20250515Comments.pdf

Tyler Grange RECEIVED
y g May 15, 2025
6149 Meeker Place IDAHO PUBLIC
Boise ID 83713 UTILITIES COMMISSION
208-997-6527
Tvler&idahomeenergy.com
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 TYLER GRANGE'S COMMENTS
NON-LEGACY ON-SITE GENERATION REGARDING THE FIRST UPDATE TO
CUSTOMERS FROM JUNE 1, 2025, IDAHO POWER'S EXPORT CREDIT
THROUGH MAY 31, 2026, IN RATE
COMPLIANCE WITH ORDER NO. 36048
At the request of IPUC Staff at the May 7t'Public Workshop, I would like to propose a separate and
simple method for determining the Export Credit Rate (ECR), supported by many of the local industry
professionals, including but not limited to installers, self-generators and distributors.
We believe the current method, approved by the IPUC, does not seek fairness for the consumer, but
rather disproportionately grants the company an excessive margin of profitability and does not pertain
directly to the fixed costs associated with providing the infrastructure needed for our distributing means
to interconnect to the grid.
Background
Without the ability to have an impartial 3'parry conduct these calculations we cannot be confident in
the utility's proposed costs to provide the infrastructure needed for self-generators to self-consume solar
production or to share excess generation with immediate neighbors. Therefore, we will not rely on
biased, historically inaccurate data to be applied.
Idaho Power unabashedly attempts to slow the growth of the self-generating community, evident by
incorrect and misleading information found on the Idaho Power website. The information provided is
inaccurate and intentionally skews the reader's opinion to deter interest in installing solar. We believe
the same effort is evident in the VODER study and recent proposal provided by Idaho Power to deter
consumers from installing the only alternative source of energy. We must remember, this is a private,
for-profit utility with a monopoly on electric resources in their service territory, and the PUC is meant to
ensure it's not overreaching.
The data received by the IPUC and applied to the current system of establishing the ECR is given from
the utility's perspective. The IPUC has rejected the overwhelming desire of the consumers it serves to
TYLER GRANGE'S COMMENTS REGARDING THE FIRST ANNUAL ECR UPDATE - 1

have the means of procuring impartial data and methodologies to be applied in determination of the
ECR. By allowing Idaho Power to develop its own methodology, with inherent biases and assumptions,
and approving that framework with very little revisions, it is our belief that the IPUC has failed its
primary regulatory duty. As the only regulatory agency tasked with checks and balances and protecting
the consumers, having failed to regulate the investor-owned utility, we believe Idaho Power can and will
be subject to an anti-trust complaint and investigation.
Customer Financial Impacts
In the May 7`'Public Workshop, the staff of the IPUC admitted having a limited understanding of the
financial impact the adjustment to ECR has on Idaho Power self-generating consumers. The negative
effects of these decisions are devastating on the well-being of the consumers the IPUC is sworn to
protect. To demonstrate the magnitude of negative effects the change to net-billing and this proposal has
had or could have,we, as industry experts, have provided a summary below, highlighting the significant
increase in cost to the consumer to maintain a similar offset of electric utility costs.
Important note: The Residential Solar Providers Disclosure Act(48-1805)was adopted to mandate that
Solar companies accurately represent the financial assumptions when estimating a system for potential
consumers. The current and proposed net-billing structure will not allow an accurate representation as
the data cannot be collected to correctly assess the utility offset.
Please review the following information. All information is accurately collected and assessed by many
industry-specific resources. We believe all information provided to the IPUC should be fact-checked by
an impartial entity.
2023 Net-Meter(excess generation)Value(avoided cost of electricity for residential consumers)= 10.97¢/kwh
Value of Net-Meter is concluded by the avoided average price per kWh, although the retail value, once solar had been
installed, was considered roughly 8.9¢/kwh as self-generators with equal annual production/consumption were not billed at a
tier 2 or tier 3 rate.
