20230802Comments_1.pdf

1

The following comment was submited via PUCWeb:

Name: Chad Surrage
Submission Time: Aug 2 2023 11:24AM
Email: [e-mail]
Telephone: [phone]
Address: 125 East 300 South
Rupert, ID 83350

Name of U�lity Company: Riverside Electric Co

Case ID: C15-E-23-01

Comment: "TEMPLATE COMMENTS
FOR SUBMISSION TO THE PUBLIC UTILITIES COMMISSION
RE: UNITED ELECTRIC CO-OP, INC. V. CITY OF BURLEY IPUC DOCKET NO. C15-E-23-01

The Commission has invited “all affected u�li�es” to provide comments suppor�ng or opposing the City
of Burley’s Pe��on for Declaratory Judgment that its exis�ng service territory agreement with United
Electric Co-op, Inc. should be terminated, in part, because:
ci�zens [should] … not be forced into using one service provider over another based on an agreement 37
years ago.
Burley makes other technical legal arguments why its service territory agreement with United Electric
should be terminated that are based on contract law. Those legal arguments are beyond the scope of
Riverside Electric Company comments. Instead, Riverside Electric Company limits its comments to
emphasize the importance of maintaining the integrity of exclusive electric u�lity service territories.
Idaho u�li�es operate in exclusive electric u�lity service territories that require ci�zens to use one
service provider over another. Idaho has never embraced open compe��on for its electric u�li�es. In
fact, the Idaho legislature has explicitly rejected the en�re concept of allowing ci�zens to arbitrarily
select their electric supplier. That is why it adopted the Electric Supplier Stabiliza�on Act (ESSA) which
prevents retail compe��on for electric customers. It has been the law in Idaho for many decades.
The express purpose of the ESSA is to promote harmony among and between electric suppliers, prohibit
pira�ng of consumers of another electric supplier, discourage duplica�on of electrical facili�es, ac�vely
supervise certain conduct of electric suppliers, and stabilize the territories and consumers served with
electricity. Voiding service territory agreements (or laws) will have the opposite effect and will increase
costs, cause uncertainty, require duplica�ve service lines, encourage pira�ng, and makes long-range
u�lity planning difficult, if not impossible.
Riverside Electric Company believes the Commission has the requisite authority to ensure that exis�ng
service territory boundary agreements are enforced and enforceable.
In Sum, Riverside Electric Company, urges the Commission to enforce and uphold the clear State policy
of protec�ng the integrity of electric u�lity service territories – including duly executed and Commission
approved agreements among u�li�es that establish such territories.

Sincerely,

Chad Surrage
Riverside Electric Company