20250818Comments_4.pdf

From: Cee Polly<[e-mail]>
Sent: Sunday, August 17, 2025 10:21 PM
To: secretary<[e-mail]>; Senator Kevin Cook
<[e-mail]>; [e-mail]; [e-mail]
Subject: Fwd: Commission reschedules virtual customer hearing to take testimony on
Rocky Mountain Power's on-site generation case, extends written comments deadline.
I am responding to this case and public the comment period extension, please provide the
following comments and attached comment letter regarding this matter to the Idaho public
utility commission secretary and commission members as our written comments to be
entered into the public record regarding the matter you emailed us about(on this
correspondence).
August 17, 2025
Honorable Brad Little; Idaho Governor
Idaho State Legislature
Idaho Public Utility Commission
Re: Proposed Rocky Mountain/Pacific Power Rate Scheme for Residential on-site Solar
Generation Systems; request to be approved for legacy status regarding upcoming rate
changes if approved and Letter to Idaho Residential on-site Solar Generation Systems
(Currently classified as Non-Legacy; however this is before the public hearing and any
proposed rate change-we are requesting this classification to be changed to Legus status -
grandfathering us into the current rate schedule as of the date of this letter August 17,2025,
if a new rate scheme is approved on any and all dates after the submittal of this letter,
please see attached in three parts Rocky Mountain Power customer letter and
cases referenced- Dated February 7, 2025.
To Whom It May Concern,
This letter is in regards to the case referenced in the IPUC notification email contained in
this correspondence and those within the February 7, 2025 letter attached along with the
new proposed rate scheme for residential on-site solar generating households. Apparently,
Rocky Mountain Power/Pacific Power Company doing business in California is proposing a
compensation and rate structure change for those Residential Idaho based on-site Solar
Generation Systems/household(s).These residential solar systems cost 10's of thousands
of dollars to install, and folks like me view them as protection to offset our utility bills in
order to provide some level of financial security. My wife and I are retired and on a fixed
income.
The letter indicates in Paragraph four on Page one that the purpose of the new rate scheme
is to provide a basis for implementing change to ensure that customers are paid a fair rate
for their export energy and those customers with Residential on-site solar generation
system are not being subsidizing by customers without solar or other self generating
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customers and therefore as indicated in Paragraph two on Page two- it will be necessary to
increase the onsite residential solar generators BILL by 72%. This will mandate that all
residential on-site solar generators pay more in order to be more equal to those customers
that do not generate their own power at their home, who have not invested 10"s of
thousands of dollars to put a roof top solar system on their home.
This is an outrageous rate scheme proposal by Rocky Mountain/Pacific Power Company
out of California, first to be compared to a billing amount of customers without solar who
did not invest 10's of thousands of dollars for some level of future financial security
regarding utility bill expenditures and second that any public utility would be bold enough
to believe that a 72% immediate increase in each residential solar on-site generators billing
amounts would be acceptable for the Idaho Public Utility Commission to implement as the
IPUC is our public steward charged with protecting their public and thus the utility
companies customers. The very purpose of the IPUC is to prevent a public utility such as
Rocky Mountain/Pacific Power Company doing business in California, whose business
mandate is to find a way to charge its customers more to bring in more revenue at any cost
to Idaho residents. Gaming the system by proposing confusing studies, which it appears
were constructed by identifying the monetary goal first and working in a financial formula
that results in the original monetary profit desired is an illegitimate means of supporting the
financial profit margin rate structure/scheme change. This just means the IPUC did a good
job with its original standards/regulations in approving an excess power generating
purchasing structure for Residential on-site solar generating households that was based on
substantial legal and legitimate facts, that outweighed their past and current analysis and
assertions, which is still the case regarding the matter before you.
The current rate structures were imposed after careful analysis, study and consideration,
which has lead to a valid rate structure, as retail rates go up, the utility company maintains
a relative purchase structure for the excess power generated by the the residential on-site
solar generating systems, which means everyone is relatively compensated fairly under the
current IPUC structure(Current IPUC residential on-site solar generation rate structure
schedule; value of credit for export energy from retail rate that is currently valued between
$0.07 and $0.18 per kwh, Paragraph three Bullet point one on Page 1).