*Retail value 10.97¢/kwh(average residential price per kwh)
Source:https://www.eia.gov/state/print.php?sid=ID
Current Net-billing (excess generation) compensation (Jan 2024—present)
Summer On-peak 16.43¢/kwh 54.5% increase from 2023
Summer Off-peak 5.6533¢/kwh 48.5%reduction from 2023
Non-Summer hours 4.8365¢/kwh 55.8%reduction from 2023
Annual Average 6.2348¢/kwh 43.1%reduction from 2023
Proposed Net-billing (excess generation) compensation:
Summer On-peak 14.0598¢/kwh 14.4%reduction from current
Summer Off-peak 1.7682¢/kwh 68.7%reduction from current
TYLER GRANGE'S COMMENTS REGARDING THE FIRST ANNUAL ECR UPDATE - 2

Non-Summer hours 0.9540¢/kwh 80.3%reduction from current
Annual Average 2.4585¢/kwh 60.2%reduction from current
Total proposed annual reduction from December of 2023 87.6%
This would be the single largest decrease to solar net-billing in the country's history,surpassing California's roughly 75%
decrease with NEM3.
A solar prospect prior to December of 2023, intending to offset 100% of their usage charges, would
have received an estimate with the following parameters:
1. The system, however designed(brand/rating of components/panels), would be required to
produce an equal or greater amount of electricity than the homeowner consumed in the prior 12
months.
a. This information is provided by software specifically designed to indicate a solar
system's potential output and includes an assumption of weather condition data.
b. The weather condition data is provided by three different condition sets, our design team
chose the middle output,providing the best chance of accuracy using the variable data.
2. The excess energy(produced by the system and not immediately consumed) would be passed
beyond the meter to be compensated for. These kWh credits would be held in perpetuity and
applicable to imported energy from Idaho Power.
3. Because the energy consumed could be easily matched by the systems expected production a
fairly accurate assessment could be made of utility offset.
4. At this time the National and regional average price per watt for a solar system fully installed
was $3.20/watt.
a. A 7 kW system would generate enough electricity to offset$100-130/month of utility
expense.
b. The variability of offset is due to the tilt, azimuth and shading of the panels as well as
many other factors.
c. A 7 kW(DC Nameplate capacity) system would sell for approximately $22,400 given the
$3.20 average above.
5. Although usage costs can be avoided, a connection fee of$5/month and a municipal charge of
16-21¢ was required to pay on all monthly bills.
A current solar prospect intending to offset 100% of their usage charges would receive an estimate
with the following parameters:
1. The system, however designed, would be required to produce a multiple of 1.155 to 1.25 times
the energy consumed in the prior 12 months.
a. Idaho Power claimed the average annual compensation for excess energy is 6.18¢/kWh.
b. Providing the majority of self-generators stayed in the tier 1 billing; the average retail
cost of electricity is roughly 9¢/kWh annually.
c. We can now deduce, on an average basis, compensation for excess energy had been
reduced by 31%.
d. A facility generating an equal amount of electricity to their prior 12 months consumption
on average uses half(50%) of the production immediately and will pass on the remaining
half(50%)to the utility for compensation to be applied to future billing.
e. If half of the energy produced loses 31% of the compensation, we believe a 15.5% (half
of 31%) deficit would need to be accounted for.
TYLER GRANGE'S COMMENTS REGARDING THE FIRST ANNUAL ECR UPDATE - 3

2. Because the value of compensation has such a vast difference seasonally and by hour it would be
nearly impossible to factor the prospects hourly consumption data vs. the hourly production data
and account for accurate excess credits. Therefore,we chose to overcompensate and
under-assume (degrade) system production relative to the loss of value at an additional cost to
the consumer.
a. If usage for the specific prospect is highest in the summer, we could assume the value of
excess energy would most likely be lower than the 6.18¢/kWh average provided by Idaho
Power. We would then propose the estimated production of 120-125% of last year's
consumption even though the potential for immediate use of solar production would
increase.
b. If usage for the specific prospect is highest in the winter, we could assume the value of
excess energy would most likely be higher than the 6.18¢/kWh average. Even though the
potential facility will most likely offset more utility expenses than we've estimated we
would still propose the estimated production would need to be a minimum of 115.5% of
last year's consumption.
