20250523Comments_7.pdf

The following comment was submitted via PUCWeb:
Name: Louis Popppler
Submission Time: May 22 2025 4:31 PM
Email: [e-mail]
Telephone: [phone]
Address:430 West Summit Ridge Road
Boise, ID 83702
Name of Utility Company: Idaho Power
Case ID: IPC-E-25-15
Comment: "I want to state my opposition to approval of Idaho Powers proposed export credit rate
decrease.The change is excessive and will negatively impact Idaho families, like mine that have invested in
solar power as a wayto ensure against rate increases and to help the planet.They estimate a 34% increase
to my power bill.That is excessive. If they wish to decrease the export credit rate,they should not be
allowed to decrease it to less than what they pay commercial solar power producers. Or, better yet,they
should just increase rates marginally for all Idaho Power customers to cover their costs, rather than punish
a select group of customers who are proactively trying to help Idaho (and Idaho Power) achieve their stated
climate goals:'
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The following comment was submitted via PUCWeb:
Name: Denver Barfuss
Submission Time: May 23 2025 8:10AM
Email: [e-mail]
Telephone: [phone]
Address:430 Summit Ridge Rd
Boise, ID 83702
Name of Utility Company: Idaho Power
Case ID: IPC-E-25-15
Comment: "We just installed solar panels on our roof and the proposed reduction in the ERC is quite
substantial and would have changed our decision on solar and battery.As it stands this rate reduction
makes our solar almost valueless and we would be better off building battery capacity rather than
delivering back to the grid.
I am NOT in favor of the proposed ERC reduction by Idaho power. "
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From: Bradley Dawson ([e-mail])Sent You a Personal Message
<kwautomai[@ph one2action.com>
Sent: Friday, May 23, 2025 9:12 AM
To: secretary
Subject: IPC-E-25-15 Public Comment
Dear Idaho Public Utilities Commission,
Electricity is becoming a more in-demand resource every year with Al and cryptocurrency needs only
adding to the demand.This proposal takes money out of the pocket of the everyday Idahoan for the benefit
of big industry and it is a terrible look for our State government.
?m very concerned about Idaho Power?s proposal to slash rooftop solar compensation rates by up to 80%.
Paying rooftop solar owners less than 1 ?/kWh for the power they put onto the grid for eight months out of
the year,while then charging regular customers at least 8?/kWh for that same electricity, is extremely
unfair.
Last yearandapos;s solar rate changes, coupled with the increased fixed service charges,were already
devastating for Idaho Power customers. Please do a thorough review to check the utilityandapos;s math
and assumptions, listen to outside experts and customers, and donandapos;t let this monopoly utility
unfairly squeeze money out of its customers and undercut their right to generate their own power.
Also, please improve the public process by adding a virtual testimony option (as is provided at Public
Service Commissions in all neighboring states)to help ensure you can hear the important perspectives
from everyone who will be impacted by Idaho Power?s changes.Written comments and public hearings
with limited times and locations are not enough.
Thank you.
Sincerely,
Bradley Dawson
628 4th Ave. N
Twin Falls, ID 83301
[e-mail]
[phone]
This message was sent by KnowWho, as a service provider, on behalf of an individual associated with Sierra
Club. If you need more information, please contact Member Care at Sierra Club at
[e-mail] or(415)977-5673.
--------------------------
The following comment was submitted via PUCWeb:
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Name: Bradley Dawson
Submission Time: May 23 2025 9:18AM
Email: [e-mail]
Telephone: [phone]
Address:628 4th Ave. N
Twin Falls, ID 83301
Name of Utility Company: Idaho Power
Case ID: IPC-E-25-15
Comment: "The proposal by Idaho Power to decrease homeowner compensation (ECRs) happens at the
same time that they propose to increase fixed charges on all customers.This will result in less electricity
available in our grid to Idahoans, even as Al and cryptocurrency mining are putting huge new demands on
our system. It's a clear attempt at monopolization for the benefit of big business at the expense of the
everyday Idahoan and should be rejected. "
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The following comment was submitted via PUCWeb:
Name:John Beecham
Submission Time: May 23 2025 12:47PM
Email:[e-mail]
Telephone: [phone]
Address:7252 N. Pierce Park Ln
Boise, ID 83714
Name of Utility Company: Idaho Power
Case ID:
Comment: "Eleven years ago, my wife and I spent$30,000 dollars on a solar system to partially meet our
demand of energy during our retirement years.At that time were we able to generate enough electricity to
eliminate our demand on the state's energy system for 8 months of the year. Since then,the PUC has
changed the rate structure compensating us for our energy production and now we cover our energy use for
about 4 months of the year.
