay for it?" The answer is "whoever determined that the
Legacy 1:1 system of renumeration needed to be replaced". By my calculation, the initial reduced ECR in
2024 saved Idaho Power approximately$4 million which they turned around and paid out to four
executives. 14,000 small capacity solar generators were shorted so that four executives could take home
an extra $1 million each on average. There is nothing "fair,just, or reasonable" about that. If Idaho
Power believes that the Legacy 1:1 payment system is unfair, then they should prove it by paying for an
unbiased independent evaluation.
6
KEVIN DICKEY'S INITIAL COMMENTS
IPC-E-25-15

Per Order 36558 1 hereby request that a hearing be held with the purpose of finding an unbiased
independent evaluator that can help determine what is "fair,just, and reasonable" in determining an
ECR. Such a step is unlikely to be fulfilled through written comments as witnesses will need to be called
and consultants evaluated.
DATED this 151" day of May, 2025.
R
Kevin Dickey
V
7
KEVIN DICKEY'S INITIAL COMMENTS
IPC-E-25-15

CERTIFICATION OF SERVICE
I hereby certify that on May 15, 2025, a true and correct copy of the within and foregoing KEVIN DICKEY'S
INITIAL COMMENTS was served in the manner shown to:
Electronic Mail (see Order 35375)
Idaho Power Company
Megan Goicoecha Allen Connie Achenbrenner
Donovan E. Walker Mary Alice Taylor
Idaho Power Company Idaho Power Company
[e-mail] (filing) [e-mail]
[e-mail] (name) [e-mail]
[e-mail]
[e-mail]
Commission Staff Clean Energy Opportunities for Idaho
Monica Barrios-Sanchez Kelsey Jae
Commission Secretary [e-mail]
[e-mail]
Erika K. Melanson
[e-mail]
Sierra Club and Vote Solar City of Boise
Gregory M. Adams Jessica Harrison
Rose Monahan Katie O'Neil
[e-mail] [e-mail]
[e-mail] [e-mail]
[e-mail]
Individual Intervenor Individual Intervenor
Martha S. Bibb Scott Pinizzotto
[e-mail] [e-mail]
s/Kevin Dickey
8
KEVIN DICKEY'S INITIAL COMMENTS
IPC-E-25-15