3. We do not account for service charges, fixed cost adjustment or power cost adjustment in the
offset assumptions, although beginning in January of 2024, these fees can be paid for by excess
generation.
a. Example: the current $15 monthly service charge could be paid for by oversizing the
system. For every $1 of offset, the system will need to export 16kWh at the recently
claimed annual average of 6.24380. If we apply these credits to the $15 service charge, an
additional 241kWh's per month would be required. The production needed to offset this
expense annually can be produced by five (5) of the current 435-watt panels we are
installing.
b. If a client would like to produce enough energy to compensate for the additional monthly
costs (aside from the base rate) although variable and prorated based on volume, we
assume an average of roughly $25-30/month, typically 8-10 additional panels required.
4. Battery storage can now increase the value of self-generated energy by increasing
grid-independence; a term used to describe the percentage of consumption directly from
distributing resources.
a. As noted above, a homeowner producing an equal amount of electricity to the
consumption will have a grid-independence of 50% on average. If the home consumes
40kWh per day the system will produce roughly 80kh. Instead of sharing the excess
40kWh beyond the home and decreasing the monetary value, a battery can store some or
all of the electricity to be used when solar production is not available. If 20kWh battery
storage capacity is available to be cycled each day, this homeowner would then have a
75% grid independence. Only 25% of the system's production would now have a reduced
value.
b. A battery system can also be programmed to offload stored electricity to the grid during
increased compensation times. During the Summer on-peak times each kWh passing
outside the home will generate a credit of 16.99660. Solar facilities with batteries are
incentivized to distribute as much energy as possible, assisting in the excess demand
Idaho Power sees in peak usage times.
c. Our estimates do not include the added benefit of grid-independence or battery
programming during Summer on-peak simply because the value cannot be determined
with the limited information available. Hourly production and consumption data for the
individual would be needed as well as hourly weather data. Once this information is
available the conclusion will be in reference to the prior years' data and consist of too
many variables to consider accurate.
TYLER GRANGE'S COMMENTS REGARDING THE FIRST ANNUAL ECR UPDATE - 4

d. The added benefit of battery storage is best calculated by assuming the remaining
grid-dependence and what percentage of the facility's production is exposed to decreased
value from net-billing. Thus, the higher the percentage of grid independence, the more
valuable the produced electricity is.
e. If a client would like to increase grid independence and mitigate the loss of value, the
cost is roughly $1.50/watt for battery storage capacity considering the battery and
additional infrastructure required.
5. Currently the National and regional average price per watt for a Solar system fully installed is
$3/watt.
a. The prior offset of$100-$130 is now increased due to the rise in the base rate of power;
almost 8% last June and almost 4% in January and now requires a production increase of
15.5-25%to offset the same monthly payment. The prior 7 kW system must now be an
average of 8.4 kW.
b. An 8.4 kW system installed is now sold at a price of$25,200 given the $3/watt.
A future Solar prospect, given the proposed net-billing compensation and intending to offset 100% of
their usage charges, could receive an estimate with the following parameters.
1. The system, however designed, would be required to produce a multiple of 1.37 to 1.52 times the
energy consumed in the prior 12 months.
a. The assumption has been made, in Idaho Power's net-billing proposal the average annual
compensation for excess energy would be 2.4585¢/kWh.
b. Providing the majority of self-generators stayed in the current tier 1 billing; the average
retail cost of electricity is still claimed to be roughly 9¢/kWh annually.
c. We can now deduce, on an average basis, compensation for excess energy will be reduced
in value by 73%.
d. A facility generating an equal amount of electricity to their prior 12 months consumption
on average uses half(50%) of the production immediately and will pass on the remaining
half(50%) to the utility for compensation to be applied to future billing.
e. If half of the energy produced loses 73% of the compensation, we believe a 36.5% (half
of 73%) deficit would need to be accounted for.
