20250717Comment_1.pdf

From: B.J. Driscoll<[e-mail]>
Sent:Thursday, July 17, 2025 11:05 AM
To: secretary<[e-mail]>
Cc:Adam Rush <[e-mail]>
Subject: PAC-E-25-02, Public Comment
Dear Idaho Public Utilities Commissioners,
I write to offer comment on Rocky Mountain Power's (RMP) application to reduce the value
of credit for energy exported from private on-site generation systems, specifically solar
panels (PAC-E-25-02). As a purchaser of such an on-site solar generation system, I am very
concerned and frustrated that RMP would attempt to"move the goalposts" by proposing to
reduce the credit value from $0.09 to$0.10 per kilowatt hour for residential customers to"a
time-differentiated financial bill credit that would be approximately$0.04 per kilowatt
hour." This is more than a 50% reduction in the credit that customers receive, a substantial
reduction by any measure. There are several reasons why RMP's proposal should be
modified.
First, private individuals cannot negotiate with public utilities. The PUC is the moderator
between the people and the monopoly of public utilities. Because we private individuals
cannot negotiate directly with public utilities, and we generally do not have the option of
"taking our business elsewhere"and selecting another provider,the PUC becomes our only
advocate and meaningful representative with the public utilities. While I understand there
are many issues involved, the PUC must remember that it is the people's representative
and defense when it comes to managing the business of our public utilities.
Second, a fundamental principle of a functioning and successful economy is to minimize
changes to the market. This is to promote stability in markets and to build confidence in
market participants. Participants will reduce or cease investment in markets that provide
no stability. Applying this economic principal to the current situation, I literally spent over
10 years looking at on-site solar generation as an investment in greater energy self-reliance,
an environmental contribution, and a tool to hedge against increasing energy costs over
time. Finally, in 2024, my financial position and my research lead me to decide to invest
roughly$60,000 in an on-site solar generation system. I knew it was not a great short-term
investment, but determined it would be valuable as a conservative long-term investment,
while providing additional energy independent and environmental benefits. A major factor
in making this decision was the energy export credit rate that I could rely on from my
summer production to offset the cost of my winter energy usage. In fact, the energy export
credit rate is the single most important factor. I also understood that the PUC had
previously granted "grandfathered"or"legacy"status to system owners established before
2020 and would maintain certain terms with them until 2045. This makes sense, balancing
the guarantee of changing circumstances and technologies and the need for reevaluation
and adjustment, against the need for stability and consistency in the market. Subsequent
customers could not get the benefit of this prior group's status, but they should be able to
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rely on the conditions of the program in effect at the time they sign up. The PUC should do
the same thing with the current application, rejecting rate reductions on current customers
who invested in reliance on the program offered at the time, while placing a later phase-out
deadline on current rates for on-site generators to 2050 or similar, thereby allowing people
to receive the benefit of their bargain as most of these system investments have a 20+year
lifespan. The PUC should only consider applying RMP's proposed reduced export credit
rate to prospective customers, not existing customers, with a reasonable sunset provision
to then reevaluate.
Even without having researched the matter in greater depth, I can appreciate that there are
many competing factors to be considered in these applications. However, at the forefront
of the consideration of this application and any enduring system must be fundamental
principals of fairness,justice, and economic stability. As the only voice of the people in
negotiating with public utilities, the PUC must remember and honor this special
responsibility.
Thank you for your consideration.
B. J. Driscoll
1051 N. 575 E.
Firth, ID 83236
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