20250515Comments.pdf

RECEIVED
May 15, 2025
Martha S Bibb IDAHO PUBLIC
810 CD Olena Dr UTILITIES COMMISSION
Hailey, ID 83333
503-539-8863
marthasbibb&gmail.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 MARTHA BIBB'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
Dear Members of the Idaho Public Utilities Commission,
Part of The Public Utility Commission's mission is to "Regulate public utilities to secure and
promote the general safety, health and public welfare."'
Pursuant to this is fostering utility rates and systems that help to achieve these ends. I am going
to focus my comments on a few related areas that Idaho Power failed to include in its rooftop
solar Export Credit Rate calculations.
Background
Distributed solar power contributes many quantifiable and tangible environmental and health
benefits that benefit all ratepayers and the public at large.
In fact, in 2021 the PUC originally directed Idaho Power to outline and quantify these benefits.
Here is an excerpt from the approved Study Framework:
'Idaho Public Utilities Commission 2024-2027 Strategic Plan,found at:
htti2s�Hnuc.idaho.gov/Fileroom/PublicFiles/laws/PUC%202024%20to%202027%20Strategic%20Planad
MARTHA BIBB'S COMMENTS REGARDING THE FIRST ANNUAL ECR UPDATE - 1

Avoided Environmental Costs and Other Benefits'
Evaluate environmental and other costs that are quantifiable, measurable, and only include
avoided costs that affect rates.
• Quantify the potential value of grid stability, resiliency, and cybersecurity protection
provided by on-site generators as a class and different penetration levels.
• Quantify the value to local public health and safety from reduced local impacts of climate
change such as reduced extreme temperatures, reduced snowpack variation, reduced
wildfire risk, and other impacts that can have direct impacts on Idaho Power customers.
• Quantify local economic benefits, including local job creation and increased economic
activity in the immediate service territory.
• Quantify the possible net value of Renewable Energy Credit sales produced by net
metering exported energy.
• Quantify the reduced risk from end-of-life disposal concerns for the Company compared
to fossil fuel resources.
However, when Idaho Power conducted its own"Value of Distributed Energy Resources"
(VODER) study, it concluded that the value of these benefits to ratepayers was 0 0/kWh.'
Unlike the inhouse study conducted by Idaho Power staff, Crossborder Energy, who conducted
an independent study, concluded that the value of these various benefits alone are between
3-11.7 ¢/kWh.4
I think it's critical that the PUC take a closer look at Idaho Power's assumptions around
quantifying the value of distributed solar to environmental and public health, which ultimately
impacts all ratepayers and utility rates, and aligns with the PUC's mission of promoting"general
safety, health and public welfare."
Quantifiable Public Health Benefits
We all know that carbon dioxide, nitrogen oxides, methane and particulates are released by
burning fossil fuels. These greenhouse gases and other pollutants are altering climate patterns,
impacting air quality, and polluting our water. They are causing an increase in extreme weather,
heat waves, drought, and wildfires here in Idaho, all of which have impacts on human health.'
'Revised Study Framework(starts on page 22 of pdf),found at
hW2s://puc.idaho.2ov/Fileroom/PublicFiles/ELEC/IPC/IPCE2121/Company/20211116Fina1%20Comments.12df
s Idaho Power VODER study,page 78,found here:
hW2s://puc.idaho.2ov/Fileroom/PublicFiles/ELEC/IPC/IPCE2222/CaseFiles/20221026 Voder%2OStud- Clean.pdf
a Crossborder Energy study,found at:ht� sn .//lf-nuc.idaho.gov/WebLink/DocViewasnx?dbid=0&id=72411
s Fifth National Climate Assessment,Chapter 27 on Northwest,found at:
hh ps://nca2023.globalchange.gov/chap ter/27/
MARTHA BIBB'S COMMENTS REGARDING THE FIRST ANNUAL ECR UPDATE - 2

Reducing fossil fuel emissions will reduce cardiovascular and pulmonary illnesses and deaths.
Morbidity and mortality are costly. Sick days are expensive to our economy. Not to mention
death.
These climate change impacts on public health have been well documented in many notable
studies, including the Idaho Climate-Economy Impacts Assessment Human Health Report'. See
also the local group of medical providers called Idaho Clinicians for Climate &Health that
research and disseminate this information in Idaho.'
The average Idahoan already spends $8,148 per person on health care (2024). Costs are predicted
to rise by 1-3%per year due to climate change. At 3% increases that cost would rise to $1,227
per person by 2030 . These are quantifiable health costs that impact ratepayers.
Distributed solar power helps displace fossil fuel power and therefore helps mitigate climate
change, resulting in tangible public health benefits and lowered health-related costs on ratepayers
and society as a whole. While Idaho Power argues that these cost savings don't relate to utility
rates, they are real costs that you, as the PUC, should feel a moral and public duty to value and
take into account in your decision-making.
Quantifiable Environmental Benefits
Fossil fuels and climate change not only increases individual medical expenses, but also
expenses for the utility company—which ultimately impacts rates and ratepayers. Distributed
solar power therefore helps reduce these expenses, as well.
Burning less fossil fuels will help to protect the utility from future necessary costs like carbon
taxes and high indemnity bonds, which would then increase costs to ratepayers. Even with
limited carbon prices or carbon reduction requirements at the federal or state level in Idaho, we
know these kinds of political and economic pressures on reducing carbon pollution will only
grow in the future as climate change intensifies. Distributed solar helps Idaho Power reduce the
need to invest in and use these other dirty fuel sources that will become more costly (for the
utility and all ratepayers) in time. Crossborder Energy quantified these avoided carbon costs in
its own study, which I urge you once again to review and consider.'
Mitigating climate change with distributed solar power also helps protect hydropower
generation, a critical component of Idaho Power's affordable power supply, which is increasingly
6 Idaho Climate-Economy Impacts Assessment Human Health Report 2021 Helen Brown,Steve Peterson,found at:
hUs://www.uidaho.edu/president/direct-reports/mcclure-center/iceia/human-health
h=s://www.idahocliniciansforclimateandhealth.orQ/
s Crossborder Energy study,found at:htt sn .//lf-puc.idaho.goy/NVebLink/DocView.asl2x?dbid=0&id=72411
MARTHA BIBB'S COMMENTS REGARDING THE FIRST ANNUAL ECR UPDATE - 3