Solar on my house uses the utility company's meter to determine the difference between
that which my system generates and I use on-site and the excess which moves through my
weatherhead and into the grid owned and managed by the utility company, which in turn
they sell at their inflated retail rates to my neighbors whom may not have solar. The amount
the utility company sells my power for is more than the utility company credits the value of
my excess energy, which my system has delivered to their grid.
In addition, I could understand a simple measurable and fair way of compensating the
utility company for using the excess energy generated from my system, even though they
are making money off the excess power my residential system generated and is passing
though my weatherhead to the utility companies grid for sale and use by my neighbors. This
compensation could be structured in such a way that the residential solar on-site excess
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power discharged to the grid from a weatherhead on a house is credited/purchased by the
utility company for resale at 25% less than the retail rate in which Rocky Mountain Power
charges the non residential solar generating customer and household. This rate structure
would allow the utility companyto obtain an instantaneous 25% profit on energy
seamlessly integrated into their system by each residential solar system at the time they
deliver the solar generated excess energy through their own utility infrastructure into the
public companies grid. My recommendation is to not approve the Rocky Mountain/Pacific
Power Companies proposal, but if an update is deemed necessary, to implement the 25%
Less rate change structure noted above and mandate all existing residential solar systems
to be classified a legacy account and system for any new rate changes.
I was also troubled to be notified in said February 7, 2025 letter from Rocky
Mountain/Pacific Power Company that a determination of Legacy status (Grandfathering)
occurred in 2020 for a 25 year period regarding schedule 136 and new on-site residential
solar generating excess bill rates and credit values, as proposed by Rocky Mountain Power
to be implemented October 1, 2025.
Therefore, if the utility companies rate scheme is approved by the IPUC, it would be
justified to grant all Residential on-site solar generating systems that are in operation as of
October 1, 2025 "Legacy Status"thereby grandfathering them into the current rates etc. for
a period of 25 years, which is a reasonable time to realize the benefit of investing 10's of
thousands of dollars per residential solar system installed on homes and protecting those
families from an unburden of purchasing solar and paying close to the average monthly bill
of non-solar customers.
Thank you for your time and consideration,
Richard and Connie
Idaho Falls Congressional District, Idaho
On Aug 13, 2025, at 4:32 PM, Adam Rush <adam.rushCa_puc.idaho.gov>wrote:
Case No. PAC-E-25-02
Order No. 36716
Contact: Adam Rush
Office: [phone]
E-mail: [e-mail]
NEWS RELEASE: Commission reschedules virtual customer hearing to take testimony on
eastern Idaho electric utility's on-site generation case, extends written comments
deadline.
BOISE(Aug. 13, 2025)—The Idaho Public Utilities Commission has rescheduled a virtual
customer hearing from Aug. 19 to Sept. 11 to take testimony on an eastern Idaho electric
utility's application to change the export credit rate given to customers who supply power
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to the utility through on-site generation. The commission also extended the deadline to
submit written comments.
Rocky Mountain Power, which serves customers in eastern Idaho, offers the credit to
customers who participate in the on-site generation. On-site generation systems, such as
solar panels, provide electricity to these customers. Any excess energy is transmitted to
the utility's system for the credit.
In the utility's application, it proposes to change the value of credit for exported energy
from a retail rate,valued at around $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. The utility also is proposing to modify the on-site generation system size
cap for commercial, industrial and irrigation customers. In addition, Rocky Mountain Power
is seeking commission approval to make annual updates to the export credit for on-site
generation customers.
The proposed changes apply to non-legacy customers. The commission previously granted
Legacy status, or grandfathered customers who had on-site generation systems installed
prior to October of 2020. Customers who installed on-site generation systems since then
have non-legacy status and have been compensated under a different structure that has
been subject to change.
