20230606Comments_1.pdf

Clean Energy Opportunities for Idaho

June 6, 2023

To: Idaho Public Utilities Commission
From: Clean Energy Opportunities for Idaho
Re: AVU-E-23-01 Comments

Clean Energy Opportunities for Idaho (CEO) acknowledges and supports a utility having the
opportunity to recover its revenue requirement, yet we request that the Commission give careful
thought to protecting the degree of freedom Idaho customers have to control their energy bills.
The greater the shift in price signals from volumetric prices to fixed monthly charges, the less
agency Idaho customers have to control their energy bills.

1) A COSS policy for allocating functionalized costs across classes does not dictate how costs
should be recovered from each individual customer. An individual customer may choose to use
more or less electricity than average, thereby benefiting more or less than average from
shared infrastructure; contributing more or less than average to the cost of shared
infrastructure is fair and reasonable.

2) To optimize long-term affordability, price signals should encourage customers to make choices
which defer future capital investment – cost additions which we customers ultimately pay for.
A shift in price signals from volumetric charges to high fixed charges reduces the incentive for
customers to conserve, ultimately accelerating the utility’s need for new infrastructure and
harming the public interest in long-term affordability. Though the utility benefits from a rate
design which leads to greater need for new capital investments, we customers rely on the
Commission to protect our interests in long-term affordability and agency over our energy
costs.

3) CEO asks that the Commission uphold the position stated by PUC staff:
“So long as rates afford the Company an opportunity to recover its revenue
requirement, Staff believes that rates may be chosen to achieve other goals, such as
energy efficiency, incenting customer behaviors that defer or avoid future plant
investment, or allowing customers the ability to control their bills.”1

The utility’s proposal to shift from volumetric to fixed monthly charges is inconsistent with that
position.

Respectfully,

Courtney White
Clean Energy Opportunities for Idaho

1 PUC Staff comments, IPC-E-18- 16, at 4. https://puc.idaho.gov/Fileroom/PublicFiles/ELEC/IPC/IPCE1816/Staff/20200121Comments.pdf
RECEIVED
Tuesday, June 6, 2023 12:14:53 PM
IDAHO PUBLIC
UTILITIES COMMISSION