20230810Comments_2.pdf

The following comment was submited via PUCWeb:

Name: Ken Dizes
Submission Time: Aug 10 2023 3:46PM
Email: [e-mail]
Telephone: [phone]
Address: PO Box 384
Challis, ID 83226

Name of U�lity Company: Salmon River Electric Coopera�ve, Inc.

Case ID: C15-E-23-01

Comment: "RE: UNITED ELECTRIC CO-OP, INC. V. CITY OF BURLEY IPUC DOCKET NO. C15-E-23-01

Salmon River Electric Coopera�ve (SREC) appreciates the opportunity to provide comments to the
Commission on the City of Burley’s Pe��on for Declaratory Judgement that its exis�ng service territory
agreement with United Electric Co-op, Inc. should be terminated.
SREC 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.
SREC believes the Commission has the requisite authority to ensure that exis�ng service territory
boundary agreements are enforced and enforceable.
In Sum, SREC, 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."

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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 affectedutilities"to provide comments
supporting or opposingthe City of Burley's Petition for Declaratory Judgmentthat
its existing serviceterritory agreementwith United Electric Co-op,Inc.should be
terminated,in part,because:
citizens [should]...not be forced into using one service provider over
anotherbased on an agreement37 years ago.'
Burley makes other technical legal argumentswhy its serviceterritory agreement
with United Electric should be terminated that are based on contract law.Those
legal argumentsare beyond the scope of Raft River Rural Electric Cooperative
(RREC)comments.Instead,RREC limits its commentsto emphasizethe
importance of maintaining the integrity of exclusive electric utility service
territories.
Idaho utilities operatein exclusive electric utility serviceterritories that require
citizens to use one serviceprovider over another.Idaho has never embracedopen
competition for its electric utilities.In fact,the Idaho legislaturehas explicitly
rejected the entire conceptof allowing citizens to arbitrarily selecttheir electric
supplier.That is why it adoptedthe Electric Supplier Stabilization Act (ESSA)
which preventsretail competition for electric customers.It has been the law in
Idaho for many decades.
The expresspurposeof the ESSA is to promote harmony among and between
electric suppliers,prohibit pirating of consumersof anotherelectric supplier,
discourageduplication of electrical facilities,actively supervisecertain conduct of
electric suppliers,and stabilize the territories and consumersservedwith
electricity.Voiding serviceterritory agreements(or laws)will have the opposite
effect and will increase costs,cause uncertainty,require duplicative service lines,
i Docket No.C15-E-23-01,Order No.35885 at pp.2 -3.
encourage pirating,and makeslong-range utility planning difficult,if not
impossible.
RREC believes the Commission has the requisite authority to ensure that existing
service territory boundary agreementsare enforced and enforceable.
In Sum,RREC,urges the Commission to enforce and uphold the clear State policy
of protecting the integrity of electric utility service territories -including duly
executed and Commission approved agreementsamong utilities that establish such
territories.
Respectfully,
Chad Black
General Manager
Raft River Rural Electric Cooperative INC.