The current proposed Idaho Power rate structure will essentially require us to donate all our energy
production to Idaho Power eliminating any benefit to us for investing in solar energy production.
Energy economists suggest that the demand for additional energy in the near term is going to require the
use of both renewable and non-renewable energy sources to maintain and eventually increase our
economic productivity in the U.S.
I see no advantage to individual solar energy producers to contribute to a system that is essentially
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"stealing"the energy we produce everyday so Idaho Power can increase their profit margin and continue to
give the CEO of Idaho Power one of the highest compensation packages in the state.The new proposed rate
schedule simply punishes individual current and future solar power producers and reduces incentives for
those producers to invest in the additional power needed to maintain and increase the economic
productivity of the state and country.
am so upset by this naked attempt to punish individual solar producers that I am contemplating turning
my system off until more forward-thinking public service representatives can be elected to reverse this
trend.Alternatively, I may invest in sufficient battery storage to allow me to operate totally off the grid. It
makes no sense to me that the PUC would approve this new rate structure proposal while, at the same
time, acknowledging that the U.S. needs electric power from all types of producers to maintain our
competitive edge in the world's economy.
Please record my opinion as a state resident(two if you include my wife)totally opposed to Idaho Power's
rate structure proposal.At the same time, I encourage the PUC to change the current rate structure to fairly
compensate all individual energy producers.
apologize if this letter is late, but I just returned from a trip and was not aware of this proposal until today.
Sincerely,
John Beecham
7252 N. Pierce Park Ln
Boise, ID 83714
[phone]"
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The following comment was submitted via PUCWeb:
Name: Michael Stone
Submission Time: May 23 2025 12:09PM
Email:[e-mail]
Telephone:[phone]
Address: 1212 N 18th St
Boise, ID 83702
Name of Utility Company: Idaho Power Company
Case ID: IPC-E-25-15
Comment: "I am writing as a concerned Idaho ratepayer to express serious objections to Idaho Power's
proposed Export Credit Rate update.
THE VER STUDY: FLAWED METHODOLOGY
At the heart of Idaho Power's rate reduction proposal lies their 2024 Variable Energy Resource study,which
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claims that integration costs have increased from$0.293 per kilowatt-hour to$0.697 per kilowatt-hour—a
staggering 138%increase. Idaho Power attributes this to increased solar penetration on their system,
which grew from 0.61%to 2.12%of total capacity.
Idaho Power is essentially arguing that solar energy becomes more expensive to integrate as more people
adopt it.This creates a perverse feedback loop where each new solar installation makes every existing
solar installation less valuable to the grid. Under this methodology, if Idaho achieved 10%solar
penetration, integration costs could theoretically become astronomical, making solar energy nearly
worthless regardless of its actual benefits.This approach defies basic economic principles. Increased
adoption leads to economies of scale and improved efficiency, especially with technological advances.
THE SMART INVERTER PARADOX
Idaho Power's analysis becomes even more questionable when we consider technological advances.
Since January 1, 2024, Idaho Power has required all new solar installations to use smart inverters
complying with IEEE 1547-2018 standards.These devices don't just convert DC solar power to AC
electricity;they actively support grid stability through voltage regulation,frequency response, and other
grid services.
Idaho Power acknowledges in their filing that"smart inverters support the distribution system's ongoing
stability and reliability."Yet their VER study appears to ignore these benefits entirely. Instead of recognizing
that modern solar installations with smart inverters might actually reduce integration costs compared to
older systems,the methodology treats all solar generation as equally challenging to integrate.This creates
an absurd situation where Idaho Power mandates technology that improves grid performance but then
penalizes customers for using it.
THE AVOIDED COST SHELL GAME
When my neighbor's solar panels generate electricity that powers my air conditioner on a hot afternoon,
that transaction doesn't require expensive transmission lines, doesn't contribute to peak demand on
distant power plants, and doesn't result in line losses.Yet Idaho Power's methodology values that locally-
generated clean energy based on wholesale market prices that may be hundreds of miles away.Solar
energy that reduces peak demand on local distribution circuits can defer expensive infrastructure upgrades
for years. In some cases, distributed generation can eliminate the need for new substations or
transmission lines entirely.These benefits should be substantial,yet they're barely reflected in Idaho
Power's calculations.
REGULATORY WHIPLASH AND BROKEN PROMISES
The Commission worked carefully to establish "legacy"and "non-legacy" customer categories specifically
to protect existing investments while allowing for future changes. Legacy customers were grandfathered
under net metering to protect their reasonable investment expectations,while non-legacy customers were
told they would be subject to new compensation structures.