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Hello,
customer with on-site generation,you are receiving this letter because we want you to be
aware of proposed changes to the compensation structure for on-site generation. This letter is
specific to your non-legacy on-site generation system at 11100111M meter number�*
If you have multiple on-site generation systems,you will receive a letter specific to each system.
Below are details about the proposed changes being considered by the Idaho Public Utilities
Commission(IPUC)with information on how you can participate.
What is this change being proposed?
Rocky Mountain Power is requesting changes to its on-site generation offering as a step towards
ensuring fair prices for all customers. Rocky Mountain Power is seeking approval of a
compensation structure that accurately measures an on-site generator's use of the electrical grid
and an excess export energy credit rate that will result in a fair and accurate valuation of customers'
exported energy.For all customers with non-legacy systems,Rocky Mountain Power is asking to
implement the proposed changes effective October 1,2025:
• A change in the value of credit for exported energy from the retail rate,valued between
$0.07 to$0.18 per kilowatt-hour for residential customers,to a time-differentiated financial
bill credit that would be approximately$0.04 per kilowatt-hour but that would be updated
annually.
• A modification in the eligibility size cap for commercial, industrial and irrigation
customers.
Why is Rocky Mountain Power requesting changes?
The proposed changes follow Rocky Mountain Power's On-Site Generation study in Case No.
PAC-E-23-17,which analyzed the benefits and costs of on-site generation on Rocky Mountain
Power's electrical grid. The study provides a basis for implementing changes to ensure that
customers are paid fair rates for their exports and customers without solar or other on-site
generation systems are not subsidizing the rates for self-generating customers.
I
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Solar power and other renewable energy sources arc an important part of Rocky Mountain Power's
energy mix,and the company supports customers who choose to participate in their own on-site
generation.The company's goal with this request is to modernize the compensation structure for
on-site generation to ensure prices for excess energy are fair and equitable for all customers.
How might m%bill be affected?
For residential customers with non-legacy systems,Rocky Mountain Power evaluateda07,j4;01J,
data to assess how customer bills may be affected by the proposed change in coJrpensataoil,
structure.The average monthly bill for residential customers under the current net billinhy
compensation structure is about$52.Under the proposed export credit price,the average bill would
increase to $89,resulting in an average increase of approximately$37 per month or about 72%.
A typical Rocky Mountain Power residential customer in Idaho has a bill of$105.48 per month.
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the chart below shows the change in average monthly bills moving from the existing retail rate
credit to an export credit valued at about 4 cents per kWh.The chart is organized by customers'
average net monthly energy consumption.
Residential Schedule 136 Average Monthly Bill Impact
1326.68
1296.66
$219.45
1167.71 I1Ba.19
$133.68
1110.66
159.48 $72 52
S2�.
A:0-500 kWh B:501.1.000 kWh C:1,001-1,500 kVJh D:1,501.2,000 kWh E:2.001 kWh.
(610 customers) (197 customers) f75 customers) (26eustomers) (20 customers)
Average one i yHY efDe4vere3k�
■Current Monthly Average Bill ■Proposed Monthly Average BIII
How would non-legacy customer generators be credited for their excess energy under the
proposed changes?
Under the proposed rate structure,customers are charged for all kWh consumed from the grid at
the retail rate,and are credited for all kWh exported to the grid at a time differentiated export credit
rate.ra .
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What is a"non-legacy"system?
As part of previous cases, the IPUC granted legacy status — sometimes referred to as
"grandfathered"—in October of 2020 to existing customers for a 25-year period and established
Schedule 136 for new customers going forward.In these previous cases,the IPUC acknowledged
certain criteria for these systems to maintain legacy status,which allows those systems to retain
the net metering compensation structure for 25 years.
All other systems,including the system referenced in this letter,are"non-legacy"and are subject
to changes in the on-site generation compensation structure,including the changes currently being
considered by the 1PUC.
How can I participate?
For more details about the proposed changes to the on-site generation compensation structure,
including the methodologies behind the net billing and excess energy export credit rate changes
customers can review Rocky Mountain Power's proposal,which is subject to approval by the
IPUC.Copies of the application are available to the public at the IPUC offices(11331 W.Chinden
Blvd. Building 8, Suite 201-A, Boise, ID 83714), Rocky Mountain Power offices, or at
RockyMountainPower.net/ExportCredit or puc.idaho.gov.Customers also may subscribe to the
IPUC's RSS feed to receive periodic updates via email about the case.