2. Because the value of compensation has such a vast difference seasonally and by hour it would be
nearly impossible to factor the consumers hourly consumption data vs. the hourly production
data and account for accurate excess credits. Therefore, we would choose to overcompensate and
under-assume (degrade) system production relative to the loss of value, at an increased cost to
the consumer.
a. If usage for the specific prospect is highest in the summer, we could assume the value of
excess energy would most likely be lower than the 2.4585¢/kWh average provided by
Idaho Power. We would then propose the estimated production of 145-152% of last
year's consumption even though the probability of immediate use of solar production
would increase.
b. If usage for the specific prospect is highest in the winter, we could assume the value of
excess energy would most likely be higher than the 2.4585¢/kWh average. Even though
the potential facility will most likely offset more utility expenses than we've estimated,
we would still propose the estimated production at 136.5% of last year's consumption.
3. We do not account for service charges, fixed cost adjustment or power cost adjustment, or other
fees in the offset assumptions. The client can request additional panels to offset the cost of these
fees, however, we would strongly discourage this as the payback on investment is now outside of
the life of the product.
TYLER GRANGE'S COMMENTS REGARDING THE FIRST ANNUAL ECR UPDATE - 5

a. Example: the current $15 monthly service charge could be paid for by oversizing the
system. For every $1 of offset, the system will need to export 41 kWh at 2.45850. If we
apply these credits to the $15 service charge, an additional 615 kWh per month would be
required. The production needed to offset this expense annually can be produced by
thirteen (13) of the current 435-watt panels we are installing.
b. If a client would like to produce enough energy to compensate for the additional monthly
costs (aside from the base rate) although variable and pro-rated based on volume, we
assume an average of roughly $25-30/month, typically 20-26 additional panels required.
4. Battery storage can increase the value of self-generated energy by increasing grid-independence
as defined above.
a. During the Summer on-peak times each kWh passing outside the home will generate a
credit of 14.05980.
b. Our estimates will not include the added benefit of grid-independence or battery
programming during Summer on-peak as explained above.
c. If a client would like to increase grid independence and mitigate the loss of value, the
cost is roughly $1.50/watt for battery storage capacity considering the battery and
additional infrastructure required, however, this cost is expected to increase as the
moratorium on tariffs for Lithium products and ancillary components has now ended.
5. The National and regional average price per watt for a solar system fully installed is expected to
increase 5-10%by Q3 of 2025 as the moratorium on tariffs for imported solar products has
ended. If we assume the lower end of the estimate (5%), the price per watt will be $3.15.
a. The prior offset of$1004130 will now require a production increase of 36.5-52%to
offset the same monthly payment. The prior 7 kW system must now be an average of
10.01 kW.
b. A 10.1 kW system installed is now sold at a price of$31,532 given the $3.15/watt.
In summary:
1. A prospective solar customer would pay 41.1%more, following the acceptance of this proposal,
to offset the same ratio of usage charges as they did in 2023. According to a well known source
for local and National solar data, Energ,�Sage, the average power bill in Idaho currently requires
12.68 kW to offset.
a. Pricing comparison:
• 12.68kW/1.2 = 10.56 kW(system size required in 2023) Cost of$33,792
■ 12.68kW(system size required currently) Cost of$38,040
• 10.56 x1.4425 = 15.233 kW(system size required June Pt as proposed) Cost of
$47,9842
2. The Idaho Public Utilities Commission has stated their Mission to be:
• Determine fair,just, reasonable and nondiscriminatory rates and utility practices for electric,
gas, telephone and water consumers.
a. This proposal is not and cannot be perceived as "fair," "just," "reasonable," or
"nondiscriminatory."
1. "Fair" - The distribution of electricity by Idaho Power is monopolistic by definition.
a. Fairness would be allowing a homeowner the ability to provide electricity
to their home by any other means not inhibited by the utility company. The
vast majority of homeowners are required to supply electricity to their
property via the electric utility company per the neighborhood CCR's. The
only alternative source of distribution, not unaffordable in comparison to
the electric utility, is privately owned solar facilities, owned and
maintained by the homeowner. Additionally Idaho Power refuses to allow
TYLER GRANGE'S COMMENTS REGARDING THE FIRST ANNUAL ECR UPDATE - 6

private individuals or companies to install community solar systems if
connected to their grid.
b. The value of the excess energy provided by the facility is uniquely
determined by the IPUC. This type of commodity value determination by
a small body of three Governor appointees is unprecedented and affects
now close to 20,000 self-generating facilities. This determination will
negatively affect the well-being of these individuals and their families
whilst granting the privately owned power company another record year of
profit.