impacted by reduced snowpack and increasing temperatures. Idaho Power studies these impacts
of climate change on its hydro system in its own Integrated Resource Plans', even measuring
how system costs will increase with increasing climate impacts over time. These costs to
ratepayers are measurable, and should be included in the rooftop solar Export Credit Rate
avoided costs calculations.
The need to conduct Public Safety Power Shut Offs during extreme weather events and wildfires
will be mitigated by working to reduce these climate driven natural disasters through distributed
solar. The same is true for the increasing preventative measures (and physical and legal
consequences) that Idaho Power is facing with more frequent and severe wildfires from climate
change, as evidenced in its own Wildfire Mitigation Plan,10 which are very costly. This will save
Idaho Power money which will save ratepayers money, and of course help ensure more safe and
reliable power for ratepayers, as well.
Distributed solar power generation also decreases the use of distant, dirty power generation,
which reduces Idaho Power's line losses, makes the grid more resilient, and offsets the
company's stated need for building new methane gas fired plants, which emit a potent
greenhouse gas that accelerates climate change." By reducing reliance on long distance
transmission from a single large source, distributed solar reduces communities' vulnerability
during power outages,protecting individual homes and families, but also critical facilities like
hospitals and clinics. All of this is exacerbated with the increasing temperatures and heat waves
we're seeing and will continue to see with climate change, which decreases the efficiency of
transmission lines at a time when electricity is direly needed to keep people and facilities cool
and safe.
While many of these components (like Line Losses, Transmission & Distribution Deferrals,
Avoided Energy, etc.) are included in Idaho Power's current calculations, you must ensure they
are capturing the full and true value that ratepayers receive, including the related climate and
environmental benefits that ultimately tie back to system costs and customer rates.
Conclusion
I, as a roof top solar power generator, am helping my neighbors by exporting power to the utility.
Producing clean solar energy translates into a low cost environmentally safe source of power
v Idaho Power Integrated Resource Plans,found at:
)hps://www.idahopower.com/energy-environment/energ;�/nlanning-and-electrical-12rp j ects/our-twenty-year-elan/
90 Idaho Power 2025 Wildfire Mitigation Plan,found at:
hUs://docs.idahopower.com/pdfs/Safety/WildfireMiti gationPlan.Rdf
11 Idaho Power 2025 IRP Draft Preferred Portfolio,found at:
https:Hdocs.idahopower.com/pdfs/AboutUs/PlanningForFuture/20251RP_DraftPreferredPortfolio.pdf
MARTHA BIBB'S COMMENTS REGARDING THE FIRST ANNUAL ECR UPDATE - 4

which mitigates medical costs caused by climate change. I am helping all ratepayers by
producing low cost, clean power. I have absorbed the costs associated with installing that power
generation. I am not using any additional land or water. I am not releasing any carbon into the
environment.
I—and any other solar owners, now and in the future—should be treated and compensated fairly.
Rooftop solar power generation saves all ratepayers money spent on climate related health care
costs. It reduces deaths. It improves air quality and liveability in our state. It decreases numerous
financial costs for the utility (including several environmentally-related expenses), which helps
keep rates low for all ratepayers. All from a personal financial investment made by individual
customers,not the utility.
Given the findings from independent research and the known environmental and health benefits
of distributed solar, it is concerning that the current valuation method appears to significantly
underrepresent these contributions.
An Export Credit Rate that dips below one cent per kWh and varies unpredictably year to year
introduces serious financial challenges for solar customers,undermining the long-term feasibility
of these systems for many Idaho families.
I respectfully ask the Commission to reassess the underlying methodology and consider
adjustments that more accurately reflect the value of customer-generated solar power in Idaho's
energy future.
Respectfully submitted,
DATED: May 15, 2025.
Martha S Bibb
MARTHA BIBB'S COMMENTS REGARDING THE FIRST ANNUAL ECR UPDATE - 5