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The problem:the first"new compensation structure"was just implemented in January 2024(barely over a
year ago). Non-legacy customers who installed solar systems in 2024 based their investment decisions on
ECR rates that are now being slashed.These aren't customers who benefited from net metering for years;
these are people who followed the new rules and made investments based on the Commission's approved
rate structure.
Now,just one year later, Idaho Power wants to change the rules again.A customer who installed a solar
system in February 2024 based on the Commission-approved ECR rates now faces a 34%bill increase.This
isn't gradual rate evolution; it's regulatory whiplash that undermines the entire framework the Commission
created to balance existing investments with evolving grid needs.
A PATH FORWARD
I'm not arguing that the ECR should never change or that Idaho Power shouldn't recover legitimate costs
associated with grid integration.What I'm asking for is a more thoughtful, evidence-based approach.The
Commission should require Idaho Power to justify their VER study methodology with independent review
and transparent analysis. Integration cost calculations should be verified by third-party experts.The
methodology should account for the benefits of modern smart inverter technology rather than treating all
solar generation as equally challenging to integrate.
As Idaho grows,we need policies that encourage innovation, support customer choice, and build energy
resilience.These proposed rate changes do the opposite—creating barriers to clean energy adoption and
undermining investments thousands of Idahoans have already made:'
From:Alison Ward <[e-mail]>
Sent: Friday, May 23, 2025 10:47 AM
To:Adam Rush
Cc: secretary
Subject: Re: Comments regarding the Idaho Power Export Credit Rate proposal
Good morning,
Perhaps we are not following the correct process, however,we have attempted to email this letter twice on
5/14 and again on 5/19 to be posted as part of the public comments for PUC Rate Case with Idaho Power
regarding the solar export rate, specifically.
I will submit a signed copy via mail as well, however, it was suggested that I try to include each of you one
more time via email.
Thank you,
Ali Ward
On Mon, May 19,2025 at 2:30 PM Alison Ward <[e-mail]>wrote:
Good afternoon,
just wanted to make sure that this letter(sent by sharon.sniderC�boiseschools.org our clerk of the board),
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dated/sent May 14,2025 is posted to the PUC's public comment section, as a .pdf it was difficult to do that
through the web portal.
Thank you,
Ali Ward
On Wed, May 14, 2025 at 10:32 AM Sharon Mast<sharon.sniderCcbboiseschools.org>wrote:
Good Morning,
Please see the attached Letter of testimony from the Boise School District regarding the Idaho Power
export credit rate proposal. Please let me know if you have any questions.
Best Regards,
Alison Ward
Boise School District
Sustainability Supervisor
208-854-4106
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......�&cationc,/........
o19 The Independent
School District of Boise City
w EST. \/ 1881
SCHOOLS 8169 W. Victory Road [phone]
Boise, Idaho 83709 Fax[phone]
SustainabMty,
May 14th, 2025
Dear Commissioners,
As a public school district serving over 22,000 students and stewarding taxpayer dollars across
dozens of facilities,we appreciate the opportunity to share our perspective on Idaho Power's
proposed changes to net metering and export rates for distributed solar.
Our district has taken thoughtful steps toward long-term financial stewardship and resilience.
Distributed solar is one of the most practical,proven tools we have to reduce emissions,improve
reliability,and manage long-term costs.We recently contracted to install behind-the-meter solar at
Whittier Elementary, funded through a mix of federal tax credits,energy efficiency savings, and local
reinvestment. Similar district-wide projects are designed to reduce operational costs by hundreds
of thousands of dollars over time and provide hands-on learning opportunities for students.
The proposed changes to export rates significantly extend our projected payback period—from 12
to as many as 18 years—introducing financial uncertainty that makes it more difficult to plan
responsibly and invest in future systems.This is especially challenging in a funding environment
where operations dollars remain flat while utility costs continue to rise. It also introduces risk
where our community expects predictability and fiscal stewardship.
We believe that distributed solar—when implemented thoughtfully—can reduce long-term costs,
strengthen local grid and energy resilience (including backup power during periods of extreme
heat),support us in responsibly reducing harmful air emissions,and prepare students for
high-demand careers in energy, engineering,and construction.
Undermining the economic viability of solar today puts at risk our ability to serve a public safety
and fiscally responsible role tomorrow.We respectfully urge the Commission to consider a fair and
comprehensive valuation of distributed solar that reflects its full benefits to the grid and to the
communities we serve.
Thank you for your consideration.
Sincerely,
Dave Wagers Lisa Roberts Alison Ward
President, Superintendent, Sustainability Supervisor
Board of Trustees Boise School District Boise School District
Boise School District
"Educating Today For a Better Tomorrow"
An Equal Opportunity Employer-Educator