20171024Comment.pdf

Diane Holt
From:Steve White <[e-mail]>
Sent:Tuesday,October 24,2017 3:56 PM
To:Diane Holt
Subject:comment on case IPC-E-17-13
Hello,
Please submit the below comment on the above-referenced case.
As a Chartered FinancialAnalyst with a career in investment advising,I would like to ensure the PUC recognizesthe
harmful impact of this filing.If approved,a separate rate class would create long-term uncertainty which changesthe
economics of investing in on-site generation.This case creates not just a short-term limbo during the proceedings,an
approval of a separate rate class would create a long-term limbo that will delay and unduly influence investment
decisions in on-site generation.
In my role,I often counsel people who are considering investing in on-site generation.Like installers,I routinely make
assumptions on the probabilityof future rate changesto forecast a return on investment.For any investment in general,
the higher the risk,the higher the return must be to motivate someone to invest.ApprovingIdaho Power (IPC)'s
request for a separate rate class would send a message that the rate structure for customers with on-site generation
will fundamentallychange,but nobody has any idea what to plug in as an assumption.The uncertainty created by
such a policy decision is toxic -it increasesthe return customers need to see to overcome the uncertainty,and it forces
installers to win or lose projects based on the aggressivenessof their rate change assumptions relative to other installers
responding to the same RFP.
The impact could be a death knell to the fledgling solar installer industry in this state.These companies are staffed by
young,competent engineers and installers-and now this filing threatens their industry's future and their individual
employment.When considering projects with economic benefits spanning 25+years,customers have the flexibility to
wait for more visibilityon rate design.Small businesses,however,need to make payroll.I am thankful that my small
business is not vulnerable to this type of disruption by a monopoly;if my customer base went on hold while waiting for
the promise of future regulation changesdown the road,I wouldn't be able to cover staff and overhead while waiting.
IPC has far more opportunity to recover its fixed costs than we small businesses do.
Some uncertainty is normal;this is not.If IPC has not provided sufficient cost/benefit analysis to establish what
customers should assume when investing in on-site generation,then the PUC does not have enough information to
conclude that the current rate design is fundamentally wrong and unstable.
Commissioners,please do not allow IPC to put this unnecessaryand unfounded burden on small business.Please
protect the interests of small business and individual customers against destructive attempts like this.
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