2. "Just"—The IPUC has refused to robustly consider third party testimony or studies
provided to discredit the findings of Idaho Power and their heavily contested value
determination of the ECR.
a. The Crossborder Energy study directly refuted much of the testimony
provided by Idaho Power in the prior case, leading to the decision to allow
the net-billing program as we have today.
b. The method for checks and balances of Idaho Power's testimony has not
been disclosed, rather a public perception exists; the IPUC seems to have
taken the private utility company at their word. This is not just, and the
people of this community have repeatedly clamored for a re-calculation by
any third parry. It is the responsibility of the IPUC to ensure that Idaho
Power is not unfairly skewing rate calculations in its favor and to justify
the decreasing compensation to the self-generators in Idaho and it is our
opinion they've failed to do so.
3. "Reasonable"—It is not reasonable to lessen the value of compensation to
self-generating consumers by 87.6% over a 1.5 year span; increasing the cost of a
system to comparatively offset by more than 41%. The current self-generators will
take a massive hit to the affordability of electricity, setting the industry and the
advancements in technology back roughly 8-10 years in regard to price vs. cost of
utility.
a. In 2019 the IPUC suggested the change in compensation would be
contingent on a third-party study, easily understood by the public and
failed to hold accountable to either of these demands when reviewing the
VODER study.
4. "Nondiscriminatory"— Service charges have openly been called discriminatory as the
fees disproportionately affect low-income individuals.
a. An individual in a large home with an average usage cost of$300/month
would have seen a$10 increase in service fees from 2023 to now; a 3.33%
increase in cost per month.
b. An individual living in a small home,potentially low-income, with a
usage cost of$50/month would have seen the same $10 increase in service
fees; a 20% increase in monthly utility expenses. Next year, the $10
addition will account for a $20 increase in monthly service fees in just two
years, a 40% increase for the small homeowner.
c. If either homeowner would prefer to provide an alternative to the utility
expense the cost has risen dramatically to pay the additional fees for
service and other charges. As indicated above, 20-26 panels, a system size
of 10.005kw ($31,515.75) is needed to cover the cost of these fees
annually, this directly discriminates against a group of people; the solar
TYLER GRANGE'S COMMENTS REGARDING THE FIRST ANNUAL ECR UPDATE - 7

community and disproportionately affects low-income individuals right to
supplement energy costs or to offset expenses.
• Ensure the delivery of safe, reliable and efficient utility services.
a. This proposal is not and cannot be determined to promote increased or even
maintained safety, reliability or efficiency.
1. "Safety" - solar energy is considered safer and more environmentally friendly
than traditional utility power sources, as it doesn't produce pollution, requires
little water, and avoids the environmental damage associated with fossil fuel
extraction. Most importantly,wildfire has never been caused by a solar panel or
solar farm in the state of Idaho. Disincentivizing solar installations in any
manner, especially as dramatic as this proposal, reduces the safety of
consumption/distribution.
2. "Reliability"—Solar installations directly affect the reliability of the grid in
positive means. Reducing the necessity for increased transmission and
distribution efforts as well as providing individual resources of sustainable
energy provisions due to isolation components with battery systems.
Disincentivizing solar installations and reducing the supplemental demand
assistance provided directly negates the mission to provide and maintain
reliability, especially as Idaho Power has increased recent messaging regarding
outage preparedness.
3. "Efficiency"—There is no more efficient manner of consuming electricity than
self-consumption and on-site generation to be used within a small radius.
Further negating the value of distributed energy resources by individuals is
harming the efficiency of transmission and distribution.
• Regulate the public utilities to secure and promote general safety, health and public welfare.
a. This proposal is not and cannot be determined to promote increased or even
maintained safety, health or public welfare.
1. "Safety" - (see point above)
2. "Health" - Solar power is generally considered healthier than the grid because
it's a clean, renewable energy source that produces zero emissions, unlike
traditional grid power often generated from fossil fuels,which contribute to
greenhouse gas emissions and air pollution. Disincentivizing solar installations
directly negates the health advantages of solar generated electricity as an
alternative to the majority of Idaho Powers procurement resources.
