20250610Comments_2.pdf

The following comment was submitted via PUCWeb:
Name: Robert Smith
Submission Time: Jun 10 2025 7:32AM
Email: skitoy55 gmail.com
Telephone: [phone]
Address: 11423 West Camas Street
Boise, ID 83709
Name of Utility Company: Idaho power
Case ID: IPC-E-25-15
Comment: "Why is Idaho power asking for Yet another rooftop solar rate of 60-80%? We
just had a rate reduction on Jan 1 st 2024 that has negative financially impacted each solar
homeowner. Now another rate reduction to estimated under 1%will make the whole
residential solar unaffordable and would be detrimental to the solar industry.
This proposal undermines the value of solar energy, contradicts Idaho Power's clean energy
goals, and disproportionately impacts lower-income customers.
Idaho Power seeks to reduce this rate to an average of 2.46 cents per kWh annually, with
potential reductions to under 1 cent per kWh during the non-summer months"
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The following comment was submitted via PUCWeb:
Name: Cynthia Gibson
Submission Time: Jun 10 2025 3:29PM
Email: [e-mail]
Telephone: [phone]
Address: 710 N. 6th St.
Boise, ID 83702
Name of Utility Company: Idaho Power
Case ID: IPC-E-25-15
Comment: "Dear Commissioners;
On behalf of the Idaho Conservation League (ICL) and our thousands of members across
the state, we respectfully submit this comment opposing Idaho Power's application in
Case# IPC-E-25-15, which proposes drastic reductions to the Export Credit Rate (ECR)for
customer-owned rooftop solar generation.
ICL represents over 30,000 supporters and organizations throughout Idaho. Among our
membership are Idaho Power customers who have purchased onsite solar generation and
others who would like to do so in the future. These members, as well as most Idahoans,
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favor reducing their power expenses by switching to clean, renewable energy and receiving
compensation for unused power.
This proposal—if approved—will fundamentally undermine the economic viability of
rooftop solar in Idaho, further weaken customer trust in the regulatory process, and set
back our state's progress toward a cleaner, more resilient energy future.
A 72% Reduction Is Unjustified and Irresponsible
Idaho Power seeks to reduce solar export compensation from 6.18 cents per kilowatt-hour
(kWh)to an annual average of just 2.46 cents per kWh—a 72% cut from the former 8.8 cent
standard. Particularly egregious is the proposed seasonal rate, which would compensate
solar exports at less than 1 cent per kWh during October through May. Meanwhile, the
utility charges consumers over 8 cents for that same energy—a stark example of
asymmetrical treatment and an unjustified financial penalty on solar-producing
households.
These deep cuts will make it far more difficult for Idahoans to invest in solar, especially
Lower- and middle-income households already burdened by rising energy costs and Idaho
Power's increasing fixed fees. Idahoans who made clean energy investments in good faith
under prior rate structures now face dramatically diminished returns.
Idaho Power's Methodology Lacks Transparency and Fairness
ICL and other independent experts have identified serious flaws in Idaho Power's 2022
Value of Distributed Energy Resources (VDER) study—the foundation of this proposal.The
utility's internal analysis cherry-picks assumptions that minimize the value of rooftop solar
while omitting or undervaluing key benefits, such as avoided transmission costs, resiliency,
grid deferral value, and societal environmental benefits.
In contrast, independent studies across the country consistently find that the value of
distributed solar often equals or exceeds retail rates when fully accounted for. Idaho
Power's process lacks the transparency, peer review, and independence that Idahoans
deserve from their monopoly utility.
The Proposal Undermines Energy Choice and Public Interest
Rooftop solar provides broad public benefits that extend far beyond the customer
generating the power.These include:
Reduced strain on the grid during peak demand periods
Lowered transmission and distribution losses
Deferred infrastructure costs that save ratepayers money
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Local job creation and economic development
Increased energy resilience and independence
Yet, under Idaho Power's proposed structure, the utility captures full retail revenues while
minimizing fair compensation to customers who invest in generating clean, distributed
power. This one-sided arrangement fails to align with the public interest and instead
reflects a business model that prioritizes shareholder profits over customer empowerment
and long-term sustainability.
A Pattern of Erosion and Instability
Over the past several years, Idaho Power has steadily dismantled the structures that once
made rooftop solar a viable option for Idahoans. From the rollback of net metering to the
introduction of Net Billing and now to this latest proposal, the utility's approach fosters
instability, distrust, and confusion—deterring new adopters and stranding existing
customers in a shifting regulatory landscape.
ICL has stood with thousands of Idahoans in every phase of this fight, urging the
Commission to maintain stable, fair, and forward-thinking policies. Unfortunately, those
pleas have often gone unheeded, and the result is a solar marketplace facing collapse.
We recommend the following:
Maintain current Export Credit Rates while an independent, transparent value-of-solar
analysis is conducted with stakeholder input.
Establish a moratorium on further ECR reductions until a more robust, evidence-based
framework is developed.
Protect customer investment and confidence by offering rate stability and grandfathering
provisions for existing and future solar customers.
Idahoans want clean, local, affordable energy. They want a fair deal from their utility. And
they want a Commission that stands up for the public good—notjust utility bottom lines.
Thank you for the opportunity to submit comments. ICL remains committed to working
collaboratively with the Commission, Idaho Power, and Idahoans to build an energy system
that reflects our shared values:'
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