20230815Comments_2.pdf

1

The following comment was submited via PUCWeb:

Name: Brad Gamet
Submission Time: Aug 14 2023 6:13PM
Email: [e-mail]
Telephone: [phone]
Address: P.O. Box 420
Mackay, ID 83251

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

Case ID: C15-E-23-01

Comment: "August 14, 2023

IDAHO PUBLIC UTILITIES COMMISSION
11331 W. Chinden Blvd.
Ste. 201-A
Boise, ID 83714
(Submited electronically via: htps://legislature.idaho.gov/statutesrules/idstat/Title61/T61CH3/SECT61-
332/)

Re: To CEQ Request for Comment IPUC DOCKET NO. C15-E-23-01

As an “affected” u�lity of the State of Idaho, Lost River Electric Coopera�ve, Inc. (herea�er LREC)
opposes 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, in part, because:

“ci�zens [should] … not be forced into using one service provider over another based on an agreement
37 years ago.”

Rather, LREC takes the stance that the Commission follow Idaho Statute—as stated in Idaho Statute Title
61, Chapter 3, Sec�on 61-332—

“(2) This act and its amendments are designed to promote harmony among and between electric
suppliers furnishing electricity within the state of Idaho, prohibit the "pira�ng" of consumers of another
electric supplier, discourage duplica�on of electric facili�es, ac�vely supervise certain conduct of electric
suppliers as it relates to this act, and stabilize the territories and consumers served with electricity by
such electric suppliers.”

LREC supports the upholding the integrity of defined u�lity service territory boundaries, while
recognizing that these service territories—and the agreements that uphold them—will need amended
from �me to �me. This approach has served in the best interest of the ci�zens of the State of Idaho
collec�vely for many years. Unilateral termina�on of such agreements sets a precedent that runs
counter to this history and several of the Commission’s core governing statutes. Predictably, the resul�ng
impacts of such precedent are highly unfavorable to the ci�zens of the State of Idaho as they run directly
counter to the aforemen�oned statute.
2

LREC believes that the Commission has the authority and preroga�ve to oversee the development of and
the upholding and enforcement of exis�ng service territory boundary agreements and strongly
encourages it to con�nue do so. Further, LREC urges the Commission enforce a well-defined policy of
promo�ng and protec�ng the u�liza�on of service territory boundaries.

Sincerely,

Brad J. Gamet
General Manager/CEO
Lost River Electric Coopera�ve, Inc."
----------------------------------------------------------------------------------------------

P. 0. Box 420 • 305 Pine Street • Mackay, Idaho 83251-0420 Telephone
[phone] • FAX [phone] • [e-mail]

August 14, 2023

IDAHO PUBLIC UTILITIES COMMISSION
11331 W. Chinden Blvd.
Ste. 201-A
Boise, ID 83714
(Submitted electronically via:
https://legislature.idaho.gov/statutesrules/idstat/Title61/T61CH3/SECT61-332/)

Re: To CEQ Request for Comment IPUC DOCKET NO. C15-E-23-01

As an “affected” utility of the State of Idaho, Lost River Electric Cooperative, Inc.
(hereafter LREC) opposes the City of Burley’s Petition for Declaratory Judgement that its
existing service territory agreement with United Electric Co-op, Inc. should be terminated,
in part, because:

“citizens [should] … not be forced into using one service provider over another
based on an agreement 37 years ago.”1

Rather, LREC takes the stance that the Commission follow Idaho Statute—as stated in
Idaho Statute Title 61, Chapter 3, Section 61-332—

“(2) This act and its amendments are designed to promote harmony among and between
electric suppliers furnishing electricity within the state of Idaho, prohibit the "pirating"
of consumers of another electric supplier, discourage duplication of electric facilities,
actively supervise certain conduct of electric suppliers as it relates to this act, and
stabilize the territories and consumers served with electricity by such electric suppliers.”2

LREC supports the upholding the integrity of defined utility service territory boundaries,
while recognizing that these service territories—and the agreements that uphold them—
will need amended from time to time. This approach has served in the best interest of the
citizens of the State of Idaho collectively for many years. Unilateral termination of such
agreements sets a precedent that runs counter to this history and several of the
Commission’s core governing statutes. Predictably, the resulting impacts of such precedent
are highly unfavorable to the citizens of the State of Idaho as they run directly counter to
the aforementioned statute.

LREC believes that the Commission has the authority and prerogative to oversee the
development of and the upholding and enforcement of existing service territory boundary
agreements and strongly encourages it to continue do so. Further, LREC urges the

1 Docket No. C15-E-23-01, Order No. 35885 at pp. 2 – 3.
2 https://legislature.idaho.gov/statutesrules/idstat/Title61/T61CH3/SECT61-332/

RECEIVED
Tuesday, August 15, 2023 11:05:10 AM
IDAHO PUBLIC
UTILITIES COMMISSION
Commission enforce a well-defined policy of promoting and protecting the utilization of
service territory boundaries.

Sincerely,

Brad J. Gamett
General Manager/CEO
Lost River Electric Cooperative, Inc.