3. "Public Welfare"—It is not in the best interest of public welfare to lessen the
value of compensation to homeowners by 87.6% over a 1.5 year span;
increasing the cost of systems to comparatively offset by more than 41%. The
current self-generators will take a massive hit to the affordability of electricity,
setting the industry and the advancements in technology back roughly 8-10
years in regard to price vs. cost of utility.
We believe the following must be considered:
1. The ECR should be easily understood by the General Public.
a. The current method of valuing the export rate credit is largely not understood by the
public or even many solar installers.
b. It is impossible for a consumer to compare their usage on an hourly basis to the
facility's production and calculate excess distribution to the grid. The current method
does not allow a consumer to fact-check the data received and advocate for
TYLER GRANGE'S COMMENTS REGARDING THE FIRST ANNUAL ECR UPDATE - 8

themselves regarding billing errors. To state that Idaho Power has never made a
billing error is grossly false, however, how would a consumer be able to tell?
c. The ECR is currently subject to change each year at the discretion of the IPUC
following reporting by Idaho Power. Consumers cannot accurately assess the value of
their distributed energy in effort to make a financial decision. We believe this is used
to intentionally deter future investments in self-generation.
2. The ECR should not be evaluated by determining the costs Idaho Power didn't have to pay
(avoided cost) to purchase energy from other resources.
a. The energy produced and consumed on site or by the next closest facility,unless rare
circumstance exists, does not utilize much of Idaho Power's infrastructure if any.
b. It is not reasonable to claim the difference between the average ECR and
average retail cost of electricity, roughly 8.5¢/kWh is required to pay for Idaho
Power's fixed costs for upkeep and maintenance due to distribution facilities.
c. Self generators should not be subject to paying for Idaho Power's other business
efforts, land purchases,profitability or any funding methods not directly related to
solar facilities.
3. The ECR should not change each year, causing high volatility and unstable investment
expectations.
a. It is irresponsible to rehash the value of excess generation each year. The use of
resources,paid for by the customers of Idaho Power,required for Idaho Power to provide
a biased and easily discredited report each year, is a waste of funds.
b. Each year the IPUC will have to review another proposal to allow Idaho Power to
lessen the value of customer owned distributed energy resources, followed by a
lengthy gripe by the affected community. Idaho Power has a lengthy and proven
record of effort to slow the growth of self-generated energy. Why would we allow the
company to repeatedly suggest less and less compensation for their only
competition each year and waste the Commission's time and the solar community's
time.
Alternative Proposal
We suggest a simple method, adopted by several other large privately owned utility companies across
the country for determining excess credit rates with an additional seasonal consideration. This method
provides the general public with an easy-to-understand calculation of export credit rates and allows the
solar community to provide accurate offset assumptions. We are willing to compromise in a good faith
effort for Idaho Power to exceed the cost recovery needed to more than pay for all infrastructure and
administrative burden caused by self-generators with additional room beyond fixed costs for profitability
or to be applied elsewhere.
Residential
1. October 1st to May 30t'of each year(non-summer); for every kWh of excess distribution from
the generating facility, the facility will receive a credit of 50% of that month's current tier 2
billing rates for residential customers.
2. June 1st to September 30t'of each year(summer); for every kWh of excess distribution from the
generating facility, the facility will receive a credit of 100% of that month's tier 2 billing rates for
residential customers.
3. The same compensation rates will apply to the customers opting for Time of Use Billing.
TYLER GRANGE'S COMMENTS REGARDING THE FIRST ANNUAL ECR UPDATE - 9

Commercial
1. Non summer(defined above); will receive 50% of the average price per kWh for the month
received.
2. Summer; will receive 100% of the average price per kWh for the month received.
Other considerations
1. The method approved will not change or be reviewed for 10 years from the active date.
2. The compensation must adjust as retail costs change for the consumer. The 50% and 100%
values will adjust as rates increase/decrease.
Respectfully submitted,
DATED: May 15, 2025.
Tyler Grange
TYLER GRANGE'S COMMENTS REGARDING THE FIRST ANNUAL ECR UPDATE - 10