Written comments regarding Rocky Mountain Power's proposal(Case No.PAC-E-25-02)may be
filed with the IPUC(puc.idaho.gov/Fomi/CaseComment).
You can find more information about Customer Generation, including FAQs, at
RockyMountainPower.net/CustomerGen. If you have additional questions, you can call our
Customer Care team at 888-221-7070.
Sincerely,
Your Rocky Mountain Power Customer Generation Team
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The following comment was submitted via PUCWeb:
Name: Cody Smith
Submission Time: Aug 16 2025 9:03AM
Email: cdsmith53Ccbgmail.com
Telephone: [phone]
Address: 3734 E 331 N
Rigby, ID 83442
Name of Utility Company: Rocky Mountain Power
Case ID: PAC-E-25-02
Comment: "From the information sent to me via email and mail, this application proposal
seems highly unfair to the individuals, like myself, who have invested in solar energy
systems. We have chosen to invest in solar energy as a renewable form of energy that also
enables energy cost savings over time. By approving this proposal, there will be less
incentive, and therefore, less solar systems being installed in Idaho, while also destroying
the energy investment many of us homeowners with solar have made.
I understand that homeowners without solar still have to pay for their power usage.While
people with solar don't have direct energy costs, they have chosen to invest into their solar
system, so they are still paying for the energy. I do not see any disparity between groups.
This proposal would be certainly irresponsible to pass as it would decrease the incentive
and number of renewable solar systems in Idaho while also decreasing the faith of Idaho
residents in the Idaho Public Utilities Commission:'
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The following comment was submitted via PUCWeb:
Name: Clifford Gibbons
Submission Time: Aug 16 2025 12:46PM
Email: Cliffgib53 yahoo.com
Telephone: [phone]
Address: 1719 Castelli Dr.
Ammon , ID 83401
Name of Utility Company: Rocky Mountain Power
Case ID: PAC-E-25-02
Comment: "Rocky Mountain Power's proposal to reduce the on site power generation rate
eliminates any potential of a break-even point of installing solar panels and eliminates any
benefit of doing so. Their proposal is tantamount to them saying "we don't want,
encourage, or support alternate energy sources:'Their proposal is not a fair business
practice to their customers. "
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The following comment was submitted via PUCWeb:
Name: Joe Jannuzzi
Submission Time: Aug 17 2025 9:40PM
Email: iannuzzipgmaiLcom
Telephone: [phone]
Address: 5319 Clearfield Lane
Ammon, ID 83406
Name of Utility Company: Rocky Mountain Power
Case ID: PAC-E-25-02
Comment: "Rocky Mountain Power is slashing the credit I receive from power production
from my solar panels. I have only had the panels for 2 and a half years and have been
steadily exporting the same amount of energy I am drawing from the grid. This was meant
to be a long term financial gain for me by paying off the solar panels and no longer needing
to worry about an electricity bill from Rocky Mountain Power. Since becoming a customer 4
years ago, Rocky Mountain power has increased my connection fee from $8 a month to
$20.75 per month with another proposed increase in the near future. On top of charging
more for the same access, they are now going to reduce my production net metering from a
1:1 ration of kWh production and consumption to a flat$0.04 from the $0.07 to $0.11
varied rate I have been receiving. I feel their support for customer generation is fake support
as not only will I be paying my solar panel payment but will begin to have an electric bill as
well due to the decrease in net metering and an increase in the monthly connection fee. I
do not have a choice to change my power provider and even if I decided to be self-sufficient
with batteries and back-ups, there is not a way to avoid the monthly fee.The utility is a
monopoly for all areas and my hopes of long term financial benefit is now being blamed as
subsidized by those not producing any power. Please stop the power and money grab and
continue to allow those with production means to continue to benefit from a 1:1 net
metering."
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